0000950123-11-085043.txt : 20120723 0000950123-11-085043.hdr.sgml : 20120723 20110916172218 ACCESSION NUMBER: 0000950123-11-085043 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 2 FILED AS OF DATE: 20110916 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Bond Fund CENTRAL INDEX KEY: 0000005094 IRS NUMBER: 520906083 STATE OF INCORPORATION: DE FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN BOND FUND DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL BOND FUND DATE OF NAME CHANGE: 19970728 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL BOND FUND INC DATE OF NAME CHANGE: 19960102 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Exchange Fund CENTRAL INDEX KEY: 0000005100 IRS NUMBER: 741908071 STATE OF INCORPORATION: CA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN EXCHANGE FUND DATE OF NAME CHANGE: 20030731 FORMER COMPANY: FORMER CONFORMED NAME: AMERICAN CAPITAL EXCHANGE FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: AMERICAN GENERAL EXCHANGE FUND DATE OF NAME CHANGE: 19831101 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM FUNDS GROUP (INVESCO FUNDS GROUP) CENTRAL INDEX KEY: 0000019034 IRS NUMBER: 060841973 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLZ STE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: INVESCO FUNDS GROUP STREET 2: 11 GREENWAY PLZ STE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM FUNDS GROUP DATE OF NAME CHANGE: 20060203 FORMER COMPANY: FORMER CONFORMED NAME: AIM FUNDS GROUP/DE DATE OF NAME CHANGE: 19940718 FORMER COMPANY: FORMER CONFORMED NAME: AIM FUNDS GROUP DATE OF NAME CHANGE: 19921016 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM EQUITY FUNDS (INVESCO EQUITY FUNDS) CENTRAL INDEX KEY: 0000105377 IRS NUMBER: 132576643 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLZ STREET 2: STE 100 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM EQUITY FUNDS DATE OF NAME CHANGE: 20000713 FORMER COMPANY: FORMER CONFORMED NAME: AIM EQUITY FUNDS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: WEINGARTEN EQUITY FUND INC DATE OF NAME CHANGE: 19880929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM GROWTH SERIES (INVESCO GROWTH SERIES) CENTRAL INDEX KEY: 0000202032 IRS NUMBER: 942362417 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM GROWTH SERIES DATE OF NAME CHANGE: 19980601 FORMER COMPANY: FORMER CONFORMED NAME: G T GLOBAL GROWTH SERIES DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: G T GLOBAL GROWTH FUNDS DATE OF NAME CHANGE: 19870617 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SHORT TERM INVESTMENTS TRUST CENTRAL INDEX KEY: 0000205007 IRS NUMBER: 741093914 STATE OF INCORPORATION: DE FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA SUITE 100 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: SHORT TERM INVESTMENTS CO DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: AIM BOND SHARES INC DATE OF NAME CHANGE: 19800909 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM SECTOR FUNDS (INVESCO SECTOR FUNDS) CENTRAL INDEX KEY: 0000725781 IRS NUMBER: 840933032 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 713-626-1919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM SECTOR FUNDS DATE OF NAME CHANGE: 20031126 FORMER COMPANY: FORMER CONFORMED NAME: AIM SECTOR FUNDS INC DATE OF NAME CHANGE: 20031001 FORMER COMPANY: FORMER CONFORMED NAME: INVESCO SECTOR FUNDS INC DATE OF NAME CHANGE: 19990330 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS) CENTRAL INDEX KEY: 0000826644 IRS NUMBER: 000000000 FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA, SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: 11GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM INVESTMENT FUNDS DATE OF NAME CHANGE: 19980529 FORMER COMPANY: FORMER CONFORMED NAME: G T INVESTMENT FUNDS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: G T GLOBAL INCOME SERIES INC DATE OF NAME CHANGE: 19890521 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM TREASURERS SERIES TRUST (INVESCO TREASURER'S SERIES TRUST) CENTRAL INDEX KEY: 0000828806 IRS NUMBER: 586213968 STATE OF INCORPORATION: DE FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 713-626-1919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM TREASURERS SERIES TRUST DATE OF NAME CHANGE: 20040707 FORMER COMPANY: FORMER CONFORMED NAME: AIM TREASURERS SERIES FUNDS DATE OF NAME CHANGE: 20031126 FORMER COMPANY: FORMER CONFORMED NAME: AIM TREASURERS SERIES FUNDS INC DATE OF NAME CHANGE: 20031001 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Municipal Income Opportunities Trust CENTRAL INDEX KEY: 0000835333 IRS NUMBER: 133473972 STATE OF INCORPORATION: MA FISCAL YEAR END: 0530 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY MUNICIPAL INCOME OPPORTUNITIES TRUST DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MSDW MUNICIPAL INCOME OPPORTUNITIES TRUST DATE OF NAME CHANGE: 19981221 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL INCOME OPPORTUNITIES TRUST/MA DATE OF NAME CHANGE: 19930721 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM INVESTMENT SECURITIES FUNDS (INVESCO INVESTMENT SECURITIES FUNDS) CENTRAL INDEX KEY: 0000842790 IRS NUMBER: 760343427 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLZ STE 100 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM INVESTMENT SECURITIES FUNDS DATE OF NAME CHANGE: 20000921 FORMER COMPANY: FORMER CONFORMED NAME: AIM INVESTMENT SECURITIES FUNDS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: AIM PRIME RATE PREMIUM INCOME FUND INC DATE OF NAME CHANGE: 19910320 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Municipal Premium Income Trust CENTRAL INDEX KEY: 0000842891 IRS NUMBER: 133498050 STATE OF INCORPORATION: NY FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY MUNICIPAL PREMIUM INCOME TRUST DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER MUNICIPAL PREMIUM INCOME TRUST DATE OF NAME CHANGE: 19981221 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL PREMIUM INCOME TRUST/MA DATE OF NAME CHANGE: 19930721 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen High Income Trust II CENTRAL INDEX KEY: 0000846671 IRS NUMBER: 366900462 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: VAN KAMPEN INVESTMENTS INC. STREET 2: 522 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212-296-6963 MAIL ADDRESS: STREET 1: VAN KAMPEN INVESTMENTS INC. STREET 2: 522 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN HIGH INCOME TRUST II DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL LIMITED TERM HIGH INCOME DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT LIMITED TERM HIGH INCOME TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Municipal Income Opportunities Trust II CENTRAL INDEX KEY: 0000847593 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY MUNICIPAL INCOME OPPORTUNITIES TRUST II DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MSDW MUNICIPAL INCOME OPPORTUNITIES TRUST II DATE OF NAME CHANGE: 19981221 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL INCOME OPPORTUNITIES TRUST II DATE OF NAME CHANGE: 19930510 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Senior Loan Fund CENTRAL INDEX KEY: 0000853180 IRS NUMBER: 366911789 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN SENIOR LOAN FUND DATE OF NAME CHANGE: 20030626 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN PRIME RATE INCOME TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL PRIME RATE INCOME TRUST DATE OF NAME CHANGE: 19951018 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Prime Income Trust CENTRAL INDEX KEY: 0000854904 IRS NUMBER: 133548050 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: INVESCO PRIME INCOME TRUST DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY PRIME INCOME TRUST DATE OF NAME CHANGE: 20010618 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER PRIME INCOME TRUST DATE OF NAME CHANGE: 19980622 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Municipal Income Opportunities Trust III CENTRAL INDEX KEY: 0000861069 IRS NUMBER: 136946092 STATE OF INCORPORATION: MA FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY MUNICIPAL INCOME OPPORTUNITIES TRUST III DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER MUNICIPAL INCOME OPPORTUNITIES TR DATE OF NAME CHANGE: 19981221 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL INCOME OPPORTUNITIES TRUST III/MA DATE OF NAME CHANGE: 19930721 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Insured Municipal Bond Trust CENTRAL INDEX KEY: 0000861185 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Insured Municipal Bond Trust DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED MUNICIPAL BOND TRUST DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER INSURED MUNICIPAL BOND TRUST DATE OF NAME CHANGE: 19981221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Quality Municipal Investment Trust CENTRAL INDEX KEY: 0000876982 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY QUALITY MUNICIPAL INVESTMENT TRUST DATE OF NAME CHANGE: 20091002 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY QUALITY MUNICIPAL INVESTMENT TRUS DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY QUALITY MUNICIPAL INVESTMENT TRUST DATE OF NAME CHANGE: 20011220 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Municipal Trust CENTRAL INDEX KEY: 0000877463 IRS NUMBER: 363779776 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MUNICIPAL TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL MUNICIPAL TRUST DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT MUNICIPAL TRUST DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Ohio Quality Municipal Trust CENTRAL INDEX KEY: 0000877649 IRS NUMBER: 363779778 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN OHIO QUALITY MUNICIPAL TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL OHIO QUALITY MUNICIPAL TRUST DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT OHIO QUALITY MUNICIPAL TRUST DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Insured Municipal Trust CENTRAL INDEX KEY: 0000880161 IRS NUMBER: 136993836 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Insured Municipal Trust DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED MUNICIPAL TRUST DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER INSURED MUNICIPAL TRUST DATE OF NAME CHANGE: 19981221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS) CENTRAL INDEX KEY: 0000880859 IRS NUMBER: 760352823 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA STE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: AIM INTERNATIONAL FUNDS INC STREET 2: 11 GREENWAY PLAZA SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM INTERNATIONAL MUTUAL FUNDS DATE OF NAME CHANGE: 20031126 FORMER COMPANY: FORMER CONFORMED NAME: AIM INTERNATIONAL FUNDS INC /MD/ DATE OF NAME CHANGE: 20000620 FORMER COMPANY: FORMER CONFORMED NAME: AIM INTERNATIONAL MUTUAL FUNDS DATE OF NAME CHANGE: 20000323 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Trust for Investment Grade Municipals CENTRAL INDEX KEY: 0000880892 IRS NUMBER: 363797841 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN TRUST FOR INVESTMENT GRADE MUNICIPALS DATE OF NAME CHANGE: 20040707 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN TRUST FOR INVSTMENT GRADE MUNICIPALS DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL TR FOR INVSTMNT GRADE MUNICIPALS DATE OF NAME CHANGE: 19960102 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Trust for Insured Municipals CENTRAL INDEX KEY: 0000880893 IRS NUMBER: 363797563 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Van Kampen Trust for Insured Municipals DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN TRUST FOR INSURED MUNICIPALS DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL TRUST FOR INSURED MUNICIPALS DATE OF NAME CHANGE: 19960102 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Trust for Investment Grade New York Municipals CENTRAL INDEX KEY: 0000883265 IRS NUMBER: 366981632 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN TRUST FOR INVESTMENT GRADE NEW YORK MUNICIPALS DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL TRUST FOR INVT GRADE NEW YORK MU DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT TRUST FOR INVESTMENT GRADE NEW YORK MUNIC DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Trust for Investment Grade New Jersey Municipals CENTRAL INDEX KEY: 0000883269 IRS NUMBER: 366981631 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Van Kampen Trust for Investment Grade New Jerset Municipals DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN TRUST FOR INVESTMENT GRADE NEW JERSEY MUNICIPALS DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL TR FOR INVT GRADE NEW JERSEY MUN DATE OF NAME CHANGE: 19960102 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Municipal Opportunity Trust CENTRAL INDEX KEY: 0000884152 IRS NUMBER: 363810337 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MUNICIPAL OPPORTUNITY TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL MUNICIPAL OPPORTUNITY TRUST DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT MUNICIPAL OPPORTUNITY TRUST DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Quality Municipal Income Trust CENTRAL INDEX KEY: 0000885125 IRS NUMBER: 136993836 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY QUALITY MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER QUALITY MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19981221 FORMER COMPANY: FORMER CONFORMED NAME: INTERCAPITAL QUALITY MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Insured Municipal Income Trust CENTRAL INDEX KEY: 0000885601 IRS NUMBER: 133647663 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O MORGAN STANLEY TRUST STREET 2: HARBORSIDE FINANCIAL CENTER, PLAZA TWO CITY: JERSEY CITY STATE: NJ ZIP: 07311 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Insured Municipal Income Trust DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 20090722 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 20011220 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Massachusetts Value Municipal Income Trust CENTRAL INDEX KEY: 0000890515 IRS NUMBER: 367017428 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MASSACHUSETTS VALUE MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL MASS VALUE MUNICIPAL INCOME TRUS DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT MASSACHUSETTS VALUE MUNICIPAL INCOME TRUS DATE OF NAME CHANGE: 19930528 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco California Insured Municipal Income Trust CENTRAL INDEX KEY: 0000894146 IRS NUMBER: 133701273 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco California Insured Municipal Income Trust DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY CALIFORNIA INSURED MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 20090827 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY CA INSURED MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 20090827 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Pennsylvania Value Municipal Income Trust CENTRAL INDEX KEY: 0000895528 IRS NUMBER: 367017427 STATE OF INCORPORATION: PA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN PENNSYLVANIA VALUE MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL PENNSYLVANIA VALUE MUNIC INCO TR DATE OF NAME CHANGE: 19971007 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT PENNSYLVANIA VALUE MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19930328 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen California Value Municipal Income Trust CENTRAL INDEX KEY: 0000895531 IRS NUMBER: 367017425 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN CALIFORNIA VALUE MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL CALIFORNIA VALUE MUNIC INC TRUST DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT CALIFORNIA VALUE MUNICIPAL INCOME TRUST DATE OF NAME CHANGE: 19930328 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Quality Municipal Securities CENTRAL INDEX KEY: 0000898496 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY QUALITY MUNICIPAL SECURITIES DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER QUALITY MUNICIPAL SECURITIES DATE OF NAME CHANGE: 19981221 FORMER COMPANY: FORMER CONFORMED NAME: INTERCAPITAL QUALITY MUNICIPAL SECURITIES DATE OF NAME CHANGE: 19950728 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco California Quality Municipal Securities CENTRAL INDEX KEY: 0000898618 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY CALIFORNIA QUALITY MUNICIPAL SECURITIES DATE OF NAME CHANGE: 20090827 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY CALIFORNIA QUALITY MUNICIPAL SECU DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER CALIFORNIA QUALITY MUNICIPAL SECU DATE OF NAME CHANGE: 19981221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco New York Quality Municipal Securities CENTRAL INDEX KEY: 0000898659 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY NEW YORK QUALITY MUNICIPAL SECURITIES DATE OF NAME CHANGE: 20090827 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY NEW YORK QUALITY MUNICIPAL SECURI DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER NEW YORK QUALITY MUNICIPAL SECURI DATE OF NAME CHANGE: 19981221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Advantage Municipal Income Trust II CENTRAL INDEX KEY: 0000908993 IRS NUMBER: 367041986 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN ADVANTAGE MUNICIPAL INCOME TRUST II DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL ADVANTAGE MUNICIPAL INCOME TR II DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT ADVANTAGE MUNICIPAL INCOME TRUST II DATE OF NAME CHANGE: 19930712 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM TAX EXEMPT FUNDS (INVESCO TAX-EXEMPT FUNDS) CENTRAL INDEX KEY: 0000909466 IRS NUMBER: 766035958 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: STE 100 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 7136261919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM TAX EXEMPT FUNDS DATE OF NAME CHANGE: 20000324 FORMER COMPANY: FORMER CONFORMED NAME: AIM TAX EXEMPT FUNDS INC/NEW DATE OF NAME CHANGE: 19940718 FORMER COMPANY: FORMER CONFORMED NAME: AIM TAX FREE FUNDS INC DATE OF NAME CHANGE: 19930721 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Select Sector Municipal Trust CENTRAL INDEX KEY: 0000912022 IRS NUMBER: 367051237 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN SELECT SECTOR MUNICIPAL TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL SELECT SECTOR MUNICIPAL TRUST DATE OF NAME CHANGE: 19960102 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN MERRITT SELECT SECTOR MUNICIPAL TRUST DATE OF NAME CHANGE: 19930914 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco High Yield Investments Fund, Inc. CENTRAL INDEX KEY: 0000912734 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY HIGH YIELD FUND, INC. DATE OF NAME CHANGE: 20090827 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY HIGH YIELD FUND INC DATE OF NAME CHANGE: 20070522 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER HIGH YIELD FUND INC DATE OF NAME CHANGE: 20000504 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Insured California Municipal Securities CENTRAL INDEX KEY: 0000913342 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Insured California Municipal Securities DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED CALIFORNIA MUNICIPAL SECURITIES DATE OF NAME CHANGE: 20090827 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED CALIFORNIA MUNICIPAL SEC DATE OF NAME CHANGE: 20080411 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Insured Municipal Securities CENTRAL INDEX KEY: 0000913345 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Invesco Insured Municipal Securities DATE OF NAME CHANGE: 20100601 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED MUNICIPAL SECURITIES DATE OF NAME CHANGE: 20011220 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY INSURED MUNICIPAL SECURITIES DATE OF NAME CHANGE: 20011220 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Senior Income Trust CENTRAL INDEX KEY: 0001059386 IRS NUMBER: 364221649 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN SENIOR INCOME TRUST DATE OF NAME CHANGE: 19981006 FORMER COMPANY: FORMER CONFORMED NAME: VAN KAMPEN AMERICAN CAPITAL SENIOR INCOME TRUST DATE OF NAME CHANGE: 19980408 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AIM COUNSELOR SERIES TRUST (INVESCO COUNSELOR SERIES TRUST) CENTRAL INDEX KEY: 0001112996 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 BUSINESS PHONE: 713-626-1919 MAIL ADDRESS: STREET 1: 11 GREENWAY PLAZA STREET 2: SUITE 2500 CITY: HOUSTON STATE: TX ZIP: 77046 FORMER COMPANY: FORMER CONFORMED NAME: AIM COUNSELOR SERIES TRUST DATE OF NAME CHANGE: 20040322 FORMER COMPANY: FORMER CONFORMED NAME: AIM COUNSELOR SERIES FUNDS DATE OF NAME CHANGE: 20031126 FORMER COMPANY: FORMER CONFORMED NAME: AIM COUNSELOR SERIES FUNDS INC DATE OF NAME CHANGE: 20031001 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Invesco Van Kampen Dynamic Credit Opportunities Fund CENTRAL INDEX KEY: 0001393662 IRS NUMBER: 208870533 FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 BUSINESS PHONE: 404-439-3217 MAIL ADDRESS: STREET 1: 1555 PEACHTREE STREET, N.E. STREET 2: SUITE 1800 CITY: ATLANTA STATE: 2Q ZIP: 30309 FORMER COMPANY: FORMER CONFORMED NAME: Van Kampen Dynamic Credit Opportunities Fund DATE OF NAME CHANGE: 20070522 FORMER COMPANY: FORMER CONFORMED NAME: Van Kampen Global Credit Opportunities Fund DATE OF NAME CHANGE: 20070319 CORRESP 1 filename1.htm corresp
     
(INVESCO LOGO APPEARS HERE)
   
 
PO Box 4333
Houston, TX 77210-4333
11 Greenway Plaza, Suite 2500
Houston, TX 77046
 
    
 
  713 626 1919
www.invesco.com
September 16, 2011
VIA EDGAR
Jeffrey Long
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Invesco Funds — 2011 Financial Report Review
         
OPEN END FUNDS
        
AIM Counselor Series Trust (Invesco Counselor Series Trust)
     811-09913  
AIM Equity Funds (Invesco Equity Funds)
     811-01424  
AIM Funds Group (Invesco Funds Group
     811-01540  
AIM Growth Series (Invesco Growth Series)
     811-02699  
AIM International Mutual Funds (Invesco International Mutual Funds)
     811-06463  
AIM Investment Funds (Invesco Investment Funds)
     811-05426  
AIM Investment Securities Funds (Invesco Investment Securities Funds)
     811-05686  
AIM Sector Funds (Invesco Sector Funds)
     811-03826  
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
     811-07890  
AIM Treasurer’s Series Trust (Invesco Treasurer’s Series Trust)
     811-05460  
Short-Term Investments Trust
     811-02729  
Invesco Van Kampen Exchange Fund
     811-02611  
CLOSED-END FUNDS
        
Invesco Municipal Income Opportunities Trust II
     811-05793  
Invesco Municipal Income Opportunities Trust III
     811-06052  
Invesco Municipal Income Opportunities Trust
     811-05597  
Invesco Municipal Premium Income Trust
     811-05688  
Invesco Van Kampen Bond Fund
     811-02090  
Invesco Van Kampen Dynamic Credit Opportunities Fund
     811-22043  
Invesco Van Kampen Senior Income Trust
     811-08743  
Invesco Van Kampen Senior Loan Fund
     811-05845  
Invesco Prime Income Trust
     811-05898  
Invesco California Insured Municipal Income Trust
     811-07344  
Invesco California Quality Municipal Securities
     811-07564  
CLOSED-END FUNDS...Continued
        
Invesco Insured California Municipal Securities
     811-07111  
Invesco Insured Municipal Bond Trust
     811-06053  
Invesco Insured Municipal Income Trust
     811-06590  
Invesco Insured Municipal Securities
     811-07109  
Invesco Insured Municipal Trust
     811-06434  
Invesco New York Quality Municipal Securities
     811-07562  
Invesco Quality Municipal Income Trust
     811-06591  
Invesco Quality Municipal Investment Trust
     811-06346  
Invesco Quality Municipal Securities
     811-07560  
Invesco Van Kampen Advantage Municipal Income Trust II
     811-07868  
Invesco Van Kampen California Value Municipal Income Trust
     811-07404  
Invesco Van Kampen Massachusetts Value Municipal Income Trust
     811-07088  
Invesco Van Kampen Municipal Opportunity Trust
     811-06567  
Invesco Van Kampen Municipal Trust
     811-06362  
Invesco Van Kampen Ohio Quality Municipal Trust
     811-06364  
Invesco Van Kampen Pennsylvania Value Municipal Income Trust
     811-07398  
Invesco Van Kampen Select Sector Municipal Trust
     811-08000  
Invesco Van Kampen Trust for Insured Municipals
     811-06472  
Invesco Van Kampen Trust for Investment Grade Municipals
     811-06471  
Invesco Van Kampen Trust for Investment Grade New Jersey Municipals
     811-06536  
Invesco Van Kampen Trust for Investment Grade New York Municipals
     811-06537  
Invesco High Yield Investments Fund, Inc.
     811-08044  
Invesco Van Kampen High Income Trust II
     811-05769  

 

Dear Mr. Long:
     This letter is to follow up on our telephone conversation on July 20, 2011, in which we discussed the comments you provided on the financial statements (and certain related materials) filed with the U.S. Securities and Exchange Commission (“SEC”) for the open-end and closed-end Invesco Funds, excluding the variable insurance funds (collectively, the “Registrants” or the “Invesco Funds”). We have provided our responses below. References in this letter to the views and beliefs of “the Staff” are to those views and beliefs expressed in your comments regarding the financial statements of the Invesco Funds. References to “we” or “Invesco” are to Invesco Funds.
Comment 1
     SEC Comment: The Staff asked what affect Ambac Financial Group, Inc.’s Chapter 11 bankruptcy filing in November 2010 had on guarantees or credit enhancements of holdings of the Invesco Funds, such as the Invesco Van Kampen Select Sector Municipal Trust.
     Invesco Response: By the time Ambac filed for bankruptcy, Invesco had already fully discounted any value ascribed to Ambac’s guarantees or credit enhancements. Therefore, the Ambac bankruptcy had a de minimis affect on the valuations of holdings of the Invesco Funds, such as the Invesco Van Kampen Select Sector Municipal Trust.
Comment 2
     SEC Comment: The Staff noted that in the Management’s Discussion of Fund Performance section of the Annual Report (“MDFP”) for the Closed-End Funds (“CEFs”), the benchmark returns were disclosed in some but not in all MDFPs. The Staff suggested that the inclusion of the benchmark returns be included or excluded consistently across all the MDFPs for the CEFs.
     Invesco Response: Invesco intends to include benchmark information in all MDFPs for the CEF’s annual report going forward.
Comment 3
     SEC Comment: Regarding the Invesco Insured Municipal Trust, Invesco Insured Municipal Bond Trust, Invesco California Quality Municipal Securities, and Invesco Van Kampen High Yield Municipal Fund, the Staff asked why the “Other Expense” line item in each of the Income Statements for the period-ended February 28, 2011 contains negative amounts.
     Invesco Response: With respect to the Invesco Insured Municipal Trust, Invesco Insured Municipal Bond Trust, and Invesco California Quality Municipal Securities, “Other Expenses” for the period ended February 28, 2011 included an adjustment for a change in accounting estimate for professional services fees during the period. Please note that the financial highlights for these three funds included a footnote disclosing the change in accounting estimates and its impact.
     With respect to the Invesco Van Kampen High Yield Municipal Fund, “Other Expenses” for the period ended February 28, 2011, included an adjustment in accrual balances as a result of a one-time change in fiscal year-end.

Page 2 of 7

 

Comment 4
     SEC Comment: The Staff commented that the legal expenses related to lawsuits involving certain CEFs appear to have been excluded from the expense limitation. The Staff provided the example of Invesco Municipal Premium Income Trust, which reported $502,743 in related legal expenses during the February 28, 2011 fiscal period and had a contractual expense limit of 1.03% in effect and a higher total expense ratio. The Staff requested the basis for the legal expenses exclusion from the expense limit. The Staff recommended that such exclusions be clearly and expressly drafted in the agreement to limit expenses paid by the fund.
     Invesco Response: The parties to the contractual agreement to limit expenses paid by the Funds are under the common understanding that litigation expenses are one of the types of expenses that are excluded from the contractual expense limitation as “non-routine or extraordinary.” Upon the next review of the contract, we will consider clarifying the contract and make any appropriate changes to the disclosure language accordingly.
Comment 5
     SEC Comment: Regarding the Invesco Van Kampen Dynamic Credit Opportunities Fund, the Staff requested details about the reimbursement by Van Kampen Advisors, Inc. of $2,209,166 “for an economic loss due to a trading error” for the year-ended July 31, 2010 as reported in the Fund’s Annual Report.
     Invesco Response: The predecessor advisor to Invesco Van Kampen Dynamic Credit Opportunities Fund did not exercise rights offered on a security for the Fund and thus lost out on an opportunity for which the predecessor advisor paid into the Fund in the amounts disclosed.
Comment 6
     SEC Comment: The Invesco Capital Development Fund held securities with valuations categorized as level 3. The Staff noted the report did not contain a level 3 roll forward table from period to period.
     Invesco Response: The disclosure practice is to evaluate the materiality of the disclosure for each fund and reporting period using quantitative and qualitative factors such as the percentage and circumstances of level 3 holdings and activity, the type of fund and fund strategy, historical practice and other information within the report. For the period ended October 31, 2010, the Fund did not meet the thresholds of the Funds’ internal disclosure policy for including a level 3 roll forward table.
Comment 7
     SEC Comment: Please explain why expenses of money market fund investments made by Invesco Commodities Strategy Fund are not reflected in the acquired fund fees and expenses line item in the November 20, 2010 prospectus fee table.

Page 3 of 7

 

     Invesco Response: All money market fund investments made by Invesco Commodities Strategy Fund are made in affiliated money market funds. An amount of the advisory fee charged by Invesco to Invesco Commodities Strategy Fund is contractually waived to the extent that an advisory fee is collected from the Invesco affiliated money market fund for these investments. Therefore, the acquired fund fees after a reduction for the waiver is reflected in the acquired fund fees and expenses line item in the Invesco Commodities Strategy Fund. Because the acquired fund fees and expenses, after the waiver, were less than 1 basis point, they are not reflected in the expense line item in the November 20, 2010 prospectus fee table.
Comment 8
     SEC Comment: Regarding the Invesco Balanced Risk Allocation Fund and Invesco Van Kampen Government Securities Fund, the Staff noted that the Income Statements reported realized gains/losses from swap agreements for the period-ended October 31, 2010. The Staff questioned whether the principal strategy section of the prospectuses should have a fuller disclosure regarding the use of swap agreements. Furthermore, the Staff said the MDFP section of each fund did not include a discussion on the effects and use of swap agreements.
     Invesco Response: Regarding the Invesco Van Kampen Government Securities Fund, the “performance summary section” in the MDFP for the period-ended September 31, 2010 stated that the Fund “underperformed the Fund’s broad market/style-specific index due mainly to yield curve positions, using interest rate swaps and exposure to non-U.S. sovereign guaranteed paper which is no longer held in the portfolio.” The information was reiterated in the “Market conditions and your Fund” section of the MDFP: “Its underperformance can be largely attributed to yield curve positions using interest rate swaps and exposure to non-U.S. sovereign guaranteed paper, both of which are no longer held in the portfolio.” In consideration of the discontinued use of swap agreements prior to the period-end and the discussions that existed in the MDFP, we believe the disclosure was appropriate. Furthermore, the Invesco Van Kampen Government Securities Fund has since been reorganized into another Invesco Fund and no longer maintains an effective N-1A prospectus.
     Regarding the Invesco Balanced Risk Allocation Fund, the MDFP for the period-ended October 31, 2010 stated the Fund may invest in swap agreements, including total return swaps. Additional details concerning the use of swap agreements are disclosed in the Annual Report’s Consolidated Schedule of Investments listing the swap agreements at the year-end, the Consolidated Statement of Assets and Liabilities, and the Consolidated Statement of Operations. Furthermore, Note 1.K. entitled “Swap Agreements” in the Notes to Consolidated Financial Statements provides detailed explanations and disclosure. Nevertheless, in light of increased industry focus on derivatives, we are considering adding or modifying language prospectively in the MDFP regarding the use of derivatives, including swaps, to affect performance.
     We believe that the disclosures in the principal strategy sections of the prospectuses for both funds, which were reviewed by the SEC examiner, were also appropriate. In light of increased industry focus on derivatives, however, we are reviewing derivatives disclosures across the Invesco Funds complex and considering whether modifications or enhancements are appropriate.

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Comment 9
     SEC Comment: Regarding the Invesco High Yield Securities Fund and Invesco Van Kampen High Yield Fund, the Staff believes that the Lipper High Current Yield Bond Funds Index does not qualify as a broad-based index to be used as a benchmark for these Funds as stated in the “Results of a $10,000 Investment” line graph in the Annual Reports.
     Invesco Response: Going forward, the Invesco High Yield Securities Fund will use the Barclays Capital U.S. Corporate High Yield 2% Issuer Cap Index, which is its broad-based index, as well as the Lipper High Current Yield Bond Fund Index in its “Results of a $10,000 Investment” chart.
     Note that the Invesco Van Kampen High Yield Fund has been reorganized into another Invesco Fund and no longer maintains an effective N-1A prospectus.
Comment 10
     SEC Comment: Regarding the return of capital in the Invesco Van Kampen Equity Premium Income Fund, the Staff sought confirmation that the requirements of Rule 19a-1 under the Investment Company Act of 1940 were met.
     Invesco Response: We believe the requirements of Rule 19a-1 under the Investment Company Act of 1940 were met by Invesco Van Kampen Equity Premium Income Fund. Note that the Invesco Van Kampen Equity Premium Income Fund has been reorganized into another Invesco Fund and no longer maintains an effective N-1A prospectus.
Comment 11
     SEC Comment: Regarding the Invesco Van Kampen Pennsylvania Tax Free Income Fund, the Staff noted that the current prospectus states that “[t]he Fund does not purchase securities that are in default or rated in categories lower than B- by Standard and Poor’s (S&P) or B3 by Moody’s Investors Service, Inc. (Moody’s) or unrated securities of comparable quality.” The Staff also noted that the current MDFP states the portfolio composition to be 29.7% in “[n]on-rated securities.” The Staff requested that we provide an explanation reconciling these two statements.
     Invesco Response: The Fund invests in securities that are rated as B- or above as well as non-rated securities of comparable quality as determined by Invesco. The 29.7% of “non-rated securities” as disclosed in the MDFP were deemed to be securities of quality comparable to B- or above.
Comment 12
     SEC Comment: Regarding the Invesco Van Kampen Pennsylvania Tax Free Income Fund Annual Report for the period-ended August 31, 2010, the Staff commented that schedule of investments listed “100.1%” investments in municipal bonds and 93.1% investments in the region of Pennsylvania. The Staff believes that

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the portfolio holdings should be further broken down by industry based on the Staff’s interpretation of Rule 12-12 of Regulation S-X.
     Invesco Response: The disclosure practice for state-specific municipal funds is to categorize investments on the Schedule of Investments by the type of investment and the geographic region of the investment. We also disclose in the MDFP, the portfolio composition categorized by credit sector.
     Nevertheless, we are considering the Staff’s comment to prospectively break down the investments by industry in the Schedule of Investments.
Comment 13
     SEC Comment: Regarding the Invesco High Yield Securities Fund amended Forms N-SAR and N-CSR for the period-ended August 31, 2010, the Staff commented on the “errors in the classification of income and realized gains from investment securities and the change in unrealized appreciation from investment securities for the fiscal year ended August 31, 2010” as well as the auditor’s statement that there was a “material weakness” in the “controls designed to ensure the correct classification of the effects of discount accretion/premium amortization and realized gain / loss recognition of certain fixed income securities.” The Staff requested an explanation of the causes for the error and the steps Invesco has taken to tighten internal controls to prevent future errors.
     Invesco Response: We are providing you the public disclosure regarding the error and changes to internal controls. Form N-CSR/A for the period-ended August 31, 2010 included the following explanatory note:
     The Registrant is filing this Amendment to its Certified Shareholder Report on Form N-CSR filed with the Securities and Exchange Commission on November 8, 2010 to amend Item 1 “Reports to Stockholders” with respect to Invesco High Yield Securities Fund’s annual report. Subsequent to issuance of its August 31, 2010 financial statements, AIM Investment Securities (Invesco Investment Securities) identified errors in the classification of income and realized gains from investment securities and the change in unrealized appreciation from investment securities for the fiscal year ended August 31, 2010. The financial statements have been restated to reflect the correction of these errors. The restatement did not impact Invesco High Yield Securities Fund’s previously reported net asset value, total returns or distributions for any share class. This N-CSR/A also updates the “Report of Independent Registered Public Accounting Firm” and Item 11 “Controls and Procedures” as required. Other than the aforementioned revisions this Form N-CSR/A does not reflect events occurring after the filing of the original Form N-CSR, or modify or update the disclosures therein in any way.
     Furthermore, Item 11 was amended as follows:
     ITEM 11. CONTROLS AND PROCEDURES.

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(a) Subsequent to the last assessment of the effectiveness of the control environment of Invesco High Yield Securities Fund a series portfolio of AIM Investment Securities Funds (Invesco Investment Securities Funds) (the “Fund”) performed on March 21, 2011 we have concluded with respect to the Fund’s controls solely related to the classification of the effects of discount accretion and realized loss recognition of certain fixed income securities did not operate effectively as of August 31, 2010. As a result the Fund’s statements of operations and of changes in net assets and financial highlights for the year ended August 31, 2010 were restated to appropriately classify such amounts.
(b) During the second fiscal quarter ended February 28, 2011 Invesco High Yield Securities Fund a series portfolio of AIM Investment Securities Funds (Invesco Investment Securities Funds) the personnel and financial reporting operating platform, policies and procedures were changed from a third party service provider to Invesco Advisers, Inc.
Comment 14
     SEC Comment: Regarding the Form N-SAR for the AIM Counselor Series Trust (Invesco Counselor Series Trust) (“ACST”), file number 811-09913, for the period-ended August 31, 2010, the Staff noted that the auditor’s internal control letter was not included.
     Invesco Response: The auditor’s internal control letter was inadvertently omitted from this filing. The Registrant will file an amended Form N-SAR to include the auditor’s internal control letter. We have since reinforced our internal controls regarding filing auditor letters.
In connection with the Registrants’ responses to the SEC Staff’s comments, as requested by the Staff, the Registrants acknowledge that: (i) the Registrants are responsible for the adequacy of the disclosure in the Registrants’ filings; (ii) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the SEC from taking any action with respect to the filings; and (iii) the Registrants may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.
If you have any questions regarding the responses in this letter, please feel free to contact me at (713) 214-4354.
         
  Regards,
 		  
  /s/ Sheri L. Morris    
  Sheri L. Morris   
  Principal Financial Officer  
 

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