SEC Company Response from AB BOND FUND, INC. (CIK 0000003794) — Feb 10, 2021
AB BOND FUND, INC. (CIK 0000003794)
Date: Feb. 10, 2021 · CIK: 0000003794 · Accession: 0000919574-21-000812
AI Filing Summary & Sentiment
File numbers found in text: 811-00204, 811-02383, 811-05088, 811-06730, 811-07732, 811-08426
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CORRESP
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AB
Funds
1345
Avenue of the Americas
New
York, NY 10105
February 10, 2021
VIA EDGAR CORRESPONDENCE
Division of Investment Management
Disclosure Review and Accounting Office
U.S. Securities and Exchange Commission
Brookfield Place
200 Vesey Street – Suite 400
New York, NY 10281-1022
Attention: Mindy Rotter
Re: In the matter of the SEC Filings set forth in Appendix B hereto
Dear Ms. Rotter:
Attached as Appendix A are responses to the comments made during
your phone conversation with Phyllis Clarke and other representatives of AllianceBernstein L.P. (the “Adviser”) on
January 13, 2021.
If you have any questions regarding our responses, please do not
hesitate to call me at 914.259.7740.
Sincerely,
/s/ Joseph Mantineo
Joseph Mantineo
Treasurer and Chief Financial
Officer of each Fund
cc: Michael Reyes, Senior Analyst of the Funds
Mark R. Manley, AllianceBernstein L.P.
Emilie Wrapp, AllianceBernstein L.P.
Eric Freed, AllianceBernstein L.P.
Vince Noto, AllianceBernstein L.P
Steve Woetzel, AllianceBernstein L.P.
Phyllis Clarke, AllianceBernstein L.P.
Appendix A
Comment #1:
All funds in complex
Please review and update EDGAR for those
funds that merged or liquidated and changed their status from active to inactive.
Response #1:
The Adviser has changed the EDGAR status
of certain funds that have merged or liquidated from active to inactive.
Comment #2:
Funds #: 1-4
Please confirm in correspondence that there
are no open payables to directors at year-end. If yes, these should be disclosed separately in accordance with Regulation
S-X 6-04.
Response #2:
The Adviser confirms there are no open
payables to directors at year-end.
Comment #3:
Funds #: 1,2
Please confirm that there are no components
of accrued expenses and other liabilities that should be separately classified on the statement of assets and liabilities.
Response #3:
The Adviser confirms there are no components
of accrued expenses and other liabilities that should be separately classified on the statement of assets and liabilities.
Comment #4:
Funds #: 1,2
Miscellaneous expenses appear to exceed
5% of total expenses. Please confirm that any category of other expenses has been separately identified in accordance with
Regulation S-X 6-07.
Response #4:
The Adviser confirms that all categories
of other expenses that exceed 5% of total expenses have been separately identified on the statement of operations.
Comment #5:
Fund #: 3
Note A in the notes to the financial statements
describes the AllianceBernstein Global High Income Fund as a diversified fund. In the disclosures and risks section of the
annual report, the fund lists diversification risk as one of its risks and notes, "the fund may have more risk because it
is non-diversified." Furthermore, the fund's website notes that “the fund is a globally diversified portfolio
that takes full advantage of our best research ideas by pursuing high income opportunities across all fixed income sectors.”
Please describe in correspondence whether the fund is diversified or non-diversified, and explain the discrepancies noted.
In addition, if the fund is a non-diversified fund, it appears to be operating as diversified fund. If the fund has been
operating as a diversified fund for more than 3 years, please confirm that the fund will receive shareholder approval prior to
changing its status back to non-diversified.
Response #5:
AllianceBernstein Global High Income Fund
was previously non-diversified, but became a diversified fund by virtue of operating as such for more than three years. Accordingly,
the Adviser confirms that the Fund will receive shareholder approval prior to operating as a non-diversified fund. In addition,
future shareholder reports will be revised to delete references to the Fund being non-diversified.
Comment #6:
Fund #: 3
The expenses noted on the website for the
AllianceBernstein Global High Income Fund indicate they are as of 3/31/18. Please explain in correspondence why the Fund’s
website has not been updated to reflect the current expenses of the Fund.
Response #6:
The Adviser has enhanced its compliance
oversight of the websites of its closed-end funds (including the Global High Income Fund) to ensure that up-to-date expense information
is posted and accurately labelled. The Adviser also notes that the Fund’s annual and semi-annual reports, which were sent
to shareholders and posted to the website, included up-to-date expense information.
Comment #7:
Fund #: 3
The portfolio statistics on the website
of the AllianceBernstein Global High Income Fund are noted as of 10/31/20. The portfolio turnover included in these statistics
is as of 3/31/18. Please explain the discrepancy in correspondence and confirm that the portfolio turnover rate for the fund
as of 3/31/20 is 32%.
Response #7:
The Adviser has enhanced its compliance
oversight of the websites of its closed-end funds (including the Global High Income Fund) to ensure that up-to-date portfolio turnover
information is posted and accurately labelled. The Adviser confirms that the Fund’s annual portfolio turnover rate as of
March 31, 2020 was 32%. The Adviser also notes that the Fund’s annual and semi-annual reports, which were sent to shareholders
and posted to the website, included up-to-date portfolio turnover information.
Comment #8:
Fund #: 3
Please explain in correspondence what the
interest expense noted on the statement of operations and highlighted in the footnotes to the financial highlights represents for
the AllianceBernstein Global High Income Fund.
Response #8
The interest expense as disclosed on the statement of operations
and in the footnotes to the financial highlights pertains to overdraft expenses and interest expenses associated with reverse repurchase
agreements.
Comment #9:
Fund #: 4
The expenses net of waivers/reimbursements
are equal to the expenses before waivers/reimbursements for the class C shares of the AB Sustainable International Thematic Fund.
Please explain in correspondence why these amounts are the same and not consistent with the current prospectus disclosure.
Response #9:
The amounts presented for expenses net
of waivers/reimbursements and expenses before such waivers/reimbursements are the same as a result of rounding. Net expenses were
2.0887%, while gross expenses were 2.0948%, both rounding to 2.09%. The ratio in the prospectus (before waivers/reimbursements)
includes the impact of acquired funds fees and expenses (“AFFE”), consistent with Instruction 3(f)(i) to Item 3 of
Form N-1A. If the 0.01% of AFFE is subtracted to bring the ratio onto a GAAP basis, the prospectus and the annual report
are consistent.
Appendix B
File #
Registrant Name
Series ID
Series Name
FYE Reviewed
1
811-02383
AB BOND FUND, INC.
S000045256
AB FlexFee High Yield Portfolio
12/31/2019
2
811-02383
AB BOND FUND, INC.
S000035798
AB FlexFee International Bond Portfolio
12/31/2019
3
811-07732
AllianceBernstein Global High Income Fund, Inc.
CEF0000449
AllianceBernstein Global High Income Fund, Inc.
3/31/2020
4
811-08426
AB Sustainable International Thematic Fund, Inc.
S000010094
AB Sustainable International Thematic Fund, Inc.
6/30/2020
5
811-00204
AB Discovery Growth Fund, Inc.
S000010117
AB Discovery Growth Fund, Inc.
7/31/2020
6
811-06730
AB Large Cap Growth Fund, Inc.
S000010251
AB Large Cap Growth Fund, Inc.
7/31/2020
7
811-05088
AB PORTFOLIOS
S000010509
AB Growth Fund
7/31/2020