Correspondence 0001137439-25-000106 from AIM GROWTH SERIES (INVESCO GROWTH SERIES) (CIK 0000202032)
AIM GROWTH SERIES (INVESCO GROWTH SERIES) (CIK 0000202032)
Date: Feb. 20, 2025 · CIK: 0000202032 · Accession: 0001137439-25-000106
AI Filing Summary & Sentiment
File numbers found in text: 811-01424, 811-01540, 811-02611, 811-02699, 811-03826, 811-05426, 811-05686, 811-06463, 811-07452, 811-21265, 811-21977, 811-22147, 811-22148, 811-22927, 811-23304, 811-23665
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street N.E. Washington DC 20549 AIM Growth Series (Invesco Growth Series) (File No. 811-02699), Invesco Exchange Fund (File No. 811-02611), AIM Equity Funds (Invesco Equity Funds) (File No. 811-01424), AIM International Mutual Funds (Invesco International Mutual Funds) (File No. 811-06463), AIM Investment Funds (Invesco Investment Funds) (File No. 811-05426), AIM Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686), AIM Funds Group (Invesco Funds Group) (811-01540), AIM Sector Funds (Invesco Sector Funds) (File No. 811-03826), and AIM Variable Insurance Funds (Invesco Variable Insurance Funds) (File No. 811-07452),Invesco Dynamic Credit Opportunity Fund (File No. 811-23665), Invesco Actively Managed Exchange-Traded Fund Trust (811-22148), Invesco Exchange-Traded Fund Trust (File No. 811-21265), Invesco Exchange-Traded Fund Trust II (File No. 811-21977), Invesco India Exchange-Traded Fund Trust (File No. 811-22147), Invesco Actively Managed Exchange-Traded Commodity Fund Trust (File No. 811-22927), and Invesco Exchange-Traded Self-Indexed Fund Trust (File No. 811-23304) (each, a “Registrant” and collectively, the “Registrants”)
RE:
Dear Mr. Manion:
On behalf of the Registrants and each respective series of the Registrants listed in Exhibit A, as applicable (each such mutual fund or ETF, a “Fund,” and collectively, the “Funds”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”) to the undersigned on January 13, 2025, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR for the fiscal years ended on the dates listed in Exhibit A, as applicable.
The Staff’s comments are summarized below in italicized text. The Registrants’ responses are set out immediately under the restated comment.
1.
Comment:
Invesco Optimum Yield Diversified Commodity Strategy No K-1 ETF has a unitary fee of 0.59%; however, the ratio to average net assets of expenses prior to waivers for the fiscal year ended October 31, 2023 in the Financial Highlights state that the Fund accrued gross expenses of 0.71%. Please explain.
Response:
The gross expenses for the fiscal year ended October 31, 2023 were incorrectly reported as 0.71%. However, the net expenses after waivers were correctly stated. The Registrant determined that this was not a material misstatement and corrected this in the Financial Highlights for the fiscal year ended October 31, 2024, which were accompanied by the following footnote: “The ratio has been
revised to correct for misstatement in the previously issued October 31, 2023 financial statements. The ratio was previously reported as 0.71%.”
2.
Comment:
The financial statements for Invesco Senior Floating Rate Fund show significant interest and related expenses but there is no disclosure related to a credit agreement. Please explain.
Response:
The Registrant notes the disclosure in Note 7 (“Cash Balances and Borrowings”) to the Financial Statements, which discloses that the Fund participates with another Invesco Fund in a committed secured borrowing facility that permits borrowings up to $1,027,500,000. During the year ended August 31, 2024, the Fund did not borrow under this agreement. The Fund is charged an annual commitment fee by the lender for the commitment to keep the line of credit open. This is the amount shown under Interest, facilities and maintenance fees on the Statement of Operations. Additionally, under Note 1 (“Significant Accounting Policies”) there is a policy note for Interest, Facilities and Maintenance fees that defines the expenses that may be included in that line item on the Statement of Operations.
3.
Comment:
With respect to Invesco Dynamic Credit Opportunity Fund and Invesco Senior Floating Rate Fund, please confirm in correspondence the Accounting Standards Codification (“ASC”) 820 level for the liabilities associated with unfunded commitments and include this balance, as applicable, in the ASC 820 table in future financial statements.
Response:
The unfunded loan commitments are shown as a security in the Schedule of Investments and are valued daily. The securities are included in the ASC 820 leveling table under the caption Variable Rate Senior Loan Interests with an assigned level based on the valuation technique used to value the securities. The unfunded loan commitments reflected as a liability on the Consolidated Statement of Assets and Liabilities which are contractual obligations for funding are not included in the leveling table.
4.
Comment:
With respect to Invesco Dynamic Credit Opportunity Fund and Invesco Senior Floating Rate Fund, please discuss in correspondence how the significant unobservable inputs table (Level 3 securities) were valued. If securities were valued using broker quotes, please include such disclosure in future financial statements in order for the table to tie to total Level 3 securities in the ASC 820 leveling table.
Response:
Effective with the October 31, 2024 reporting cycle, Invesco enhanced the disclosures for the significant unobservable inputs used in determining Level 3 investments. The table will include all Level 3 investments with the valuation technique used and the unobservable input. If the holdings were valued using a vendor price without adjustment that amount will be included in a footnote to the table so that the table will now tie in total to the Level 3 securities reported in the ASC 820 leveling table.
5.
Comment:
With respect to Invesco Dynamic Credit Opportunity Fund and Invesco Senior Floating Rate Fund, please discuss in correspondence the accounting method for unfunded commitments and how such method complies with ASC 450-20.
Response:
The Registrant confirms that the unfunded commitments meet the accrual standard as of the reporting date of the financial statements due to the following conditions of; an obligation has been incurred; availability of information before the financial statements are issued; probability that the loan is expected to be funded; and the amount can be reasonably estimated. The Notes to Financial Statements disclose the nature of the unfunded commitments as well as the
amount and location of the accrued liability recorded in the Statement of Assets and Liabilities.
6.
Comment:
The annual report for each of the following Funds states that the Fund is non-diversified: Invesco S&P 500 Equal Weight Communication Services ETF, Invesco Gold & Special Minerals Fund, and Invesco V.I. Technology Fund. Please confirm such Funds continue to qualify as non-diversified funds. The Staff reminds the Registrants that if any such Fund has been operating continuously as diversified for more than three years, the Fund would be required to obtain shareholder approval prior to changing its operating status back to non-diversified.
Response:
Each of Invesco S&P 500 Equal Weight Communication Services ETF and Invesco V.I. Technology Fund continues to qualify as a non-diversified fund. If, in the future, a Fund were to operate in a diversified manner continuously for a three-year period, we confirm that such Fund would seek shareholder approval prior to changing its operating status back to non-diversified, unless the Fund could rely on the no-action letter issued to Stradley Ronon Stevens & Young, LLP on June 24, 2019. Invesco Gold & Special Minerals Fund was inadvertently described as a non-diversified fund in its annual report, which will be corrected in the Fund’s next annual report.
7.
Comment:
Certain Funds (for example, Invesco BuyBack Achievers ETF, Invesco V.I. U.S. Government Money Portfolio, Invesco V.I. S&P 500 Buffer Fund – December and Invesco Main Street Mid Cap Fund) show negative expenses on the respective Fund’s Statement of Operations. Please explain how presentation of such negative expenses is appropriate. Include in your response any relevant accounting guidance to support the presentation.
Response:
Each of Invesco BuyBack Achievers ETF, Invesco V.I. U.S. Government Money Portfolio, Invesco V.I. S&P 500 Buffer Fund – December and Invesco Main Street Mid Cap Fund experienced negative expenses that were not material to the Funds due to a normal true up of expenses that were identified and adjusted in a subsequent financial reporting period. True up of expenses are recorded in the same manner as initially recorded to the Fund. According to 210.4-01(c) Negative amounts shall be shown in a manner which clearly distinguishes the negative attribute. No separate disclosure of the negative expenses is required on the Statement of Operations because none of the expense reversals exceeded 5% of total expenses as required per 210.6-07.2(b).
Please do not hesitate to contact me at 713-214-4345 if you have any questions or wish to discuss any of the responses presented above.
Sincerely,
/s/ Adrien Deberghes
Show Raw Text
CORRESP
1
filename1.htm
February 20, 2025
VIA EDGAR
Mr. David Manion
Division of Investment Management
Securities and Exchange Commission
100 F Street N.E.
Washington DC 20549
RE:
AIM Growth Series (Invesco Growth Series) (File No. 811-02699), Invesco Exchange Fund (File No. 811-02611), AIM Equity Funds (Invesco Equity Funds) (File No. 811-01424), AIM International Mutual Funds (Invesco International Mutual Funds)
(File No. 811-06463), AIM Investment Funds (Invesco Investment Funds) (File No. 811-05426), AIM Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686), AIM Funds Group (Invesco Funds Group) (811-01540), AIM
Sector Funds (Invesco Sector Funds) (File No. 811-03826), and AIM Variable Insurance Funds (Invesco Variable Insurance Funds) (File No. 811-07452),Invesco Dynamic Credit Opportunity Fund (File No. 811-23665), Invesco Actively Managed
Exchange-Traded Fund Trust (811-22148), Invesco Exchange-Traded Fund Trust (File No. 811-21265), Invesco Exchange-Traded Fund Trust II (File No. 811-21977), Invesco India Exchange-Traded Fund Trust (File No. 811-22147), Invesco Actively
Managed Exchange-Traded Commodity Fund Trust (File No. 811-22927), and Invesco Exchange-Traded Self-Indexed Fund Trust (File No. 811-23304) (each, a “Registrant” and collectively, the “Registrants”)
Dear Mr. Manion:
On behalf of the Registrants and each respective series of the Registrants listed in Exhibit A, as applicable (each such mutual fund or ETF, a “Fund,” and collectively, the “Funds”), this letter responds to comments provided by the staff of the
Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”) to the undersigned on January 13, 2025, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR for the
fiscal years ended on the dates listed in Exhibit A, as applicable.
The Staff’s comments are summarized below in italicized text. The Registrants’ responses are set out immediately under the restated comment.
1.
Comment:
Invesco Optimum Yield Diversified Commodity Strategy No K-1 ETF has a unitary fee of 0.59%; however, the ratio to average net assets of expenses prior to waivers for the fiscal year ended October 31, 2023 in the
Financial Highlights state that the Fund accrued gross expenses of 0.71%. Please explain.
Response:
The gross expenses for the fiscal year ended October 31, 2023 were incorrectly reported as 0.71%. However, the net expenses after waivers were correctly stated. The Registrant determined that this was not a material misstatement and
corrected this in the Financial Highlights for the fiscal year ended October 31, 2024, which were accompanied by the following footnote: “The ratio has been
revised to correct for misstatement in the previously issued October 31, 2023 financial statements. The ratio was previously reported as 0.71%.”
2.
Comment:
The financial statements for Invesco Senior Floating Rate Fund show significant interest and related expenses but there is no disclosure related to a credit agreement. Please explain.
Response:
The Registrant notes the disclosure in Note 7 (“Cash Balances and Borrowings”) to the Financial Statements, which discloses that the Fund participates with another Invesco Fund in a committed secured borrowing facility that permits
borrowings up to $1,027,500,000. During the year ended August 31, 2024, the Fund did not borrow under this agreement. The Fund is charged an annual commitment fee by the lender for the commitment to keep the line of credit open. This is the
amount shown under Interest, facilities and maintenance fees on the Statement of Operations. Additionally, under Note 1 (“Significant Accounting Policies”) there is a policy note for Interest, Facilities and Maintenance fees that defines the
expenses that may be included in that line item on the Statement of Operations.
3.
Comment:
With respect to Invesco Dynamic Credit Opportunity Fund and Invesco Senior Floating Rate Fund, please confirm in correspondence the Accounting Standards Codification (“ASC”) 820 level for the liabilities
associated with unfunded commitments and include this balance, as applicable, in the ASC 820 table in future financial statements.
Response:
The unfunded loan commitments are shown as a security in the Schedule of Investments and are valued daily. The securities are included in the ASC 820 leveling table under the caption Variable Rate Senior Loan Interests with an assigned
level based on the valuation technique used to value the securities. The unfunded loan commitments reflected as a liability on the Consolidated Statement of Assets and Liabilities which are contractual obligations for funding are not included
in the leveling table.
4.
Comment:
With respect to Invesco Dynamic Credit Opportunity Fund and Invesco Senior Floating Rate Fund, please discuss in correspondence how the significant unobservable inputs table (Level 3 securities) were valued. If
securities were valued using broker quotes, please include such disclosure in future financial statements in order for the table to tie to total Level 3 securities in the ASC 820 leveling table.
Response:
Effective with the October 31, 2024 reporting cycle, Invesco enhanced the disclosures for the significant unobservable inputs used in determining Level 3 investments. The table will include all Level 3 investments with the valuation
technique used and the unobservable input. If the holdings were valued using a vendor price without adjustment that amount will be included in a footnote to the table so that the table will now tie in total to the Level 3 securities reported
in the ASC 820 leveling table.
5.
Comment:
With respect to Invesco Dynamic Credit Opportunity Fund and Invesco Senior Floating Rate Fund, please discuss in correspondence the accounting method for unfunded commitments and how such method complies with
ASC 450-20.
Response:
The Registrant confirms that the unfunded commitments meet the accrual standard as of the reporting date of the financial statements due to the following conditions of; an obligation has been incurred; availability of information before
the financial statements are issued; probability that the loan is expected to be funded; and the amount can be reasonably estimated. The Notes to Financial Statements disclose the nature of the unfunded commitments as well as the
2
amount and location of the accrued liability recorded in the Statement of Assets and Liabilities.
6.
Comment:
The annual report for each of the following Funds states that the Fund is non-diversified: Invesco S&P 500 Equal Weight Communication Services ETF, Invesco Gold & Special Minerals Fund, and Invesco V.I.
Technology Fund. Please confirm such Funds continue to qualify as non-diversified funds. The Staff reminds the Registrants that if any such Fund has been operating continuously as diversified for more than three years, the Fund would be
required to obtain shareholder approval prior to changing its operating status back to non-diversified.
Response:
Each of Invesco S&P 500 Equal Weight Communication Services ETF and Invesco V.I. Technology Fund continues to qualify as a non-diversified fund. If, in the future, a Fund were to operate in a diversified manner continuously for a
three-year period, we confirm that such Fund would seek shareholder approval prior to changing its operating status back to non-diversified, unless the Fund could rely on the no-action letter issued to Stradley Ronon Stevens & Young, LLP
on June 24, 2019. Invesco Gold & Special Minerals Fund was inadvertently described as a non-diversified fund in its annual report, which will be corrected in the Fund’s next annual report.
7.
Comment:
Certain Funds (for example, Invesco BuyBack Achievers ETF, Invesco V.I. U.S. Government Money Portfolio, Invesco V.I. S&P 500 Buffer Fund – December and Invesco Main Street Mid Cap Fund) show negative
expenses on the respective Fund’s Statement of Operations. Please explain how presentation of such negative expenses is appropriate. Include in your response any relevant accounting guidance to support the presentation.
Response:
Each of Invesco BuyBack Achievers ETF, Invesco V.I. U.S. Government Money Portfolio, Invesco V.I. S&P 500 Buffer Fund – December and Invesco Main Street Mid Cap Fund experienced negative expenses that were not material to the Funds due
to a normal true up of expenses that were identified and adjusted in a subsequent financial reporting period. True up of expenses are recorded in the same manner as initially recorded to the Fund. According to 210.4-01(c) Negative amounts
shall be shown in a manner which clearly distinguishes the negative attribute. No separate disclosure of the negative expenses is required on the Statement of Operations because none of the expense reversals exceeded 5% of total expenses as
required per 210.6-07.2(b).
Please do not hesitate to contact me at 713-214-4345 if you have any questions or wish to discuss any of the responses presented above.
Sincerely,
/s/ Adrien Deberghes
Adrien Deberghes
Principal Financial Officer, Treasurer and Vice President of the OEF Registrants and CEF Registrant and
Vice President of the ETF Registrants
cc:
Kelli Gallegos
Melanie Ringold
Taylor Edwards
Patricia Jones
3
Mark Greer
Adam Henkel
Mena Larmour
4
EXHIBIT A
Series ID
File No
Series Name
Registrant Name
Last FYE Reviewed
S000064593
811-21977
Invesco S&P 500 Revenue ETF
Invesco Exchange-Traded Fund Trust II
8/31/2024
S000064595
811-21977
Invesco S&P MidCap 400 Revenue ETF
Invesco Exchange-Traded Fund Trust II
8/31/2024
S000064596
811-21977
Invesco S&P SmallCap 600 Revenue ETF
Invesco Exchange-Traded Fund Trust II
8/31/2024
S000064597
811-21977
Invesco S&P Ultra Dividend Revenue ETF
Invesco Exchange-Traded Fund Trust II
8/31/2024
S000000277
811-01424
Invesco Charter Fund
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
10/31/2023
S000000281
811-01424
Invesco Diversified Dividend Fund
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
10/31/2023
S000064631
811-01424
Invesco Main Street All Cap Fund
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
10/31/2023
S000064632
811-01424
Invesco Main Street Fund
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
10/31/2023
S000064633
811-01424
Invesco Rising Dividends Fund
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
10/31/2023
S000022173
811-01424
Invesco Summit Fund
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
10/31/2023
S000025654
811-05426
Invesco Balanced-Risk Allocation Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000030111
811-05426
Invesco Balanced-Risk Commodity Strategy Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000064702
811-05426
Invesco Core Bond Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000064706
811-05426
Invesco Developing Markets Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000064710
811-05426
Invesco Discovery Mid Cap Growth Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000064696
811-05426
Invesco Fundamental Alternatives Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000064695
811-05426
Invesco Global Allocation Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000045037
811-05426
Invesco Global Infrastructure Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000008408
811-05426
Invesco Greater China Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000000235
811-05426
Invesco Health Care Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000038362
811-05426
Invesco Macro Allocation Strategy Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
5
Series ID
File No
Series Name
Registrant Name
Last FYE Reviewed
S000035024
811-05426
Invesco Multi-Asset Income Fund
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
10/31/2023
S000064626
811-06463
Invesco Advantage International Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000000226
811-06463
Invesco EQV Asia Pacific Equity Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000000227
811-06463
Invesco EQV European Equity Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000000230
811-06463
Invesco EQV International Equity Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000064624
811-06463
Invesco Global Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000064625
811-06463
Invesco Global Opportunities Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000064623
811-06463
Invesco International Small-Mid Company Fund
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
10/31/2023
S000054632
811-06463
Invesco MSCI Worl