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Amundi
ASSET MANAGEMENT
October 16, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: SEC Staff Sarbanes-Oxley Review of Filings by Pioneer Funds
Ladies and Gentlemen:
This letter is to respond to comments received on September 18, 2023 from
Mr. Chad Eskildsen of the Staff of the Securities and Exchange Commission in
connection with the Staff's review of financial statements and other filings by
the Pioneer Funds listed on Appendix A (the "Funds"). Following are the Staff's
comments and the Funds' responses thereto.
1. Comment: The Staff noted that Pioneer Strategic Income Fund appears to
have made a tax return of capital distribution during the fiscal
year ended September 30, 2022. The Staff requested that the Fund
confirm that it complied with Section 19(a) of the 1940 Act and
Rule 19a-1 notice requirements with respect to such return of
capital. The Staff referred to IM-DCFO 2019-02, the Dear CFO
Letter dated 11/22/2019, with respect to the Staff's position
that Section 19(a) requires that distributions made from any
source other than the Fund's net income be accompanied by
written statements.
The Staff also requested that the Fund explain why the Fund
responded "no" to Item B.23 of Form N-CEN filed for the fiscal
year ended September 30, 2022 ("During the reporting period, did
the Registrant pay any dividend or make any distribution in the
nature of a dividend payment, required to be accompanied by a
written statement pursuant to Section 19(a) of the [1940 Act]
and Rule 19a-1 thereunder").
Response: Pioneer Strategic Income Fund notes that it did not make any
distributions that were in excess of its book income during the
fiscal year ended September 30, 2022. The Fund notes that the
distribution referenced by the Staff was determined to be a
return of capital on a tax basis due to tax adjustments after
the Fund calculated its taxable income for the fiscal year.
Accordingly, the Fund respectfully submits that (i) a Rule 19a-1
notice was not required with respect to the tax return of
capital distribution referenced by the Staff, and (ii) the Fund
correctly responded "no" to Item B.23 of Form N-CEN filed for
the fiscal year ended September 30, 2022.
2. Comment: The Staff noted that Items 4(i) and 4(j) of Form N-CSR,
regarding Holding Foreign Companies Accountable Act disclosure,
became effective as of January 10, 2022. The
Staff requested that the Funds confirm that they will include
these items, and appropriate responses, in future Form N-CSR
filings.
Response: The Funds confirm that they will include Items 4(i) and 4(j),
and appropriate responses, in future Form N-CSR filings.
3. Comment: The Staff noted that the Form N-CEN filed by Pioneer Variable
Contracts Trust for the fiscal year ended December 31, 2022
reported in response to Item B.22. that payments were made to
shareholders or shareholder accounts were reprocessed as a
result of an error in calculating the net asset value of each of
Pioneer Bond VCT Portfolio, Pioneer High Yield VCT Portfolio and
Pioneer Strategic Income VCT Portfolio, but that no
corresponding disclosure was included in the financial
statements of such Funds. The Staff requested that the Funds
describe the nature and circumstances of such NAV errors, any
associated internal control implications, mitigating actions
taken with respect to such NAV errors and any internal control
issues, and amounts reimbursed to shareholders, if any. The
Staff also requested that, if amounts have been reimbursed to
shareholders, to please explain why such payments were not
disclosed in the Funds' financial statements, citing U.S. GAAP.
Response: The Funds note that the NAV errors reported in response to Item
B.22 with respect to Pioneer Bond VCT Portfolio, Pioneer High
Yield VCT Portfolio and Pioneer Strategic Income VCT Portfolio
related to incorrect processing of gain/loss information for
certain credit default swap index (CDX) transactions by such
Funds.
The Funds note that the transaction processing system used
during the fiscal year ended December 31, 2022 by Amundi Asset
Management US, Inc. ("Amundi US"), the Funds' adviser,
compressed CDX transactions, collapsing two or more derivative
trades in the same security with the goal of combining the
notional outstanding into a single position, for risk management
purposes. However, it was determined that, as a result of such
compression trade processing and related adjustments, gain/loss
amounts with respect to CDX transactions were recorded
incorrectly during the fiscal year ended December 31, 2022 for
Pioneer Bond VCT Portfolio, Pioneer High Yield VCT Portfolio and
Pioneer Strategic Income VCT Portfolio.
Amundi US identified the issue in January 2023 in connection
with the audits of the financial statements of certain funds in
the Pioneer Funds complex. In response to the issue, Amundi US
implemented a temporary manual process to reclassify unrealized
and realized gain/loss related to CDX transactions for financial
reporting purposes. This manual process was effective during the
audit of the financial statements of each of Pioneer Bond VCT
Portfolio, Pioneer High Yield VCT Portfolio and Pioneer
Strategic Income VCT Portfolio for the fiscal year ended
December 31, 2022, and no internal control deficiency, including
with respect to CDX transactions, was identified for such Funds
for the fiscal year ended December 31, 2022. Subsequently, a
fully automated CDX trade integration process was implemented in
an effort to mitigate the risk of potential future NAV errors
and reporting issues.
As reported in response to Item B.22 of Form N-CEN, it was
determined that the NAVs of Pioneer Bond VCT Portfolio, Pioneer
High Yield VCT Portfolio and Pioneer Strategic Income VCT
Portfolio were misstated for the period between September 30,
2022 and November 23, 2022. The NAVs reported during the
misstatement period were subsequently recalculated. It was
determined that the daily misstatement for each
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Fund ranged from $0.02 to $0.04 per share. Amundi US reimbursed
each Fund as a result of the NAV error, and each Fund then
reprocessed activity for shareholders who experienced a loss by
redeeming shares at an incorrect NAV. The total reimbursements
were calculated on a daily basis for the period noted above, in
accordance with the Funds' NAV error correction policy. The
amounts reimbursed were $5,166 to shareholders of Pioneer Bond
VCT Portfolio (Net Assets at 12/31/22 $142.2m), $11,123 to
shareholders of Pioneer High Yield VCT Portfolio (Net Assets at
12/31/22 $27.4m), and $2,107 to shareholders of Pioneer
Strategic Income VCT Portfolio (Net Assets at 12/31/22 $32.5m).
The Funds note that the reimbursements discussed
above were determined and made in February 2023, subsequent to
the end of the Funds' fiscal year ended December 31, 2022.
Accordingly, such reimbursements were not disclosed in the
Funds' financial statements for the fiscal year ended
December 31, 2022. The Funds confirm that such reimbursements
will be disclosed in the Funds' audited financial statements for
the fiscal year ended December 31, 2023 in accordance with the
guidance in FASB ASC 946-20, and related guidance including
946-205.
Please call the undersigned at 617-422-4697 with any questions.
Sincerely,
/s/ Anthony J. Koenig, Jr.
Anthony J. Koenig, Jr.
Managing Director, Chief
Operations Officer and Fund
Treasurer
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APPENDIX A
Series Identifier File No. Registrant Fund Fiscal Year End
S000004007 811-21569 PIONEER ASSET ALLOCATION Pioneer Solutions - Balanced Fund 7/31/2022
TRUST
S000070623 811-23613 Pioneer Core Trust I Pioneer High Income Municipal 8/31/2022
Portfolio
S000003948 811-08657 PIONEER EQUITY INCOME FUND Pioneer Equity Income Fund 10/31/2022
CEF0010133 811-21654 Pioneer Floating Rate Fund, Inc. Pioneer Floating Rate Fund, Inc. 11/30/2022
S000003991 811-01466 PIONEER FUND /MA/ Pioneer Fund 12/31/2022
S000003994 811-09685 PIONEER HIGH YIELD FUND Pioneer High Yield Fund 10/31/2022
S000004143 811-06106 PIONEER MID CAP VALUE FUND Pioneer Mid Cap Value Fund 10/31/2022
S000009919 811-05099 PIONEER MONEY MARKET TRUST Pioneer U.S. Government Money 12/31/2022
Market Fund
S000010000 811-07870 PIONEER REAL ESTATE SHARES Pioneer Real Estate Shares 12/31/2022
S000010084 811-21460 PIONEER SERIES TRUST II Pioneer Select Mid Cap Growth Fund 11/30/2022
S000010085 811-21460 PIONEER SERIES TRUST II Pioneer AMT-Free Municipal Fund 12/31/2022
S000010093 811-21664 Pioneer Series Trust III Pioneer Disciplined Value Fund 8/31/2022
S000010109 811-21781 Pioneer Series Trust IV Pioneer Balanced ESG Fund 7/31/2022
S000035110 811-21781 Pioneer Series Trust IV Pioneer Multi-Asset Income Fund 7/31/2022
S000072337 811-21781 Pioneer Series Trust IV Pioneer Securitized Income Fund 7/31/2022
S000010121 811-21823 Pioneer Series Trust V Pioneer Global Sustainable Equity Fund 8/31/2022
S000013005 811-21823 Pioneer Series Trust V Pioneer High Income Municipal Fund 8/31/2022
S000015510 811-21978 Pioneer Series Trust VI Pioneer Floating Rate Fund 10/31/2022
S000028857 811-21978 Pioneer Series Trust VI Pioneer Flexible Opportunities Fund 10/31/2022
S000010203 811-10395 PIONEER SERIES TRUST VII Pioneer Global High Yield Fund 10/31/2022
S000004011 811-07318 PIONEER SERIES TRUST VIII Pioneer International Equity Fund 11/30/2022
S000010136 811-01835 PIONEER SERIES TRUST XI Pioneer Core Equity Fund 12/31/2022
S000004009 811-08547 PIONEER SERIES TRUST XII Pioneer Disciplined Growth Fund 8/31/2022
S000070201 811-08547 PIONEER SERIES TRUST XII Pioneer MAP High Income Municipal 8/31/2022
Portfolio
S000065786 811-09223 PIONEER SERIES TRUST XIV Pioneer Emerging Markets Equity Fund 9/30/2022
S000010131 811-09223 PIONEER SERIES TRUST XIV Pioneer Strategic Income Fund 9/30/2022
S000071518 811-09223 PIONEER SERIES TRUST XIV Pioneer Global Sustainable Growth 9/30/2022
Fund
S000071519 811-09223 PIONEER SERIES TRUST XIV Pioneer Global Sustainable Value Fund 9/30/2022
S000071520 811-09223 PIONEER SERIES TRUST XIV Pioneer Intrinsic Value Fund 9/30/2022
S000010228 811-21558 PIONEER SHORT TERM INCOME Pioneer Short Term Income Fund 8/31/2022
FUND
S000010159 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Fund VCT Portfolio 12/31/2022
TRUST /MA/
S000010160 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Real Estate Shares VCT 12/31/2022
TRUST /MA/ Portfolio
S000010163 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Strategic Income VCT Portfolio 12/31/2022
TRUST /MA/
S000010170 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Select Mid Cap Growth VCT 12/31/2022
TRUST /MA/ Portfolio
S000010172 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Bond VCT Portfolio 12/31/2022
TRUST /MA/
S000010181 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Equity Income VCT Portfolio 12/31/2022
TRUST /MA/
S000010184 811-08786 PIONEER VARIABLE CONTRACTS Pioneer High Yield VCT Portfolio 12/31/2022
TRUST /MA/
S000010186 811-08786 PIONEER VARIABLE CONTRACTS Pioneer Mid Cap Value VCT Portfolio 12/31/2022
TRUST /MA/
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