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          K&L GATES LLP

          1601 K STREET, N.W.

          WASHINGTON, DC 20006

          T +1 202 778 9000    F +1 202 778 9100  klgates.com

    July 13, 2020

    VIA EDGAR

    Mr. David Manion

    Securities and Exchange Commission

    Division of Investment Management

    100 F Street, N.E.

    Washington, DC 20549

            Re:

              American Beacon Funds (File Nos. 033-11387 and 811-04984)

                American Beacon Select Funds (File Nos. 333-88343 and 811-09603)

                  American Beacon Institutional Funds Trust (File No. 811-23239)

                American Beacon Sound Point Enhanced Income Fund (File Nos. 333-222968 and 811-23326)

                 American Beacon Apollo Total Return Fund (File Nos. 333-225559 and 811-23351)
                  (each, a “Registrant” and, collectively, the “Registrants”)

              Responses to SEC Comments – Sarbanes-Oxley Review

    Dear Mr. Manion:

    The following are responses by and on behalf of the Registrants to the comments you provided by telephone on May
      20, 2020, regarding the examination of the public filings of the Registrants and their respective series (collectively, the “Funds”) on Form N-CSR and Form N-CEN for the fiscal year reporting periods ended June 30, 2019, August 31, 2019, October 31,
      2019, December 31, 2019 and January 31, 2020.  The comments provided by the staff (“Staff”) of the Securities and Exchange Commission (“SEC”) and the Registrants’ responses are set forth below.

          1.

            Investments in Affiliates: All Funds (except American Beacon U.S. Government Money Market Select Fund).  For each Fund that invests in the American Beacon U.S. Government Money Market Select Fund, include
              in the notes to the Fund’s financial statements the table required by Regulation S-X Rule 12-14.

    The Registrants confirm that, in future filings, they will include in the notes to the financial statements the table
      required by Regulation S-X Rule 12-14.

          2.

            Covenant-Lite Loans: American Beacon Crescent Short Duration High Income Fund (“Crescent Fund”), American Beacon Apollo Total Return Fund (“Apollo Fund”), American Beacon Sound Point Enhanced Income Fund
                (“SPEI Fund”), and American Beacon Sound Point Floating Rate Income Fund (“SPFR Fund”) (each, a “Bank Loan Fund” and, collectively, the “Bank Loan Funds”).  Please discuss in correspondence whether any of the Bank Loan Funds invests in
              covenant-lite loans and, if so, the extent of such investments.  If applicable, please consider adding

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              disclosure regarding these investments to a Bank Loan Fund’s prospectus and financial statements.

    The Registrants confirm that the Bank Loan Funds hold investments in covenant-lite loans. As of January 31, 2020,
      covenant-lite loans represented: (1) 20% of the net assets of the Crescent Fund; (2) 65% of the net assets of the Apollo Fund; (3) 68% of the net assets of the SPEI Fund; and (4) 80% of the net assets of the SPFR Fund.  To the extent that the Bank
      Loan Funds invest significantly in covenant-lite loans, the Registrants will include disclosure regarding covenant-lite loans in future registration statement updates and financial statements for the Bank Loan Funds, as applicable, except for the
      Crescent Fund, which is expected to be liquidated on or about July 31, 2020.

          3.

            Loan Income:  Bank Loan Funds.  Please discuss in correspondence whether any of the Bank Loan Funds received a significant amount of other income (i.e., restructuring fees or commitment fees) related to
              bank loan investments.  If a Bank Loan Fund received a significant amount of such other income, please disclose these amounts in a separate line item and include disclosure regarding the appropriate accounting policies for the recognition of
              this income.

    Rule 6-07(1) of Regulation S-X requires that the Statement of Operations for each Bank Loan Fund separately disclose
      other income, such as restructuring fees, consent fees or commitment fees, if that income exceeds 5% of the Bank Loan Fund’s Investment Income.  The Bank Loan Funds each had restructuring fees, consent fees or commitment fee income in an amount that
      was less than 5% of the Bank Loan Fund’s Investment Income, as reflected in its Statement of Operations for its last fiscal year.  If a Bank Loan Fund receives restructuring fees, consent fees, commitment fees or other income that exceeds 5% of the
      Bank Loan Fund’s Investment Income, the Registrants will separately disclose these amounts in the Statement of Operations for that Bank Loan Fund.

          4.

            Management’s Discussion of Fund Performance (“MDFP”):  American Beacon GLG Total Return Fund.  The MDFP disclosure discusses the Fund’s investment strategies, including that it uses derivative
              instruments.  In future annual shareholder reports, discuss how the Fund uses derivative instruments to achieve its investment strategy and the impact of derivative instruments on the Fund’s performance.

    As discussed with the Staff, the Fund was liquidated on June 30, 2020.  As a result, the Fund does not intend to file
      a future annual shareholder report on Form N-CSR.

          5.

            Line Graph Presentation of the Growth of a $10,000 Investment: American Beacon ARK Transformational Innovation Fund (“ARK Fund”).  In the line graph depicting the growth of a $10,000 investment in the
              Fund, the Registrant reflects the growth of a $10,000 investment for the life of the Fund as compared to the S&P 500

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                  Index.  It appears to the Staff that plot points were shown on the line for the Fund with respect to each period shown, but plot points were not shown on the line for the S&P 500 Index.  Please discuss
                    in correspondence whether the line graph properly presents the S&P 500 Index in accordance with Form N-1A, Item 27(b)(7).

    The Registrant confirms that plot points for the S&P 500 Index were not reflected in the line graph presentation
      for the growth of a $10,000 investment for the ARK Fund.  In the future, the Registrant will disclose in the line graph the plot points depicting each year of the life of the Fund and the S&P 500 Index in the annual report on Form N-CSR for the
      ARK Fund.

          6.

            Organizational and Offering Costs:  Apollo Fund.  Note 1 to the Fund’s financial statements discloses the Fund’s organizational and offering expenses, which exceeded of 5% of the Fund’s net assets as of
              June 30, 2019.  The Staff notes that organizational and offering expenses are not reflected on the Fund’s Statement of Operations.  Please discuss in correspondence the accounting treatment for the Fund’s organizational and offering expenses
              and where the various amounts have been recorded.

    In accordance with FASB ASC 720-15-25 and 946-20-25 of U.S. GAAP Accounting Standards: (1) organizational costs, including the costs of
      creating the Apollo Fund, initial board meetings, negotiating administration, custody and transfer agency agreements, and related legal services, were booked as expenses immediately as incurred; and (2) offering costs, including the costs of the
      preparation, review and filing of the Apollo Fund’s registration statement on Form N-2, the  printing, mailing and other distribution of the Fund’s prospectus and statement of additional information, filing fees, and related legal services, were
      amortized over twelve months on a straight-line basis as of the Apollo Fund’s commencement of operations.  American Beacon Advisors, Inc. (the “Manager”) paid all organizational and offering costs prior to the Apollo Fund’s commencement of
      operations.

    For the fiscal year ended June 30, 2019, the Fund recorded $211,100 of organizational costs and amortized offering costs of $345,534,
      which were included on the Fund’s Statement of Operations.

    Organizational costs were disclosed in the following line-items:

            Legal expense included in Professional fees
            $ 210,850

            Other expenses
                      250

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    The amortized offering costs were disclosed in the following line-items:

              Professional fees:

            Legal Expense
            $ 295,248

            Audit Expense

              11,959

            Registration fees and expenses
                 24,815

            Prospectus and shareholder report expenses
            12,931

            Other expense

            581

          7.

            Expenses Subject to Recoupment:  Apollo Fund.  For the fiscal year ended June 30, 2019, the Fund recorded gross expenses of $996,496, of which $923,319 were reimbursed or waived by the Manager and are
              subject to the Fund’s recoupment policy.  For the same period, the Fund’s Statement of Assets and Liabilities reflected amounts Payable to the Manager of $147,651, and the Statement of Operations reflected Net Expenses of $73,177.   Please
              discuss in correspondence how the Fund has an amount payable to the Manager that exceeds the Fund’s Net Expenses when the expenses waived or reimbursed by the Manager are subject to recoupment and the Fund has not recorded a liability for the
              amount payable to the Manager.

    As the Staff observed, the Fund recorded gross expenses of $996,496, of which $923,319 were fees waived by or expenses reimbursed by the
      Manager.  Accordingly, the Fund recorded Net Expenses of $73,177.

    The $147,651 payable to the Manager that is disclosed on the Statement of Assets and Liabilities for the fiscal year ended June 30, 2019
      consisted of: (1) $87,868 of remaining offering costs that will be amortized and reflected as an expense on the Apollo Fund’s Statement of Operations for the fiscal year ended June 30, 2020; and (2) a payable to the Manager of $57,783 on the Fund’s
      books and records that represented an over-reimbursement of expenses by the Manager in May 2019.  The offering costs (as reflected in the above response to comment 6) were not included in the Apollo Fund’s Net Expenses because they were not expensed
      during the fiscal year ended June 30, 2019.

          8.

            Short Selling Fees:  American Beacon SSI Alternative Income Fund.  Please discuss in correspondence where other fees incurred by the Fund in connection with
                short sales, such as prime broker expenses, are recorded in the Fund’s financial statements for the fiscal year ended June 30, 2019.  Please consider disclosing these amounts in future shareholder reports.

    The Fund did not incur any fees in connection with securities sold short during the fiscal year ended June 30, 2019.
      The Fund included in “Interest Income” on the Statement of Operations amounts paid to the Fund by the prime broker in connection with the Fund’s securities sold short during the period.  The Interest Income paid to the Fund by the prime broker
      amounted to approximately 17% of the Fund’s total Investment Income.  In the

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      future, the Registrant will disclose “Interest Income from short securities held at broker” as a separate line item on the Statement of Operations.  Dividends and interest on securities sold short are currently disclosed in a separate line item of
      Expenses on the Statement of Operations.

          9.

            Unfunded Loan Commitments:  Bank Loan Funds and Other Funds, as applicable.  Please discuss in correspondence the Funds’ accounting methodology for unfunded amounts and reference the appropriate Generally
              Accepted Accounting Principles (“U.S. GAAP”) standard associated with this accounting methodology.

    In accordance with FASB ASC 440-10 of U.S. GAAP Accounting Standards, each Bank Loan Obligation is disclosed in the
      Schedule of Investments f and reflects both the funded portion of a bank loan as well as the unfunded commitment.  The details of the unfunded commitments are disclosed in the footnotes to the Schedule of Investments.  Unfunded commitments also are
      disclosed in the aggregate as a Liability in the Statement of Assets and Liabilities.  The commitment fee, which is included in “Interest income” on the Statement of Operations, is recognized ratably over the commitment period.

          10.

            Form N-CEN:  American Beacon Large Cap Value Fund (“Large Cap Value Fund”) and American Beacon Mid-Cap Value Fund (“Mid-Cap Value Fund”).  In response to Form N-CEN, Item C.8, each Fund disclosed that fees
              waived pursuant to an expense limitation arrangement during the reporting period are not subject to recoupment.  However, the Funds also disclosed in response to Form N-CEN, Item C.8 that expenses previously waived had been recouped during
              the reporting period.  Please confirm in correspondence that previously waived expenses of the Funds are subject to recoupment.

    The Registrant confirms that previously waived expenses of the Large Cap Value Fund and Mid-Cap Value Fund are subject
      to recoupment.  The Registrant will disclose that fees waived pursuant to an expense limitation are subject to recoupment in future Form N-CEN filings.

          11.

            Net Asset Value (“NAV”) Errors:  American Beacon Frontier Markets Income Fund (“Frontier Markets Fund”), American Beacon GLG Total Return Fund (“GLG Fund”) and American Beacon AHL Managed Futures Strategy Fund
                (“AHL Fund”).  Each Fund reported one or more NAV errors during the last fiscal year on Form N-CEN.  Please discuss in correspondence the cause of the Funds’ NAV errors and confirm that any necessary reprocessing of shareholder
              transactions was completed and accurate.

    The NAV error that was reported in response to Item B.22 in the Annual Report on Form N-CEN for the AHL Fund that was
      filed with the SEC on March 13, 2020, related to an issue with the trade instructions provided by the Fund’s sub-adviser to the Fund’s

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        custodian.  The NAV was understated and the error was greater than one-half of one percent.  However, as there was no shareholder activity on the date of the NAV error, the  Registrant did not reprocess shareholder
          transactions.

    The NAV error that was reported in response to Item B.22 in the Annual Report on Form N-CEN for the GLG Fund that was
      filed with the SEC on April 14, 2020, related to a variance between the price booked by the Fund and the price subsequently identified by a pricing vendor with respect to a Brazilian interest rate swap on March 26, 2019.  As a result, the Fund’s NAV
      was understated by more than one-half of one percent.  There was shareholder redemption activity in the GLG Fund’s Ultra Class shares on March 27, 2019.  Accordingly, the shareholder activity was reprocessed and the loss of $1,410.45 was reimbursed
      to the GLG Fund by the Registrant’s sub-administrator.

      The NAV error that was reported in response to Item B.22 in the Annual Report on Form N-CEN for the Frontier Markets Fund that was
        filed with the SEC on April 14, 2020, related to an issue with the calculation of the appropriate recoupable amount of previously waived fees and/or expenses during the period from January 16, 2019 through May 2