May 11, 2018

Mr. James O’Connor

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:

American Beacon Funds (File No. 811-04984) Registration Statement on Form N-1A

Dear Mr. O’Connor:

The following are responses by and on behalf of the American Beacon Funds (“Registrant”) to the comments received from you on April 10, 2018, regarding the presentation of performance information in recent prospectuses for the various series of the Registrant (each, a “Fund” and collectively, the “Funds”).  Your comments and the Registrant’s responses are set forth below.

1.

Review the prospectuses for all Funds in the complex and identify any Funds that do not accurately reflect in the Funds’ average annual total returns table the deduction of the maximum applicable sales charges.

The Registrant has reviewed the performance information presented in the Funds’ average annual total returns tables in the prospectuses for all Funds and share classes.  The performance information in the average annual total returns tables in those prospectuses accurately reflects the deduction of the maximum applicable sales charges, except as follows:  (1) with respect to each Fund that offers A Class shares, the average annual total returns table for all time periods reflects accurate NAV-based performance, but without the deduction of the maximum applicable sales charge imposed on purchases; and (2) with respect to each Fund that offers C Class shares, the average annual total returns table for the one-year period reflects accurate NAV-based performance, but without the deduction of the maximum applicable contingent deferred sales charge.  In conducting the review of the average annual total returns table for all Funds in the complex, the Registrant identified, with respect to the American Beacon Large Cap Value Fund, that, as a result of isolated clerical errors, the average annual total returns table for the one-year period does not accurately reflect the performance of the Y Class shares and the average annual total returns table for the one-year and five-year periods does not accurately reflect the performance of the R6 Class shares.  A list of the affected Funds and share classes is attached as Exhibit A.

2.

Please explain to us whether the Funds’ marketing materials also fail to accurately reflect the deduction of the maximum applicable sales charges in the standardized performance presentation included in those materials.

The standardized performance presentation included in the marketing materials for each Fund is fully correct, other than with respect to A Class shares of the American Beacon Grosvenor Long/Short Fund (“Grosvenor Fund”).  The standardized performance information in the marketing materials for the A Class shares of the Grosvenor Fund reflected the deduction of a front-end sales charge of 4.75% (which is the maximum A Class sales load for certain other Funds that offer Class A shares) rather than 5.75%, which is the maximum sales charge assessed on sales of Grosvenor Fund A Class shares.  The Grosvenor Fund maximum sales charge was correctly disclosed in the prospectus and marketing materials as 5.75%.  As noted in the table attached as Exhibit B, the Grosvenor Fund sold a total of only $20,000 of A Class shares with a sales load throughout the relevant period.

3.

For each Fund that has not disclosed accurate performance information in the average annual total return tables, provide to the Securities and Exchange Commission (“SEC”) staff: (a) the date the Fund began using incorrect performance information, and (b) the number and dollar value of shares sold for those classes that had incorrect performance information.

A table providing the requested information is included in Exhibit B.  In addition to the information that you requested, Exhibit B also includes the number and dollar value of the A Class shares sold by each Fund without the imposition of any sales load.  This additional data reflects that the great majority of A Class shares were sold without a sales load imposed.  The information regarding the number and dollar value of shares sold is provided from the date that the Fund began using incorrect performance information to April 18, 2018.

4.

Please explain how the Registrant intends to address this issue.

On April 18, 2018, the Registrant filed with the U.S. Securities and Exchange Commission (“SEC”) a supplement to the prospectuses and summary prospectuses revising the average annual returns tables for the Funds listed in Exhibit A to reflect performance information for the A Class and C Class shares that reflects the deduction of the maximum applicable sales charge.  The supplement explains that the performance information for A Class and C Class shares included in the original performance table did not reflect the deduction of applicable sales charges, and that the returns for A Class shares (for all periods) and C Class shares (for the 1-year period) are lower than the returns that were previously disclosed.  The supplement also revised the performance information reflected for the Y Class and R6 Class shares of the Large Cap Value Fund for the one-year period.  The supplement has been distributed to all affected shareholders.  A copy of the supplement is attached as Exhibit C.

On April 18, 2018, the Registrant also filed with the SEC summary prospectuses that have been updated to reflect the revised performance information.

On April 16, 2018, the Grosvenor Fund A Class performance was revised to reflect the correct sales load in the Registrant’s monthly Performance at a Glance – A Class flyer that included performance as of March 31, 2018.  On April 19, 2018, the Registrant updated its website to reflect the deduction of the 5.75% front-end sales load on Grosvenor Fund A Class shares.  No other marketing materials for the Grosvenor Fund include A Class performance data.

5.

Please describe any procedures that the Registrant will establish to ensure that this error does not occur in the future.

The Registrant is reinforcing its policies and procedures with respect to the preparation and review of the Funds’ performance disclosures to ensure that: (1) data provided to service providers for calculation of Fund performance is accurate, and (2) the performance information included in the Funds’ prospectuses reflects the maximum applicable sales charges.  In addition, although a third party service provider calculates performance information for the Registrant to publish in its prospectuses and marketing materials, the Registrant also performs its own calculations for comparison as an additional safeguard to ensure the accuracy of the information.  Differences between the two performance calculations can occur due to rounding. Registrant has reinforced its procedures to ensure that the correct performance information is used. The Registrant has also clarified roles and responsibilities of personnel responsible for reviewing performance information and additional training will be conducted to ensure that regulatory requirements are met.

 

If you have any questions regarding the matters discussed above, please feel free to call me at (202) 778-9015.

 

Sincerely,

/s/ Kathy Kresch Ingber

Kathy Kresch Ingber

cc:	Rosemary Behan Diana Lai Teresa Oxford    American Beacon Advisors, Inc.

 

 

EXHIBIT A

 

AFFECTED FUNDS AND SHARE CLASSES

 

 

 

 

EXHIBIT B

 

[To be provided under separate cover.]

 

 

 

 

 

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