SecProbe.io

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Seward & Kissel LLP

901 K Street, NW

Suite 800

Washington, DC 20001

Telephone: (202) 737-8833

Facsimile: (202) 737-5184

www.sewkis.com

    April 23, 2021

Via EDGAR CORRESPONDENCE

Ms. Kimberly Browning

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

    Re:
    AB Bond Fund, Inc.

    - AB FlexFee High Yield Portfolio (to be renamed AB High Yield Portfolio)

    Post-Effective Amendment No. 205

    File Nos. 2-48227 and 811-02383

Dear Ms. Browning:

This letter responds to comments
of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to the above-referenced post-effective
amendment to the registration statement filed on March 1, 2021 (the “Post-Effective Amendment”), on Form N-1A for AB FlexFee
High Yield Portfolio (to be renamed AB High Yield Portfolio) (the “Fund”), a series of AB Bond Fund, Inc. (the “Registrant”).
You provided the Staff’s comments to me by telephone on April 9, 2021.

The Staff’s comments and
our responses thereto are set forth below. The changes referenced in the responses will be reflected in a Rule 497 filing.

    General

    Comment 1:
    The Prospectus contains incomplete and bracketed information. Confirm that a filing will be made that contains all final information.

    Response:
    Registrant will file a Prospectus pursuant to Rule 497 that contains all final information.

     Page 1

    Comment 2:
    The Post-Effective Amendment indicates that the name of the Fund will be changed to AB High Yield Portfolio, but the SEC facing sheet and the EDGAR series identifier reflect the old fund name.  Also explain how shareholders have been made aware of the Fund’s name change.

    Response:
    The name change for the Fund will become effective on April 30, 2021.  The series identifier on EDGAR will be updated to reflect the new name at the time of the filing of the next post-effective amendment or Rule 497 filing for the Fund made on or prior to April 30, 2021, which filing will reflect the Fund’s new name.  With respect to notice to Fund shareholders, a definitive proxy statement for the Fund filed on November 30, 2020, primarily relating to the advisory fee change, and a prospectus supplement for the Fund filed on January 20, 2021, reference the name change.

    Comment 3:
    The Fund currently only offers Advisor Class shares. The Post-Effective Amendment includes Class A shares and Class Z shares previously offered by the Fund.  Please explain.

    Response:
    As indicated in “Summary Information – Bar Chart and Performance Information,” the Fund offered Class A shares and Class Z shares prior to the implementation of a performance-based fee on February 26, 2018.  The Post-Effective Amendment reflects the Fund’s new advisory fee and the resumption of the offer of Class A shares and Class Z shares, which Post-Effective Amendment becomes effective on April 30, 2021.

    Prospectus

    Summary Information

    Comment 4:
    Under “Fees and Expenses of the Fund,” the inclusion of the second sentence noting recent changes in advisory fee arrangements does not comply with Instruction 1(b) of Item 3 of Form N-1A because that sentence is not “comparable information” to the narrative explanation provided under the item.  The sentence should be deleted.  In addition, the model narrative explanation under Item 3 of Form N-1A indicates that the second paragraph under “Fees and Expenses of the Fund” should appear as the second sentence under the first paragraph.

    Response:
    The second sentence under “Fees and Expenses of the Fund” noting recent changes in advisory fee arrangements will be removed, and the second paragraph will be moved and appear as the second sentence under the first paragraph, in response to this comment.  Please see the following revised and restated disclosure:

    This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. You may be required to pay commissions and/or other forms of compensation to a broker for transactions in Advisor Class shares, which are not reflected in the tables or the examples below.  You may qualify for sales charge reductions if you and members of your family invest, or agree to invest in the future, at least $100,000 in AB Mutual Funds. More information about these and other discounts is available from your financial intermediary and in Investing in the Fund—Sales Charge Reduction Programs for Class A Shares on page 26 of this Prospectus, in Appendix C—Financial Intermediary Waivers of this Prospectus and in Purchase of Shares—Sales Charge Reduction Programs for Class A Shares on page 86 of the Fund’s Statement of Additional Information (“SAI”).

     Page 2

    Comment 5:
    Explain why “Other Expenses” are estimated for the Fund, as indicated by footnote (c) to the Annual Fund Operating Expenses table.

    Response:
    “Other Expenses” are only estimated for Class A and Class Z shares of the Fund, as indicated by footnote (c), which only appears next to data in the table columns for these share classes.  As indicated in the response to Comment 3 and under “Summary Information – Bar Chart and Performance Information,” Class A shares and Class Z shares are not currently in operation (and were not active during the Fund’s last fiscal year) and will resume operations on April 30, 2021.  In response to this comment, footnote (c) will be clarified and restated as follows:

    “Total Other Expenses for Class A and Class Z shares are based on estimated amounts for the current fiscal year.”

    Comment 6:

    The disclosure describing the Fund’s fee waiver
    under footnote (d) to the Annual Fund Operating Expenses table needs to be clarified. The disclosure references an expense limitation
    that expires on April 30, 2022, but also references fees and expenses borne by the Adviser through December 31, 2019 and potential reimbursements
    under an expense limitation in effect prior to that date, without explaining the meaning of the December 31, 2019 date or the terms of
    the prior expense limitation. In addition, the disclosure does not explain whether any fees waived pursuant to the expense limitation
    expiring on April 30, 2022 are subject to reimbursement. The disclosure should clearly describe the various waivers, the time periods
    and the reimbursement provisions. Furthermore, for any such recoupment arrangement, the disclosure should indicate that any such repayment
    will not cause the Fund’s expense ratio (after the repayment is taken into account) to exceed either (1) the expense cap in effect
    at the time of waiver or (2) the expense cap in effect at the time of recapture.

    In addition, the expense limitation agreements must
    be filed as exhibits to the registration statement.

    Response:
    In response to this comment, footnote (d) will be revised and restated to include information about the expense limitation previously in effect, as follows:

    (d) The Adviser has contractually agreed to
    waive fees and/or to bear expenses of the Fund until April 30, 2022 to the extent necessary to prevent total Fund operating expenses
    (excluding acquired fund fees and expenses other than the advisory fees of any AB Mutual Funds in which the Fund may invest, interest
    expense, taxes, extraordinary expenses, and brokerage commissions and other transaction costs), on an annualized basis, from exceeding
    0.85%, 0.60% and 0.60% of average daily net assets, respectively, for Class A, Advisor Class and Class Z shares (“expense limitations”).
    The expense limitations will remain in effect until April 30, 2022 and may only be terminated or changed with the consent of the
    Fund’s Board of Directors. In addition, the expense limitations will be automatically extended for one-year terms unless the Adviser
    provides notice of termination to the Fund at least 60 days prior to the end of the period.

    Any fees waived and expenses borne by the Adviser
    through December 31, 2019 under the expense limitation in effect prior to that date may be reimbursed by the Fund until the end of
    the third fiscal year after the fiscal period in which the fee was waived or the expense was borne, provided that no reimbursement payment
    will be made that would cause the Fund’s total Fund operating expenses to exceed the expense limitations. For the period from February
    26, 2018 through December 31, 2019, the Adviser had contractually agreed to waive fees and/or to bear expenses of the Fund to the extent
    necessary to prevent “Total Other Expenses,” on an annualized basis, from exceeding 0.10% of average daily net assets. Total
    Other Expenses refers to aggregate expenses incurred by the Fund, but do not include (i) advisory fees; (ii) distribution and/or service
    (Rule 12b-1) fees; (iii) extraordinary expenses; (iv) interest expense; (v) acquired fund fees and expenses other than the advisory fees
    of any AB Mutual Funds in which the Fund may invest; (vi) expenses associated with securities sold short; (vii) taxes; and (viii) brokerage
    commission and other transaction costs.

    Furthermore, there is no recoupment arrangement
    under the new expense limitations, so no such arrangement is disclosed.

    Registrant also confirms that any reimbursement
    of expenses will not cause the Fund’s expense ratio (after the repayment is taken into account) to exceed either (1) the expense
    cap in effect at the time of waiver or (2) the expense cap in effect at the time of recapture.

    Lastly, the new expense limitation undertaking
    will be filed in a post-effective amendment and is attached hereto as Exhibit A.

     Page 3

    Comment 7:
    The disclosure in footnote (d) to the Annual Fund Operating Expenses table indicates that any fees waived and expenses borne by the Adviser may be reimbursed by a Fund until the end of the third fiscal year after the fiscal period in which the fee was waived or the expense was borne.  Confirm supplementally that the investment adviser may only recoup from the Fund amounts waived or reimbursed within three years from the date that the waiver or reimbursement occurred.  If the Fund does not limit recoupment to three years from the time of waiver or reimbursement, please confirm that the Fund has conducted an analysis under Statement of Financial Accounting Standards No. 5 (“FAS 5”) and concluded that recoupment is not probable and that the Fund has provided such FAS 5 to the Fund’s auditor.

    Response:

    The Staff comment suggests that it would not
    be appropriate for the Fund’s operating expenses table to show total annual operating expenses net of waived fees where the
    recoupment does not occur within three years of the specific waiver. Registrant believes that the Fund’s current structure
    for recoupment complies with applicable SEC rules and accounting pronouncements.  Registrants advised by the Adviser have previously
    responded in detail to a comment on a three-year period for recoupment (see, for example, the response dated March 9, 2017, to the
    Staff's comments on Post-Effective Amendment Nos. 221 and 222 to the Registration Statement of AB Cap Fund, Inc.).1

    Registrant notes that Instruction 3(e) to Item
    3 of Form N-1A indicates that the operating expenses table may reflect the amount of the expense reimbursement or fee waiver, and the
    fund’s net expenses after subtracting the fee reimbursement/expense waiver from total fund operating expenses, provided the
    expense reimbursement/fee waiver agreement is effective for a period of no less than one year from the effective date of the fund’s
    registration statement. This requirement is supplemented by the Staff’s response to Question 6 of the Q&A Letter on Form N-1A,
    dated October 2, 1998, which requires the expense limitation/fee waiver arrangement to be contractual. These requirements for reflecting
    a fund’s net expenses are not conditioned, however, on the duration of any recoupment provision of the expense reimbursement/fee
    waiver agreement.

    Registrant further notes that the recoupment period
    is three years measured on a fiscal year basis, which is appropriate given that the fee table is based on a fiscal year period. In this
    regard, the final determination of the amount of any recoupment that the Adviser may receive is measured on an accrual basis and can only
    occur as of the end of the fiscal year.

    The disclosure has not been revised in response
    to this comment.

1 See
AB Cap Fund, Inc., File Nos. 2-29901 and 811-01716, EDGAR Correspondence filed on March 9, 2017, SEC Accession No. 0000919574-17-002611.

     Page 4

    Comment 8:
    The Staff notes that significant market events have occurred as a result of the COVID-19 pandemic. Please consider updating the Fund’s disclosure, including “Market Risk,” to clarify how COVID-19 may affect the Fund and its investments or supplementally explain why additional revisions are not required.

    Response:
    Registrant has reviewed and updated its risk disclosures since the onset of the COVID-19 pandemic and believes that the Fund’s current disclosure reflects investment risks resulting from the pandemic. For example, disclosure under “Principal Risks – Market Risk” indicates that the value of the Fund’s investments may decline, sometimes rapidly and unpredictably, due to certain events, including public health crises (including the occurrence of a contagious disease or illness).  Disclosure in the Prospectus will not be revised in response to this comment.

    Comment 9:
    Under “Bar Chart and Performance Information,” footnotes to the performance table for Class A shares and Class Z shares reference linking of the performance of the Fund’s Advisor Class shares during certain periods.  Review and revise the performance disclosure for Class A shares and Class Z shares to clarify the time periods these classes were actually in operation.

    Response:
    The disclosure will be clarified in response to this comment.  Please see revised footnote disclosure in the “Bar Chart and Performance Information” section of the Prospectus provided in Exhibit B.

    Additional Information About the Fund’s Strategies, Risks and Investments

    Comment 10:
    Disclosure under the first paragraph under “Additional Information About the Fund’s Strategies, Risks and Investments” is potentially confusing and needs to be clarified. The disclosure references principal and non-principal strategies and risks.  The disclosure also indicates that the “Prospectus does not describe all of the Fund’s investment practices,” which, for instance, could suggest that the Fund’s principal strategies and principal risks are not fully disclosed, as required by Item 4 of Form N-1A.

    Response:

    The Fund identifies all of its principal strategies
    and principal risks in the Summary Section under “Principal Strategies” and “Principal Risks.” The disclosure
    under “Additional Information About the Fund’s Strategies, Risks and Investments” does not describe all non-principal
    strategies and risks. The disclosure in the first paragraph under “Additional Information About the Fund’s Strategies, Risks
    and Investments” will be clarified to remove any suggestion that the Fund’s principal strategies and principal risks are not
    fully disclosed in the Prospectus. The first paragraph will be revised and restated as follows:

    This section of the Prospectus provides additional
    information about the Fund’s investment strategies, practices and related risks, including principal and non-principal strategies
    and risks. This Prospectus does not describe all of the Fund’s investment practices that are non-principal strategies and the related
    risks of such strategies; additional i