SecProbe.io

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    1900 K Street, NW

                                                           Washington, DC 20006-1110

    +1 202 261 3386 Main

    +1 202 261 3333 Fax

    www.dechert.com

        WILLIAM BIELEFELD

    william.bielefeld@dechert.com

    +1 202 261 3386 Direct

    +1 773 562 8222 Fax

August 4, 2023

Alberto H. Zapata, Esq.

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management – Disclosure Review and Accounting
Office

100 F Street NE

Washington, D.C. 20549-0504

 Re: Accordant ODCE Index Fund

File Nos: 333-271866, 811-23460

Dear Mr. Zapata:

We are writing in response
to comments provided on June 12, 2023 with respect to the registration statement on Form N-2 (the “Registration Statement”)
under the Securities Act of 1933, as amended (the “1933 Act”), and the Investment Company Act of 1940, as amended (the “1940
Act”) filed on May 12, 2023 on behalf of Accordant ODCE Index Fund (the “Fund”), a closed-end management investment
company. The Fund has considered your comments and has authorized us, on its behalf, to make the responses and changes discussed below
to the Registration Statement. Capitalized terms have the meanings attributed to such terms in the Registration Statement.

Concurrently with this letter,
the Fund is filing Pre-Effective Amendment No. 4 to its Registration Statement, which reflects the disclosure changes discussed
below.

On behalf of the Fund, set
forth below are the SEC staff’s comments along with our responses to or any supplemental explanations of such comments, as requested.

General Comments

Comment
1.	     Please clarify whether the Fund will invest in pooled investment vehicles that rely
on the exclusions from the definition of investment company in section 3(c)(1) or 3(c)(7) of the 1940 Act. If the Fund will
invest more than 15% of its net assets in such pools, please, supplementally, please explain in your response why the Fund will not be
limited to investment by accredited investors. We may have additional comments after reviewing your response.

Response
1.	     The Fund does not intend to invest more than 15% of its net assets in pooled investment
vehicles that rely on the exclusion from the definition of investment company in Section 3(c)(1) or 3(c)(7) of the Act.

    – 1  –

Comment
2.	     No cover letter was filed with this Registration Statement. Please include a cover letter
in the future.

Response
2.	     The Fund acknowledges this comment and will include a cover letter with future filings.

Comment 3.	     The
EDGAR company identifier for this Registration Statement is currently: IDR Core Property Index Fund Ltd, which does not track the name
of the Fund in the Registration Statement. Please correct the Fund’s EDGAR identifier.

Response
3.	     The Fund will change its name and update its EDGAR identifier after the shareholder meeting
on August 31, 2023 and prior to seeking effectiveness.

Comment 4.	     We
note that the Registration Statement is missing information and exhibits and contains bracketed disclosures (e.g., the fee table, service
providers, board of directors and officers tables, portfolio managers, and financial statements). We may have comments on such portions
when you complete them in any pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally,
or on exhibits filed in any pre-effective amendment.

Response
4.	     The Fund acknowledges this comment.

Comment 5.	     Please
advise us if you have submitted or intend to submit any exemptive application(s) or no-action request(s) in connection with
your Registration Statement, including with respect to co-investments and multi-class relief.

Response
5.	     The Fund intends to seek exemptive relief from the SEC to issue multiple classes of shares
of common stock. The Fund confirms that it has not submitted and does not anticipate submitting a no-action request in connection with
the Registration Statement.

Comment 6.	     Please
confirm whether the Fund intends to issue preferred or debt securities within a year from the effective date of the Registration Statement.

Response
6.	     We hereby confirm that the Fund does not intend to offer preferred shares within 12 months
of effectiveness of the Registration Statement.

Comment 7.	     Please
tell us if you have presented or will present any “test the waters” materials to potential investors in connection with this
offering. If so, please provide us with copies of such materials.

Response
7.	     We hereby confirm that no test-the-water materials have been presented to potential investors
in connection with this offering.

    – 2  –

Comment 8.	     We
note that on June 2, 2023, the Fund filed a proxy statement that notifies shareholders of a special shareholder meeting that will
be held sometime in August, at which meeting the shareholders will be asked to vote on several proposals, including a proposal to convert
the Fund into an interval fund and to approve new advisory and related agreements stemming from a recent change in control of the Adviser.
In your response, please confirm that the Fund does not plan to request acceleration of the Registration Statement until the various proposals
are approved by shareholders and implemented. Does the Fund plan to amend its current Registration Statement to reflect the recent change
in control of the Fund’s adviser and the interim advisory agreement with the Fund?

Response
8.	     The Fund confirms that it will not be filing an acceleration request for the Registration
Statement prior to the proposals set forth in the proxy statement being approved by shareholders. The Fund confirms that Fund investors consented to the change in control of IDR Investment Management, LLC (“IDR”). The Fund
notes that the change in control of IDR did not result in any changes in the personnel or operations of IDR or any changes to the day-to-day
management of IDR or the Fund.

Comment 9.	     Given
that the Fund’s investments in real estate, please state whether the Fund intends to utilize wholly-owned or controlled subsidiaries
to implement its strategies. We may have further comments depending on the Fund’s response.

Response
9.	     The Fund does not intend to utilize wholly-owned or controlled subsidiaries to implement
its investment program.

Cover Page

Comment
10.	     The Fund states that it will invest at least 80% of its total assets in real estate
investment vehicles that comprise the NFI-ODCE Index. Please revise the Fund’s 80% policy to clarify that the Fund will invest 80%
of its total assets in the Index given the Fund’s name, which includes the term index.

Response
10.	     The Fund has revised its 80% policy to align with the "80% Policy Proposal" described in the Fund's proxy statement filed July 27, 2023.

Comment
11.	     The Fund states that it intends to rely on exemptive relief from the Commission in
order to issue multiple classes of shares. Please add further disclosure explaining that the Commission has not granted such relief and
that there is no guarantee that such relief will be granted.

Response 11.	     The
disclosure has been revised accordingly.

    – 3  –

Comment
12.	     Please add the year the Sub-Adviser was established to the investment advisers subsection
of the cover page.

Response
12.	     The disclosure has been revised accordingly.

Comment
13.	     Please provide the intervals between deadlines for repurchase requests, pricing and
repayment and, if applicable, the anticipated timing of the Fund’s initial repurchase offer. See Guide 10 to Form N-2.

Response
13.	     The disclosure has been revised accordingly.

Comment
14.	     Please add the following statement to the third bolded bullet on the cover page: “Such
distributions may constitute a return of capital and reduce the amount of capital available to us for investment.”

Response
14.	     The disclosure has been revised accordingly.

Comment
15.	     The fifth bullet states that no secondary market may develop for the Fund’s shares.
If the Fund intends to list Fund Shares, please make this clear in the disclosure. If not, please revise bullet five. Further, reconcile
bullet five with the related disclosure on page 2 regarding the listing of Common Stock.

Response
15.	     The disclosure has been revised accordingly.

Prospectus Summary

Comment
16.	     The Fund states that it will give investors access to real estate investment vehicles
(“Underlying Funds”). Please add disclosure to the investment strategies subsection that clarifies what Underlying Funds,
other than Eligible Component Funds, the Fund may invest in. To the extent that the two terms are coextensive, please use the same defined
term consistently. Please also reconcile definitions for these terms with the disclosure on page 35 of Risks discussion stating that
the Fund will only be investing in Eligible Component Funds. Further, please disclose the percent of total assets that the Fund intends
to invest in Underlying Funds that are not Eligible Component Funds. We may have additional comments.

Response
16.	     The disclosure has been revised accordingly. The Fund expects to invest 100% of net
assets in Eligible Component Funds but has flexibility to invest up to 20% of net assets in Underlying Funds that are not Eligible
Component Funds. The Fund expects that under normal circumstances any investments in Underlying Funds that are not Eligible
Component Funds will be temporary.

    – 4  –

Comment
17.	     Further, the disclosure states that the Fund may invest in “cash equivalents,
short-term investments, or other liquid securities.” Please revise the disclosure to describe the Fund’s principal investments
with specificity. Explain what types of “short-term investments” or “liquid securities” the Fund may invest in.

Response
17.	     The disclosure has been revised accordingly.

Comment
18.	     The Fund states that allocating a portion of an investment portfolio to Underlying
Funds which invest in real estate may provide investors with a steady source of income, portfolio diversification, a hedge against inflation,
and attractive risk-adjusted returns. Please add disclosure to explain why this is the case and that there is no guarantee that the Fund’s
investments will provide these benefits, or delete.

Response
18.	     The disclosure has been revised accordingly.

Comment
19.	     Please add disclosure to describe the index methodology and rules that govern
the index provider’s selection of Eligible Component Funds. Please disclose the number of index components that are normally included
in the index (a range is sufficient) and the number of components that the Fund expects to invest in, under normal circumstances (a range
is acceptable).

Response
19.	     The disclosure has been revised accordingly.

Comment
20.	     The Fund states that: “[M]any investors have not adopted an allocation to real
estate, whether due to the perceived complexity of the asset class, the typically onerous subscription processes, or a lack of guidance
as to how to use real estate in investor portfolios.” Please provide disclosure supporting these statements or delete this disclosure.

Response
20.	     The disclosure has been revised accordingly.

Comment
21.	     The Fund states that it will indirectly bear its pro rata share of expenses including
any fees or expenses that Underlying Fund Managers may pay. “Underlying Fund Managers” is formatted as a defined term, but
it is not defined in the prospectus. Please remedy.

Response
21.	     The disclosure has been revised accordingly.

    – 5  –

Comment
22.	     The Fund states that it intends to rely on exemptive relief from the Commission in
order to issue multiple classes of shares. Please add further disclosure explaining that the Commission has not granted such relief and
that there is no guarantee that such relief will be granted.

Response
22.	     The disclosure has been revised accordingly.

Comment
23.	     (p. 4) In its discussion of investor suitability, the Fund states that Class I
Shares may be made available to, among others, joint venture partners. In your response, please describe the type of joint ventures contemplated
by the disclosure.

Response
23.	     The Fund does not currently expect to use joint venture partners. Accordingly, this has
been struck from the disclosure.

Comment
24.	     (p. 4) Clarify whether recordkeeping or servicing fees will be paid with respect to
Class I Shares.

Response
24.	     The disclosure has been revised accordingly.

Comment
25.	     (p. 7) The Fund states that it has a fundamental policy to invest, under normal
circumstances, 25% or more of its total assets in REITs or companies that otherwise operate in the real estate industry. Please add
this statement to the beginning of the Prospectus Summary which addresses the Fund’s investment strategies.

Response
25.	     The disclosure has been revised accordingly.

Comment
26.	     (p. 10) The Fund states that it may not be able to invest in certain Eligible Component
Funds due to various constraints ((a)-(c)). Please describe the impact of these constraints on the Fund’s ability to track the NFI-ODCE
Index, including any constraints this may place on the Fund’s 80% policy.

Response
26.	     The Fund expects that it will continue to follow its 80% policy to invest in Eligible
Component Funds even if the weightings allocated to Eligible Component Funds change due to various constraints.

    – 6  –

Comment
27.	     (p. 15) The Fund states that certain of its investments in Eligible Component Funds
are likely to be subject to lock-up periods or a suspension in redemptions. Please describe the impact of these constraints on the Fund’s
ability to track the NFI-ODCE Index, including any constraints this may place on the Fund’s 80% policy.

Response
27.	     The Fund expects that it will continue to follow its 80% policy to invest in Eligible
Component Funds even if the weightings allocated to Eligible Component Funds change due to any lock-up periods or suspensions in redemptions.

Comment
28.	     (p. 19) The Fund states that it may declare a “Consent Dividend” which
would result in stockholders experiencing “Phantom Income.” Please disclose how investors will be notified of such Consent
Dividends and add disclosure that investors should consult with a tax professional.

Response
28.	     The disclosure has been revised accordingly.

Summary of Fund Expenses

Comment
29.	     With respect to any fee waivers that are part of the Operating Expense Limitation Agreement,
the staff notes that the waived amounts are subject to a five-year recoupment arrangement. Please discuss in correspondence whether a
liability for the recoupment will be recorded. Please include in the discussion references to ASC 450, ASC 946-20-05-08 and other guidance
including AICPA Investment Company Expert Panel and

Industry Audit Alerts.

Response
29.	     The Fund has revised the discussion of the Operating Expense Limitation Agreement in the
Registration Statement. Under the Operating Expense Limitation Agreement, IDR continues to remain entitled to reimbursement of expenses
it previously waived or reimbursed to the Company, rather than having such reimbursements be paid to the Adviser, and the Adviser will
only be entitled to reimbursement of any fees the Adviser previously waived or expenses the Adviser reimbursed. The Operating Expense
Limitation Agreement has also been revised such that organizational and offering-related expenses are subject to a three-year recoupment
period rather than a five-year recoupment period.

    – 7  –

Comment
30.	     In footnote one to the fee table, the Fund states that Selling Agents may, in their
sole discretion, reduce or waive the selling commission. Please rephrase to state that the Selling Agent may reduce or waive the sale
load, if accurate.

Respo