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    787 Seventh Avenue

New York, NY 10019-6099

Tel: 212 728 8000

Fax: 212 728 8111

December 7, 2012

Via EDGAR

Laura Hatch

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:	Comments on BlackRock Shareholder Reports

Dear Ms. Hatch:

This letter responds to comments provided
by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (“SEC”)
in telephone conversations on September 19, 2012, September 26, 2012, September 28, 2012 and October 5, 2012 regarding the shareholder
reports of the registrants as identified on Exhibit A (the “Registrants”).

For your convenience, the substance of
the Staff’s comments has been restated below. Each Registrant’s joint or individual responses to each comment, as applicable,
are set out immediately under the restated comment.

General Comments

 Comment No. 1. (Comment on N-1A Filings) For share classes that automatically
convert to another share class after a certain period of time, please confirm that the average annual total returns included in
the performance table reflects the returns of the class being converted into.

 Response No. 1: The Registrants confirm that when reporting performance
after a share class conversion, the ten year average annual total return included in the performance table reflects the returns
of the class into which the shares are being converted.

New
York  Washington, DC  Paris  London
Milan  Rome  Frankfurt
Brussels

    December 7, 2012
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 Comment No. 2. The Notes to Financial Statements for certain Funds (generally
for those Funds that engage in securities lending activities) state that with respect to a Fund’s investment in BlackRock
Liquidity Series, LLC Money Market Series (the “Money Market Series”) “the Fund
may withdraw up to 25% of its investment daily, although the manager of the Money Market Series, in its sole discretion, may permit
an investor to withdraw more than 25% on any one day.” Please consider adding this language as a tickmark in the Schedule
of Investments.

 Response No. 2: The suggested change will be made to future shareholder
reports, when applicable. The Schedules of Investments will include the following tickmark where appropriate: “The Fund
may withdraw up to 25% of its investment in the BlackRock Liquidity Series, LLC Money Market Series (the “Money Market
Series”) daily, although the manager of the Money Market Series, in its sole discretion, may
permit an investor to withdraw more than 25% on any one day.”

 Comment No. 3. On the Statement of Operations,
certain Funds (e.g., BlackRock Mid-Cap Growth Equity Portfolio and BlackRock Mid-Cap Value Equity Portfolio) list “Litigation
proceeds” under the “Realized Gain” sub-heading. Please confirm that these proceeds are not from securities
currently held by the Funds. If the litigation proceeds are from securities held by a Fund, the proceeds should be characterized
as unrealized gain and should be re-classified as an offset to costs.

 Response No. 3: The “Litigation proceeds” of BlackRock Mid-Cap
Growth Equity Portfolio are not from securities currently held by the Fund. The majority (97%) of the “Litigation proceeds”
of BlackRock Mid-Cap Value Equity Portfolio are not from securities currently held by the Fund. The remaining 3%, which are from
securities currently held by the Fund, was deemed immaterial. The Registrants confirm that if litigation proceeds are primarily
from securities held by a Fund, these proceeds will be characterized as unrealized gain.

 Comment No. 4. Please confirm whether recoupment of manager fee waivers
are applied on a class level or on a Fund level. If recoupment is applied on a class level, amounts should be provided on a class-by-class
basis in the Notes to Financial Statements (certain Funds disclose recoupment amounts on a Fund level basis, e.g. BlackRock Core
Bond Fund).

 Response No. 4: Expense waiver recoupments can occur both at the class level
and the fund level. The amounts that have been recouped during the fiscal year are disclosed by class level in the Notes to Financial
Statements. Amounts subject to possible future recoupment will be shown on a class-by-class basis, when applicable, in all future
shareholder reports.

 Comment No. 5. On the Fair Valuation Input table in the Schedule of
Investments, certain Funds (e.g., BlackRock Energy & Resources Portfolio) that had Level 3 holdings do not show a roll forward
from the previous year. Please confirm whether a materiality

    December 7, 2012
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threshold
is being applied to determine whether to exclude the roll forward. If you are willing, please state what that materiality threshold
is.

 Response No. 5: The Registrants confirm that a materiality threshold is
being applied to determine whether to exclude a roll forward from the previous year in the Level 3 holdings. A Fund will include
a Level 3 roll forward if the Level 3 investments at the beginning or end of the period are greater in the aggregate than 1% of
the Fund’s net assets. Per FASB ASC 105-10-05-06, the provisions of the FASB Codification need not be applied to immaterial
items. The Registrants take the position that a Level 3 roll forward may be omitted in situations where the amount of Level 3
assets or liabilities is not material.

 Comment No. 6. For Funds that have heavy derivatives exposure, please
disclose information about the existence and nature of credit-risk-related contingent features. Reference is made to accounting
guidance ASC 815-10-50-4H.

 Response No. 6: The Funds currently disclose the following in accordance
with FASB ASC 815-10-50-4H: “Certain ISDA Master Agreements allow counterparties to OTC derivatives to terminate derivative
contracts prior to maturity in the event the Funds’ net assets decline by a stated percentage or the Funds fail to meet
the terms of its ISDA Master Agreements, which would cause the Funds to accelerate payment of any net liability owed to the counterparty.”

 Comment No. 7. For Funds that write or sell credit default swaps, please
confirm that the Funds cover the full notional amount of the credit default swap.

 Response No. 7: If a Fund writes (sells) a credit default swap, then the
Fund will, during the term of the swap agreement, cover the full amount owed to the counterparty under the swap agreement upon
the occurrence of a credit default event, as defined under the terms of the particular swap agreement.

 Comment No. 8. Certain Funds appear to have outstanding debt (other
than a line of credit) but do not provide a cash flow statement (e.g., BlackRock Strategic Income Opportunities Portfolio, BlackRock
Low Duration Bond Portfolio and BlackRock Core Bond Portfolio). Please explain how Fund management determined that these Funds
do not need to provide a cash flow statement.

 Response No. 8: A Fund will present a Statement of Cash Flows in the financial
statements if average borrowings for the period exceed 10% of its average total assets. None of the Funds referenced above had
average borrowings for the relevant period exceeding the 10% threshold. The Registrants note that for these purposes reverse repurchase
agreements are included in the borrowings calculation.

    December 7, 2012
 Page 4

Money Market Fund Comments

 Comment No. 9. Certain Funds disclose a different expense ratio in the
Expense Example in the Annual Report than is disclosed in the Financial Highlights. Please explain the reason for this discrepancy.

For
example:

BlackRock
Municipal Money Market Portfolio – Investor A

Expense
Example expense ratio: 0.18%

Financial
Highlights expense ratio: 0.25%

BlackRock
New Jersey Municipal Money Market Portfolio – Investor A

Expense
Example expense ratio: 0.24%

Financial
Highlights expense ratio: 0.38%

BlackRock
Ohio Municipal Money Market Portfolio – Investor A

Expense
Example expense ratio: 0.16%

Financial
Highlights expense ratio: 0.27%

 Response No. 9: The expense ratio in the Financial Highlights is calculated
using the amount of expenses shown in each Fund’s Statement of Operations for the period, per Regulation S-X. The expense
ratio in the annual report is calculated using a 12-month period while the expense ratio in the semi-annual report is calculated
using a 6-month period. A Fund’s expense ratio used in the Expense Example, which is calculated in the manner required by
Instruction 4(b) to Item 13(a) of Form N-1A, requires the use of the Fund’s most recent fiscal half-year (e.g., the Fund’s
second fiscal half-year in the case of an annual report) on an annualized basis. Voluntary expense waivers that were instituted
in order to maintain minimum levels of daily net investment income for these Funds were higher in the second half of the year
than they were in the first half of the year. Therefore the expense ratio in the expense example is lower than the expense ratio
in the financial highlights.

 Comment No. 10. Certain Funds disclose a different expense ratio in the
prospectus expense table than is disclosed in the Financial Highlights. Please explain the reason for this discrepancy.

For
example:

BIF
Government Securities Fund

Expense
table expense ratio: 0.70%

Financial
Highlights expense ratio: 0.49%

BIF
Treasury Fund

Expense
table expense ratio: 0.58%

Financial
Highlights expense ratio: 0.49%

    December 7, 2012
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 Response No. 10: The net expense ratios in the prospectus fee table reflect
only contractual fee waivers and do not include additional voluntary waivers that were instituted in order to maintain minimum
levels of daily net investment income. The net expense ratios in the financial highlights include all fee waivers.

 Comment No. 11. For BlackRock Money Market Portfolio, the Financial Highlights
for Investor A Shares is missing tickmark “2” on the “Total Investment Return” line item for the period
October 1, 2008 to March 31, 2009.

 Response No. 11: The missing tickmark will be added to all future shareholder
reports, when applicable.

 Comment No. 12. For all Money Market Funds, consider tickmarking all
values below 0.0005 on the Financial Highlights tables.

 Response No. 12: The suggested change will be made to all future shareholder
reports, when applicable.

 Comment No. 13. For the BIF Ohio Municipal Money Fund, the Schedule of
Investments shows that the Fund held 68% of its assets in Ohio municipal securities. The Fund’s prospectus discloses that
the “Fund will generally invest at least 80% of its assets in Ohio municipal securities.” Please explain whether the
Fund was in compliance with its stated 80% policy.

 Response No. 13: The Fund confirms that it was in compliance with its stated
80% policy.

 Comment No. 14. For the BIF Ohio Municipal Money Fund, the Statement
of Assets and Liabilities discloses “Investments sold receivable” of approximately $28M (which was approximately 28%
of the Fund’s net assets), however, the Staff did not see any Fund liability that would require the Fund to raise that much
cash. Was the Fund aware of an incoming redemption that was not included on the Statement of Assets and Liabilities? (The Staff
notes that in the next quarterly report for the period ended June 30, 2012, the Fund’s assets decreased by approximately
$25M.)

 Response No. 14: The “Investments sold receivable” was not related
to redemption activity and represents called bonds which settled on April 2, 2012. The Fund notes that it had approximately $100
million in net assets as of March 31, 2012 and approximately $84 million in net assets as of June 30, 2012. The difference in
net assets between the first and second quarters is not related to the called bonds.

Closed-end Municipal Funds

 Comment No. 15. For Funds that hold Tender Option Bonds (TOBs), please
confirm that the Funds segregate liquid assets equal to the amount of the bond plus accrued interest.

    December 7, 2012
 Page 6

 Response No. 15: The Registrants confirm that Funds that hold TOBs segregate
liquid assets equal to the amount of the short term floating rate securities issued by the tender option bond trust plus accrued
interest.

 Comment No. 16. In the section of the shareholder reports captioned “The
Benefits and Risks of Leveraging,” please explain why the figures provided in the “Percentage of Leverage” table
do not correspond to the level of leverage disclosed in the Schedule of Investments.

For
Example:

    Fund Ticker
    Percentage of Leverage disclosed in The Benefits and Risks of Leverage Section
    Percentage of leverage disclosed in the Schedule of Investments

    MUC
    43%
    74.3%

    MUJ
    37%
    59.4%

    MFT
    39%
    63.6%

    MIY
    38%
    60.4%

    MJI
    35%
    53.7%

 Response No. 16: The Registrants note that the percentages for leverage in
the Schedule of Investments are based solely on a Fund’s net asset value, as noted at the top of the Schedule of Investments.
The percentages in the section captioned “The Benefits and Risks of Leveraging” are based on a Fund’s managed
assets, which include the net asset value and borrowings.

 Comment No. 17. In the Statement of Operations included in future reports,
please separately report interest expense and amortization of offering costs.

 Response No. 17: The Registrants respectfully decline to make this change.
In accordance with FASB ASC 835-30-45, debt issue costs are recorded as a deferred charge and amortized to interest expense over
the term of the life of the debt. Because these costs are amortized to interest expense, these are included as one line item on
the Statement of Operations and it is indicated that the line item includes interest expense and offering cost amortization.

 Comment No. 18. For Funds that have issued VRDP Shares, the Notes to
Financial Statements (Note 1) states that costs in connection with the issuance of VRDP Shares are
recorded

    December 7, 2012
 Page 7

as
a deferred charge and will be amortized over the 30-year life of the VRDP Shares with the exception of upfront fees paid to the
liquidity provider which are amortized over the life of the liquidity agreement. Similarly, certain Funds disclose that costs
in connection with the issuance of VMTP Shares are recorded as a deferred charge and will be amortized over 3 years. Please explain
the accounting treatment of these policies. Reference is made to accounting guidance in paragraphs 5-6 of FASB ASC 946-20-25 and
946-20-35-5, which requires that offering costs of closed-end funds shall be charged to paid-in capital upon sale of the shares
or units.

 Response No. 18: VRDP and VMTP Shares (“Preferred Shares”) have
(i) a mandatory redemption 30 years and 3 years, respectively, from the date of issuance, (ii) a conditional demand feature and
(iii) an optional redemption provision that allows a Fund to redeem the Preferred Shares. FASB ASC 480-10-25-4 states that a mandatorily
redeemable financial instrument shall be classified as a liability unless the redemption is required to occur only upon the liquidation
or termination of the reporting entity. Because the redemption will occur up to 3 or 30 years, as applicable, from the date of
issuance (which will not be the termination date of the issuing Fund), the Preferred Shares are considered debt of the issuing
Fund. In accordance with FASB ASC 835-30-45, debt issue costs are recorded as a deferred charge and amortized to interest expense
over the term of the life of the debt. Upfront fees paid to the liquidity provider (in the case of VRDP only) are amortized over
the life of the agreement since the agreements typically have a one- or two-year term. FASB ASC 946-20-25 and FASB ASC 946-20-35-5
are applicable to the initial offering of shares or units before commencement of operations, as no shares were issued (and thus
that guidance is not applicable to the issuance of debt).

 Comment No. 19. For the Funds that have issu