March 16, 2018

Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office

100 F Street, N.E.
Washington, D.C. 20549
Attn: Christina DiAngelo Fettig

Re: Deutsche Funds

Dear Ms. Fettig:

Thank you for your telephonic comments on January 8, 2018 regarding the Deutsche Funds listed below. We have considered your comments and have included our responses below.

The Registrants referenced in the response include:

Deutsche Massachusetts Tax-Free Fund

The Central Europe, Russia and Turkey Fund, Inc.

Deutsche Real Estate Securities Fund

Deutsche Global Infrastructure Fund

Deutsche Enhanced Emerging Markets Fixed Income Fund

We confirm that these Funds continue to be classified as non-diversified Funds. In the event they should convert to diversified status by Board action or under current SEC interpretation of Section 13(a)(1) and Rule 13a-1, we confirm that shareholder approval would be obtained to convert the Funds back to non-diversified.

 We have updated our “Regional focus risk” disclosure for the Deutsche Latin America Equity Fund effective February 1 to include the following:

The fund typically invests a large portion of its assets in common stocks of companies in Brazil, and, therefore, adverse developments in Brazil may have a significant impact on the fund’s performance.  Investments in Brazil are subject to foreign investment risk, currency risk, Latin America risk and emerging markets risk, among other risks described herein.

Additionally, we had added additional disclosure to the “Latin America risk” to indicate that securities of companies in Latin America countries may be subject to significant price volatility which could impact fund performance.  

We note that Deutsche CROCI® International Fund VIP, as well as other Deutsche funds investing in foreign securities, include risk disclosure regarding investing in foreign countries, including the effect of Brexit on global markets. We have updated Brexit disclosure effective February 1, 2018 and will include it in relevant Fund annual prospectus updates going forward.

We note that the stock market risk included in each Fund’s prospectus, except Deutsche High Income VIP which does not have stock market risk disclosure, includes disclosure relating to the impact to performance associated with focusing on a particular sector. Nonetheless, we have added Focus Risk to the Fund prospectuses for those Funds updating on February 1 (Deutsche Capital Growth Fund, Deutsche Emerging Markets Equity Fund and Deutsche Latin America Equity Fund), and will add such disclosure to the other Fund prospectuses in their next annual registration update.

For each of the Deutsche Capital Growth Fund and Deutsche Short-Term Municipal Bond Fund which updated their registration statements on February 1, 2018, disclosure regarding instruments referenced in the above chart has been moved to “Fund Details” under “Other Investment Strategies” in each Fund’s statutory prospectus. We will evaluate each Fund’s use of the relevant instruments in connection with its next prospectus update to determine whether a similar change is appropriate.

The Deutsche Global Income Builder Fund and Deutsche Global Income Builder VIP were each complying with the investment policy that requires each Fund to invest at least 25% of net assets in fixed income senior securities as of January 29, 2018.

 
Each of these Funds currently invests more than 40% of its assets in foreign securities and invests in more than three countries, one of which is the U.S. Further, Deutsche Global Real Estate Securities Fund’s prospectus indicates that it will invest a significant amount of its assets in non-US issuers and the Deutsche Global Small Cap Fund has a non-fundamental policy to generally invest in at least three different countries. Accordingly, we believe that each Fund’s name is appropriate given its investment portfolio. We are not aware that the Staff has issued written guidance to require a 40% investment policy and, therefore, would prefer not to add such an investment policy at this time. However, we will continue to evaluate whether such a policy may be appropriate in the future.

 
In response to prior comments from the Staff of the Securities and Exchange Commission provided on January 19, 2012, to consider adding disclosure to the Fund’s summary prospectus relating to the Fund’s dollar-weighted average effective portfolio maturity as of a particular date, the Fund includes disclosure in the summary section of the Fund’s prospectus under “Main investments” in the section entitled “Principal Investment Strategy” to reflect its dollar-weighted average effective portfolio maturity as of a recent date.

In the “Fund Details” section of the statutory prospectus under “Other Policies,” the Fund has disclosure indicating that “From time to time the fund may have a concentration of shareholder accounts holding a significant percentage of shares outstanding. Investment activities of these shareholders could have a material impact on the fund.” Accordingly, we do not believe that additional risk disclosure is needed at this time.

In the “Fund Details” section of the statutory prospectus under “Liquidity risk,” the following disclosure is currently included:

Senior loans may have longer trade settlement periods than other types of investments which could result in the fund not receiving the proceeds from a sale of a senior loan for an extended period after such sale. To the extent that other sources of liquidity are unavailable, the uncertainty of trade settlement periods could lead to shortfalls in cash needed to handle fund redemptions, especially during periods of heavy redemption activity.

Accordingly, we do not believe that additional risk disclosure is needed at this time.

On September 28, 2017, the Deutsche Small Cap Growth Fund acquired the Deutsche Mid Cap Growth Fund. The “other accrued expenses and liabilities” of the Deutsche Small Cap Growth Fund as of September 30, 2017 includes $363,949 of liabilities from the acquired Deutsche Mid Cap Growth Fund.

For each of the annual reports dated December 31, 2016, pricing expense, which is included in “Other expenses,” represents 9% of gross expenses for the Deutsche Bond VIP and 13% of gross expenses for Deutsche U.S. Bond Index Fund. For future reports, any expense over 5% of gross expenses will be separately disclosed. There were no other expense greater than 5% of gross expenses.

As disclosed in the “Financial Highlights” section of the annual report, the Deutsche EAFE® Equity Index Fund received a non-recurring payment for overbilling of prior years’ custodian out-of-pocket fees. The entire “Other income” represents this payment received. Accordingly, we believe this not-recurring payment is adequately disclosed.

On October 3, 2016, the portfolio management team changed. Although the principal management process of bottom up stock selection did not change, the investment portfolio was repositioned. As a result of this portfolio management change, a prospectus supplement, dated September 28, 2016, was issued to update

the Portfolio Manager and to update the investment process changes. On September 29, 2016, the prospectus supplement was mailed to existing shareholders

We can confirm that return of capital distributions were in compliance with Rule 19a-1 under the Investment Company Act of 1940, as amended.

 In future filings, we will update the certifications to reflect the new filing date.

In future reports we will include the following accounting policy for liquidity fees and redemption gates:

Liquidity Fees and Gates. The Fund may impose a liquidity fee on redemptions of up to 2% of the value of shares redeemed and/or temporarily suspend (gate) redemptions for up to 10 business days in any 90 day period in the event that the Fund’s weekly liquid assets fall below designated thresholds. Any liquidity fees imposed are retained by the Fund for the benefit of the remaining shareholders and are recorded as an addition to paid-in-capital. There were no liquidity fees or gates imposed for the period ended _______.

 
The Deutsche Central Cash Management Government Fund and Government Cash Management Portfolio each comply with the monthly website disclosure as required by the 2010 amendments to the rules that govern money market funds.

We note that income on bank loans, other than interest income, was less than 5% of gross income on each of the funds. For future reports, income on bank loans, other than interest income, if material, will be separately disclosed.

In order to comply with the requirements of Section 18 of the 1940 Act for Tender Option Bonds, each Fund segregates liquid assets in an amount equal to the principal amount of the floating rate note plus six months of accrued interest, if any.

In future filings, we will include the date the information is provided for Item 8A (1) and 8A (3).

We note that the feeder financial statements include the financial statements for the master, including disclosure for the portfolio turnover of the master portfolio in the master portfolio’s financial highlights. Nonetheless, in future filings, we will include the portfolio turnover of the master portfolio in the financial highlights of the feeder portfolio.

In future filings, we will include our affiliated cash management vehicle, Deutsche Central Cash Management Government Fund, and our affiliated security lending cash sweep vehicle, Deutsche Government & Agency Securities Portfolio in the affiliated table. For the Deutsche Government & Agency Securities Portfolio we do not have purchase and sale information at the Fund level since the collateral investment to/from the investment vehicle is done at the aggregate level by the lending agent as opposed to the Fund level. As such, in the affiliated table we will include a net purchase and sale number for the Deutsche Government & Agency Securities Portfolio.

We note that the number of shares or principal amount and information required by footnotes 2 and 5-9, as applicable, are included in the “Investment Portfolio.” In future reports, we will also include these items, as applicable, in the affiliated table.

If you have any questions concerning the foregoing, or need further information, please contact the undersigned at (617) 295-2663.

Sincerely,

/s/Paul Schubert 

Paul Schubert

Managing Director, Deutsche Investment Management Americas Inc.

Treasurer, Deutsche Funds