SEC Division of Investment Management staff letter: Pioneer Funds

Associate Director and Chief Counsel
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 40549
Re: Pioneer Funds
Status of Stephen K. West as an Independent Trustee under Rule 10A-3 of the Securities and Exchange Act of 1934 and Form N-CSR Dear Mr. Scheidt:
Wilmer Cutler Pickering Hale and Dorr LLP acts as counsel for each of the Pioneer Funds1 . We are writing this letter on behalf of the Pioneer Funds to confirm our view that Stephen K. West, who is a trustee of the Pioneer Funds, is “independent” within the meaning of Rule 10A-3(b)(iii) under the Securities Exchange Act of 1934, as amended (the “1934 Act”), and Item 3 of Form N￾CSR and Sub-Item 102P3(b)(2) of Form N-SAR under the Investment Company Act of 1940, as amended (the “1940 Act”). Facts Mr. West has served as an independent Trustee of each of the Pioneer Funds since 1993. As currently composed, the Board of Trustees of each of the Pioneer Funds includes two members who are affiliated with Pioneer Investment Management, Inc. (“Pioneer”), the investment adviser to the Pioneer Funds, and six members, including Mr. West, who are not interested persons of Pioneer or the Pioneer Funds (as such term is defined in Section 2(a)(19) of the 1940 Act).2 Mr. West was selected and nominated to the Boards of the Pioneer Funds which are listed, closed￾end investment companies by the non-interested Trustees at the same time he was selected and nominated to the Boards of the open-end funds in the Pioneer complex or upon the later organization of such funds. As a result and as required by various 1940 Act Rules that apply to open-end and closed-end funds (e.g., Rule 17(e)-1(c)(1)), his nomination and selection were