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CORRESP
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CORRESP

 VIA EDGAR

July 24, 2014

 Mr. Jeff Long

Ms. Christina Fettig

 Division of Investment Management

Securities and Exchange Commission

 100 F Street, N.E.

Washington, DC 20549

Re:
AIM Funds Group (Invesco Funds Group), AIM Growth Series (Invesco Growth Series), AIM Investment Securities Funds (Invesco Investment Securities Funds), AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds), AIM Sector
Funds (Invesco Sector Funds), AIM Counselor Series Trust (Invesco Counselor Series Trust), AIM Treasurer’s Series Trust (Invesco Treasurer’s Series Trust), Short-Term Investments Trust, AIM Equity Funds (Invesco Equity Funds), AIM
International Mutual Funds (Invesco International Mutual Funds), AIM Investment Funds (Invesco Investment Funds), Invesco Securities Trust, Invesco Exchange Fund, Invesco Advantage Municipal Income Trust II, Invesco Bond Fund, Invesco California
Value Municipal Income Trust, Invesco Dynamic Credit Opportunities Fund, Invesco High Income Trust II, Invesco Municipal Income Opportunities Trust, Invesco Municipal Opportunity Trust, Invesco Municipal Trust, Invesco Pennsylvania Value Municipal
Income Trust, Invesco Quality Municipal Income Trust, Invesco Senior Income Trust, Invesco Senior Loan Fund, Invesco Trust for Investment Grade Municipals, Invesco Trust for Investment Grade New York Municipals and Invesco Value Municipal Income
Trust (each, a “Trust” and collectively, the “Trusts”)/(I/C File Nos. 811-01540, 811-02699, 811-05686, 811-07890, 811-03826, 811-09913, 811-05460, 811-02729, 811-01424, 811-06463, 811-05426, 811-22793, 811-02611, 811-07868,
811-02090, 811-07404, 811-22043, 811-05769, 811-05597, 811-06567, 811-06362, 811-07398, 811-06591, 811-08743, 811-05845, 811-06471, 811-06537, 811-06590, respectively).

Financial Statement Review

 Dear Mr. Long and
Ms. Fettig:

 On behalf of the Trusts, thank you for speaking with us on February 27, 2014 about the Trusts’ financial
statements dated as of December 31, 2012, February 28, 2013, April 30, 2013, August 31, 2013 and October 31, 2013 (each, a “Financial Statement” and collectively, the “Financial
Statements”). In furtherance of our discussions, set forth below are our responses to the oral comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) regarding the Financial Statements. (For your convenience, we have restated your oral comments below, followed by our written responses.)

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1.
Filing History

i.
Comment: An amended N-CSR was filed for the AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) and AIM Counselor Series Trust (Invesco Counselor Series Trust) on July 5, 2013 and November 8, 2013,
respectively, in order to modify certain information replying to Item 1. Please explain what information was changed and state whether modified reports were mailed to fund shareholders.

Response: The N-CSRs were amended to correct the total return numbers provided for style-specific benchmarks included in the average
annual total returns charts for certain funds. The corrected information was distributed to Fund shareholders and posted to the fund website.

ii.
Comment: An amended N-CSR was filed for the Invesco Senior Loan Fund on May 9, 2013 in order to modify certain information replying to Item 1. Please explain what information was changed and state
whether modified reports were mailed for fund shareholders. Going forward, please include a separate correspondence or cover letter to describe these types of changes.

Response: The N-CSR was amended to include five full years of audited information in the financial highlights section. The corrected
information was distributed to fund shareholders and posted to the fund website. Going forward, we will consider including additional correspondences to describe these types of changes.

2.
Management’s Discussion of Fund Performance

i.
Comment: In the Management’s Discussion of Fund Performance, the Invesco Gold and Precious Metals Fund has an index that is referred to as a “price only index.” Please describe that term. Also,
please address why it is not appropriate to provide an index that includes reinvested dividends.

 Response: A
‘price only index’ is an index showing a normalized average of prices for a given class of goods or services in a given region during a given interval of time. We believe it is appropriate to disclose the ‘price only index’ for
this Fund because it provides historical data over the life of the Fund while the total return version of the index does not have sufficient historical data.

3.
Average Annual Total Returns Chart

i.
Comment: Going forward, consider disclosing the returns of the fund benchmark in the average annual total returns chart for open-end funds for the standard time periods.

Response: We have considered the benchmark disclosure in light of this comment and have determined that we will continue to disclose
fund benchmarks in a manner that is compliant with regulatory requirements.

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4.
Schedule of Investments

i.
Comment: The Invesco Gold and Precious Metals Fund discloses 63.27% of its assets in Canadian holdings as of April 30, 2013. Please confirm that the prospectus references the concentration of country risks.

 Response: Going forward we will add a risk related to geographic concentration.

ii.
Comment: The Invesco Pacific Growth Fund discloses 50.38% of its assets in Japanese holdings as of October 31, 2013. Please confirm that the prospectus references the concentration of country risks.

 Response: The prospectus includes disclosure related to the risks of investing foreign securities and also discusses
the risks of geographic concentration.

iii.
Comment: For the Invesco Exchange Fund, the sum of individual holdings accounting for more than 5% of its portfolio exceeds 50%. Please confirm that the Fund meets the tax diversification requirements of
Subchapter M of the Internal Revenue Code for registered investment companies.

 Response: The Fund is treated as a
partnership for U.S. federal income tax purposes and therefore is not subject to the tax diversification requirements of Subchapter M of the Internal Revenue Code for registered investment companies.

iv.
Comment: The Invesco Balanced-Risk Allocation Fund discloses swap agreement holdings. Consider identifying the type of swap agreement going forward.

Response: The financial statements include a derivatives table for swap agreements which specifically states the type of swap
agreement, the primary risk exposure, as well as collateral held, if any.

v.
Comment: Certain funds (e.g. Invesco Senior Income Trust and Invesco Floating Rate Fund) invest in PIK bonds. Going forward, please disclose the cash portion of the interest rate separate from the in-kind portion
of the interest rate.

 Response: Going forward, we will disclose the cash portion of the interest rate for PIK bonds
separate from the in-kind portion.

vi.
Comment: The Invesco Balanced-Risk Retirement Now Fund, Invesco Balanced-Risk Retirement 2020 Fund and Invesco Balanced-Risk Retirement 2030 Fund each disclose large holdings (60.16%, 87.70% and 78.90%
respectively, as of December 31, 2012) in the Invesco Balanced-Risk Allocation Fund. Please confirm whether shareholders of the Retirement Funds are sent a copy of or link to the shareholder report for the Invesco Balanced-Risk Allocation Fund.

 Response: The shareholder reports of the Retirement Funds include a discussion of the risks and strategies of the
Invesco Balanced-Risk Allocation Fund as well as a description of the fund-of-funds structure and disclosure that the financial statements of the underlying funds are publicly available. Shareholders of the Retirement Funds are not specifically sent
a copy of or link to the shareholder report for the Invesco Balanced-Risk Allocation Fund, but the report is available on Invesco’s public website.

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5.
Statement of Assets and Liabilities

i.
Comment: Going forward, please consider breaking out amounts payable to affiliates.

Response: We consider the materiality of the individual components that make up the amounts payable to affiliates when determining
whether to break them out individually and will continue to do so going forward. We believe this complies with GAAP.

ii.
Comment: Please include a line item for ‘commitments and contingent liabilities’ and a reference on the balance sheet amount to details in the financial statement pursuant to Rule 6-04(15) of Regulation
S-X. See, for example, the Invesco Technology Fund.

 Response: The amount of the commitment is disclosed as a
footnote to the Schedule of Investments. The amount of the commitment is not material and does not meet the criteria for accrual under GAAP, therefore we do not include a line item on the balance sheet.

6.
Statement of Operations

i.
Comment: For closed-end funds, under Expenses, please review whether individual expenses in the ‘Interest, facilities and maintenance fees’ category total greater than 5% of total expenses. If so, break
out the expense separately or consider breaking out the components of interest, facilities and maintenance fees in the footnotes.

Response: None of the components, other than interest, are greater than 5% of total expenses. Currently, the interest, facilities and
maintenance fees line item represents the aggregate costs incurred by a fund due to the use of leverage, which we believe represents the costs incurred due to financing and provides clarity to the reader of the financial statements. Under the
significant accounting policy section of the notes to the financial statements, a description of the nature of the specific services included in the interest, facilities and maintenance section line item is provided for each fund. Going forward, we
will consider breaking out the components in the Notes to Financial Statements if any exceed 5% of total expenses.

7.
Financial Highlights

i.
Comment: For the Invesco Balanced-Risk Allocation Fund, note (e) in the October 31, 2013 report describes a revision to the portfolio turnover rate. Please describe how this calculation was revised.

 Response: The calculation of the portfolio turnover rate presented in the October 31, 2011 annual report
incorrectly included in the monthly average value of portfolio securities (denominator) securities whose maturities or expiration dates at the time of acquisition were one year or less. Such securities were correctly excluded from the amounts of
purchases and sales (numerator). Commencing with the April 30, 2012 semiannual report, the calculation of the October 31, 2011 portfolio turnover was revised to more appropriately exclude these items from both the numerator and the
denominator. As the staff has noted, this revision was disclosed in a footnote to the financial highlights.

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ii.
Comment: For the Invesco Low Volatility Equity Yield Fund, the portfolio turnover rate for 2012 was 45% while the rate for 2013 was 107%. Please confirm the Fund’s policy for compliance with Item 16(e)
of Form N-1A.

 Response: We confirm that the Statement of Additional Information for the Fund provides the reason for
the Fund’s significant variation in portfolio turnover rate pursuant to Item 16(e) of Form N-1A.

8.
Notes to Financial Statements

i.
Comment: Note 1 describes federal income taxes. Please consider expanding the disclosure going forward to be more consistent with sample guidance in the AICPA Audit Guide for Investment Companies, Chapter 7,
Section 194.

 Response: Going forward, we will expand the policy note for federal income taxes to more closely
follow the example in the AICPA Audit Guide for Investment Companies, Chapter 7, Section 194.

ii.
Comment: Note J describes foreign currency transactions and states that certain foreign securities may be subject to foreign taxes. Going forward for funds that pay such taxes and where such taxes are disclosed,
please state specific taxes paid.

 Response: Each fund discloses such taxes, if any, in the Statement of Operations.
Going forward, we will enhance the footnote disclosure to the extent a fund is subject to foreign taxes.

iii.
Comment: With respect to the description of derivatives in the notes, please use more specificity when describing what investments a particular fund made during the period.

Response: For funds with significant derivatives usage, the use of specific derivatives and their impact on the funds’
performance, as well as the risks associated with investing in derivatives, is disclosed in the fund’s Management’s Discussion of Fund Performance section. Schedules of derivatives holdings at period end categorized by risk type are
included with the Schedule of Investments. Current balances and activity for the types of derivatives in which a fund invested during the reporting period are included on the Statement of Assets and Liabilities and Statement of Operations,
respectively. The Notes to the Financial Statements further describe the risks of the types of derivatives used by the funds. The derivatives tables included in the notes to the financial statements specifies the type of derivatives, collateral
held, if any and the type of investment risk . We believe the funds’ disclosures comply with GAAP requirements.

iv.
Comment: With respect to funds that use swap agreements, note 1 for swap agreements states that “[t]he Fund segregates liquid securities having a value at least equal to the amount of the potential
obligation of a Fund under any swap transaction.” Please describe what is meant by the phrase ‘potential obligation.’

Response: The term ‘potential obligation’ means the net amount owed (if any) under the swap contract determined on a daily
marked-to-market basis, provided that the swap agreement requires netting. For swaps whose ISDAs do not require netting, ‘potential obligation’ means the notional amount of the swap contract.

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v.
Comment: For the Invesco High Yield Fund, please confirm that the Fund covers the full notional value of written credit default swaps.

Response: Yes, we confirm that the Invesco High Yield Fund covers the full notional value of written credit default swaps.

vi.
Comment: For any fund that invests in total return swaps as part of its principal investment strategies, please add disclosure addressing costs embedded in such swaps, such as third party management fees, and add
an explanatory line to the fee table, as applicable.

 Response: We considered the sample fee table disclosure of the
Insignia Macro Fund suggested by the Staff and note that the footnotes in that document indicate that the fund invests through swap agreements in underlying funds managed by commodity trading advisors. The fees charged by those commodity trading
advisors for management and performance are embedded in the swap agreements. Invesco funds do not currently use swaps to invest in underlying funds that charge management and performance fees in this manner. Thus, we do not believe our funds incur
this type of embedded costs. We will monitor swap agreement usage going forward and consider appropriate disclosure changes as needed.

vii.
Comment: Going forward, in Note 2, for funds with tiered advisory fee rates, please consider disclosing the effective fee rate paid.

Response: We will include the disclosure going forward.

viii.
Comment: Going forward, if fees waived are subject to recapture, disclose the recapture arrangement.

Response: Waived fees are not subject to recapture after a fiscal period end.

ix.
Comment: Going forward, consider adding more detail regarding fee rates for affiliated services such as transfer agency and administrative services.

Response: While we believe that we are in compliance with the Form N-1A Item 19(d), instruction No. 1 (and, for the
closed-end funds, Form N-2, Items 20(4) and (8)) requirements for disclosure of affiliated services, we will review our disclosure goin