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Proskauer Rose LLP Eleven Times Square	New York, NY 10036

December 14, 2023

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Emily Rowland

Brian Szilagyi

Re: 	BNY Mellon New York AMT-Free Municipal Fund (811-06377)

Registration Statement on Form N-14 (333-275603)

On November 16,
2023, BNY Mellon New York AMT-Free Municipal Fund (the "Acquiring Fund") filed a registration statement on Form N-14
(the "N-14 Registration Statement"). The N-14 Registration Statement contains a Prospectus/Proxy Statement (the "Prospectus/Proxy
Statement") seeking the approval of shareholders of BNY Mellon New York Tax Exempt Bond Fund, Inc. (the "Fund")
of an Agreement and Plan of Reorganization to allow the Fund to transfer its assets in a tax-free reorganization to the Acquiring Fund
in exchange solely for Class Z shares of the Acquiring Fund and the assumption by the Acquiring Fund of the Fund's stated liabilities
(the "Reorganization"). If the Reorganization is approved by Fund shareholders, each Fund shareholder will receive a
number of Class Z shares (or fractions thereof) of the Acquiring Fund equal in value to the aggregate net asset value of the shareholder's
Fund shares as of the closing date of the Reorganization. The Acquiring Fund and the Fund are each an open-end management investment company.
The Acquiring Fund and the Fund are advised by BNY Mellon Investment Adviser, Inc. ("BNYM Investment Adviser") and are
sub-advised by Insight North America LLC ("INA"), an affiliate of BNYM Investment Adviser.

Brian Szilagyi and Emily Rowland of the staff
(the "Staff") of the Securities and Exchange Commission provided comments to the N-14 Registration Statement to the undersigned
on November 30, 2023 and December 11, 2023, respectively. The Acquiring Fund intends to file pursuant to Rule 497 under the Securities
Act, as amended, a definitive version of the Prospectus/Proxy Statement reflecting comments received from the Staff. For convenience,
set forth below are those comments provided by Staff and the responses thereto. Management of the Acquiring Fund and the Fund represents
that it will make changes to the definitive version of the Prospectus/Proxy Statement in response to comments from the Staff that are
satisfactory to the Staff. Management of the Acquiring Fund and the Fund acknowledge that the funds are responsible for the accuracy and
adequacy of the Prospectus/Proxy Statement notwithstanding Staff comments.

We have considered comments made by the Staff
with respect to one section of the N-14 Registration Statement as applicable to the referenced section and similar disclosure elsewhere
in the N-14 Registration Statement. Capitalized terms used herein and not otherwise defined are used with the meanings assigned to them
in the N-14 Registration Statement.

Questions and Answers

 1. Staff Comment: In the Question and Answer regarding "What are
the expected benefits of the proposed reorganization of the fund for me?", please provide a cross-reference to the part of the Prospectus/Proxy

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Statement where other potential benefits
of the reorganization are described in greater detail as noted in the last sentence to that Question and Answer.

Response: As the potential benefits
of the reorganization are described in the referenced Question and Answer and elsewhere in the Prospectus/Proxy Statement to the same
extent described in the Question and Answer, they are not described in greater detail elsewhere in the Prospectus/Proxy Statement. Therefore,
the last sentence in the Question and Answer will be deleted in the definitive version of the Prospectus/Proxy Statement.

 2. Staff Comment: In the Question and Answer regarding "Do the
funds have similar investment goals, strategies and risks?", please consider adding cross-references to the parts of the Prospectus/Proxy
Statement where investment risks, such as investing in high yield securities, and management arrangements are described in greater detail.

Response: Cross-references will
be added to the noted Question and Answer where appropriate in the definitive version of the Prospectus/Proxy Statement.

 3. Staff Comment: In the Question and Answer regarding "Do the
funds have similar investment goals, strategies and risks?", please consider revising the disclosure that suggests there is a risk
that the universe of potential investments for the Acquiring Fund may be smaller than that of the Fund because the Acquiring Fund focuses
on investments in municipal bonds that provide income that is exempt from the federal AMT, since both funds may invest up to 20% of its
net assets in municipal bonds the income from which may be subject to the federal AMT.

Response: The referenced disclosure
will be revised in the definitive version of the Prospectus/Proxy Statement.

 4. Staff Comment: In the Question and Answer regarding "What are
the tax consequences of the proposed reorganization?", please consider adding cross-references to the parts of the Prospectus/Proxy
Statement where the tax consequences of the reorganization are described in greater detail.

Response: Cross-references will
be added to the noted Question and Answer in the definitive version of the Prospectus/Proxy Statement.

 5. Staff Comment: In the Question and Answer regarding "Will I
enjoy the same privileges as a shareholder of the Acquiring Fund that I currently have as a shareholder of the Fund?", please describe
the eligibility requirements for an exchange of the Acquiring Fund's Class Z shares into shares of another fund in the BNY Mellon Family
of Funds.

Response: The following parenthetical
will be added in the Prospectus/Proxy Statement after reference to the noted eligibility requirements: "(as is the case with Fund
shares, the Acquiring Fund's Class Z shares may be exchanged for no-load fund shares, Class A shares and Class D shares of such funds)".

 6. Staff Comment: In the Question and Answer regarding "Will the
proposed reorganization result in a higher management fee or higher total fund expenses?", please consider adding a cross-reference
to the part of the Prospectus/Proxy Statement where fees and expenses are described in greater detail. In addition, please state that
the total annual expense ratio of the Acquiring Fund's Class Z shares may increase after the current expense waiver arrangement terminates.

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Response: A cross-reference to
the noted Question and Answer and the following sentence will be added in the in the definitive version of the Prospectus/Proxy Statement:
"Total expenses of Class Z shares of the Acquiring Fund may increase after the termination of this expense limitation agreement".

 7. Staff Comment: In the Question and Answer regarding "Who will
pay the expenses of the proposed reorganization?", please describe the expenses related to the reorganization and disclose the monetary
impact of those expenses on a Fund share.

Response: The expenses related
to the reorganization will be described and the monetary impact of those expenses on a Fund share will be disclosed in the definitive
version of the Prospectus/Proxy Statement.

 8. Staff Comment: In the Question and Answer regarding "How does
the Fund's Board recommend I vote?", please consider adding a cross-reference to the part of the Prospectus/Proxy Statement where
the Board's considerations are described in greater detail.

Response: A cross-reference will
be added to the noted Question and Answer in the definitive version of the Prospectus/Proxy Statement.

 9. Staff Comment: In the Question and Answer regarding "Who is
Equiniti Fund Solutions, LLC?", please disclose who will bear the costs of the proxy solicitor.

Response: Disclosure will be
added in the definitive version of the Prospectus/Proxy Statement stating that such costs will be borne by the Fund.

Prospectus/Proxy Statement

 10. Staff Comment: On the second page of the cover, please list all documents
incorporated by reference into the Prospectus/Proxy Statement, provide the '33 Act and 1940 Act numbers as applicable, and the dates of
the shareholder reports. Also, hyperlink such documents.

Response: The requested changes
will be made in the definitive version of the Prospectus/Proxy Statement.

 11. Staff Comment: On the second page of the cover, please add disclosure
regarding the notice of internet availability of the proxy materials.

Response: Disclosure regarding
the notice of internet availability of the proxy materials will be added in the definitive version of the Prospectus/Proxy Statement.

 12. Staff Comment: In the introductory paragraph to the "Summary"
referencing additional information contained elsewhere, please add the Acquiring Fund's and Fund's Statement of Additional Information.

Response: Reference to the Acquiring
Fund's and Fund's Statement of Additional Information will be added to the noted introductory paragraph in the definitive version of the
Prospectus/Proxy Statement.

 13. Staff Comment: In the first paragraph under "Summary—Transaction",
please state that the number of Acquiring Fund Class Z shares a Fund shareholder receives in the reorganization may be different from
the number of Fund shares held by the shareholder at the time of the reorganization.

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Response: The requested disclosure
will be made in the definitive version of the Prospectus/Proxy Statement.

 14. Staff Comment: In the third paragraph under "Summary—Sales
Charges, Shareholder Servicing Arrangements and Purchase, Redemption and Exchange Policies and Procedures",
please add the word "additional" before Class Z shares.

Response: The word
"additional" will be added as indicated in the definitive version of the Prospectus/Proxy Statement.

 15. Staff Comment: In the third paragraph under "Summary—Fees
and Expenses", please explicitly state that the fees and expenses are for Class Z shares of the Acquiring Fund. In addition, please
note that the Acquiring Fund offers other share classes which will not be exchanged as part of the reorganization.

Response: The requested disclosure
will be made in the definitive version of the Prospectus/Proxy Statement.

 16. Staff Comment: With respect to the Fee Table, please delete the footnote
as it is described in the text to the table.

Response: The requested deletion
will be made in the definitive version of the Prospectus/Proxy Statement.

 17. Staff Comment: With respect to the Fee Table, please supplementally
confirm that any fees or expenses waived or reimbursed are not subject to re-capture in the future.

Response: Fund management has
confirmed that any fees or expenses waived or reimbursed are not subject to re-capture in the future.

 18. Staff Comment: In the second and third paragraph under "Fund
Details—Investment Adviser and Sub-Adviser", please disclose the date of the "last fiscal year". In addition, please
disclose that the boards' most recent approvals of the advisory agreements will be available in the reports for the most recently completed
fiscal period.

Response: The requested disclosures
will be made in the definitive version of the Prospectus/Proxy Statement.

 19. Staff Comment: In the second paragraph under "Fund Details—Investment
Adviser and Sub-Adviser", the disclosure states that the Acquiring Fund paid a management fee for the past fiscal year "at the
effective annual rate of 0.39%". Please supplementally explain why the effective annual rate paid was higher than the contractual
rate of the management fee payable.

Response: As noted, during the
past fiscal year, the management fee payable by the Acquiring Fund was reduced pursuant to an expense
limitation agreement by BNYM Investment Adviser then in place, resulting in an effective
annual rate paid of 0.39%.

 20. Staff Comment: Under "Fund Details—Capitalization",
please include all classes of the Acquiring Fund in the tables. In addition, please supplementally confirm that the capitalization of
the Acquiring Fund and the Fund reflected in the tables is not materially different from that of their most recent balance sheets.

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Response: The capitalization
all classes of the Acquiring Fund will be provided in the definitive version of the Prospectus/Information Statement. In addition, fund
management has confirmed that the capitalization of the Acquiring Fund and the Fund reflected in the tables is not materially different
from that of their most recent balance sheets.

 21. Staff Comment: Under "Fund Details—Capitalization",
please provide the adjustment amount for the net asset value per share of Class Z shares as a result of the reorganization.

Response: The amount of the adjustment
to the net asset value per share of Class Z shares will be provided in the definitive version of the Prospectus/Proxy Statement.

 22. Staff Comment: Under the "Reasons for the Reorganization",
please disclose what, if any, adverse factors of the reorganization the Boards considered.

Response: The Boards concluded
that there were no adverse factors that could materially affect the proposed reorganization.

 23. Staff Comment: Under the "Information about the Reorganization—Plan
of Reorganization", please disclose that the tax opinion will be filed in a Post-Effective Amendment to the N-14 Registration Statement.

Response: The requested disclosure
and exhibit will be provided in the definitive version of the Prospectus/Proxy Statement and the Post-Effective Amendment to the N-14
Registration Statement, respectively.

 24. Staff Comment: Under the "Information about the Reorganization—Plan
of Reorganization", please describe what actions will be taken if the reorganization is not approved by shareholders.

Response: The requested disclosure
will be provided in the definitive version of the Prospectus/Proxy Statement.

 25. Staff Comment: Under "Voting Information", please consider
revising the disclosure regarding a broker-dealer that is not a member of the New York Stock Exchange potentially being permitted to vote
shares with respect to which it has not received voting instructions from its customers, as the Staff considers all broker-dealers to
be subject to the rules of the New York Stock Exchange and, thus, not being permitted to vote such shares for which no instructions have
been received from customers in connection with non-routine proposals.

Response: The requested revision
will be made in the definitive version of the Prospectus/Proxy Statement.

 26. Staff Comment: In the sentence under "Voting Information"
that begins with the word "Ordinarily," please consider clarifying that the statement refers to routine matters.

Response: The requested revision
will be made in the definitive version of the Prospectus/Proxy Statement.

 27. Staff Comment: For shares held through an intermediary, the disclosure
should also address how these votes will be counted for quorum purposes – i.e., if correct, since the intermediary is the
record owner of the shares, the votes will be counted as present for purposes of quorum.

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Response: The requested disclosure
will be provided in the definitive version of the Prospectus/Proxy Statement.

 28. Staff Comment: Please consider revising the Statement of Additional
Information to list only those documents incorporated by reference into the Prospectus/Proxy Statement.

Response: The requested revision
will be made in the Statement of Additional Information.

*	*	*

We hope the Staff finds that this letter and
the revisions included in the definitive Prospectus/Proxy Statement are responsive to the Staff's comments. Should members of the Staff
have any questions or comments, please contact David Stephens at 212.969.3357.

Very truly yours,

/s/ David Stephens

David Stephens

cc:	Jeff Prusnofsky

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