AB Funds

1345 Avenue of the Americas

New York, NY 10105

March 27, 2020

VIA EDGAR CORRESPONDENCE

Division of Investment Management

Disclosure Review and Accounting Office

U.S. Securities and Exchange Commission

Brookfield Place

200 Vesey Street – Suite 400

New York, NY 10281-1022

Attention: Mindy Rotter

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

Dear Ms. Rotter:

Attached as Appendix A are responses to the comments made during your phone conversation with Phyllis Clarke and other representatives of AllianceBernstein L.P. on February 27, 2020.

If you have any questions regarding our response, please do not hesitate to call me at 914.259.7740.

Sincerely,

/s/ Joseph Mantineo

Joseph Mantineo

Treasurer and Chief Financial

Officer of each Fund

Appendix A

Comment #1: 

Various Funds

The funds did not use the current version of Form N-CSR. For future filings, please use the current version of the form that can be found on the SEC's website.  (It is not necessary to refile previously filed reports as the updates to the form pertain to closed-end funds.)

Response #1: The Funds will use the current version of Form N-CSR for all future filings.

Comment #2:

Funds #: 1- 3, 5-11, 35-43, 45-47 & 69-85

Please confirm in correspondence that there were no open payables to directors at year-end; if there were, these payables should be disclosed separately on the Statement of Assets and Liabilities in accordance with Rule 6-04 of Regulation S-X. 

Response #2: It is the Adviser's policy to disclose open payables to directors separately on the Statement of Assets and Liabilities in accordance with Rule 6-04 of Regulation S-X. In the case of the annual reports noted by the Staff, funds 71-85 had such payables that were not separately disclosed. The annual reports for the other referenced funds separately disclosed such payables. The Adviser will ensure the cited guidance is applied to all funds in the future.

Comment #3:

Funds #: 3, 6-8, 11, 14, 18, 20-21, 23-29, 32, 36, 42, 45, 53, 57-59, 66, 68, 72 & 77

Please confirm that there are no components of accrued expenses and other liabilities that should appear separately on the Statement of Assets and Liabilities. For the referenced funds, certain amounts appear to represent greater than 5%.

Response #3: It is the Adviser's policy to disclose separately any components of accrued expenses and other liabilities that are greater than 5% of the total liabilities on the Statement of Assets and Liabilities. In the case of the annual reports noted by the Staff, funds 6, 7, 8 & 29 had such components that were not separately disclosed. No component of accrued expenses and other liabilities exceeded 5% for the other referenced funds. The Adviser will ensure that components exceeding 5% are disclosed for all funds in the future.

Comment #4:

Funds #: 3, 6-8 & 10

Miscellaneous expenses as presented in the Statements of Operations for the referenced funds exceed 5% of total expenses. Please confirm that any categories of miscellaneous expenses have been separately identified to the extent required by Rule 6-07(2)(b) of Regulation S-X. 

Response #4: It is the Adviser's policy to disclose miscellaneous expenses in the Statement of Operations in accordance with Rule 6-07(2)(b) of Regulation S-X. In the case of the annual reports noted by the Staff, funds 6, 7, 8 and 10 had categories of expenses exceeding 5% of total expenses that were not separately disclosed. No component of miscellaneous expenses exceeded 5% for fund 3. The Adviser will ensure that the cited guidance is applied to all funds in the future.

Comment #5: 

Fund #: 35

Please consider adding disclosure to the Notes to the Financial Statements stating that the distributions received from real estate investment trusts (REITs) may be classified as dividends, capital gains, and/or returns of capital.

Response #5: The Registrant has determined to add the recommended disclosure to this fund’s future shareholder reports.

Comment #6: 

Funds #: 11, 37-51, 53-66, 69,70, 72, 75 & 80-85

The referenced funds disclosed that management was still evaluating the impact of Accounting Standards Update 2017-08 - Receivables - Nonrefundable Fees and Costs (Subtopic 310-20), Premium Amortization on Purchased Callable Debt Securities.  This ASU became effective for fiscal years (and interim periods within fiscal years) beginning after December 15, 2018.  Accordingly, please explain in correspondence why management is still evaluating the impact.

Response #6: The referenced funds were not yet required to disclose the impact of the implementation in the reports reviewed.  As noted, the ASU became effective for fiscal years beginning after December 15, 2018, and all of the reports reviewed were for periods beginning prior to that date.

Comment #7: 

Fund #: 48

Please explain the significant increase in the portfolio turnover rate in comparison to the prior year, as presented in the referenced fund’s Financial Highlights.

Response #7: During the fiscal year, the referenced fund’s portfolio managers identified and traded based on certain opportunities that they believed existed in the markets. The fund’s portfolio turnover rate for the six-month period ended October 31, 2019 (unannualized) returned to the more typical level of approximately 25%.

Comment #8: 

Fund #: 1

Please explain in correspondence how the amount disclosed for expenses net of waivers/reimbursements for Class B shares, as presented in the referenced fund’s Financial Highlights, was derived.

Response #8: The gross expense ratio on Class B shares is 1.88%.  This ratio is reduced by a voluntary fee waiver by the distributor of .60% and a contractual fee waiver by the Adviser of .02% due to the fund’s investment in an affiliated fund.  This results in the reported net expense ratio of 1.26% disclosed in the fund’s Financial Highlights. Pursuant to SEC regulations, the voluntary fee waiver was not reflected in the referenced fund’s prospectus fee table.

Comment #9: 

Fund #: 37

Please explain the difference between the net assets at end of period as presented in the Statement of Assets and Liabilities versus that presented in the Financial Highlights.

Response #9: The difference in net assets was due to adjustments made on the Statement of Assets and Liabilities that were not flowed through to the Financial Highlights. (The Fund will reflect such adjustments in the Financial Highlights included in the semi-annual report for the period ending June 30, 2020.)

Comment #10:

Fund #: 5

Please explain why the expense ratios of 1.84%, 2.71% and 1.64% (for Class A, Class C and Adviser Class shares respectively) in the Management’s Discussion of Fund Performance do not agree with the percentages noted in the referenced fund’s February 28, 2018 prospectus.

Response #10: The referenced fund’s prospectus was supplemented on June 14, 2018 to correct errors in the fee table in the February 28, 2018 prospectus that had the effect of overstating the net expense ratios of the fund. The gross expense ratios in the Management’s Discussion of Fund Performance match those in the prospectus as supplemented.

Comment #11: 

Fund #: 70

The referenced fund’s prospectus applicable at the time of this filing and its website note that the minimum initial investment in the fund is $3,000,000. Please explain in correspondence why the line graph is not based on this amount in accordance with the instructions to Item 27(b)(7)(ii)(A) of Form N-1A. 

Response #11: The Adviser will use the minimum investment of $3,000,000 in the line graphs in the fund’s shareholder reports going forward.

Comment #12: 

Fund #: 27

The staff noted that the registrant responded “Yes” to Item C.6.b of Form N-CEN (regarding securities lending), but responded “N/A” to Item C.6.f.  Please confirm the accuracy of these responses; if a response is incorrect, please provide the required information and consider filing an amended Form N-CEN including this information.

Response #12: The Registrant had only one day of securities lending activity during the fiscal year, and the weighted average value of securities on loan rounded to 0.00. In the past, the Adviser had received a suspension notification from EDGAR for attempting to file with a numeric zero and therefore changed the answer to "N/A" to avoid future suspensions. The Adviser has since confirmed with EDGAR filer support that “0.00” is a valid dollar value and will be filing as such in future filings where applicable.

Appendix B