<SEC-DOCUMENT>0000276776-23-000148.txt : 20231120
<SEC-HEADER>0000276776-23-000148.hdr.sgml : 20231120
<ACCEPTANCE-DATETIME>20231016155410
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000276776-23-000148
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20231016

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER ASSET ALLOCATION TRUST
		CENTRAL INDEX KEY:			0001288255
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			0731

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER IBBOTSON ASSET ALLOCATION SERIES
		DATE OF NAME CHANGE:	20041116

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER ASSET ALLOCATION SERIES
		DATE OF NAME CHANGE:	20040422

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER CORE TRUST I
		CENTRAL INDEX KEY:			0001823387
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			0831

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	Pioneer CoreTrust I
		DATE OF NAME CHANGE:	20200902

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER MONEY MARKET TRUST
		CENTRAL INDEX KEY:			0000812195
		IRS NUMBER:				046569772
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE ST 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER MID CAP VALUE FUND
		CENTRAL INDEX KEY:			0000863334
		IRS NUMBER:				043091159
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1031

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST - 5TH FL
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER CAPITAL GROWTH FUND /MA/
		DATE OF NAME CHANGE:	19980630

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER GROWTH TRUST
		DATE OF NAME CHANGE:	19920703

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER EQUITY INCOME FUND
		CENTRAL INDEX KEY:			0000869356
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1031

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SERIES TRUST VIII
		CENTRAL INDEX KEY:			0000893660
		IRS NUMBER:				043170886
		STATE OF INCORPORATION:			MA
		FISCAL YEAR END:			1130

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST- 5TH FL
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER INTERNATIONAL VALUE FUND
		DATE OF NAME CHANGE:	20010730

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER INTERNATIONAL GROWTH FUND
		DATE OF NAME CHANGE:	19930328

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER REAL ESTATE SHARES
		CENTRAL INDEX KEY:			0000908996
		IRS NUMBER:				043201341
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER WINTHROP REAL ESTATE INVESTMENT FUND
		DATE OF NAME CHANGE:	19930713

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER VARIABLE CONTRACTS TRUST /MA/
		CENTRAL INDEX KEY:			0000930709
		IRS NUMBER:				000000000
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			021091820

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	VARIABLE INSURANCE CONTRACTS TRUST
		DATE OF NAME CHANGE:	19940929

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SERIES TRUST XII
		CENTRAL INDEX KEY:			0001051010
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			MA
		FISCAL YEAR END:			0831

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET, 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET, 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER INDEPENDENCE FUND
		DATE OF NAME CHANGE:	19971208

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SERIES TRUST XIV
		CENTRAL INDEX KEY:			0001077452
		IRS NUMBER:				043453709

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER STRATEGIC INCOME FUND
		DATE OF NAME CHANGE:	19990122

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER HIGH YIELD FUND
		CENTRAL INDEX KEY:			0001094521
		IRS NUMBER:				043500606
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1031

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SERIES TRUST VII
		CENTRAL INDEX KEY:			0001140157
		IRS NUMBER:				043567848
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1031

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER GLOBAL HIGH YIELD FUND
		DATE OF NAME CHANGE:	20010507

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SERIES TRUST II
		CENTRAL INDEX KEY:			0001265389
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SHORT TERM INCOME FUND
		CENTRAL INDEX KEY:			0001286364
		IRS NUMBER:				562451408
		FISCAL YEAR END:			0831

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER SHORT TERM BOND FUND
		DATE OF NAME CHANGE:	20040407

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Pioneer Floating Rate Fund, Inc.
		CENTRAL INDEX KEY:			0001305767
		IRS NUMBER:				582683903
		STATE OF INCORPORATION:			MD
		FISCAL YEAR END:			1130

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	Pioneer Floating Rate Trust
		DATE OF NAME CHANGE:	20041013

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Pioneer Series Trust III
		CENTRAL INDEX KEY:			0001306349
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			0630

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		(617)742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Pioneer Series Trust IV
		CENTRAL INDEX KEY:			0001331854
		IRS NUMBER:				000000000

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Pioneer Series Trust V
		CENTRAL INDEX KEY:			0001341256
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			0831

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Pioneer Series Trust VI
		CENTRAL INDEX KEY:			0001380192
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1031

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER FUND /MA/
		CENTRAL INDEX KEY:			0000078713
		IRS NUMBER:				046013015
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST., 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER FUND INC
		DATE OF NAME CHANGE:	19920703

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	FIDELITY INVESTMENT ASSOCIATES INC
		DATE OF NAME CHANGE:	19680607

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PIONEER SERIES TRUST XI
		CENTRAL INDEX KEY:			0000078758
		IRS NUMBER:				042458787
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			0930

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		60 STATE ST
		STREET 2:		5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		617-742-7825

	MAIL ADDRESS:	
		STREET 1:		60 STATE STREET, 5TH FLOOR
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109-1820

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER VALUE FUND
		DATE OF NAME CHANGE:	20010402

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER II
		DATE OF NAME CHANGE:	19920703

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PIONEER II INC
		DATE OF NAME CHANGE:	19851112
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>

[LOGO]
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

<PAGE>

              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

                                      2

<PAGE>

        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

                                      3

<PAGE>

                                  APPENDIX A

<TABLE>
<CAPTION>
Series Identifier File No.  Registrant                        Fund                                    Fiscal Year End
<C>               <C>       <S>                               <C>                                     <C>
   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/
</TABLE>

                                      4
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>