May 24, 2021

VIA EDGAR

Mr. Tony Burak

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

(Securities Act File No. 333-179904 and

Investment Company Act File No. 811-22649)

Dear Mr. Burak:

This letter responds to your comments with respect to certain of the Trust’s annual reports and post-effective amendments to its registration statement, each of which were filed by the Trust on behalf of the series listed on Appendix A (each, a “Fund,” and together, the “Funds”). The comments were provided by the SEC staff (the “Staff”) in a telephone conversation on April 19, 2021. For your convenience, the Staff’s comments are summarized below, and each comment is followed by the Trust’s response. Capitalized terms have the meanings assigned in each Fund’s prospectus unless otherwise defined in this letter. The following responses apply to each Fund unless stated otherwise.

Comment 1: A statement in “General Information – Availability of Quarterly Schedule of Investments” of the Funds’ annual reports indicates that quarterly schedules of investment are available on a Fund’s website and refers specifically to Form N-Q. In future reports, please revise the reference to include Form N-PORT also.

Response: Starting with the Funds’ annual report for the fiscal year ended September 30, 2020 and in subsequent annual reports, the “General Information – Availability of Quarterly Schedule of Investments” section states the following, which includes a reference to Form N-PORT: “The iShares Funds file their complete schedule of portfolio holdings with the SEC for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The iShares Funds’ Forms N-PORT are available on the SEC’s website at sec.gov.”

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If you have any questions or need further information, please call me at (202) 303-1124.

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APPENDIX A

A-1