Correspondence 0000276776-23-000073 from PIONEER BOND FUND /DE/ (CIK 0000276776)
PIONEER BOND FUND /DE/ (CIK 0000276776)
Date: April 14, 2023 · CIK: 0000276776 · Accession: 0000276776-23-000073
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[LOGO] Amundi
April 14, 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 Pioneer Bond Fund Filings
Ladies and Gentlemen:
This letter is to respond to a follow-up comment received on March 22, 2023
from Ms. Lauren Hamilton of the Staff of the Securities and Exchange Commission
in connection with the Staff's review of financial statements for the fiscal
year ended June 30, 2022 and other filings made by Pioneer Bond Fund (the
"Registrant"). Following is the Staff's comment and the Registrant's response
thereto:
1. Comment: The Staff noted the Registrant's explanation of the accounting
treatment for insurance-linked securities in response to the
Staff's initial comment. The Staff requested that the Registrant
supplementally confirm the dollar amount and percentage of income
recognized for the fiscal year ended June 30, 2022 that was
related to the collateralized reinsurance, reinsurance sidecars
and industry loss warranties held by the Registrant. The Staff
further requested that the Registrant supplementally explain how
such income is being accounted for and recognized in the
financial statements.
Response: The Registrant confirms that, for its fiscal year ended June 30,
2022, it recognized $1,273,323, $3,134,597 and $0 of dividend
income related to collateralized reinsurance, reinsurance
sidecars and industry loss warranties, respectively, representing
0.81%, 2.00% and 0.00% of the Registrant's gross income,
respectively.
The Registrant notes that dividend income from collateralized
reinsurance, reinsurance sidecars and industry loss warranties is
accounted for and recognized in the financial statements when a
cash payment is received. The Registrant notes that
collateralized reinsurance and reinsurance sidecars are based on
a reinsurer's catastrophe-oriented loss experience whereas
industry loss warranties are based on catastrophe-oriented
losses experienced by the insurance industry as a whole.
Investors generally receive information on income payable by
such investments only after such amounts are communicated
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pursuant to terms of the investment. Accordingly,
dividend income from such investments is recognized on a cash
basis.
Please contact me directly at 617-422-4697 if you require any further
clarification.
Very truly yours,
/s/ Anthony J. Koenig, Jr.
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Anthony J. Koenig, Jr.
Treasurer, Pioneer Funds
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