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    February 23, 2026

    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 International Mutual Funds (Invesco International Mutual Funds) (File No. 811-06463), AIM Investment Funds (Invesco Investment Funds) (File No.
              811-05426), AIM Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686), Invesco Management Trust (File No. 811-22957), AIM Sector Funds (Invesco Sector Funds) (File No. 811-03826), AIM Tax-Exempt Funds (Invesco
              Tax-Exempt Funds) (File No. 811-07890), AIM Treasurer's Series Trust (Invesco Treasurer's Series Trust) (File No. 811-05460), and Short-Term Investments Trust (File No. 811-02729), Invesco Actively Managed Exchange-Traded Fund Trust (File No.
              811-22148), Invesco Exchange-Traded Fund Trust (File No. 811-21265), Invesco Exchange-Traded Fund Trust II (File No. 811-21977), and Invesco Exchange-Traded Self-Indexed Fund Trust (File No. 811-23304), 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 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 Senior Loan Fund (File No. 811-05845), 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) (each, a “Registrant” and collectively, 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 January 16, 2026, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR and 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.

    Global Comments

            1.

            Comment:

            The N-CSR disclosure states, in the Notes to the Financials – Segment Reporting, that the Adviser will act as a Fund’s chief operating decision maker (“CODM”). Please consider naming the titles of the persons at
              the Adviser that comprise the “group” acting as the CODM. Alternatively, please explain how all personnel of the Adviser are considered a group for purpose of the CODM definition. See Accounting Standards Codification (ASC) 280-10-50-5.

            Response:

            The Registrants have revised the applicable disclosure to name the titles of the persons at the Adviser that comprise the group acting as the CODM. The revised disclosure is below (underlined language added):

            “Subject to the oversight and, when applicable, approval of the Board of Trustees, portfolio managers and senior executives at the Adviser act as the Trust’s chief operating decision maker (“CODM”), assessing performance and making
              decisions about resource allocation within the Trust.”

            2.

            Comment:

            The Funds’ N-CEN filings do not consistently report the Legal Entity Identifier (“LEI”) for each of the Funds’ custodians. Please include the LEI for the Funds’ custodians in future N-CEN filings.

            Response:

            The Registrants acknowledge that the LEI for certain sub-custodians was omitted from the Funds’ N-CEN filings and will be included in future filings.

            Fund Specific Comments

            3.

            Comment:

            Invesco Pennsylvania Municipal Fund appears to have had a net asset value (“NAV”) error during the fiscal year ended February 28, 2025. Please describe the nature and circumstances
                of the NAV error, associated internal control implications, mitigating actions, and whether any related reprocessing or reimbursement has been completed.

            Response:

            A NAV error occurred with respect to Invesco Pennsylvania Municipal Fund for one day due to the improper application of a valuation for a manually priced fixed income security. The error was identified the following day by the Registrant
              during the daily review of manually priced securities, a key control within the valuation process. Upon review, the controls were deemed reasonable and have been reinforced and, where necessary, enhanced to prevent recurrence. Shareholder
              redemptions were reprocessed and the third-party administrator reimbursed the Fund for losses associated with shareholder subscriptions affected by the error.

            4.

            Comment:

            The Schedule of Investments in the N-CSR filings for certain Funds, such as Invesco Limited Term Municipal Income Fund and Invesco Rochester Municipal Opportunities Fund, show that the Funds hold MuniFund
              Preferred Shares. The footnote related to the Funds’ MuniFund Preferred Share holdings does not disclose the applicable rates of those holdings. Please include such information in future N-CSR filings.

            Response:

            The applicable rates for MuniFund Preferred Shares held by the Funds will be included in future N-CSR filings, as requested.

            5.

            Comment:

            Certain Funds hold loans that are tied to an applicable reference rate; however, the rate shown in the financial statements does not tie to the applicable reference rate. For example, see X Corp. held by Invesco
              Corporate Bond Fund, Invesco High Yield Fund and Invesco Short-Term Bond Fund. Please explain how the rates shown in the financial statements were determined and how they reconcile to the applicable reference rates.

            Response:

            The Registrants acknowledge that although the reference rates disclosed within the Schedules of Investments were accurate, the end of period rate disclosed for certain loans was inadvertently understated. The end of period rate has been
              corrected within the Schedules of Investments issued subsequent to the period reviewed as shown in Exhibit A.

            6.

            Comment:

            The N-CSR filings for certain Funds do not include the required disclosure regarding the usage of certain derivatives in the Notes to the Financials. Specifically, the usage for call options purchased and
              written is not included; see

      2

            Invesco Bond Fund as an example. Please add such disclosure in the Notes to the Financials in future N-CSR filings.

            Response:

            The Notes to the Financials related to derivatives used by the Funds will be reviewed to confirm that all such Notes include the requisite disclosure regarding derivatives usage.  Specifically, the Note “Call Options Purchased and Written”
              included in the Notes to the Financials for certain Funds, including Invesco Bond Fund, will be updated to include the specific usage of call options purchased and written.

            7.

            Comment:

            The Statement of Assets and Liabilities for Invesco Senior Income Trust and Invesco Municipal Income Opportunities Trust
                show receivables for “Fund expenses absorbed.”   Please explain the transactions to which these receivables relate.

            Response:

            The Registrants confirm that the receivables for “Fund expenses absorbed” represent amounts related to deferred offering costs incurred in connection with the common share “shelf” registration pursuant to Rule 415 under the Securities Act
              of 1933, as amended. Costs incurred by the Funds in relation to the shelf offering are recorded as deferred offering costs and amortized pro rata as common shares are sold. Effective with the August 31, 2025 reporting cycle, Invesco updated
              the presentation to classify these as prepaid expenses on the Statement of Assets and Liabilities.

            8.

            Comment:

            The Notes to the Financials in the N-CSRs for the Invesco Corporate Bond BulletShares ETFs and Invesco High Yield BulletShares ETFs include disclosure regarding Rule 17a-7 transactions conducted by such ETFs
              that appear to be related to Level 2 securities. Please explain how such transactions comport with Rule 17a-7 and Rule 2a-5 which defines readily available market quotations to mean “a market quotation is readily available only when that
              quotation is a quoted price (unadjusted) in active markets for identical investments that the fund can access at the measurement date, provided that a quotation will not be readily available if it is not reliable.”

            Response:

            Section 17(a) of the 1940 Act prohibits the purchase or sale of securities between a registered fund and its affiliates. Rule 17a-7 was adopted to address potential affiliated transaction issues raised by cross-trades. Rule 17a-7, as
              pertinent here, exempts from the prohibitions of Section 17(a) certain purchases and sales between registered investment companies or separate series of registered investment companies and certain affiliated persons, where any affiliation
              arises solely because they have a common investment adviser.1  To rely on the exemption, among other conditions set forth in the rule, the transactions must be purchases or sales of a security “for which market quotations are
              readily available.” Certain debt instruments, however, may not have an active trading market but can be valued using alternative approaches of “Level 2” fair valuation that ensure appropriate fair valuation of the securities. The

    1 The SEC has indicated its view that investment companies that share a common investment adviser (or have investment advisers that are affiliated persons of one another) may be deemed to be “under common control”.  See Payment of Asset-Based Sales Loads by Registered Open-End Mgmt. Inv. Companies, Release No. IC-16431 (June 13, 1988) (“Funds that share a common investment adviser may, depending on the circumstances,
        be deemed to be under common control, and, therefore, to be “affiliated persons” of each other under section 2(a)(3)(C) of the [1940] Act”). But see Exemption of Certain Purchase or Sale Transactions Between A Registered Inv. Co.
          & Certain Affiliated Persons Thereof, Release No. IC-11676 (Mar. 10, 1981) (“[R]ule [17a-7] does not represent a Commission finding that investment companies having common officers, directors or investment advisers are always affiliated
        persons or affiliated persons of an affiliated person. They may or may not be, depending on the facts. The rule enables the parties to go forward without resolving that question if the requirements of the rule are met.”)

      3

            SEC staff has granted a series of no-action letters that permit cross trades in reliance on such Level 2 valuations. 2

            The Invesco BulletShares ETFs invest in these types of Level 2 valued securities.  In order to reduce costs to their shareholders, the Invesco Corporate Bond BulletShares ETFs, and Invesco High Yield BulletShares ETFs engage in
              cross-trades (specifically, with other Invesco BulletShares ETFs that invest in the same respective fixed-income asset classes) in reliance on these no-action letters issued by the SEC staff. In issuing such no-action relief, the SEC staff in
              United Municipal Bond Fund I agreed that it would not recommend that the SEC take any enforcement action under Section 17(a) of the 1940 Act if an open-end fund, in reliance on Rule 17a-7, engaged in a cross trade for municipal bonds for
              which market quotations are not readily available, provided that the fund complied with the following conditions:

            (1) the bonds are valued by averaging prices obtained from at least three independent matrix pricing services, or by averaging three independent bid prices, or by averaging three prices obtained from some combination of independent pricing
              services and independent bid prices;

            (2) the independent matrix pricing services are not affiliated persons of the Funds or affiliated persons of affiliated persons of the Funds as defined in Section 2(a)(3) of the 1940 Act;

            (3) the independent matrix pricing services are not engaged directly or through affiliated persons in underwriting or distributing the municipal bonds;

            (4) no brokerage commission, fee (except for customary transfer fees and matrix pricing servicing fees) or other remuneration is paid in connection with the transactions; and

            (5) the funds comply with paragraphs (c), (e), and (f) of Rule 17a-7.3

            In cross trading their respective securities, the Invesco BulletShares Municipal Bond ETFs, the Invesco Corporate Bond BulletShares ETFs and Invesco High Yield BulletShares ETFs comply with these stated conditions for relief under these
              letters.

            We note that in the Rule 2a-5 Adopting Release, when discussing how new definitions in the rule might limit the ability of funds to engage in cross-trades, the SEC cited to United Municipal Bond Fund I and United Municipal Bond Fund II and
              noted that the letters remain in effect.4  As the SEC neither rescinded nor expressly limited the scope of the Municipal Bond Fund Letters either at the time it adopted Rule 2a-5 or subsequent to that rule’s issuance, the
              Registrant is of the view that the letters currently remain available.  We are unaware of any statement from the SEC staff indicating these letters have been withdrawn. As a result, the Funds believe that the cross-trading of fixed-income
              securities by the

    2 See
        United Municipal Bond Fund, SEC No-Action Letter (pub. avail. July 30, 1992) (“United Municipal Bond Fund I”); United Municipal Bond Fund, SEC No-Action Letter (pub. avail. Jan. 27, 1995) (“United Municipal Bond Fund II”); and Federated Municipal
        Funds, SEC No-Action Letter (pub. avail. Nov. 20, 2006) (“Federated”) (collectively, the “Municipal Bond Fund Letters”).

    3 Subsequent to the issuance of United
        Municipal Bond Fund I, the staff issued United Municipal Bond Fund II, which endorsed United Municipal Bond Fund I and modified the requirements of the earlier letter to permit the use an evaluated price provided by a single, independent pricing
        service.  Later, in issuing the Federated letter, the staff reasserted the positions taken in both United Municipal Bond Fund I and United Municipal Bond Fund II and clarified that any independent pricing service may be used.

    4 See Good Faith Determination of Fair Value, SEC Rel. No. IC-34128 (Dec. 3, 2020) at pp. 94-95 (“Rule 2a-5 Adopting Release”): “We also understand that many cross trades today are done taking into consideration certain