CORRESP 1 filename1.htm

May 27, 2025

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Megan F. Miller

Re: 408 SOX Review -- BNY Mellon Family of Funds Listed in Appendix A

Ladies and Gentlemen:

On behalf of the funds in the BNY Mellon Family of Funds listed in Appendix A hereto (each, a "Fund"), transmitted for filing as EDGAR correspondence are the Funds' responses to the comments of the accounting staff (the "Staff") of the Securities and Exchange Commission (the "Commission"), provided by Megan F. Miller, Staff Accountant, to the undersigned by telephone on February 26, 2025 and May 1, 2025. The Staff's comments related to the three-year review of the audited financial statements of the Funds for the fiscal years ended on the respective dates noted in Appendix A, included in the Funds' annual reports on Form N-CSR as filed with the Commission, pursuant to Rule 408(c) of the Sarbanes-Oxley Act of 2002.

Set forth below is a summary of the Staff's comments, and the Funds' responses thereto.

BNY Bond Market Index Fund

Comment 1:  Please confirm that the disclosure for TBA investments aligns with Regulation S-X 6-07.7 (see AICPA Expert Panel Minutes, November 13, 2023).

Response 1:  Fund management confirms that going forward realized and unrealized TBA will be broken out to align with Regulation S-X 6-07.7.

Comment 2:  Please consider updating the disclosure for caption "Statement of Operations" to state securities lending income is presented net of any rebates or fees paid to Borrowers.

Response 2:  Fund management confirms that going forward the Statement of Operations will state securities lending income net of any rebates or fees paid to Borrowers and will update applicable notes.

BNY Mellon Yield Enhancement Strategy Fund

Comment 3:  Please confirm Financial Highlights include to the extent required a footnote stating that "Ratio of net investment income" does not reflect proportionate share of income of the Underlying Funds in which the Fund invests. (See ASC 946-205-50-16.)

Response 3:  Included in the Items 7-11, "Annual Financials and Other Information" dated October 31, 2024, is a footnote that reads "excludes expenses of underlying funds", and such footnote will be included, as applicable, for the fund going forward.

BNY Mellon Natural Resources Fund

Comment 4:  Please note, the S&P Global Natural Resources Index was incorrectly tagged in XBRL as the "broad based" index.

Response 4:  Going forward, the broad-based index will be correctly tagged in XBRL. The order in which each index was disclosed was switched, which caused an inadvertent tagging error.

BNY Mellon Funds Trust – Municipal Funds

Comment 5:  Please consider including a "Total'" for "accumulated earnings" in Table 1 -- Components of Accumulated Earnings.

Response 5:  Going forward, the word "Total" will be included in Table 1, as requested.

Funds that Engage in Securities Lending

Comment 6:  Please explain why securities lending income is not noted as "affiliate" on Statement of Operations.

Response 6  Going forward, securities lending income will include the word "affiliate", as requested.

All Relevant Funds

Comment 7:  Please explain how Item 10 of N-CSR meets the requirement to disclose aggregate remuneration paid by the Company during the period covered by the report if payments are disclosed in multiple locations in Item 7 (e.g., Item 10 reflects payment to Trustees, Line 7 states payable to CCO) (See TSR FAQ No.3).

Response 7:   For those Funds that have relevant payments disclosed in multiple locations in Item 7, Item 10 of N-CSR, the disclosure will be revised going forward to include the aggregate dollar amount of relevant remuneration paid by the Fund during the period covered by the report. Examples of the revised disclosure:

For Funds without unitary fee:

Each board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets. The fund is charged for services performed by the fund's Chief Compliance Officer. Compensation paid by the fund during the period to the board members and the Chief Compliance Officer are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and expenses and Chief Compliance Officer fees, respectively. The aggregate amount of Directors'[/Trustees'] fees and expenses and Chief Compliance Officer fees paid by the fund during the period was $_____. 

For Funds with unitary fee:

Each board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets. The Adviser reimburses the fund for the fees and expenses of the non-interested board members. Compensation paid by the fund to the board members and board member fees reimbursed by the Adviser during the period are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and Directors'[/Trustees'] fees reimbursed by BNY Mellon Investment Adviser, Inc., respectively.

BNY Mellon Municipal Income and BNY Mellon Strategic Municipal Bond Fund

Comment 8:  Please confirm that description of Debt in Notes to Financial Statements includes the effective interest rate in addition to the stated rate (See ASC 835-30-45-2).

Response 8:  The description of debt in Note 1(e) includes the effective interest rate in addition to the stated rate.

All Relevant Funds

Comment 9:  Please explain why overdraft fees are netted with interest income as opposed to an expense to the Fund (see Note in Statement of Operations). Specifically, the rationale for netting overdraft fees from interest income.

Response 9:  Per the rule, expenses are only broken out if expenses exceeded 5% of total expenses or total income. The rationale for netting is because the amounts were immaterial.

Unitary Fee Funds

Comment 10:  Please confirm what fees and expenses are excluded from the management fee (e.g., are loan commitment fees, interest expense and securities lending fees paid by the Fund).

Response 10:  Fees and expenses excluded from the unitary management fee are: 12b-1 fees, if applicable, shareholder services fees, if applicable, loan commitment fee from borrowings and interest expense as well as any extraordinary expenses.

* * * * *

Should you have any questions or comments, please feel free to contact me at 212.540.4569 (dstephens@stradley.com) .

Very truly yours,

/s/ DAVID STEPHENS
David Stephens

cc: Sarah Kelleher

 Amanda Quinn

APPENDIX A1

      

0000718935

811-03721

BNY Mellon Intermediate Municipal Bond Fund, Inc.

S000000073

BNY Mellon Intermediate Municipal Bond Fund, Inc.

5/31/2024

0000875732

811-06325

BNY MELLON MIDCAP INDEX FUND, INC.

S000000078

BNY Mellon Midcap Index Fund, Inc.

10/31/2024

0000828475

811-05454

BNY MELLON NEW JERSEY MUNICIPAL BOND FUND, INC.

S000000091

BNY Mellon New Jersey Municipal Bond Fund, Inc.

12/31/2023

0000737520

811-03940

BNY Mellon Strategic Funds, Inc.

S000000092

BNY Mellon Active MidCap Fund

12/31/2023

0000797920

811-04765

BNY MELLON NEW YORK AMT-FREE MUNICIPAL BOND FUND

S000000093

BNY Mellon New York AMT-Free Municipal Bond Fund

11/30/2023

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000371

BNY Mellon Small Cap Multi-Strategy Fund

8/31/2024

0000857114

811-05883

BNY MELLON INDEX FUNDS, INC.

S000000130

BNY Mellon International Stock Index Fund

10/31/2024

0001199348

811-21236

BNY MELLON STOCK FUNDS

S000000354

BNY Mellon International Core Equity Fund

9/30/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000362

BNY Mellon Massachusetts Intermediate Municipal Bond Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000364

BNY Mellon National Intermediate Municipal Bond Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000365

BNY Mellon National Municipal Money Market Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000366

BNY Mellon National Short-Term Municipal Bond Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000367

BNY Mellon Pennsylvania Intermediate Municipal Bond Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000368

BNY Mellon Short-Term U.S. Government Securities Fund

8/31/2024

0000914775

811-07123

BNY Mellon Advantage Funds, Inc.

S000000498

BNY Mellon Dynamic Value Fund

8/31/2024

  

BNY Mellon Advantage

S000000500

BNY Mellon Technology

8/31/2024

 
 

1  As provided by Megan F. Miller of the Staff.

      

0000914775

811-07123

Funds, Inc.

 

Growth Fund

 

0000878092

811-06377

BNY MELLON MUNICIPAL FUNDS, INC.

S000000330

BNY Mellon AMT-Free Municipal Bond Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000369

BNY Mellon Income Stock Fund

8/31/2024

0000353560

811-03207

GENERAL MONEY MARKET FUND, INC.

S000000119

GENERAL MONEY MARKET FUND, INC

11/30/2023

0000030167

811-02192

BNY Mellon Sustainable U.S. Equity Fund, Inc.

S000000095

BNY Mellon Sustainable U.S. Equity Fund, Inc.

5/31/2024

0000897569

811-07512

BNY Mellon Worldwide Growth Fund, Inc.

S000000096

BNY Mellon Worldwide Growth Fund, Inc.

10/31/2024

0000030146

811-00523

BNY Mellon Large Cap Securities Fund, Inc.

S000000068

BNY Mellon Large Cap Securities Fund, Inc.

12/31/2023

0000889169

811-06718

BNY Mellon Investment Funds VII, Inc.

S000000297

BNY Mellon Short Term Income Fund

7/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000370

BNY Mellon Mid Cap Multi-Strategy Fund

8/31/2024

0000818972

811-05245

BNY MELLON STRATEGIC MUNICIPALS, INC.

CEF0014552

BNY MELLON STRATEGIC MUNICIPALS, INC.

9/30/2024

0000855887

811-05877

BNY MELLON STRATEGIC MUNICIPAL BOND FUND, INC.

CEF0013739

BNY MELLON STRATEGIC MUNICIPAL BOND FUND, INC.

11/30/2023

0000819940

811-05202

BNY Mellon Investment Funds IV, Inc.

S000000299

BNY Mellon Institutional S&P 500 Stock Index Fund

10/31/2024

0000819940

811-05202

BNY Mellon Investment Funds IV, Inc.

S000000305

BNY Mellon Tax Managed Growth Fund

10/31/2024

0000819940

811-05202

BNY Mellon Investment Funds IV, Inc.

S000000307

BNY Mellon Bond Market Index Fund

10/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000021515

BNY Mellon New York Intermediate Tax-Exempt Bond Fund

8/31/2024

0000737520

811-03940

BNY Mellon Strategic Funds, Inc.

S000015656

BNY Mellon Global Stock Fund

11/30/2023

0000737520

811-03940

BNY Mellon Strategic Funds, Inc.

S000015657

BNY Mellon International Stock Fund

11/30/2023

0000878092

811-06377

BNY MELLON MUNICIPAL FUNDS, INC.

S000002850

BNY Mellon High Yield Municipal Bond Fund

8/31/2024

0001591556

811-22912

BNY Mellon Investment Funds II, Inc.

S000043942

BNY Mellon Global Emerging Markets Fund

10/31/2024

0000737520

811-03940

BNY Mellon Strategic Funds, Inc.

S000029388

BNY Mellon Select Managers Small Cap

5/31/2024

      
    

Growth Fund

 

0000881773

811-06490

BNY Mellon Investment Funds V, Inc.

S000019789

BNY Mellon Large Cap Equity Fund

12/31/2023

0000881773

811-06490

BNY Mellon Investment Funds V, Inc.

S000019790

BNY Mellon Developed Markets Real Estate Securities Fund

10/31/2024

0000053808

811-00524

BNY Mellon Investment Funds III

S000012565

BNY Mellon Equity Income Fund

5/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000023621

BNY Mellon Municipal Opportunities Fund

8/31/2024

0000857114

811-05883

BNY MELLON INDEX FUNDS, INC.

S000000131

BNY Mellon S&P 500 Index Fund

10/31/2024

0000857114

811-05883

BNY MELLON INDEX FUNDS, INC.

S000000132

BNY Mellon Smallcap Stock Index Fund

10/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000372

BNY Mellon International Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000373

BNY Mellon Emerging Markets Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000374

BNY Mellon Asset Allocation Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000375

BNY Mellon Bond Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000000376

BNY Mellon Intermediate Bond Fund

8/31/2024

0000914775

811-07123

BNY Mellon Advantage Funds, Inc.

S000000461

BNY Mellon Opportunistic Midcap Value Fund

8/31/2024

0000914775

811-07123

BNY Mellon Advantage Funds, Inc.

S000000462

BNY Mellon Opportunistic Small Cap Fund

8/31/2024

0001111565

811-09903

BNY MELLON FUNDS TRUST

S000035959

BNY Mellon Corporate Bond Fund

8/31/2024

0000819940

811-05202

BNY Mellon Investment Funds IV, Inc.

S000042108

BNY Mellon Floating Rate Income Fund

8/31/2024

0000737520

811-03940

BNY Mellon Strategic Funds, Inc.

S000024356

BNY Mellon Select Managers Small Cap Value Fund

11/30/2023

0000318478

811-03081

BNY MELLON APPRECIATION FUND, INC.

S000000008

BNY Mellon Appreciation Fund, Inc.

12/31/2023

0000720064

811-03757

BNY MELLON CALIFORNIA AMT-FREE MUNICIPAL BOND FUND, INC.

S000000016

BNY Mellon California AMT-Free Municipal Bond Fund, Inc.

5/31/2024

0001493580

811-23477

BNY Mellon ETF Trust

S000073736

BNY Mellon Concentrated International ETF

10/31/2024

      

0000839122

811-05652

BNY MELLON MUNICIPAL INCOME, INC.

CEF0014355

BNY MELLON MUNICIPAL INCOME, INC.

9/30/2024

0001224568

811-21327

BNY Mellon Investment Funds VI

S000000342

BNY Mellon Balanced Opportunity Fund

11/30/2023

0001111178

811-09891

BNY MELLON OPPORTUNITY FUNDS

S000001720

BNY Mellon Natural Resources Fund

9/30/2024

0001591556

811-22912

BNY Mellon Investment Funds II, Inc.

S000044141

BNY Mellon Yield Enhancement Strategy Fund

10/31/2024

0000737520

811-03940

BNY Mellon Strategic Funds, Inc.

S000022407

BNY Mellon U.S. Equity Fund

11/30/2023