Annual CCO Certification Pursuant to Form N-
CEN Item G.1.a.v.( )

In regard to the interfund lending program, I certify
that the Lord Abbett Family of Funds and Lord,
Abbett & Co. LLC have established procedures
reasonably designed to achieve compliance with the
terms and conditions of the exemptive order issued
by the U.S. Securities and Exchange Commission,
which are designed to achieve the following
objectives:  (a) that the Interfund Loan Rate will be
higher than the Repo Rate, but lower than the Bank
Loan Rate; (b) compliance with the collateral
requirements as set forth in the Application; (c)
compliance with the percentage limitations on
interfund borrowing and lending; (d) allocation of
interfund borrowing and lending demand in an
equitable manner and in accordance with
procedures established by the Fund Board; and (e)
that the interest rate on any Interfund Loan does not
exceed the interest rate on any third-party
borrowings of a borrowing Fund at the time of the
Interfund Loan.


/s/ Joseph McGill
			November 4, 2019
Joseph McGill
Chief Compliance Officer
The Lord Abbett Family of Funds