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            2005 Market Street

            Suite 2600

            Philadelphia, PA 19103

              T: 215.564.8000

            Jonathan M. Kopcsik

            jkopcsik@stradley.com

            215.564.8099

    July 9, 2025

    VIA EDGAR TRANSMISSION

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, DC  20549

    Filing Desk

    Attn: Kalkidan Ezra

            Re:

            Delaware Group® Adviser Funds (File No. 811-07972)

            Delaware Group Cash Reserve (File No. 811-02806)

            Delaware Group Equity Funds II (File No. 811-00750)

            Delaware Group Equity Funds IV (File No. 811-04413)

            Delaware Group Equity Funds V (File No. 811-04997)

            Delaware Group Global & International Funds (File No. 811-06324)

            Delaware Group Government Funds (File No. 811-04304)

            Delaware Group Income Funds (File No. 811-02071)

            Delaware Group Limited-Term Government Funds (File No. 811-03363)

            Delaware Group State Tax-Free Income Trust (File No. 811-02715)

            Delaware Group Tax-Free Fund (File No. 811-03850)

            Delaware Pooled® Trust (File No. 811-06322)

            Delaware VIP® Trust (File No. 811-05162)

            Ivy Funds (File No. 811-06569)

            Ivy Variable Insurance Portfolios (File No. 811-05017)

            Voyageur Mutual Funds (File No. 811-07742)

            Voyageur Mutual Funds II (File No. 811-04989)

            Voyageur Tax Free Funds (File No. 811-03910)

            Comments on Preliminary Proxy Materials for Special Shareholder Meeting

    Ms. Ezra:

    On behalf of the above-referenced Registrants and their respective series therein (each a “Fund” and collectively, the “Funds”), the following are the Registrants’ responses to the comments of the staff (the “Staff”) of the U.S. Securities and
      Exchange Commission (the “SEC”) communicated telephonically on June 30, 2025 with respect to the Registrants’ joint preliminary proxy statement, which was filed on June 20, 2025 (the “Proxy Statement”).  Each Staff comment is summarized below,
      followed by the Registrants’ response to the comment. Any capitalized terms used herein that are not defined have the same meaning as in the Proxy Statement.

      Stradley Ronon Stevens & Young, LLP  |  stradley.com

      Chicago  |  Los Angeles  |  New York  |  Philadelphia  |  Washington, D.C.

      Kalkidan Ezra

      July 9, 2025

      Page 2

            1.

            Comment: Review and revise, if necessary, the Proxy Statement to ensure that all hyperlinks are active.

            Response: The Funds will ensure that all hyperlinks are active for the definitive version of the Proxy Statement.

            2.

            Comment: Under the heading “What is the Transaction and why am I being asked to vote?” in the Q&A section, clarify that shareholders are not being asked to vote on the transaction itself, but only on the proposal to approve a
              new advisory contract with Delaware Management Company (the “Proposal”).

            Response: The Funds will make the requested change.

            3.

            Comment: Under the heading “Introduction” in the discussion of the Proposal, if applicable, disclose with as much precision as possible the estimated monetary benefit to be received by the Funds’ interested Trustees in connection
              with the Transaction.

            Response: The Funds will add the following disclosure at the end of the last paragraph of that section: “Mr. Lytle may be considered to have a material interest in the Transaction and approval of the New Investment Advisory
              Agreements because he will receive substantial amounts in the form of closing and retention payments if the Transaction closes. The Funds do not bear any of the costs related to such payments.”

            4.

            Comment: Under the heading “Board Considerations in Approving the Proposed New Investment Advisory Agreements”, supplementally confirm that all of the interim advisory agreements may be terminated on 10 days written notice by the
              Board and if so, disclose this information in the Proxy Statement.

            Response: The Funds so confirm and will include the requested information in the Proxy Statement.

            5.

            Comment: Provide a completed proxy card for the Ivy Funds registrant with the Funds’ comment-response letter.

            Response: A copy of the final version of a proxy card for the Ivy Funds is attached as Exhibit A to this letter.

            6.

            Comment: Provide a written response letter to the Staff’s comments and a redline comparing the Proxy Statement to a revised version that reflects the Staff’s comments, five business days before mailing the Proxy Statement.

      Kalkidan Ezra

      July 9, 2025

      Page 3

            Response: The Funds undertake to do so.

    * * *

    Please direct questions or comments relating to this filing to me at the above-referenced telephone number or Taylor Brody at (215) 564-8071.

    Sincerely,

    /s/Jonathan M. Kopcsik

    Jonathan M. Kopcsik

              cc:

                Emilia Wang, Esq.

               Macquarie Asset Management

      Kalkidan Ezra

      July 9, 2025

      Page 4

    EXHIBIT A

    IVY FUNDS PROXY CARD