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CORRESP
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CORRESP

 COLUMBIA FUNDS SERIES TRUST II

290 Congress Street

Boston, MA 02210

 October 4, 2021

 VIA EDGAR

 Mr. Mark Cowan

U.S. Securities and Exchange Commission

 Division of Investment
Management, Disclosure Review Office

 100 F Street, N.E.

Washington, D.C. 20549

RE:

 Columbia Funds Series Trust II (the Registrant)

Columbia Integrated Large Cap Growth Fund

 Columbia Integrated
Large Cap Value Fund

 Columbia Integrated Small Cap Growth Fund

Columbia Pyrford International Stock Fund

 Columbia Ultra Short
Municipal Bond Fund

 Post-Effective Amendment No. 222 (the Filing)

File No. 333-131683 /811-21852

 Dear Mr. Cowan:

 This
letter responds to comments received from the staff of the Securities and Exchange Commission (the Staff) on September 29, 2021 for the Filing filed by and on behalf of the Registrant on behalf of its series, Columbia Integrated Large Cap
Growth Fund, Columbia Integrated Large Cap Value Fund, Columbia Integrated Small Cap Growth Fund, Columbia Pyrford International Stock Fund and Columbia Ultra Short Municipal Bond Fund (each, the Fund, or collectively, the Funds).

As reflected in the Filing, the shares registered for offer and sale under the Filing with respect to the Funds will not be offered or sold to any person(s)
under this registration statement unless and until the reorganization of the Predecessor Fund(s), each a series of BMO Funds, Inc., into the corresponding Fund as outlined below (each, a Reorganization, or collectively, the Reorganizations) and as
contemplated by the registration statement filed on Form N-14 filed by Columbia Funds Series Trust II (File No. 333-258932), is completed.

 Predecessor Fund(s)

 Corresponding Fund

BMO Large-Cap Growth Fund

Columbia Integrated Large Cap Growth Fund

 BMO Large-Cap Value Fund(1)

BMO Dividend Income Fund(1)

BMO Low Volatility Equity Fund(1)

Columbia Integrated Large Cap Value Fund

BMO Small-Cap Growth Fund

Columbia Integrated Small Cap Growth Fund

BMO Pyrford International Stock Fund

Columbia Pyrford International Stock Fund

BMO Ultra Short Tax-Free Fund

Columbia Ultra Short Municipal Bond Fund

(1)
 Unless and until at least one of the reorganizations is completed.

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 Comments and responses are outlined below.

PROSPECTUS COMMENTS:

 All Funds

General:

 Comment 1:

Please remember to update the series/class identifiers on EDGAR to reflect the ticker symbols once they are available. See Rule 313 of Regulation S-T.

 Response:

The series and class identifiers on EDGAR will be updated to reflect the ticker symbols of the shares for each Fund.

Prospectus Cover:

 Comment 2:

Please update the legend on the cover of the prospectuses that references the reorganization as contemplated by the registration statement filed by the Registrant on Form N-14 on or about
August 18, 2021, to include the file number of the registration statement.

 Response:

Such reference to the Registrant’s registration statement filed on Form N-14 will be revised to include reference to the registration statement file
No. 333-258932.

Fees and Expenses of the Fund:

 Comment 3:

The following disclosure is not permitted or required under the Fees and Expenses of the Fund section in the summary prospectus. Please move this disclosure in response to Item 12.

 You may be required to pay such brokerage commissions and other fees to financial intermediaries when transacting in
any class of Fund shares, including those that do not assess any front-end sales charge, contingent deferred sales charge, or other asset-based fee for sales or distribution. Such brokerage commissions and
other fees are set by the financial intermediary.

 Response:

This disclosure will be moved to Item 12.

 Comment 4:

Since this is not a new fund as defined by Item 3 Instruction 6, ‘Other Expenses’ should not be estimated, unless you expect that there will be changes in these expenses that are materially different from the prior fiscal
year because of the Reorganization. In that case, (A) Restate the expense information using the current fees as if they had been in effect during the previous fiscal year; and (B) In a footnote to the table, disclose that the expense
information in the table has been restated to reflect current fees. See Item 3, Inst. 3(d).

 Response:

The amounts for Other Expenses in the table are restated from those of the Predecessor Fund using the current fees of the Fund for share classes that have a corresponding Predecessor Fund share class. The amounts of Other
Expenses for other share classes of the Fund (i.e., share classes not offered by a Predecessor Fund) are based on estimated amounts. Accordingly, the footnote will be revised as shown below:

 Other expenses have been restated to reflect current fees paid by the Fund and other expenses for [share classes
without corresponding Predecessor Fund share classes] are based on estimated amounts for the Fund’s current fiscal year.

 Comment 5:

In the last footnote to the Annual Fund Operating Expenses table, please delete the phrase “assuming approval by shareholders of the Reorganization, effective upon the closing of the Reorganization” because the Fund
will not launch unless the Reorganization is completed.

 Response:

The footnote will be so revised in the definitive filing.

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Summary of the Fund — Principal Risks

(revisions should be reflected in the corresponding disclosure in the More Information About the Fund section, as necessary)

 Comment 6:

The Fund’s Principal Risks should be presented in order of significance to the Fund rather than in alphabetical order. Please revise. Please see IM Director’s October 2018 speech and IM Guidance 2014-08 (Risk Guidance).

 Response:

We have considered this comment and have taken measures across the fund complex to identify, at the very beginning of each Fund’s Principal Risks discussion, what the Fund views as its main principal risks, which is
meant to guide investors as to the few key risks of investing in the Fund. We believe this approach to be consistent with the intent and spirit of ADI 2019-08. Also, the Funds note that the Commission has
proposed amendments in this regard (https://www.sec.gov/rules/proposed/2020/33-10814.pdf), so the Funds, with all due respect, prefer to await final Commission guidance in this regard before instituting an
approach to disclosure that does not align to any potential Commission guidance in this regard.

 Comment 7:

In the first paragraph under Principal Risks, replace “these and other” with “the.”

 Response:

Please see response to Comment 6 above.

 Comment 8:

In the first paragraph under Principal Risks, please delete the risks listed in the first sentence. There is no reason to call these out. All of the risks set forth below are to be principal risks.

 Response:

Please see response to Comment 6 above.

Performance Information

 Comment 9:

In the first sentence in the Performance Information paragraph, delete “Predecessor”. This should only reference “the Fund” because the Fund is adopting the Predecessor Fund’s performance.

 Response:

This disclosure will be so revised in the definitive filing.

 Comment 10:

Please state that the bar chart does not reflect sales charges, and if it did, performance would be lower.

 Response:

The statement will be included for bar charts that reflect the performance of a share class that assesses a sales charge. Otherwise, the disclosure will not appear as it is not applicable.

 Comment 11:

Please delete the sentence that describes the difference between the sales charge assessed by the Predecessor Fund and the Fund. The prior sentence already states that the Average Annual Returns table reflects the applicable sales
load in the Fee Table (i.e., 5.75% for Class A). Instead, add that the annual average returns have not been adjusted for other Fund fees and expenses, if true.

 Response:

The disclosure will be modified to reflect that the performance shown is that of the corresponding share class of the Predecessor Fund and no adjustments have been made to reflect current fees and expenses of the Fund. The
disclosure will be further modified to reflect that, if performance had been adjusted to reflect current fees and expenses of the Fund, returns would be lower for all periods.

 Comment 12:

Please revise the last sentence of the first paragraph to name the other share classes and revise the last phrase to “therefore, no performance information is shown.”

 Response:

The sentence will be so revised in the definitive filing.

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Fund Management

 Comment 13:

Please indicate whether the portfolio managers are jointly and primarily responsible for day-to-day management of the Funds.

 Response:

The disclosure will be revised to reflect that each of the Funds is co-managed by each of the portfolio managers.

More Information About the Fund — Principal Risks

 Comment 14:

Please note that, other than Active Management Risk, the risk disclosure in the More Information About the Fund section is identical to the risk disclosure in the Summary of the Fund section. Please revise.

 Response:

We appreciate the Staff’s comment and have reviewed IM Guidance 2014-08. In our view, the disclosure of principal risks and principal investment strategies of investing in the Fund in
response to Item 4 accurately summarizes the key information that is important to an investor decision and we do not believe the Item 4 disclosure reflects long, complex and detailed descriptions of principal risks and principal investment
strategies that are dense and not user-friendly, as discussed in IM Guidance 2014-08. Certain principal risk and principal investment strategy disclosures provided in response to Item 9 are identical to those
provided in response to Item 4 which reflects our view that, in such instances, expanding on the key information provided in response to Item 4 would not add significant incremental benefit to making an investment decision. While we understand that
information disclosed in response to Item 4 need not be repeated in response to Item 9, we believe omitting such information in response to Item 9 could result in investor confusion and misunderstanding of the principal risks and principal
investment strategies of investing in the Fund.

More Information About the Fund — Additional Investment Strategies and Policies

 Comment 15:

Please consider disclosing non-principal risks and investment strategies in the Fund’s Statement of Additional Information rather than in the Fund’s prospectus. The Staff believes
that including this disclosure in the prospectus may overwhelm other important information. See ADI 2019-08.

 Response:

After giving consideration to the comment, the Registrant elects to include certain information, including certain investment strategies and the risks thereof that are not principal investment strategies of the Fund, in the
prospectus in accordance with General Instruction C.3(b) of Form N-1A.

 Comment 16:

The prospectus disclosure reflects certain terms of the Fund’s management agreement and its fee waiver/expense reimbursement agreement. Please ensure the corresponding agreements are filed as exhibits.

 Response:

The agreements will be filed as exhibits in the definitive filing.

Columbia Integrated Large Cap Growth Fund, Columbia Integrated Large Cap Value Fund, and Columbia Integrated Small Cap Growth Fund

Summary of the Fund — Principal Investment Strategies

(revisions should be reflected in the corresponding disclosure in the More Information About the Fund section as necessary)

 Comment 17:

Please disclose the equity securities the Fund principally investments in and add appropriate risk disclosure.

 Response:

The second paragraph of Principal Investment Strategies will be revised to reflect that the equity securities that the Fund invests in generally include common stocks.

 Comment 18:

Please explain the criteria or metrics the portfolio managers will use to evaluate and/or measure “improving investor interest.”

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 Response:

The disclosure will be revised to reflect that the criteria the portfolio managers use to measure improving investor interest includes factors “such as positive price momentum”.

More Information About the Fund — Principal Investment Strategies

 Comment 19:

This strategy disclosure is virtually identical to the summary except for the mention of ESG. Please revise to provide fulsome disclosure of the Fund’s principal strategies in accordance with Item 9, including more details
about how the Fund determines when to buy and sell securities.

 Response:

Discussion of how the Fund determines when to buy and sell securities, including its consideration of environmental, social, and governance considerations, is appropriately included in the disclosure. Although not necessary, the
disclosure of the Fund’s principal investment strategies that is included in the Summary of the Fund section is replicated in this section for context.

 Comment 20:

In the first paragraph discussion of market capitalization range, for clarity, you should add a sentence that the determination of a company’s market capitalization size is made at time of investment. Also, this language is
overly broad as to what the Fund can do if investments subsequently fall outside of the stated capitalization range. Please revise (i.e., add that the Fund cannot purchase additional investments in that security as part of its 80% policy).

 Response:

The disclosure will be revised to address the Staff’s comment.

 Comment 21:

Please briefly identify examples of ESG criteria considered and whether the screen is applied to all investments. The Fund should also disclose, where appropriate, how the Fund will approach relevant ESG proxy issues for their
portfolio companies. Alternatively, the Fund should explain in correspondence why it believes such disclosure is not required.

 Response:

The following disclosure will be added to the paragraph that discusses ESG considerations:

 The ESG factors considered as part of the Investment Manager’s overall assessment of the risks and opportunities
presented by an investment vary by issuer, depending in part on the availability and reliability of relevant information, and may include risks to the issuer’s business arising out of its environmental and social impacts and its corporate
governance practices.

The Fund’s proxy voting policies and guidelines with respect to portfolio companies is described in the Statement of Additional Information in the Corporate Governance and Proxy Voting Principles section.

Columbia Pyrford International Stock Fund

Summary of the Fund — Principal Investment Strategies

(revisions should be reflected in the corresponding disclosure in the More Information About the Fund section as necessary)

Comment 22:

Please clarify whether the Fund invests primarily in companies that are constituents of the MSCI EAFE index. Otherwise, please explain how merely being located in one of the 21 countries within the MSCI EAFE index satisfies the
“economically tied.” See Investment Company Names, Investment Company Act Release No. 24828, at n. 42 (Jan. 17, 2001).

Response:

The following disclosure will be added to the first paragraph:

 In determining where a company is located, the Fund primarily relies on the country where the company is organized, but
also may consider the country where the company’s revenues are primarily derived and the primary market listing for the class of company shares to be purchased.

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 Comment 23:

If a significant amount of the Fund’s assets will be invested in a particular sector, geographic region or country, please include strategy and risk disclosure to that effect. We note the Fund invests significantly in Asia
Pacific and Europe based on risk disclosure. At a minimum, this should be identified in the strategies, and the same comment applies for consumer sector and indust