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CORRESP
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    June 2, 2023

    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 Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686); AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) (File No.
              811-07890); AIM Investment Funds (Invesco Investment Funds) (File No. 811-05426); AIM Treasurer’s Series Trust (Invesco Treasurer’s Series Trust) (File No. 811-05460); Short-Term Investments Trust (File No. 811-02729); and Invesco Management
              Trust (File No. 811-22957) (each, an “OEF Registrant” and collectively, the “OEF Registrants”); and Invesco Dynamic Credit Opportunity Fund (File No. 811-23665) (a “CEF Registrant”); and Invesco Exchange-Traded Fund Trust (File No.
              811-21265); Invesco Exchange-Traded Fund Trust II (File No. 811-21977); and Invesco Actively Managed Exchange-Traded Fund Trust (File No. 811-22148) (each, an “ETF Registrant” and collectively, the “ETF Registrants” and together, with the OEF
              Registrants and CEF Registrant, the “Registrants”)

    Dear Mr. Manion:

    On behalf of the Registrants and each respective series of the Registrants listed in Exhibit A, as applicable (each such mutual fund or ETF, 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 and Exchange Commission (the “Commission” or “SEC”) to the undersigned on April 4, 2023, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR and the
      annual reports on Form N-CEN 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.

            I.

            FORM N-CSR COMMENTS

            1.

            Comment:

            The annual report for each of the following Funds states that the Fund is non-diversified:  Invesco Gold & Special Minerals Fund, Invesco American Franchise Fund, Invesco International BuyBack Achievers ETF
              and Invesco MSCI Global Timber ETF.  Please confirm such Funds continue to qualify as non-diversified funds, and also please identify the compliance testing performed to monitor each Fund’s diversification status.  The Staff reminds the
              Registrants that if any such Fund has been operating as diversified for more than three years, the Fund would be required to obtain shareholder approval prior to changing its operating status back to non-diversified.

            Response:

            Each of Invesco Gold & Special Minerals Fund, Invesco American Franchise Fund, International BuyBack Achievers ETF and Invesco MSCI Global Timber ETF, continues to qualify as a non-diversified fund.  The compliance department of the
              respective Funds’ adviser monitors the diversification status of each Fund on a daily basis. If, in the future, a Fund were to operate in a diversified manner continuously for a
              three-year period, we confirm that such Fund would seek shareholder approval prior to changing its operating status back to non-diversified, unless the Fund could rely on the no-action letter issued to Stradley Ronon Stevens & Young, LLP
              on June 24, 2019.

            2.

            Comment:

            Certain Funds, such as Invesco Equity and Income Fund and Invesco Growth and Income Fund, report foreign tax reclaim income in such Funds’ annual reports.  Please discuss the accounting and disclosure practices
              with regard to foreign tax reclaims, including whether closing agreements with the IRS were reached, whether the netting method was applied and whether professional or compliance fees were incurred.

            Response:

            The Registrant’s policy is to record foreign tax reclaims when they satisfy the “more likely than not” criteria under Accounting Standards Codification No. 740. In the event that tax refunds received during the year exceed the foreign
              withholding taxes paid by a Fund for the year, and the Fund previously passed foreign tax credits on to its shareholders, the Funds intend to enter into closing agreements with the IRS in order to pay the associated tax liability on behalf of
              the Funds’ shareholders. The Funds disclose the following  with respect to foreign tax reclaims: (i) presenting separately tax reclaims in accordance with Regulation S-X 6-07, IRS closing agreement fees, if any, as contra-income and any
              associated fees as Professional fees within the Statement of Operations, (ii) presenting a receivable for the refunds and payable for any fees, if any, within the Statement of Assets and Liabilities and (iii) including footnote disclosure
              regarding impacts to total return and/or net investment income ratios/per share values within the Financial Highlights, if deemed material.

            Invesco Equity and Income Fund and Invesco Growth and Income Fund followed the disclosure practice outlined above. The tax refunds received did exceed foreign withholding taxes paid for the year, however neither Fund entered into an IRS
              closing agreement because they did not previously pass foreign tax credits on to its shareholders for the years related to the refund. Additionally, no professional or compliance fees were incurred.

            3.

            Comment:

            Certain Funds, such as Invesco Core Plus Bond Fund and Invesco Floating Rate ESG Fund, disclose “investments matured” in the financial statements that are shown outside of the investments sold receivables line
              item.  Please discuss in correspondence the nature of these investments, including the nature of the principal or income associated with such investments.

            Response:

            The Registrant confirms that the Receivable for Investments Matured line item represents securities which have yet to return principal amounts and have exceeded their stated maturity date prior to financial statement date. All but one of
              the securities were in a default status and were no longer accruing interest income. One security was not considered to be in a default status and continued to accrue interest income as the issuer had not missed any interest payments. With respect to these securities, the practice is to disclose the value of such securities as a receivable for investments matured until final principal payments are received. The securities continue to
              be marked to market but are no longer included on the Schedule of Investments as they have reached their maturity date.  Additionally, the securities continue to be monitored for collectability of both principal and interest.  If any future
              payments of principal and/or interest are

            deemed to be uncollectable, the Registrant will write off any remaining interest receivables or principal balances.

            4.

            Comment:

            Please consider adding additional disclosure related to when the Funds incur domestic and foreign currency overdrafts, including the terms of the overdraft (e.g., average interest rate, period of open overdraft,
              interest expense), as required by Regulation S-X 5-02(19)(b).

            Response:

            The Registrants have reviewed the applicable accounting guidance including the requirements of Regulation S-X 5-02(19)(b) and since any domestic and foreign currency overdrafts incurred by the Funds during the applicable fiscal years were
              not significant, we respectfully do not believe any additional disclosure is required.

            5.

            Comment:

            Performance shown for the new share classes of Invesco Dynamic Credit Opportunity Fund appear to be based on past performance of the predecessor closed-end fund’s common shares, which reorganized into Class AX
              shares of Invesco Dynamic Credit Opportunity Fund.  Consider adding additional disclosure regarding how performance was calculated for each of the Fund’s new share classes in the annual report.

            Response:

            The Registrant has added the requested disclosure.

            6.

            Comment:

            The following Funds appear to have had NAV errors during the reporting periods reviewed:  Invesco Gold & Special Minerals Fund, Invesco Global Listed Private Equity ETF, Invesco Floating Rate ESG Fund,
              Invesco MSCI Sustainable Future ETF, Invesco S&P 500 Equal Weight Technology ETF, Invesco Taxable Municipal Bond ETF, Invesco Total Return Bond ETF, Invesco SteelPath MLP Alpha Fund, Invesco SteelPath MLP Alpha Plus Fund, Invesco
              SteelPath MLP Income Fund and Invesco SteelPath MLP Select 40 Fund. Please describe the nature and circumstances of each NAV error, associated internal control implications, mitigating actions, and whether any related reprocessing or
              reimbursement has been completed.  Please include in your discussion citations to applicable GAAP and Regulation S-X requirements including as they pertain to financial statement requirements and disclosure regarding amounts reimbursed.

            Response:

            The Registrants note that the historical practice followed by the Registrants when reporting under Form N-CEN Item B.22 Net asset value error corrections, was to report any NAV error over $0.01 which resulted in the over-reporting of NAV
              errors in Form N-CEN in that errors were reported that did not result in reimbursement to shareholders or accounts being reprocessed. Effective with the December 31, 2022, Form N-CEN reporting, the Registrants revised this policy to only
              report NAV errors resulting in reimbursement to shareholders or accounts being reprocessed, in accordance with Form N-CEN Item B.22 instructions. With respect to the NAV errors for the Funds listed below, the NAV error did not breach the
              threshold outlined in the Registrants’ NAV error correction policy requiring account reprocessing or payments to shareholders, however a pay-in was made to each Fund to reimburse the Fund for any net loss in accordance with the Registrants’
              NAV error correction policy. For each instance, controls were reviewed and determined to be reasonable and were reinforced and/or enhanced to prevent recurrence, if needed. In accordance with Accounting Standards Codification No. 946, the
              Funds disclose amounts and circumstances of payments by affiliates to reimburse the Fund for losses on investment transactions in the financial statements, the notes to financial statements and the

            effect on total return on the financial highlights, if material.  None of the NAV errors listed below met the foregoing materiality threshold for disclosure.

            Fund Name

            Error Summary

            Invesco Floating Rate ESG Fund

            Corporate Action – A position that was recorded on the investment book of record was not recorded timely in the accounting book of record

            Invesco Global Listed Private Equity ETF

            Corporate Action – Incomplete instructions on a corporate action resulted in the event not being processed timely

            Invesco MSCI Sustainable Future ETF

            Trade Processing – A duplicated FX transaction was executed

            Invesco Gold & Special Minerals Fund

            Corporate Action – A security ID change was not identified timely causing an incorrect price being applied

            Invesco S&P 500 Equal Weight Technology ETF

            Income – Dividends on shares received from a merger were not booked timely

            Invesco Taxable Municipal Bond ETF

            Trade Processing – Variable fees on a cash creation order were not processed timely

            Invesco Total Return Bond ETF

            Trade Processing – A credit default swap trade was processed incorrectly

            The NAV errors reported within Form N-CEN for Invesco SteelPath MLP Alpha Fund, Invesco SteelPath MLP Alpha Plus Fund, Invesco SteelPath MLP Income Fund and Invesco SteelPath MLP Select 40 Fund were in connection with an NAV error and
              related remediation plan originally discussed in the Funds’ November 30, 2018 Amended Form N-CSR filed on March 30, 2020. Management determined that a material weakness related to the determination of the valuation allowance on deferred tax
              assets in accordance with Accounting Standards Codification No. 740, Income Taxes existed and resulted in a material NAV error.  As disclosed in the November 30, 2020 Form N-CSR, Management strengthened the Funds’ internal control over
              financial reporting and concluded that the material weakness was fully remediated. Although this error occurred in a prior year, the payments to impacted shareholders occurred during fiscal year ended November 30, 2021 and therefore were
              disclosed in the November 30, 2021 Form N-CEN to align with the instructions to include a response of Yes, if payments were made to shareholders during the period.

            7.

            Comment:

            Funds that invest in unfunded loan commitments, such as Invesco Dynamic Credit Opportunity Fund, appear to disclose such commitments on a gross basis for financial reporting purposes.  Please discuss in
              correspondence how the accounting for unfunded loan commitments is done in accordance with GAAP and the implications of Accounting Standards Codification No. 450 with regard to accounting and recording of contingencies.  Please also discuss
              whether management fees are paid based on gross assets.

            Response:

            The Registrant confirms that the unfunded commitments meet the accrual standard in accordance with Accounting Standards Codification No. 450, due to meeting the conditions of; availability of information before the financial statements are
              issued; probability that a liability has been incurred; and the amount can be reasonably estimated. The Notes to Financial Statements disclose the nature of the contingency as well as the amount and location of the

            accrued liability recorded in the Statement of Assets and Liabilities. With respect to management fees, the advisory agreement defines “Managed assets” as the Trust’s net assets, plus assets attributable to outstanding preferred shares and
              the amount of any borrowings incurred for the purposes of leverage (whether or not such borrowed amounts are reflected in the Trust’s financial statements for purposes of generally accepted accounting principles). The management fee
              calculation using the definition of Managed assets above are paid on the Trust’s net assets, which would result in the same fee whether the unfunded commitments were booked on a gross or net basis.

            8.

            Comment:

            It appears that cash collateral from the Funds’ securities lending activity is invested in private vehicles that operate like money market funds, and that these vehicles are categorized as Level 2 investments
              under Accounting Standards Codification No. 820.  In correspondence, please provide analysis as to how these vehicles count as collateral under Rule 18f-4 and/or whether these vehicles should be reported as Level 1 investments under
              Accounting Standards Codification No. 820.

            Response:

            The Registrants conf