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CORRESP
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 AB FUNDS

 501 Commerce Street

 Nashville, TN 37203

 June 27, 2025

 VIA EDGAR CORRESPONDENCE

 Division of Investment Management

 Disclosure Review and Accounting Office

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, DC 20549

 Attention: Shandy Pumphrey

 Re: In the matter of the SEC Filings set forth
in Appendix B hereto

 Dear Ms. Pumphrey:

 Attached as Appendix A are responses to the comments made
during your phone conversation with Phyllis Clarke and other representatives of AllianceBernstein L.P. (the "Adviser" or "we")
on May 28, 2025.

 If you have any questions regarding our response, please do not
hesitate to call me at 629.213.5769.

 Sincerely,

 /s/ Stephen Woetzel

 Stephen Woetzel

 Treasurer and Chief Financial

 Officer of each Fund

 cc: Michael Reyes, Senior
Vice President of the Funds

 Nancy Hay, AllianceBernstein L.P.

 Stephen Laffey, AllianceBernstein L.P.

 Vince Noto, AllianceBernstein L.P.

 Jennifer Friedland, AllianceBernstein L.P.

 Phyllis Clarke, AllianceBernstein L.P.

 Appendix A

 Comment #1

 Tailored Shareholder Reports ("TSR")

 Consider adding a footnote within the semi-annual TSRs for
the cost of $10K noting the percent is annualized.

 Response #1:

 The Adviser will include this disclosure going forward in
the semi-annual TSRs.

 Comment #2

 Tailored Shareholder Reports ("TSR")

 Please explain if the hypothetical expense reflects a partial
period or is annualized. If not a full year, please explain what the hypothetical expense would be.

 Response #2:

 The Adviser will add this explanation going forward.

 Comment #3

 Tailored Shareholder Reports ("TSR")

 The language relating to the Board's approval of the
advisory agreement was moved to the N-CSR, please remove the language regarding approval of the advisory agreement from the TSR. In future
filings please consider adding information requested for item 11 under the section. If included in that section the disclosure should
be in a format that is easily distinguished.

 Response #3:

 The Adviser intends to remove the disclosure relating to
the Board's approval of the advisory agreement from the TSRs going forward. This disclosure will be included in Item 11 in the N-CSRs.

 Comment #4

 Form N-CSR – All Funds

 Form N-CSR items 7-11 should be posted to the website. Item
7 was included, but items 8-11 were not included. Please include on the website going forward the section on the Form N-CSR that contains
the listing of 8-11.

 Response #4:

 The Adviser believes that the website is in compliance with
the website availability requirements specified in the rule, as the links within the TSR direct the shareholder to the appropriate information
required for items 7-11.

 Comment #5

 Tailored Shareholder Reports ("TSR")

 Please update website addresses within the TSR that direct
the shareholder to performance information. The Staff noted the TSRs provide links to updated performance information, however, the links
do not open to a page that shows performance information, just a listing of shareholder reports and holdings reports.

 Response #5:

 The Adviser intends to update the website to present a direct
link to the performance information.

 Comment #6

 AB Sustainable Global Thematic Fund &
Bernstein Fund, Inc.

 Please explain why the TSRs were missing the disclosure
stating, "The Fund's past performance is not a good predictor of the Fund's future performance".

 Response #6:

 The Adviser will ensure the required disclosure is included
in all future filings.

 Comment #7

 All Funds – Form N-CSR

 Please explain how item 10 of Form N-CSR meets the requirements
to disclose the aggregate renumeration paid by the company and reference the instruction noted in Form N-CSR item 10 as part of the response.
Additionally, please consider including the information requested for item 10 under that section in the Form N-CSR.

 Response #7:

 The Adviser confirms that the aggregate renumeration paid
by the company to all directors and advisory Board members is disclosed under item 7 on the statement of operations.

 Comment #8

 AB Cap Fund, AB Core Opportunities Fund,
 AB Equity Income Fund, AB Global Real Estate Investment Fund, AB Global Risk Allocation Fund, AB Trust, AB
Variable Products Series Funds, & AB Active ETFs

 Please explain why Form N-CSR items 10 and 11 point to item
1 and please explain why item 7 is listed as not applicable.

 Response #8:

 The Adviser confirms that "not applicable" and
item 1 were inadvertently presented within the Form N-CSR. The Adviser will ensure that "not applicable" is removed from item
7 and that item 7 is properly referenced in items 10 and 11 for all future filings.

 Comment #9

 AB High Income Municipal Portfolio

 Per Item C15 on Form N-CEN for affiliated brokers, AB
High Income Municipal Portfolio paid $4k to Sanford C. Bernstein, an affiliate. Please explain why it was not disclosed in Form
N-CSR.

 Response #9:

 The Adviser confirms that AB High Income Municipal Portfolio
inadvertently omitted the $4k payment to Sanford C. Bernstein within the 5/31/24 annual financial statements. The Adviser will ensure
all affiliated transactions are presented appropriately going forward.

 Comment #10

 Bernstein International Strategic Equities Portfolio

 Form N-CSR period 9/30/24 for International Strategic Equities
Portfolio received payment from affiliate of $53,150 during the period due to a NAV error, however, the Staff did not note an affirmative
response in item B22 of Form N-CEN related to such payment. Please explain.

 Response #10:

 The Adviser confirms that International Strategic Equities
Portfolio inadvertently provided a negative response regarding payment from an affiliate. The Adviser will ensure item B22 of Form N-CEN
is updated appropriately going forward.

 Comment #11

 AB Sustainable Global Thematic Fund

 Please explain why item B12 of Form N-CEN for AB Sustainable
Global Thematic Fund denotes "No" for shareholder votes when there was a shareholder meeting held on July 18, 2024, to elect
directors.

 Response #11:

 The Adviser confirms that AB Sustainable Global
Thematic Fund inadvertently omitted the shareholder votes from item B12 on Form N-CEN. The Adviser will ensure item B12 of Form
N-CEN is updated appropriately going forward.

 Comment #12

 AB Global Real Estate Investment Fund II

 Line graph assumes a $10k investment however according to
the prospectus, the institutional class has a minimum investment of $2MM. Please explain why the line graph does not show a $2MM investment.

 Response #12:

 The Fund's prospectus refers to a minimum initial
investment requirement of $10K for Bernstein clients and $2MM for certain other investors. As of June 24, 2025, 96% of the Fund's
shareholders have accounts with less than $2MM. Accordingly, we believe it is appropriate to assume a $10K investment in the line graph.

 Comment #13

 AB Sustainable Thematic Credit Portfolio, AB Active ETFs
(AB Short Duration High Yield ETF, AB Corporate Bond ETF & AB High Yield ETF)

 The Staff does not consider the Bloomberg US Corporate Bond
Index to be a broad-based index. In future filings, please add an index that provide information about the performance of the Fund against
a broader market. Please remember to describe this change in the following TSR. If you consider the noted index to be appropriate broad-base
index, please explain why.

 Response #13:

 The Adviser believes that the Bloomberg US Corporate Bond
Index is a broad-based index. The index is comprised of over 900 issuers and over 8000 individual CUSIPs. The Bloomberg US Corporate Bond
Index is widely referenced as a primary broad-based benchmark by other fund firms.

 Comment #14

 Bernstein Small Cap Core Portfolio

 Please describe which index is the broad-based index as
the Russell 2000 is tagged as the broad-based index with the S&P 500 tagged as the additional index.

 Response #14:

 The Adviser confirms that the Portfolio's broad-based
index is the S&P 500, while the Russell 2000 is the additional index. The Adviser will ensure the tagging is updated in future filings.

 Comment #15

 AB Global Real Estate Investment Fund

 Please tag additional indexes as only broad-based index
was tagged.

 Response #15:

 The Adviser confirms that AB Global Real Estate Investment
 Fund inadvertently did not apply the appropriate tagging of the additional indexes.

 Comment #16

 AB Active ETFs

 Please explain whether any of the creation/redemption fees
charged by the ETFs are retained by the ETFs. If so, please disclose accounting policy for the fees, and disclose any fees that are paid
to related parties.

 Response #16:

 The Adviser confirms creation/redemption fees are not retained
by the ETFs.

 Comment #17

 AB Active ETFs

 Please explain why Form N-CSR item 5 was marked as not applicable
for the AB Active ETFs.

 Response #17:

 The Adviser confirms that AB Active ETFs inadvertently
presented "not applicable" for Form N-CSR item 5. The Adviser will ensure Form N-CSR item 5 is presented appropriately for
future filings.

 Comment #18

 AllianceBernstein National Municipal Income Fund

 Please explain why an updated Form N-CSR was not used for
the 10/31/24 annual report for Closed End AllianceBernstein National Municipal Income Fund. Confirm updated form will be used going forward.

 Response #18:

 The Adviser will use an updated Form N-CSR for AllianceBernstein
National Municipal Income Fund for future filings.

 Comment #19

 AB Variable Products Series Funds

 Certification - Item 4d of the Variable Products
Series Fund certification required by item 19a of Form N-CSR filed for 12/31/24 does not appear to refer to the correct time period.
Item 4d requires disclosure of any changes in the registrant's internal control over financial reporting that occurred during
the period covered by this report. Please file an amended Form N-CSR to include the correct form of certification and ensure the
certification is signed with current date.

 Response #19:

 The Adviser will update this certification going forward
and will file an amended Form N-CSR for 12/31/24.

 Comment #20

 AB Sustainable International Thematic Fund, AB Short
Duration High Yield ETF and AB Short Duration Income ETF

 In accordance with Rule 313 of Regulation S-T, please update
the status of the following series classes from active to inactive.

 Response #20:

 The Adviser will update the status for AB Short
Duration High Yield ETF and AB Short Duration Income ETF from active to inactive. The Adviser confirms that AB Sustainable
International Thematic Fund is currently still active and should not be updated.

 Appendix B

 1940 Act File Number
 Registrant Name
 Series Name
 Fiscal Year-End Reviewed

 811-07732
 AllianceBernstein Global High Income Fund, Inc.
 ALLIANCEBERNSTEIN GLOBAL HIGH INCOME FUND, INC.
 3/31/2024

 811-07618
 AB Municipal Income Fund II
 AB Minnesota Portfolio
 5/31/2024

 811-07618
 AB Municipal Income Fund II
 AB New Jersey Portfolio
 5/31/2024

 811-07618
 AB Municipal Income Fund II
 AB Ohio Portfolio
 5/31/2024

 811-07618
 AB Municipal Income Fund II
 AB Pennsylvania Portfolio
 5/31/2024

 811-07618
 AB Municipal Income Fund II
 AB Virginia Portfolio
 5/31/2024

 811-07618
 AB Municipal Income Fund II
 AB Arizona Portfolio
 5/31/2024

 811-07618
 AB Municipal Income Fund II
 AB Massachusetts Portfolio
 5/31/2024

 811-04791
 AB Municipal Income Fund, Inc.
 AB National Portfolio
 5/31/2024

 811-04791
 AB Municipal Income Fund, Inc.
 AB New York Portfolio
 5/31/2024

 811-04791
 AB Municipal Income Fund, Inc.
 AB California Portfolio
 5/31/2024

 811-04791
 AB Municipal Income Fund, Inc.
 AB High Income Municipal Portfolio
 5/31/2024

 811-03131
 AB Sustainable Global Thematic Fund, Inc.
 AB SUSTAINABLE GLOBAL THEMATIC FUND, INC.
 7/31/2024

 811-06554
 AB Global Bond Fund, Inc.
 AB GLOBAL BOND FUND, INC.
 9/30/2024

 811-23100
 Bernstein Fund, Inc.
 International Strategic Equities Portfolio
 9/30/2024

 811-23100
 Bernstein Fund, Inc.
 International Small Cap Portfolio
 9/30/2024

 811-23100
 Bernstein Fund, Inc.
 Small Cap Core Portfolio
 9/30/2024

 811-02383
 AB Bond Fund, Inc.
 AB Income Fund
 10/31/2024

 811-02383
 AB Bond Fund, Inc.
 AB Total Return Bond Portfolio
 10/31/2024

 811-02383
 AB Bond Fund, Inc.
 AB Tax-Aware Fixed Income Opportunities Portfolio
 10/31/2024

 811-02383
 AB Bond Fund, Inc.
 AB Sustainable Thematic Credit Portfolio
 10/31/2024

 811-02383
 AB Bond Fund, Inc.
 AB All Market Real Return Portfolio
 10/31/2024

 811-02383
 AB Bond Fund, Inc.
 AB Bond Inflation Strategy
 10/31/2024

 811-02383
 AB Bond Fund, Inc.
 AB Municipal Bond Inflation Strategy
 10/31/2024

 811-08188
 AB High Income Fund, Inc.
 AB HIGH INCOME FUND, INC.
 10/31/2024

 811-08403
 AB Institutional Funds, Inc.
 AB Global Real Estate Investment Fund II
 10/31/2024

 811-00126
 AB Relative Value Fund, Inc.
 AB RELATIVE VALUE FUND, INC.
 10/31/2024

 811-10573
 AllianceBernstein
 National Municipal Income Fund, Inc.
 ALLIANCEBERNSTEIN
 NATIONAL MUNICIPAL INCOME FUND, INC
 10/31/2024

 811-23799
 AB Active ETFs, Inc.
 AB Corporate Bond ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB High Yield ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Conservative Buffer ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Short Duration High Yield ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Short Duration Income ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB International Low Volatility Equity ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB US High Dividend ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Ultra Short Income ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Tax-Aware Intermediate Municipal ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Core Plus Bond ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Tax-Aware Long Municipal ETF
 11/30/2024

 1940 Act File Number
 Registrant Name
 Series Name
 Fiscal Year-End Reviewed

 811-23799
 AB Active ETFs, Inc.
 AB US Large Cap Strategic Equities ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Disruptors ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB Tax-Aware Short Duration Municipal ETF
 11/30/2024

 811-23799
 AB Active ETFs, Inc.
 AB US Low Volatility Equity ETF
 11/30/2024

 811-01716
 AB CAP FUND, INC.
 AB All China Equity Portfolio
 11/30/2024

 811-01716
 AB CAP FUND, INC.
 AB Mid Cap Value Portfolio
 11/30/2024

 811-01716
 AB CAP FUND, INC.
 AB Small Cap Value Portfolio
 11/30/2024

 811-09687
 AB CORE OPPORTUNITIES FUND, INC.
 AB CORE OPPORTUNITIES FUND, INC.
 11/30/2024

 811-07916
 AB EQUITY INCOME FUND, INC.
 AB EQUITY INCOME FUND, INC.
 11/30/2024

 811-07707
 AB GLOBAL REAL ESTATE INVESTMENT FUND, INC.
 AB GLOBAL REAL ESTATE INVESTMENT FUND, INC.
 11/30/2024

 811-00134
 AB GLOBAL RISK ALLOCATION FUND, INC.
 AB GLOBAL RISK ALLOCATION FUND, INC.
 11/30/2024

 811-10221
 AB TRUST
 AB Large Cap Value Fund
 11/30/2024

 811-10221
 AB TRUST
 AB Discovery Value Fund
 11/30/2024

 811-10221
 AB TRUST
 AB International Value Fund
 11/30/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Small Cap Growth Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Balanced Hedged Allocation Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Global Risk Allocation-Moderate Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Dynamic Asset Allocation Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Sustainable Global Thematic Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Relative Value Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB International Value Portfolio
 12/31/2024

 811-05398
 AB VARIABLE PRODUCTS SERIES FUND, INC.
 AB Large Cap Growth Portfoli