SEC Company Response from Invesco California Value Municipal Income Trust (VCV) (CIK 0000895531) (VCV) — Sep 16, 2011
Invesco California Value Municipal Income Trust (VCV) (CIK 0000895531)
Date: Sept. 16, 2011 · CIK: 0000895531 · Accession: 0000950123-11-085043
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-01424, 811-01540, 811-02090, 811-02611, 811-02699, 811-02729, 811-03826, 811-05426, 811-05460, 811-05597, 811-05686, 811-05688, 811-05769, 811-05793, 811-05845, 811-05898, 811-06052, 811-06053, 811-06346, 811-06362, 811-06364, 811-06434, 811-06463, 811-06471, 811-06472, 811-06536, 811-06537, 811-06567, 811-06590, 811-06591, 811-07088, 811-07109, 811-07111, 811-07344, 811-07398, 811-07404, 811-07560, 811-07562, 811-07564, 811-07868, 811-07890, 811-08000, 811-08044, 811-08743, 811-09913, 811-22043
Letter
VIA EDGAR Invesco High Yield Investments Fund, Inc. 811-08044 Invesco Van Kampen High Income Trust II 811-05769
Dear Mr. Long:
This letter is to follow up on our telephone conversation on July 20, 2011, in which we discussed the comments you provided on the financial statements (and certain related materials) filed with the U.S. Securities and Exchange Commission (“SEC”) for the open-end and closed-end Invesco Funds, excluding the variable insurance funds (collectively, the “Registrants” or the “Invesco Funds”). We have provided our responses below. References in this letter to the views and beliefs of “the Staff” are to those views and beliefs expressed in your comments regarding the financial statements of the Invesco Funds. References to “we” or “Invesco” are to Invesco Funds.
Comment 1
SEC Comment: The Staff asked what affect Ambac Financial Group, Inc.’s Chapter 11 bankruptcy filing in November 2010 had on guarantees or credit enhancements of holdings of the Invesco Funds, such as the Invesco Van Kampen Select Sector Municipal Trust.
Invesco Response: By the time Ambac filed for bankruptcy, Invesco had already fully discounted any value ascribed to Ambac’s guarantees or credit enhancements. Therefore, the Ambac bankruptcy had a de minimis affect on the valuations of holdings of the Invesco Funds, such as the Invesco Van Kampen Select Sector Municipal Trust.
Comment 2
SEC Comment: The Staff noted that in the Management’s Discussion of Fund Performance section of the Annual Report (“MDFP”) for the Closed-End Funds (“CEFs”), the benchmark returns were disclosed in some but not in all MDFPs. The Staff suggested that the inclusion of the benchmark returns be included or excluded consistently across all the MDFPs for the CEFs.
Invesco Response: Invesco intends to include benchmark information in all MDFPs for the CEF’s annual report going forward.
Comment 3
SEC Comment: Regarding the Invesco Insured Municipal Trust, Invesco Insured Municipal Bond Trust, Invesco California Quality Municipal Securities, and Invesco Van Kampen High Yield Municipal Fund, the Staff asked why the “Other Expense” line item in each of the Income Statements for the period-ended February 28, 2011 contains negative amounts.
Invesco Response: With respect to the Invesco Insured Municipal Trust, Invesco Insured Municipal Bond Trust, and Invesco California Quality Municipal Securities, “Other Expenses” for the period ended February 28, 2011 included an adjustment for a change in accounting estimate for professional services fees during the period. Please note that the financial highlights for these three funds included a footnote disclosing the change in accounting estimates and its impact.
With respect to the Invesco Van Kampen High Yield Municipal Fund, “Other Expenses” for the period ended February 28, 2011, included an adjustment in accrual balances as a result of a one-time change in fiscal year-end.
Page 2 of 7
Comment 4
SEC Comment: The Staff commented that the legal expenses related to lawsuits involving certain CEFs appear to have been excluded from the expense limitation. The Staff provided the example of Invesco Municipal Premium Income Trust, which reported $502,743 in related legal expenses during the February 28, 2011 fiscal period and had a contractual expense limit of 1.03% in effect and a higher total expense ratio. The Staff requested the basis for the legal expenses exclusion from the expense limit. The Staff recommended that such exclusions be clearly and expressly drafted in the agreement to limit expenses paid by the fund.
Invesco Response: The parties to the contractual agreement to limit expenses paid by the Funds are under the common understanding that litigation expenses are one of the types of expenses that are excluded from the contractual expense limitation as “non-routine or extraordinary.” Upon the next review of the contract, we will consider clarifying the contract and make any appropriate changes to the disclosure language accordingly.
Comment 5
SEC Comment: Regarding the Invesco Van Kampen Dynamic Credit Opportunities Fund, the Staff requested details about the reimbursement by Van Kampen Advisors, Inc. of $2,209,166 “for an economic loss due to a trading error” for the year-ended July 31, 2010 as reported in the Fund’s Annual Report.
Invesco Response: The predecessor advisor to Invesco Van Kampen Dynamic Credit Opportunities Fund did not exercise rights offered on a security for the Fund and thus lost out on an opportunity for which the predecessor advisor paid into the Fund in the amounts disclosed.
Comment 6
SEC Comment: The Invesco Capital Development Fund held securities with valuations categorized as level 3. The Staff noted the report did not contain a level 3 roll forward table from period to period.
Invesco Response: The disclosure practice is to evaluate the materiality of the disclosure for each fund and reporting period using quantitative and qualitative factors such as the percentage and circumstances of level 3 holdings and activity, the type of fund and fund strategy, historical practice and other information within the report. For the period ended October 31, 2010, the Fund did not meet the thresholds of the Funds’ internal disclosure policy for including a level 3 roll forward table.
Comment 7
SEC Comment: Please explain why expenses of money market fund investments made by Invesco Commodities Strategy Fund are not reflected in the acquired fund fees and expenses line item in the November 20, 2010 prospectus fee table.
Page 3 of 7
Invesco Response: All money market fund investments made by Invesco Commodities Strategy Fund are made in affiliated money market funds. An amount of the advisory fee charged by Invesco to Invesco Commodities Strategy Fund is contractually waived to the extent that an advisory fee is collected from the Invesco affiliated money market fund for these investments. Therefore, the acquired fund fees after a reduction for the waiver is reflected in the acquired fund fees and expenses line item in the Invesco Commodities Strategy Fund. Because the acquired fund fees and expenses, after the waiver, were less than 1 basis point, they are not reflected in the expense line item in the November 20, 2010 prospectus fee table.
Comment 8
SEC Comment: Regarding the Invesco Balanced Risk Allocation Fund and Invesco Van Kampen Government Securities Fund, the Staff noted that the Income Statements reported realized gains/losses from swap agreements for the period-ended October 31, 2010. The Staff questioned whether the principal strategy section of the prospectuses should have a fuller disclosure regarding the use of swap agreements. Furthermore, the Staff said the MDFP section of each fund did not include a discussion on the effects and use of swap agreements.
Invesco Response: Regarding the Invesco Van Kampen Government Securities Fund, the “performance summary section” in the MDFP for the period-ended September 31, 2010 stated that the Fund “underperformed the Fund’s broad market/style-specific index due mainly to yield curve positions, using interest rate swaps and exposure to non-U.S. sovereign guaranteed paper which is no longer held in the portfolio.” The information was reiterated in the “Market conditions and your Fund” section of the MDFP: “Its underperformance can be largely attributed to yield curve positions using interest rate swaps and exposure to non-U.S. sovereign guaranteed paper, both of which are no longer held in the portfolio.” In consideration of the discontinued use of swap agreements prior to the period-end and the discussions that existed in the MDFP, we believe the disclosure was appropriate. Furthermore, the Invesco Van Kampen Government Securities Fund has since been reorganized into another Invesco Fund and no longer maintains an effective N-1A prospectus.
Regarding the Invesco Balanced Risk Allocation Fund, the MDFP for the period-ended October 31, 2010 stated the Fund may invest in swap agreements, including total return swaps. Additional details concerning the use of swap agreements are disclosed in the Annual Report’s Consolidated Schedule of Investments listing the swap agreements at the year-end, the Consolidated Statement of Assets and Liabilities, and the Consolidated Statement of Operations. Furthermore, Note 1.K. entitled “Swap Agreements” in the Notes to Consolidated Financial Statements provides detailed explanations and disclosure. Nevertheless, in light of increased industry focus on derivatives, we are considering adding or modifying language prospectively in the MDFP regarding the use of derivatives, including swaps, to affect performance.
We believe that the disclosures in the principal strategy sections of the prospectuses for both funds, which were reviewed by the SEC examiner, were also appropriate. In light of increased industry focus on derivatives, however, we are reviewing derivatives disclosures across the Invesco Funds complex and considering whether modifications or enhancements are appropriate.
Page 4 of 7
Comment 9
SEC Comment: Regarding the Invesco High Yield Securities Fund and Invesco Van Kampen High Yield Fund, the Staff believes that the Lipper High Current Yield Bond Funds Index does not qualify as a broad-based index to be used as a benchmark for these Funds as stated in the “Results of a $10,000 Investment” line graph in the Annual Reports.
Invesco Response: Going forward, the Invesco High Yield Securities Fund will use the Barclays Capital U.S. Corporate High Yield 2% Issuer Cap Index, which is its broad-based index, as well as the Lipper High Current Yield Bond Fund Index in its “Results of a $10,000 Investment” chart.
Note that the Invesco Van Kampen High Yield Fund has been reorganized into another Invesco Fund and no longer maintains an effective N-1A prospectus.
Comment 10
SEC Comment: Regarding the return of capital in the Invesco Van Kampen Equity Premium Income Fund, the Staff sought confirmation that the requirements of Rule 19a-1 under the Investment Company Act of 1940 were met.
Invesco Response: We believe the requirements of Rule 19a-1 under the Investment Company Act of 1940 were met by Invesco Van Kampen Equity Premium Income Fund. Note that the Invesco Van Kampen Equity Premium Income Fund has been reorganized into another Invesco Fund and no longer maintains an effective N-1A prospectus.
Comment 11
SEC Comment: Regarding the Invesco Van Kampen Pennsylvania Tax Free Income Fund, the Staff noted that the current prospectus states that “[t]he Fund does not purchase securities that are in default or rated in categories lower than B- by Standard and Poor’s (S&P) or B3 by Moody’s Investors Service, Inc. (Moody’s) or unrated securities of comparable quality.” The Staff also noted that the current MDFP states the portfolio composition to be 29.7% in “[n]on-rated securities.” The Staff requested that we provide an explanation reconciling these two statements.
Invesco Response: The Fund invests in securities that are rated as B- or above as well as non-rated securities of comparable quality as determined by Invesco. The 29.7% of “non-rated securities” as disclosed in the MDFP were deemed to be securities of quality comparable to B- or above.
Comment 12
SEC Comment: Regarding the Invesco Van Kampen Pennsylvania Tax Free Income Fund Annual Report for the period-ended August 31, 2010, the Staff commented that schedule of investments listed “100.1%” investments in municipal bonds and 93.1% investments in the region of Pennsylvania. The Staff believes that
Page 5 of 7
the portfolio holdings should be further broken down by industry based on the Staff’s interpretation of Rule 12-12 of Regulation S-X.
Invesco Response: The disclosure practice for state-specific municipal funds is to categorize investments on the Schedule of Investments by the type of investment and the geographic region of the investment. We also disclose in the MDFP, the portfolio composition categorized by credit sector.
Nevertheless, we are considering the Staff’s comment to prospectively break down the investments by industry in the Schedule of Investments.
Comment 13
SEC Comment: Regarding the Invesco High Yield Securities Fund amended Forms N-SAR and N-CSR for the period-ended August 31, 2010, the Staff commented on the “errors in the classification of income and realized gains from investment securities and the change in unrealized appr
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PO Box 4333
Houston, TX 77210-4333
11 Greenway Plaza, Suite 2500
Houston, TX 77046
713 626 1919
www.invesco.com
September 16, 2011
VIA EDGAR
Jeffrey Long
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Invesco Funds — 2011 Financial Report Review
OPEN END FUNDS
AIM Counselor Series Trust (Invesco Counselor Series Trust)
811-09913
AIM Equity Funds (Invesco Equity Funds)
811-01424
AIM Funds Group (Invesco Funds Group
811-01540
AIM Growth Series (Invesco Growth Series)
811-02699
AIM International Mutual Funds (Invesco International Mutual Funds)
811-06463
AIM Investment Funds (Invesco Investment Funds)
811-05426
AIM Investment Securities Funds (Invesco Investment Securities Funds)
811-05686
AIM Sector Funds (Invesco Sector Funds)
811-03826
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
811-07890
AIM Treasurer’s Series Trust (Invesco Treasurer’s Series Trust)
811-05460
Short-Term Investments Trust
811-02729
Invesco Van Kampen Exchange Fund
811-02611
CLOSED-END FUNDS
Invesco Municipal Income Opportunities Trust II
811-05793
Invesco Municipal Income Opportunities Trust III
811-06052
Invesco Municipal Income Opportunities Trust
811-05597
Invesco Municipal Premium Income Trust
811-05688
Invesco Van Kampen Bond Fund
811-02090
Invesco Van Kampen Dynamic Credit Opportunities Fund
811-22043
Invesco Van Kampen Senior Income Trust
811-08743
Invesco Van Kampen Senior Loan Fund
811-05845
Invesco Prime Income Trust
811-05898
Invesco California Insured Municipal Income Trust
811-07344
Invesco California Quality Municipal Securities
811-07564
CLOSED-END FUNDS...Continued
Invesco Insured California Municipal Securities
811-07111
Invesco Insured Municipal Bond Trust
811-06053
Invesco Insured Municipal Income Trust
811-06590
Invesco Insured Municipal Securities
811-07109
Invesco Insured Municipal Trust
811-06434
Invesco New York Quality Municipal Securities
811-07562
Invesco Quality Municipal Income Trust
811-06591
Invesco Quality Municipal Investment Trust
811-06346
Invesco Quality Municipal Securities
811-07560
Invesco Van Kampen Advantage Municipal Income Trust II
811-07868
Invesco Van Kampen California Value Municipal Income Trust
811-07404
Invesco Van Kampen Massachusetts Value Municipal Income Trust
811-07088
Invesco Van Kampen Municipal Opportunity Trust
811-06567
Invesco Van Kampen Municipal Trust
811-06362
Invesco Van Kampen Ohio Quality Municipal Trust
811-06364
Invesco Van Kampen Pennsylvania Value Municipal Income Trust
811-07398
Invesco Van Kampen Select Sector Municipal Trust
811-08000
Invesco Van Kampen Trust for Insured Municipals
811-06472
Invesco Van Kampen Trust for Investment Grade Municipals
811-06471
Invesco Van Kampen Trust for Investment Grade New Jersey Municipals
811-06536
Invesco Van Kampen Trust for Investment Grade New York Municipals
811-06537
Invesco High Yield Investments Fund, Inc.
811-08044
Invesco Van Kampen High Income Trust II
811-05769
Dear Mr. Long:
This letter is to follow up on our telephone conversation on July 20, 2011, in which we
discussed the comments you provided on the financial statements (and certain related materials)
filed with the U.S. Securities and Exchange Commission (“SEC”) for the open-end and closed-end
Invesco Funds, excluding the variable insurance funds (collectively, the “Registrants” or the
“Invesco Funds”). We have provided our responses below. References in this letter to the views
and beliefs of “the Staff” are to those views and beliefs expressed in your comments regarding the
financial statements of the Invesco Funds. References to “we” or “Invesco” are to Invesco Funds.
Comment 1
SEC Comment: The Staff asked what affect Ambac Financial Group, Inc.’s Chapter 11
bankruptcy filing in November 2010 had on guarantees or credit enhancements of holdings of the
Invesco Funds, such as the Invesco Van Kampen Select Sector Municipal Trust.
Invesco Response: By the time Ambac filed for bankruptcy, Invesco had already fully
discounted any value ascribed to Ambac’s guarantees or credit enhancements. Therefore, the Ambac
bankruptcy had a de minimis affect on the valuations of holdings of the Invesco Funds, such as the
Invesco Van Kampen Select Sector Municipal Trust.
Comment 2
SEC Comment: The Staff noted that in the Management’s Discussion of Fund Performance
section of the Annual Report (“MDFP”) for the Closed-End Funds (“CEFs”), the benchmark returns were
disclosed in some but not in all MDFPs. The Staff suggested that the inclusion of the benchmark
returns be included or excluded consistently across all the MDFPs for the CEFs.
Invesco
Response: Invesco intends to include benchmark information in all MDFPs for the CEF’s annual report going forward.
Comment 3
SEC Comment: Regarding the Invesco Insured Municipal Trust, Invesco Insured Municipal
Bond Trust, Invesco California Quality Municipal Securities, and Invesco Van Kampen High Yield
Municipal Fund, the Staff asked why the “Other Expense” line item in each of the Income Statements
for the period-ended February 28, 2011 contains negative amounts.
Invesco
Response: With respect to the Invesco Insured Municipal Trust, Invesco Insured Municipal Bond Trust, and Invesco California Quality Municipal Securities, “Other Expenses” for the period ended February 28, 2011 included an
adjustment for a change in accounting estimate for professional
services fees during the period. Please note that the financial highlights for these three funds included a footnote disclosing the change in accounting estimates and its impact.
With respect to the Invesco Van Kampen High Yield Municipal Fund, “Other Expenses” for the period ended February 28, 2011, included an adjustment in accrual balances as a result of a one-time change in fiscal year-end.
Page 2 of 7
Comment 4
SEC Comment: The Staff commented that the legal expenses related to lawsuits
involving certain CEFs appear to have been excluded from the expense limitation. The Staff
provided the example of Invesco Municipal Premium Income Trust, which reported $502,743 in related
legal expenses during the February 28, 2011 fiscal period and had a contractual expense limit of
1.03% in effect and a higher total expense ratio. The Staff requested the basis for the legal
expenses exclusion from the expense limit. The Staff recommended that such exclusions be clearly
and expressly drafted in the agreement to limit expenses paid by the fund.
Invesco Response: The parties to the contractual agreement to limit expenses paid by
the Funds are under the common understanding that litigation expenses are one of the types of
expenses that are excluded from the contractual expense limitation as “non-routine or
extraordinary.” Upon the next review of the contract, we will consider clarifying the contract and
make any appropriate changes to the disclosure language accordingly.
Comment 5
SEC Comment: Regarding the Invesco Van Kampen Dynamic Credit Opportunities Fund, the
Staff requested details about the reimbursement by Van Kampen Advisors, Inc. of $2,209,166 “for an
economic loss due to a trading error” for the year-ended July 31, 2010 as reported in the Fund’s
Annual Report.
Invesco Response: The predecessor advisor to Invesco Van Kampen Dynamic Credit
Opportunities Fund did not exercise rights offered on a security for the Fund and thus lost out on
an opportunity for which the predecessor advisor paid into the Fund in the amounts disclosed.
Comment 6
SEC Comment: The Invesco Capital Development Fund held securities with valuations
categorized as level 3. The Staff noted the report did not contain a level 3 roll forward table
from period to period.
Invesco Response: The disclosure practice is to evaluate the materiality of the
disclosure for each fund and reporting period using quantitative and qualitative factors such as
the percentage and circumstances of level 3 holdings and activity, the type of fund and fund
strategy, historical practice and other information within the report. For the period ended
October 31, 2010, the Fund did not meet the thresholds of the Funds’ internal disclosure policy for
including a level 3 roll forward table.
Comment 7
SEC Comment: Please explain why expenses of money market fund investments made by
Invesco Commodities Strategy Fund are not reflected in the acquired fund fees and expenses line
item in the November 20, 2010 prospectus fee table.
Page 3 of 7
Invesco Response: All money market fund investments made by Invesco Commodities
Strategy Fund are made in affiliated money market funds. An amount of the advisory fee charged by Invesco
to Invesco Commodities Strategy Fund is contractually waived to the extent that an advisory fee is
collected from the Invesco affiliated money market fund for these
investments. Therefore, the acquired fund fees after a reduction for
the waiver is reflected in the acquired fund fees and expenses
line item in the Invesco Commodities Strategy Fund. Because the acquired fund fees and expenses,
after the waiver, were less than 1 basis point, they are not reflected in the expense line item in
the November 20, 2010 prospectus fee table.
Comment 8
SEC Comment: Regarding the Invesco Balanced Risk Allocation Fund and Invesco Van
Kampen Government Securities Fund, the Staff noted that the Income Statements reported realized
gains/losses from swap agreements for the period-ended October 31, 2010. The Staff questioned
whether the principal strategy section of the prospectuses should have a fuller disclosure
regarding the use of swap agreements. Furthermore, the Staff said the MDFP section of each fund
did not include a discussion on the effects and use of swap agreements.
Invesco Response: Regarding the Invesco Van Kampen Government Securities Fund, the
“performance summary section” in the MDFP for the period-ended September 31, 2010 stated that the
Fund “underperformed the Fund’s broad market/style-specific index due mainly to yield curve
positions, using interest rate swaps and exposure to non-U.S. sovereign guaranteed paper which is
no longer held in the portfolio.” The information was reiterated in the “Market conditions and
your Fund” section of the MDFP: “Its underperformance can be largely attributed to yield curve
positions using interest rate swaps and exposure to non-U.S. sovereign guaranteed paper, both of
which are no longer held in the portfolio.” In consideration of the discontinued use of swap
agreements prior to the period-end and the discussions that existed in the MDFP, we believe the
disclosure was appropriate. Furthermore, the Invesco Van Kampen Government Securities Fund has
since been reorganized into another Invesco Fund and no longer maintains an effective N-1A
prospectus.
Regarding the Invesco Balanced Risk Allocation Fund, the MDFP for the period-ended October 31,
2010 stated the Fund may invest in swap agreements, including total return swaps. Additional
details concerning the use of swap agreements are disclosed in the Annual Report’s Consolidated
Schedule of Investments listing the swap agreements at the year-end, the Consolidated Statement of
Assets and Liabilities, and the Consolidated Statement of Operations. Furthermore, Note 1.K.
entitled “Swap Agreements” in the Notes to Consolidated Financial Statements provides detailed
explanations and disclosure. Nevertheless, in light of increased industry focus on derivatives, we
are considering adding or modifying language prospectively in the MDFP regarding the use of
derivatives, including swaps, to affect performance.
We believe that the disclosures in the principal strategy sections of the prospectuses for
both funds, which were reviewed by the SEC examiner, were also appropriate. In light of increased
industry focus on derivatives, however, we are reviewing derivatives disclosures across the Invesco
Funds complex and considering whether modifications or enhancements are appropriate.
Page 4 of 7
Comment 9
SEC Comment: Regarding the Invesco High Yield Securities Fund and Invesco Van Kampen
High Yield Fund, the Staff believes that the Lipper High Current Yield Bond Funds Index does not
qualify as a broad-based index to be used as a benchmark for these Funds as stated in the “Results
of a $10,000 Investment” line graph in the Annual Reports.
Invesco Response: Going forward, the Invesco High Yield Securities Fund will use the
Barclays Capital U.S. Corporate High Yield 2% Issuer Cap Index, which is its broad-based index, as
well as the Lipper High Current Yield Bond Fund Index in its “Results of a $10,000 Investment”
chart.
Note that the Invesco Van Kampen High Yield Fund has been reorganized into another Invesco
Fund and no longer maintains an effective N-1A prospectus.
Comment 10
SEC Comment: Regarding the return of capital in the Invesco Van Kampen Equity Premium
Income Fund, the Staff sought confirmation that the requirements of Rule 19a-1 under the Investment
Company Act of 1940 were met.
Invesco Response: We believe the requirements of Rule 19a-1 under the Investment
Company Act of 1940 were met by Invesco Van Kampen Equity Premium Income Fund. Note that the
Invesco Van Kampen Equity Premium Income Fund has been reorganized into another Invesco Fund and no
longer maintains an effective N-1A prospectus.
Comment 11
SEC Comment: Regarding the Invesco Van Kampen Pennsylvania Tax Free Income Fund, the
Staff noted that the current prospectus states that “[t]he Fund does not purchase securities that
are in default or rated in categories lower than B- by Standard and Poor’s (S&P) or B3 by Moody’s
Investors Service, Inc. (Moody’s) or unrated securities of comparable quality.” The Staff also
noted that the current MDFP states the portfolio composition to be 29.7% in “[n]on-rated
securities.” The Staff requested that we provide an explanation reconciling these two statements.
Invesco Response: The Fund invests in securities that are rated as B- or above as
well as non-rated securities of comparable quality as determined by Invesco. The 29.7% of
“non-rated securities” as disclosed in the MDFP were deemed to be securities of quality comparable
to B- or above.
Comment 12
SEC Comment: Regarding the Invesco Van Kampen Pennsylvania Tax Free Income Fund
Annual Report for the period-ended August 31, 2010, the Staff commented that schedule of
investments listed “100.1%” investments in municipal bonds and 93.1% investments in the region of
Pennsylvania. The Staff believes that
Page 5 of 7
the portfolio holdings should be further broken down by industry based on the Staff’s
interpretation of Rule 12-12 of Regulation S-X.
Invesco Response: The disclosure practice for state-specific municipal funds is to
categorize investments on the Schedule of Investments by the type of investment and the geographic
region of the investment. We also disclose in the MDFP, the portfolio composition categorized by credit sector.
Nevertheless, we are considering the Staff’s comment to prospectively break down the
investments by industry in the Schedule of Investments.
Comment 13
SEC Comment: Regarding the Invesco High Yield Securities Fund amended Forms N-SAR and
N-CSR for the period-ended August 31, 2010, the Staff commented on the “errors in the
classification of income and realized gains from investment securities and the change in unrealized
appr