AllianceBernstein Funds
1345 Avenue of the Americas
New York, NY 10105
March 14, 2013
VIA EDGAR
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Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Cathy Churkok
Re: In the matter of the following N-CSR Filings:
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Fund Fiscal Year End
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AllianceBernstein Global Thematic Growth Fund, Inc. (811-03131) 7/31/2012
AllianceBernstein Pooling Portfolios - (811-21673)
Volatility Management Portfolio 8/31/2012
AllianceBernstein Blended Style Series, Inc. - (811-21081)
AllianceBernstein Retirement Strategies 8/31/2012
AlianceBernstein Global Bond Fund, Inc. (811-06554) 9/30/2012
AllianceBernstein Institutional Funds, Inc. - (811-8403)
AllianceBernstein Global Real Estate Investment Fund II 10/31/2012
AllianceBernstein High Income Fund, Inc. (811-08188) 10/31/2012
AllianceBernstein Unconstrained Bond Fund, Inc. (811-07391) 10/31/2012
Alliance California Municipal Income Fund, Inc. (811-10575) 10/31/2012
Alliance New York Municipal Income Fund, Inc. (811-10577) 10/31/2012
AllianceBernstein National Municipal Income Fund, Inc. (811-10573) 10/31/2012
Dear Ms. Churkok:
Enclosed are responses to the requests made during my phone conversation with
you and other members of AllianceBernstein on February 14, 2013.
We hereby acknowledge that (i) each Fund is responsible for the adequacy and
accuracy of the disclosures in this filing; (ii) Staff comments or changes to
disclosures in response to Staff comments in the filing reviewed by the Staff do
not foreclose the SEC from taking any action with respect to the filing; and
(iii) a Fund named in this filing may not assert Staff comments as a defense in
any proceedings initiated by the SEC or any person under the federal securities
laws of the United States.
If you have any questions regarding our response, please do not hesitate to call
me at 914.259.7740.
Sincerely,
/s/ Joseph Mantineo
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Joseph Mantineo
Treasurer and Chief Financial
Officer of each Fund
cc: Larry Cranch, AllianceBernstein L.P.
Phil Kirstein, Senior Officer of the Funds
Mark R. Manley, AllianceBernstein L.P.
Emilie Wrapp, AllianceBernstein L.P.
Stephen Laffey, AllianceBernstein L.P.
Vince Noto, AllianceBernstein L.P
Steve Woetzel, AllianceBernstein L.P.
Phyllis Clarke, AllianceBernstein L.P.
Comment #1:
All Applicable Funds - Form N-CSR
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The expense ratios in the Financial Highlights should only include the gross and
net expense ratios. Any additional expense ratios should be disclosed in
footnotes to the Financial Highlights as supplementary information, including
expense ratios which exclude interest expense and expenses associated with the
TALF program.
Response #1:
Effective with the April 30, 2013 reports, the funds will present the gross and
net expense ratios in the Financial Highlights. Any additional expense ratios
will be disclosed in footnotes to the Financial Highlights.
Comment #2:
AllianceBernstein Global Bond Fund and Alliance California Municipal Income Fund
- Form N-CSR
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The funds did not include a sensitivity analysis on level 3 securities.
Response #2:
A level 3 sensitivity analysis was included for the Alliance California
Municipal Income Fund annual report. With respect to the AllianceBernstein
Global Bond Fund's annual report, no sensitivity analysis was included in the
fair value hierarchy as none of the level 3 securities, by asset class, exceeded
the 1% net asset threshold established by the fund.
Comment #3:
Alliance California Municipal Income Fund - Form N-CSR
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Add additional stratification if a security type has a wide range of prices that
are classified under level three.
Response #3:
Effective with the April 30, 2013 reports, the funds will add additional
stratification if a security type has a wide range of prices that are classified
under level three.
Comment #4:
AllianceBernstein High Income Bond Fund - Form N-CSR
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Does the fund cover the notional amount of sales of credit default swaps
outstanding?
Response #4:
The fund monitors the availability of cash and/or liquid assets to cover the
fund's unrealized exposure on all credit default swaps.
Comment #5:
All Applicable Funds - Form N-CSR
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If a fund receives PIK income representing more than 5% of total income, such
amount should be disclosed on a separate line item in the statement of
operations.
Response #5:
The funds have standing procedures to disclose PIK income if it is more than 5%
of total income.
Comment #6:
AllianceBernstein High Income Bond Fund - Form N-CSR
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What does "other fee income" represent in the statement of operations?
Response #6:
The "other fee income" in the statement of operations was comprised of
commitment fees and additional funding fees from unfunded loan commitments and
unfunded loan participation commitments.