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CORRESP
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CORRESP

 1900 K Street, NW

Washington, DC 20006-1110

 +1 202 261
3300 Main

 +1 202 261 3333 Fax

www.dechert.com

 ADAM T. TEUFEL

 adam.teufel@dechert.com

+1 202 261 3464 Direct

 +1 202 261
3164 Fax

 April 4, 2023

VIA EDGAR

Anu Dubey

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: PIMCO Funds (the “Registrant”)

File Nos. 033-12113; 811-05028

Dear Ms. Dubey:

You previously communicated the Securities and Exchange Commission (“SEC”) staff’s (the “Staff”)
comments on Post-Effective Amendment No. 345 (“PEA 345”) to the Registrant’s registration statement under the Securities Act of 1933 (the “1933 Act”), as amended, and Amendment No. 493 to the Registrant’s
registration statement under the Investment Company Act of 1940, as amended (the “1940 Act”), as filed on February 10, 2023. PEA 345 was filed to register Class C shares of the PIMCO TRENDS Managed Futures Strategy Fund, an
existing series of the Registrant (the “Fund”). A summary of the Staff’s comments, along with the Registrant’s responses, is set forth below. Undefined capitalized terms used herein have the same meaning as in PEA 345. All
references to “Fund” refer only to the Fund, unless noted otherwise.

 Prospectus

Comment 1: Please add the EDGAR Class IDs for all share classes of the Fund since PEA 345 amends the registration
statement for all classes of the Fund.

 Response: As noted in the explanatory note to PEA 345, PEA 345 was filed
solely for the purpose of registering Class C shares for the Fund. Class C shares for the Fund were added to the Fund’s existing statutory Prospectus and Statement of Additional Information (“SAI”) for administrative
convenience in lieu of creating a standalone prospectus or SAI to register Class C shares of the Fund. PEA 345 did not amend the registration statement for any other series or classes of the Registrant. Accordingly, none of the
Registrant’s other EDGAR series and class identifiers were included as part of PEA 345, and the Registrant respectfully declines to amend PEA 345 to include the other class IDs of the Fund.

 Anu Dubey

 April 4, 2023

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Comment 2: The Prospectus cover page includes a date of “August 1, 2022 (as supplemented [ ], 2023).”
As required by Rule 423 under the 1933 Act and General Instruction C.3(e) of Form N-1A, please revise the date on the Prospectus cover page with a single date that is approximately the date that the amended
Prospectus will become effective.

 Response: Registrant acknowledges the Staff’s request to date any
prospectus and SAI included in post-effective amendments to its registration statement as of the date the amendment will become effective. As noted above, the sole purpose of PEA 345 was to register Class C shares of the Fund. In lieu of
creating a standalone new prospectus and SAI solely for the addition of Class C shares of the Fund, the Registrant updated the existing Prospectus and SAI for the Fund, dated August 1, 2022, to add the share class. The definitive
post-effective amendment for this purpose is expected to be filed and effective on or about April 11, 2023 (“PEA 349”). If effective on that date, the Prospectus in PEA 349 will be dated “August 1, 2022 (as supplemented
April 11, 2023).” Just as in PEA 345, the Prospectus and SAI in PEA 349 will include the existing classes of the Fund in addition to the Class C shares of the Fund for which PEA 345 was filed, and PEA 349 will be filed under the
Class C identifier for the Fund only and not all of the other classes that are included in the Prospectus and SAI. This is being done for administrative convenience in recognition of the fact that the Registrant intends to offer Class C
shares of the Fund, together with other classes of the Fund, in the existing August 1, 2022 Prospectus and SAI, not in a new standalone prospectus and an SAI dated on or about April 11, 2023.

An alternative approach would have been to draft and file a new standalone prospectus and an SAI solely for Class C
shares of the Fund, via a post-effective amendment dated on or about April 11, 2023, or such later effective date that may be designated through a subsequent post-effective amendment filing, and immediately supersede that filing with a 497
filing incorporating the newly effective class of the Fund within the existing August 1, 2022 Prospectus and SAI with a dating convention of “August 1, 2022 (as supplemented April 11, 2023).” In other words, we could create two
different sets of prospectuses and SAIs, one of which would be used solely for PEA 349 and then discarded, the other used for a subsequent 497 filing and actual delivery to shareholders. We respectfully assert that such alternative approach would
have created substantial administrative burdens and costs for no discernible benefit, solely to ensure that the Prospectus and SAI within PEA 349 were dated in technical conformance with Rule 423. For these reasons, we respectfully assert that the
dating convention used in PEA 345 is appropriate as is.

 Comment 3: If the Fund expects to derive its returns
principally from swaps, please add a footnote to the fee table disclosing estimated costs of investing in swaps and state that embedded swap costs are indirect fund expenses that are not included in the fee table or expense example.

 Anu Dubey

 April 4, 2023

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Response: The Registrant respectfully submits that it is not aware of any requirement in Form N-1A that would require the requested disclosure.

 Comment 4:
Please remove footnote 1 to the Fund’s fee table. Such information is neither permitted nor required in the Fund’s fee table. See General Instruction C(3)(b) to Form N-1A.

Response: The Registrant has reviewed this footnote in light of the Staff’s comment and has already consolidated
interest expense-related footnotes into a single footnote to the Fund fee table, consistent with the Staff comment provided to the 2016 annual update of the Registrant’s registration
statement.1 However, the Registrant respectfully declines to remove the footnote in its entirety. The Registrant’s response, set forth below, is the same as the response provided to similar
comments to several prior post-effective amendments of PIMCO-advised registrants.2

To the extent the Fund enters into certain investments, such as reverse repurchase agreements or short sales, the Fund incurs
interest expense. Interest expense is required to be treated as an expense of the Fund for accounting purposes,3 but the amount of interest expense, if any, will vary from year to year with the
Fund’s use of such investments as an investment strategy.

 Unlike many other fund complexes, the Fund has a
“unified fee” structure wherein the Fund pays two fixed fees to PIMCO in return for required services that PIMCO provides or arranges to provide for the Fund. This unified fee is comprised of the investment advisory fee and supervisory and
administrative fee as described in the Fund’s statutory prospectuses and disclosed in the combined “Management Fees” line item of the fee table. Under the unified fee, PIMCO provides or procures advisory and supervisory and
administrative services for shareholders and also bears the costs of various third-party services required by the Fund, including audit, custodial, portfolio accounting, legal, transfer agency and printing costs. As such, the unified fee structure
is designed to be an “all-in” fee structure that pays for the fees and costs of all PIMCO and third-party provided services

1
 See, e.g., Letter from Adam T. Teufel to Amy Miller, Division of Investment Management, U.S.
Securities and Exchange Commission, Responding to Comments on PIMCO Funds’ Post-Effective Amendment No. 284, at comment 2 (Aug. 11, 2016).

2
 See, e.g., Letter from Adam T. Teufel to Anu Dubey, Division of Investment Management, U.S.
Securities and Exchange Commission, Responding to Comments on PIMCO Funds Post-Effective Amendment No. 292, at comment 3 (Nov. 14, 2018); Letter from Adam T. Teufel to Anu Dubey, Division of Investment Management, U.S. Securities and Exchange
Commission, Responding to Comments on PIMCO Funds Post-Effective Amendment No. 311, at comment 5 (Feb. 27, 2019).

3
 See Fin. Accounting Standards Bd. Accounting Standards Codification 946-225-45-3 (requiring investment companies to report interest expense separately when calculating net assets for purposes of the fund’s statement of operations).

 Anu Dubey

 April 4, 2023

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 under
more or less a fixed fee. Accordingly, the Registrant believes that investors have come to expect a total expense ratio from year to year that is generally fixed.

There are, however, certain expenses the Fund does bear that are not covered under the unified fee structure that may
materially impact the total level of expenses that shareholders generally expect to pay under a unified fee structure. One of the few expenses not covered by the unified fee, and thus reflected in the “Other Expenses” line item of the fee
table, is the Fund’s interest expense. As interest expense may vary, causing the Fund to disclose a different total expense ratio from year to year, the Registrant believes that failure to include an explanation for this variance may create
investor confusion. The Registrant believes explanatory footnotes appropriately placed where they are most likely to be read by investors (i.e., immediately adjacent to the fee table and expense ratio) are helpful and informative for the average
investor, not confusing or burdensome.

 The Registrant notes that the SEC, in adopting the summary prospectus amendments
to Form N-1A, indicated that “[t]he fee table and example are designed to help investors understand the costs of investing in a fund and compare those costs with the costs of other funds” (emphasis
added).4 The SEC further stated that the “prospectus summary section is intended to provide investors with streamlined disclosure of key mutual fund information at the front of the statutory
prospectus, in a standardized order that facilitates comparisons across funds” (emphasis added).5 The Registrant agrees. The primary goal of a statutory prospectus summary section should be
to provide clear, concise information to facilitate investor comparison of the Fund with other mutual funds. Without the current fee table footnotes describing the Fund’s interest expense and its effect on the Fund’s expense ratios, the
Registrant believes the Fund’s fee tables would not adequately facilitate an investor comparison of the Fund’s costs against other mutual funds’ costs as investors will not have the context in which to accurately make such a
comparison. Because the Fund has a unique unified fee structure as described above, what comprises “Other Expenses” for the Fund is likely very different from what comprises “Other Expenses” for other mutual funds. Therefore, the
impact of “Other Expenses” on the Fund’s total expense ratio from year to year as compared to other mutual funds’ expense ratios is likely to be quite different. For example, because the Fund does not include any routine
servicing or administrative expenses under “Other Expenses,” as such expenses are covered by the unified fee, any “Other Expenses” reflect non-routine activities such as interest expense
accrued as a result of discretionary investment activities. Since the unified fee structure renders “Other Expenses” a non-routine line item for the Fund, investors in the Fund have reasonably come
to expect that the total expense ratio of the Fund is often the unified fee plus any share class-specific fixed expenses (such as 12b-1 fees). Thus, without the footnotes to explain the non-routine instances where the Fund needs to disclose “Other Expenses,” investors may not

4
 Summary Prospectus Adopting Release at 31.

5
 Id. at 16-17.

 Anu Dubey

 April 4, 2023

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understand that the Fund operates under a unified fee structure, as they may mistakenly assume that such “Other
Expenses” are expenses that are in fact covered by the unified fee. This is particularly true under the “summary prospectus” paradigm where the statutory prospectus is not required to be sent unless the investor requests it and
detailed information about the unified fee structure is only included in the statutory prospectus. Accordingly, the Registrant believes an investor could be unaware of the Fund’s unified fee structure unless the Fund includes explanatory
footnotes in the summary prospectus. The Registrant believes deleting these footnotes would cause its fee tables to fall short in meeting the SEC’s objective of providing clear, concise, standardized information to facilitate cost comparisons
across different mutual funds because the Registrant’s unified fee structure is unique as compared to most other mutual funds.

Thus, as General Instruction C(1)(a) to Form N-1A states that the requirements of the
Form are “intended to promote effective communication between the [Fund] and prospective investors,” the Registrant believes it is “effective communication” within the meaning of the General Instruction to include a limited
number of footnotes as part of the table to clearly communicate the nature and amount of the Funds’ interest expense, where applicable, including why interest expense is incurred and that interest expense may vary from year to year (i.e., that
it is not a fixed fee or expense, like the other line items in the Fund’s fee table). The Registrant believes the failure to do so may result in investors not otherwise understanding why the Fund’s total expense ratio may differ, sometimes
substantially, each year largely as a function of interest expense. Moreover, the inclusion of the interest expense footnote, in addition to providing clarifying information to investors, does not lengthen the summary section of the statutory
prospectus in any meaningful way or otherwise interfere with a concise, plain English presentation of material information to investors. To the contrary, the interest expense footnotes provide helpful, clarifying information for investors.

Comment 5: In footnote 3 to the Fund’s fee table, please disclose that the Adviser may recoup certain waived
and/or reimbursed expenses in future periods, and the terms of such recoupment, if applicable.

 Response: The
Registrant confirms that, under the contractual arrangements for the fee waiver described in footnote 3 to the Fund’s fee table, the Adviser does not have the ability to recoup waivers and reimbursements in future periods. Accordingly, the
Registrant believes that no additional disclosure is necessary.

 Comment 6: Pursuant to Instruction 3(e) to Item 3
of Form N-1A, a fee waiver may be disclosed in the fee table only if it will be in effect for at least one year from the effective date of the Prospectus. Please delete the disclosure of the fee waiver
described in footnote 4 to the Fund’s fee table, and revise the expense example accordingly, since the fee waiver expires less than one year after the effective date of the amended Prospectus.

 Anu Dubey

 April 4, 2023

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Response: Footnote 4 relates to Class I-3 shares of the Fund. PEA 345 was
filed only to register Class C shares of the Fund. Accordingly, PEA 345 did not amend the registration statement for other classes of the Fund included in the Prospectus. Therefore, the Registrant believes that no update to footnote 4 is
required.

 Comment 7: In footnote 4 to the Fund’s fee table, the Staff notes that PIMCO has contractually
agreed to reduce its supervisory and administrative fee for the Fund’s I-3 shares by 0.05%. Please confirm this fee waiver is appropriate under Rule 18f-3 of the
1940 Act and does not result in other share classes subsidizing advisory fees of I-3 shares.

Response: The Registrant confirms that the Fund’s supervisory and administrative fee waiver for the Fund’s Class I-3 shares does not re