SecProbe.io

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    May 17, 2022

    VIA EDGAR

    Mr. David Manion

    Division of Investment Management

    Securities and Exchange Commission

    100 F Street N.E.

    Washington DC  20549

            RE:

            AIM Counselor Series Trust (Invesco Counselor Series Trust) (File No. 811-09913); AIM Funds Group (Invesco Funds Group) (File No. 811-01540); AIM Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686); AIM
              Tax-Exempt Funds (Invesco Tax-Exempt Funds) (File No. 811-07890); AIM Sector Funds (Invesco Sector Funds) (File No. 811-03826); AIM Equity Funds (Invesco Equity Funds) (File No. 811-01424); AIM Investment Funds (Invesco Investment Funds)
              (File No. 811-05426); AIM International Mutual Funds (Invesco International Mutual Funds) (File No. 811-06463); AIM Growth Series (Invesco Growth Series) (File No. 811-02699); AIM Variable Insurance Funds (Invesco Variable Insurance Funds)
              (File No. 811-07452); Invesco Exchange Fund (File No. 811-02611) (each, an “OEF Registrant” and collectively, the “OEF Registrants”) and Invesco Advantage Municipal Income Trust II (File No. 811-07868), Invesco Bond Fund (File No. 811-02090),
              Invesco California Value Municipal Income Trust (File No. 811-07404), Invesco Dynamic Credit Opportunities Fund (File No. 811-22043), Invesco High Income 2023 Target Term Fund (File No. 811-23186), Invesco High Income 2024 Target Term Fund
              (File No. 811-23251), Invesco High Income Trust II (File No. 811-05769), Invesco Municipal Income Opportunities Trust (File No. 811-05597), Invesco Municipal Opportunity Trust (File No. 811-06567), Invesco Municipal Trust (File No.
              811-06362), Invesco Pennsylvania Value Municipal Income Trust (File No. 811-07398), Invesco Quality Municipal Income Trust (File No. 811-06591), Invesco Senior Income Trust (File No. 811-08743), Invesco Trust for Investment Grade Municipals
              (File No. 811-06471), Invesco Trust for Investment Grade New York Municipals (File No. 811-06537), Invesco Value Municipal Income Trust (File No. 811-06590) and Invesco Senior Loan Fund (File No. 811-05845) (each, an “CEF Registrant” and
              collectively, the “CEF Registrants” and together, with the OEF Registrants, the “Registrants”)

    Dear Mr. Manion:

    On behalf of the Registrants and each respective series of the Registrants listed in Exhibit A, as applicable (each, a “Fund,” and collectively, the “Funds”) this letter responds to comments provided by the staff of the Division of Investment
      Management (the “Staff”) of the Securities Exchange Commission (the “Commission” or “SEC”) to the undersigned on April 8, 2022, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR for the fiscal years ended on the
      dates listed in Exhibit A, as applicable.

    The Staff’s comments are summarized below in italicized text. The Registrants’ responses are set out immediately under the restated comment.

            1.

            Comment:

            Invesco Peak Retirement 2025 Fund, Invesco Peak Retirement 2030 Fund, Invesco Peak Retirement 2035 Fund and Invesco Peak Retirement 2040 Fund disclose the Bloomberg U.S. Aggregate Bond Index as each Fund’s
              broad-based benchmark index.  The Staff notes that over 50% of the underlying funds of such Invesco Peak Retirement Funds appear to be equity funds.  Please explain why the Bloomberg U.S. Aggregate Bond Index is an appropriate benchmark index
              for such Invesco Peak Retirement Funds in light of the Funds’ significant exposure to equities.

            Response:

            The Registrant believes the Bloomberg U.S. Aggregate Bond Index is an appropriate broad-based securities market index for the Invesco Peak Retirement 2025 Fund, Invesco Peak Retirement 2030 Fund, Invesco Peak Retirement 2035 Fund and
              Invesco Peak Retirement 2040 Fund (herein, the “Funds”) for purposes of comparing performance.  Form N-1A defines an appropriate broad-based securities market index as one administered by an organization that is not an affiliated person of
              the fund, its investment adviser, or principal underwriter, unless the index is widely recognized and used.1  The Commission has described such an index as “one that
              provides investors with a performance indicator of the overall applicable stock or bond markets, as applicable,” while also stating that a fund would have “considerable flexibility in selecting a broad-based index that it believes best
              reflects the market(s) in which it invests.”2  The Registrant believes the Bloomberg U.S Aggregate Bond Index meets the Form N-1A definition and is also one that provides investors in
              the Funds with a performance indicator of a relevant overall market.  The Funds are designed for investors expecting to retire in each Fund’s respective specified year in its name and/or begin to withdraw their retirement assets around that
              year.  While each Fund had exposure to more than 50% in underlying equity funds as of the most recent fiscal year end, each Fund’s portfolio also had significant exposure to non-equity funds, i.e., significantly in fixed income, as well as
              alternative and/or money market funds.  Each Fund’s principal investment strategy indicates in its prospectus that the Fund “follows a glide path that adjusts the combination of underlying funds to generally become more conservative over
              time, until the Fund reaches its destination point, which is approximately 15 years after the target retirement date stated in the Fund’s name.”  As investors’ appetite for risk tends to decline as they get closer to their specified target
              retirement date for these Funds – and the Funds’ portfolios gradually become more conservative - the Registrant believes it is reasonable to compare the Funds’ performance against a benchmark that represents the more conservative U.S.
              investment-grade, fixed income market.

          Importantly, we emphasize that the Funds also compare their performance against custom, style-specific benchmarks which are blended benchmarks composed of the following indexes:  Russell
            3000 Index, MSCI EAFE Index and the Bloomberg U.S. Aggregate Bond Index. The Registrant believes the full performance presentation meets the N-1A requirement, provides investors with a comprehensive picture regarding how each Fund’s performance
            compares against relevant indices, and is practically relevant and useful.

            2.

            Comment:

            Invesco Convertible Securities Fund appears to disclose convertible securities held by the Fund as Level 1 per the GAAP hierarchy and as referenced in Note 1

    1 N-1A Item 27(b)(7), Instruction 5.

    2 Tailored Shareholder Reports, Treatment of Annual Prospectus Updates for Existing Investors, and Improved Fee and Risk Disclosure for Mutual Funds and Exchange-Traded
      Funds; Fee Information in Investment Company Advertisements, Rel. No. 33-10814 (Aug. 5, 2020).

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            to the Financial Statements.  Please explain how these convertible securities were determined to be Level 1.

            Response:

            The Registrant notes that, as of December 31, 2021, a majority of the Fund’s portfolio, specifically $1,047,730,846, was comprised of securities that were determined to be Level 2 per the GAAP hierarchy.  The convertible securities held by
              the Fund were assigned as Level 2 due to the prices being determined using other significant observable inputs.  The Level 1 securities held by the Fund were primarily preferred stocks and money market funds which are listed on an exchange
              and the quoted prices are readily available. The Registrant has reviewed the language in Note 1 to the Financial Statements and will remove the parenthetical exception-based reference regarding convertible securities going forward.

            3.

            Comment:

            Invesco Convertible Securities Fund holds zero coupon convertible bonds with a 0.00% interest rate. Please explain the accounting for these instruments, including
                how portions of the discount are determined to be associated with the equity and fixed income components of the instrument.

            Response:

            Zero coupon convertible bonds do not accrue interest but do amortize and/or accrete premiums and discounts until call/conversion date. Upon conversion date, a new cusip and holding will be received by the Fund at which time it will be
              accounted for as an equity instrument.

            4.

            Comment:

            Invesco Global Core Equity Fund recorded a non-cash dividend of $579,721 in its Statement of Operations for the fiscal year ended December 31, 2021.  Please discuss the nature of this income (for example, is it
              warrants, rights, etc.).

            Response:

            This was the result of a special dividend paid by Constellation Software Inc. in the form of a dividend-in-kind of subordinate voting shares of Topicus.com for each common share of Constellation Software Inc. held on December 28, 2020 in
              connection with the acquisition by Constellation Software Inc. of 100% of the shares of Topicus.com.

            5.

            Comment:

            The disclosure in various annual reports provided in accordance with Accounting Standards Codification No. 815 (Derivatives and Hedging) indicates that notional value was used to determine the fair valuation of
              certain derivatives but does not indicate the frequency with which such value was determined.  Please consider adding in future shareholders reports the frequency of such determinations (e.g. daily, monthly, etc.).

            Response:

            The Registrants believe that the shareholder reports comply with Accounting Standards Codification No. 815 (Derivatives and Hedging) requirements of disclosure and that the current disclosure provides sufficient information to
              shareholders. The Registrants believe that including additional data points in the already lengthy disclosure may be confusing to shareholders, and therefore respectfully decline to make the change at this time.

            6.

            Comment:

            Invesco Oppenheimer V.I. International Growth Fund held a preferred interest in Zee Entertainment Enterprises Ltd. (“Zee”) as of December 31, 2021 with a par value of $599,541 and cost of $0.  Please discuss: 1)
              how the preferred holding was acquired and why no cost was assigned to it; and 2) why it was determined to be Level 1 per the GAAP hierarchy.

            Response:

            These are “Preference Shares” awarded by Zee to equity shareholders as a bonus at no cost to the equity shareholders and not purchased in the open

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            market, hence zero cost.  The security is valued as Level 1 because the security was readily available and priced on the Bombay Stock Exchange (BSE).

            7.

            Comment:

            For Funds that have a wholly-owned subsidiary (“Subsidiary”) organized under the laws of the Cayman Islands, please consider disclosing the percentage of net assets held in the Subsidiary and related current
              value rather than, or in addition to, the maximum percentage amount that could be invested in the Subsidiary.

            Response:

            The Registrants believe that the current disclosure complies with applicable requirements and provides sufficient information to shareholders. The Registrants fully consolidate the Subsidiary financial statements with the Fund’s financial
              statements and believe that including additional information about the Subsidiary may be confusing to shareholders, and therefore respectfully decline to make the change at this time.

            8.

            Comment:

            Please confirm whether Invesco Multi-Asset Income Fund and Invesco Income Advantage International Fund present equity-linked notes (“ELNs”) by issuer or underlying reference asset in the Schedule of Investments.
              If ELNs are presented by issuer, consider adding underlying reference asset in future shareholder reports.

            Response:

            The Registrants confirm that ELNs currently reference the issuer and not the underlying reference asset in the shareholder reports.  For future shareholder reports, the underlying reference asset will be included in the ELN security
              description on the Schedule of Investments.

            9.

            Comment:

            The registration statements for certain Funds were supplemented to add risk disclosure regarding Chinese variable interest entities (“VIEs”). Please explain why some Funds with exposure to China were not
              supplemented.

            Response:

            The Registrants confirm that risk disclosure regarding Chinese VIEs was added to all Funds with exposure to China.  For some Funds, the disclosure was incorporated into a Fund’s registration statement during its annual update as the timing
              of the supplement coincided with such Funds’ annual updates.

            10.

            Comment:

            Invesco Equally Weighted S&P 500 Fund’s financial statements for the prior fiscal year ended August 31, 2020, include the effect of an Adviser pay-in for an economic loss as a result of a delay in
              rebalancing to the index that occurred on April 24, 2020.  Please discuss: 1) how the error was detected and procedures put in place to mitigate re-occurrence; and 2) whether the error resulted in a net asset value (“NAV”) error and
              remediation to shareholders.

            Response:

            On April 24, 2020, S&P rebalanced the S&P 500 Equal Weight Index (the “S&P 500 EW Index”); such rebalancing had previously been scheduled for March 31, 2020 but was postponed due to market volatility and other circumstances
              surrounding the coronavirus pandemic.  The Fund’s portfolio managers did not realize the S&P 500 EW Index was rebalanced until April 29, 2020, at which time they promptly rebalanced the Fund’s portfolio accordingly.

            Shortly after the rebalancing error was identified, the Fund’s investment team implemented internal control and process enhancements designed to prevent the re-occurrence of the error.

            The Adviser decided to transition management of the Fund from the existing team to the investment team in Invesco Capital Management LLC’s (“ICM”) ETFs and Indexed Strategies Group. This change was effective on July 13, 2020.

            Upon assuming management of the Fund, ICM’s investment team immediately implemented its standard index fund management procedures and added the

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            Fund to its proprietary platform. ICM’s investment team has successfully rebalanced the Fund since assuming responsibility for its management.

            Finally, the Adviser’s Investment Risk Management team has enhanced its process for daily monitoring of active/excess returns and tracking error in passive funds.

            In addition to the trade error Adviser pay-in, Invesco remediated the Fund and certain shareholders who transacted in the Fund during the period consistent with the provisions of the Fund’s NAV Error Correction Policy.

            11.

            Comment:

            Certain Funds that hold Arkansas River Power Authority bonds disclose such bonds as issued by the state of Arkansas.  Please correct this in future shareholder reports.

            Response:

            The Registrants confirm that future shareholder reports will remove the reference indic