[Invesco Letterhead]
February 12, 2019
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
100 F Street NE
Washington, DC 20549
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Re:
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AIM Sector Funds (Invesco Sector Funds)
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CIK No. 0000725781; File No. 333-229241
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Ladies and Gentlemen:
In accordance with
Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, AIM Sector Funds (Invesco Sector Funds)
(the “Registrant”) and Invesco Distributors, Inc., the distributor of the Registrant’s shares, hereby request acceleration of the effective date of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-14 (File
No. 333-229241) so that such Registration Statement may be
declared effective on February 13, 2019, or as soon as practicable thereafter.
The Registrant hereby
acknowledges that: (1) should the Securities and Exchange Commission (the “Commission”) or its staff (“Staff”), acting pursuant to delegated authority, declare the above-referenced registration statement effective, it does not foreclose the
Commission from taking any action with respect to the filing; (2) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filing and the Staff’s comments, the Registrant’s changes to the disclosure in response to the
Staff’s comments or the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, do not relieve the Registrant of this responsibility; and (3) the Registrant may not assert this action or
the Staff’s comments as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States.
Please send copies of all correspondence with respect to this request for acceleration to the undersigned or contact me at
(713) 214-7888.
Very truly yours,
AIM Sector Funds (Invesco Sector Funds)
/s/ Peter A. Davidson
Peter A. Davidson
Assistant General Counsel
Invesco Distributors, Inc.
/s/ Peter A. Davidson
Peter A. Davidson
Assistant Secretary