CORRESP 1 filename1.htm






February 23, 2026

VIA EDGAR

Mr. David Manion
Division of Investment Management
Securities and Exchange Commission
100 F Street N.E.
Washington DC  20549

 
RE:
AIM Counselor Series Trust (Invesco Counselor Series Trust) (File No. 811-09913), AIM International Mutual Funds (Invesco International Mutual Funds) (File No. 811-06463), AIM Investment Funds (Invesco Investment Funds) (File No. 811-05426), AIM Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686), Invesco Management Trust (File No. 811-22957), AIM Sector Funds (Invesco Sector Funds) (File No. 811-03826), AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds) (File No. 811-07890), AIM Treasurer's Series Trust (Invesco Treasurer's Series Trust) (File No. 811-05460), and Short-Term Investments Trust (File No. 811-02729), Invesco Actively Managed Exchange-Traded Fund Trust (File No. 811-22148), Invesco Exchange-Traded Fund Trust (File No. 811-21265), Invesco Exchange-Traded Fund Trust II (File No. 811-21977), and Invesco Exchange-Traded Self-Indexed Fund Trust (File No. 811-23304), Invesco Advantage Municipal Income Trust II (File No. 811-07868), Invesco Bond Fund (File No. 811-02090), Invesco California Value Municipal Income Trust (File No. 811-07404), Invesco High Income Trust II (File No. 811-05769), Invesco Municipal Income Opportunities Trust (File No. 811-05597), Invesco Municipal Opportunity Trust (File No. 811-06567), Invesco Municipal Trust (File No. 811-06362), Invesco Pennsylvania Value Municipal Income Trust (File No. 811-07398), Invesco Quality Municipal Income Trust (File No. 811-06591), Invesco Senior Income Trust (File No. 811-08743), Invesco Senior Loan Fund (File No. 811-05845), Invesco Trust for Investment Grade Municipals (File No. 811-06471), Invesco Trust for Investment Grade New York Municipals (File No. 811-06537), Invesco Value Municipal Income Trust (File No. 811-06590) (each, a “Registrant” and collectively, the “Registrants”)

Dear Mr. Manion:

On behalf of the Registrants and each respective series of the Registrants listed in Exhibit A, as applicable (each such mutual fund or ETF, a “Fund,” and collectively, the “Funds”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”) to the undersigned on January 16, 2026, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR and Form N-CEN for the fiscal years ended on the dates listed in Exhibit A, as applicable.

The Staff’s comments are summarized below in italicized text. The Registrants’ responses are set out immediately under the restated comment.

Global Comments

1.
Comment:
The N-CSR disclosure states, in the Notes to the Financials – Segment Reporting, that the Adviser will act as a Fund’s chief operating decision maker (“CODM”). Please consider naming the titles of the persons at the Adviser that comprise the “group” acting as the CODM. Alternatively, please explain how all personnel of the Adviser are considered a group for purpose of the CODM definition. See Accounting Standards Codification (ASC) 280-10-50-5.
     
 
Response:
The Registrants have revised the applicable disclosure to name the titles of the persons at the Adviser that comprise the group acting as the CODM. The revised disclosure is below (underlined language added):

   
“Subject to the oversight and, when applicable, approval of the Board of Trustees, portfolio managers and senior executives at the Adviser act as the Trust’s chief operating decision maker (“CODM”), assessing performance and making decisions about resource allocation within the Trust.” 
     
2.
Comment:
The Funds’ N-CEN filings do not consistently report the Legal Entity Identifier (“LEI”) for each of the Funds’ custodians. Please include the LEI for the Funds’ custodians in future N-CEN filings.
     
 
Response:
The Registrants acknowledge that the LEI for certain sub-custodians was omitted from the Funds’ N-CEN filings and will be included in future filings.
     
Fund Specific Comments
     
3.
Comment:
Invesco Pennsylvania Municipal Fund appears to have had a net asset value (“NAV”) error during the fiscal year ended February 28, 2025. Please describe the nature and circumstances of the NAV error, associated internal control implications, mitigating actions, and whether any related reprocessing or reimbursement has been completed.
     
 
Response:
A NAV error occurred with respect to Invesco Pennsylvania Municipal Fund for one day due to the improper application of a valuation for a manually priced fixed income security. The error was identified the following day by the Registrant during the daily review of manually priced securities, a key control within the valuation process. Upon review, the controls were deemed reasonable and have been reinforced and, where necessary, enhanced to prevent recurrence. Shareholder redemptions were reprocessed and the third-party administrator reimbursed the Fund for losses associated with shareholder subscriptions affected by the error.
     
4.
Comment:
The Schedule of Investments in the N-CSR filings for certain Funds, such as Invesco Limited Term Municipal Income Fund and Invesco Rochester Municipal Opportunities Fund, show that the Funds hold MuniFund Preferred Shares. The footnote related to the Funds’ MuniFund Preferred Share holdings does not disclose the applicable rates of those holdings. Please include such information in future N-CSR filings.
     
 
Response:
The applicable rates for MuniFund Preferred Shares held by the Funds will be included in future N-CSR filings, as requested.
     
5.
Comment:
Certain Funds hold loans that are tied to an applicable reference rate; however, the rate shown in the financial statements does not tie to the applicable reference rate. For example, see X Corp. held by Invesco Corporate Bond Fund, Invesco High Yield Fund and Invesco Short-Term Bond Fund. Please explain how the rates shown in the financial statements were determined and how they reconcile to the applicable reference rates.
     
 
Response:
The Registrants acknowledge that although the reference rates disclosed within the Schedules of Investments were accurate, the end of period rate disclosed for certain loans was inadvertently understated. The end of period rate has been corrected within the Schedules of Investments issued subsequent to the period reviewed as shown in Exhibit A.
     
6.
Comment:
The N-CSR filings for certain Funds do not include the required disclosure regarding the usage of certain derivatives in the Notes to the Financials. Specifically, the usage for call options purchased and written is not included; see
2

   
Invesco Bond Fund as an example. Please add such disclosure in the Notes to the Financials in future N-CSR filings.
     
 
Response:
The Notes to the Financials related to derivatives used by the Funds will be reviewed to confirm that all such Notes include the requisite disclosure regarding derivatives usage.  Specifically, the Note “Call Options Purchased and Written” included in the Notes to the Financials for certain Funds, including Invesco Bond Fund, will be updated to include the specific usage of call options purchased and written.
     
7.
Comment:
The Statement of Assets and Liabilities for Invesco Senior Income Trust and Invesco Municipal Income Opportunities Trust show receivables for “Fund expenses absorbed.”   Please explain the transactions to which these receivables relate.
     
 
Response:
The Registrants confirm that the receivables for “Fund expenses absorbed” represent amounts related to deferred offering costs incurred in connection with the common share “shelf” registration pursuant to Rule 415 under the Securities Act of 1933, as amended. Costs incurred by the Funds in relation to the shelf offering are recorded as deferred offering costs and amortized pro rata as common shares are sold. Effective with the August 31, 2025 reporting cycle, Invesco updated the presentation to classify these as prepaid expenses on the Statement of Assets and Liabilities.
     
8.
Comment:
The Notes to the Financials in the N-CSRs for the Invesco Corporate Bond BulletShares ETFs and Invesco High Yield BulletShares ETFs include disclosure regarding Rule 17a-7 transactions conducted by such ETFs that appear to be related to Level 2 securities. Please explain how such transactions comport with Rule 17a-7 and Rule 2a-5 which defines readily available market quotations to mean “a market quotation is readily available only when that quotation is a quoted price (unadjusted) in active markets for identical investments that the fund can access at the measurement date, provided that a quotation will not be readily available if it is not reliable.”
     
 
Response:
Section 17(a) of the 1940 Act prohibits the purchase or sale of securities between a registered fund and its affiliates. Rule 17a-7 was adopted to address potential affiliated transaction issues raised by cross-trades. Rule 17a-7, as pertinent here, exempts from the prohibitions of Section 17(a) certain purchases and sales between registered investment companies or separate series of registered investment companies and certain affiliated persons, where any affiliation arises solely because they have a common investment adviser.1  To rely on the exemption, among other conditions set forth in the rule, the transactions must be purchases or sales of a security “for which market quotations are readily available.” Certain debt instruments, however, may not have an active trading market but can be valued using alternative approaches of “Level 2” fair valuation that ensure appropriate fair valuation of the securities. The


1 The SEC has indicated its view that investment companies that share a common investment adviser (or have investment advisers that are affiliated persons of one another) may be deemed to be “under common control”.  See Payment of Asset-Based Sales Loads by Registered Open-End Mgmt. Inv. Companies, Release No. IC-16431 (June 13, 1988) (“Funds that share a common investment adviser may, depending on the circumstances, be deemed to be under common control, and, therefore, to be “affiliated persons” of each other under section 2(a)(3)(C) of the [1940] Act”). But see Exemption of Certain Purchase or Sale Transactions Between A Registered Inv. Co. & Certain Affiliated Persons Thereof, Release No. IC-11676 (Mar. 10, 1981) (“[R]ule [17a-7] does not represent a Commission finding that investment companies having common officers, directors or investment advisers are always affiliated persons or affiliated persons of an affiliated person. They may or may not be, depending on the facts. The rule enables the parties to go forward without resolving that question if the requirements of the rule are met.”)
3

   
SEC staff has granted a series of no-action letters that permit cross trades in reliance on such Level 2 valuations. 2
     
   
The Invesco BulletShares ETFs invest in these types of Level 2 valued securities.  In order to reduce costs to their shareholders, the Invesco Corporate Bond BulletShares ETFs, and Invesco High Yield BulletShares ETFs engage in cross-trades (specifically, with other Invesco BulletShares ETFs that invest in the same respective fixed-income asset classes) in reliance on these no-action letters issued by the SEC staff. In issuing such no-action relief, the SEC staff in United Municipal Bond Fund I agreed that it would not recommend that the SEC take any enforcement action under Section 17(a) of the 1940 Act if an open-end fund, in reliance on Rule 17a-7, engaged in a cross trade for municipal bonds for which market quotations are not readily available, provided that the fund complied with the following conditions:
     
   
(1) the bonds are valued by averaging prices obtained from at least three independent matrix pricing services, or by averaging three independent bid prices, or by averaging three prices obtained from some combination of independent pricing services and independent bid prices;
(2) the independent matrix pricing services are not affiliated persons of the Funds or affiliated persons of affiliated persons of the Funds as defined in Section 2(a)(3) of the 1940 Act;
(3) the independent matrix pricing services are not engaged directly or through affiliated persons in underwriting or distributing the municipal bonds;
(4) no brokerage commission, fee (except for customary transfer fees and matrix pricing servicing fees) or other remuneration is paid in connection with the transactions; and
(5) the funds comply with paragraphs (c), (e), and (f) of Rule 17a-7.3
     
   
In cross trading their respective securities, the Invesco BulletShares Municipal Bond ETFs, the Invesco Corporate Bond BulletShares ETFs and Invesco High Yield BulletShares ETFs comply with these stated conditions for relief under these letters.
     
   
We note that in the Rule 2a-5 Adopting Release, when discussing how new definitions in the rule might limit the ability of funds to engage in cross-trades, the SEC cited to United Municipal Bond Fund I and United Municipal Bond Fund II and noted that the letters remain in effect.4  As the SEC neither rescinded nor expressly limited the scope of the Municipal Bond Fund Letters either at the time it adopted Rule 2a-5 or subsequent to that rule’s issuance, the Registrant is of the view that the letters currently remain available.  We are unaware of any statement from the SEC staff indicating these letters have been withdrawn. As a result, the Funds believe that the cross-trading of fixed-income securities by the


2 See United Municipal Bond Fund, SEC No-Action Letter (pub. avail. July 30, 1992) (“United Municipal Bond Fund I”); United Municipal Bond Fund, SEC No-Action Letter (pub. avail. Jan. 27, 1995) (“United Municipal Bond Fund II”); and Federated Municipal Funds, SEC No-Action Letter (pub. avail. Nov. 20, 2006) (“Federated”) (collectively, the “Municipal Bond Fund Letters”).
3 Subsequent to the issuance of United Municipal Bond Fund I, the staff issued United Municipal Bond Fund II, which endorsed United Municipal Bond Fund I and modified the requirements of the earlier letter to permit the use an evaluated price provided by a single, independent pricing service.  Later, in issuing the Federated letter, the staff reasserted the positions taken in both United Municipal Bond Fund I and United Municipal Bond Fund II and clarified that any independent pricing service may be used.
4 See Good Faith Determination of Fair Value, SEC Rel. No. IC-34128 (Dec. 3, 2020) at pp. 94-95 (“Rule 2a-5 Adopting Release”): “We also understand that many cross trades today are done taking into consideration certain letters by our staff that address, among other things, the application of the term readily available market quotations in the context of certain transactions under rule 17a-7.  The staff is reviewing these letters to determine whether these letters, or portions thereof, should be withdrawn. Separately, consideration of potential revisions to rule 17a-7 is on the rulemaking agenda.  We welcome input from the public as we undertake our consideration of rule 17a-7.”
4

   
Invesco Corporate Bond BulletShares ETFs and Invesco High Yield BulletShares ETFs involves facts and circumstances that are substantially similar to those described in the Municipal Bond Fund Letters and have made such trades (at significant cost savings to fund shareholders) in reliance on the relief promulgated in those letters.
     
9.
Comment:
The Statement of Assets and Liabilities for Invesco MSCI EAFE Income Advantage ETF, Invesco S&P 500 Equal-Weighted Advantage ETF, and Invesco QQQ Income Advantage ETF show receivables for “Fund expenses absorbed” yet these ETFs have a unitary fee. Please explain what expenses were absorbed.
     
 
Response:
The receivables for “Fund expenses absorbed” consist of a receivable balance due from the Adviser. All three Funds commenced operations on July 15, 2024, and the Adviser had agreed to waive 100% of each Fund’s unitary management fee through June 30, 2025, as disclosed in Note 3 footnote (b) in the Notes to Financial Statements. Each Fund accrues the unitary management fee daily, recording a corresponding payable to the Adviser. Simultaneously, an offsetting waiver of the unitary fee is booked daily, creating a corresponding receivable from the Adviser. These payable and receivable accounts are relieved monthly for the prior month’s activity.
     
10.
Comment:
Please explain why, with respect to each of Invesco Food & Beverage ETF, Invesco NextGen Media & Gaming ETF, Invesco Oil & Gas Services ETF, Invesco RAFI US 1000 ETF and Invesco RAFI US 1500 Small-Mid ETF, accrued recapture fees for the Fund exceed the Fund’s recapture expenses for the year.
     
 
Response:
The Registrants confirm the amounts and disclosures related to accrued recapture fees do not exceed the potential recapture expenses for the period. The recapture expenses disclosed in the Notes to Financial Statements represent the amounts available for potential future recapture by the Adviser. Additionally, the payable for “Expenses recaptured” reported on the Statement of Assets and Liabilities is based on the potential future recapture amounts as of the fiscal year ended April 30, 2024.

Please do not hesitate to contact me at 713-214-4345 if you have any questions or wish to discuss any of the responses presented above.

Sincerely,


/s/ Adrien Deberghes
Adrien Deberghes
Principal Financial Officer, Treasurer and Vice President of the Registrants for the Open-End and Closed-End Funds and Vice President of the Registrants for the ETFs

cc:
Kelli Gallegos
 
Melanie Ringold
 
Taylor Edwards
 
Patricia Jones
 
Mark Greer
 
Adam Henkel
 
Mena Larmour


5

EXHIBIT A

Series ID
File No
Series Name
Registrant Name
FYE Reviewed
S000027822
811-09913
Invesco American Franchise Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000025657
811-09913
Invesco Core Plus Bond Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000064618
811-09913
Invesco Discovery Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000064617
811-09913
Invesco Discovery Large Cap Fund (fka Invesco Capital Appreciation Fund)
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000027808
811-09913
Invesco Equity and Income Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000011801
811-09913
Invesco Floating Rate ESG Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000014560
811-09913
Invesco Global Real Estate Income Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000027810
811-09913
Invesco Growth and Income Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000008063
811-09913
Invesco Income Advantage U.S. Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000027821
811-09913
Invesco S&P 500 Index Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000051015
811-09913
Invesco Short Duration High Yield Municipal Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000064614
811-09913
Invesco Short Term Municipal Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000079749
811-09913
Invesco SMA Municipal Bond Fund
AIM Counselor Series Trust (Invesco Counselor Series Trust)
8/31/2025
S000064622
811-06463
Invesco Global Focus Fund
AIM International Mutual Funds (Invesco International Mutual Funds)
10/31/2024
S000064693
811-05426
Invesco Emerging Markets Local Debt Fund
AIM Investment Funds (Invesco Investment Funds)
10/31/2024
S000000234
811-05426
Invesco EQV Emerging Markets All Cap Fund
AIM Investment Funds (Invesco Investment Funds)
10/31/2024
S000064708
811-05426
Invesco Global Strategic Income Fund
AIM Investment Funds (Invesco Investment Funds)
10/31/2024
S000064709
811-05426
Invesco International Bond Fund
AIM Investment Funds (Invesco Investment Funds)
10/31/2024
S000064699
811-05426
Invesco SteelPath MLP Alpha Fund
AIM Investment Funds (Invesco Investment Funds)
11/30/2024
S000064701
811-05426
Invesco SteelPath MLP Alpha Plus Fund
AIM Investment Funds (Invesco Investment Funds)
11/30/2024
S000064700
811-05426
Invesco SteelPath MLP Income Fund
AIM Investment Funds (Invesco Investment Funds)
11/30/2024
S000064698
811-05426
Invesco SteelPath MLP Select 40 Fund
AIM Investment Funds (Invesco Investment Funds)
11/30/2024
S000027851
811-05686
Invesco Corporate Bond Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000010736
811-05686
Invesco Global Real Estate Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
6

S000000253
811-05686
Invesco Government Money Market Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000000243
811-05686
Invesco High Yield Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000000251
811-05686
Invesco Income Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000000255
811-05686
Invesco Real Estate Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000000252
811-05686
Invesco Short Duration Inflation Protected Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000000256
811-05686
Invesco Short Term Bond Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000079750
811-05686
Invesco SMA High Yield Bond Fund
AIM Investment Securities Funds (Invesco Investment Securities Funds)
2/28/2025
S000027834
811-03826
Invesco Comstock Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000064612
811-03826
Invesco Comstock Select Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000000161
811-03826
Invesco Dividend Income Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000000155
811-03826
Invesco Energy Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000027837
811-03826
Invesco Small Cap Value Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000000160
811-03826
Invesco Technology Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000027840
811-03826
Invesco Value Opportunities Fund
AIM Sector Funds (Invesco Sector Funds)
4/30/2025
S000064640
811-07890
Invesco AMT-Free Municipal Income Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064641
811-07890
Invesco California Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064634
811-07890
Invesco Environmental Focus Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000027866
811-07890
Invesco High Yield Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000027868
811-07890
Invesco Intermediate Term Municipal Income Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064642
811-07890
Invesco Limited Term California Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000000172
811-07890
Invesco Limited Term Municipal Income
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000027869
811-07890
Invesco Municipal Income Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064639
811-07890
Invesco New Jersey Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064637
811-07890
Invesco Pennsylvania Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
7

S000064636
811-07890
Invesco Rochester Limited Term New York Municipal Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064638
811-07890
Invesco Rochester Municipal Opportunities Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000064635
811-07890
Invesco Rochester New York Municipals Fund
AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds)
2/28/2025
S000000173
811-05460
Invesco Premier Portfolio
AIM Treasurer's Series Trust (Invesco Treasurer's Series Trust)
8/31/2025
S000000176
811-05460
Invesco Premier U.S. Government Money Portfolio
AIM Treasurer's Series Trust (Invesco Treasurer's Series Trust)
8/31/2025
S000078941
811-22148
Invesco AAA CLO Floating Rate Note ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000023365
811-22148
Invesco Active U.S. Real Estate ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000068054
811-22148
Invesco High Yield Bond Factor ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000078942
811-22148
Invesco High Yield Select ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000085179
811-22148
Invesco MSCI EAFE Income Advantage ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000085601
811-22148
Invesco QQQ Income Advantage ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000078943
811-22148
Invesco Rochester High Yield Municipal ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000036643
811-22148
Invesco S&P 500 Downside Hedged ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000085602
811-22148
Invesco S&P 500 Equal Weight Income Advantage ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000078944
811-22148
Invesco Short Duration Total Return Bond ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000060784
811-22148
Invesco Total Return Bond ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000060783
811-22148
Invesco Ultra Short Duration ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
S000051678
811-22148
Invesco Variable Rate Investment Grade ETF
Invesco Actively Managed Exchange-Traded Fund Trust
10/31/2024
CEF0014258
811-07868
Invesco Advantage Municipal Income Trust II
Invesco Advantage Municipal Income Trust II
2/28/2025
CEF0013849
811-02090
Invesco Bond Fund
Invesco Bond Fund
2/28/2025
CEF0015018
811-07404
Invesco California Value Municipal Income Trust
Invesco California Value Municipal Income Trust
2/28/2025
S000003033
811-21265
Invesco AI and Next Gen Software ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003026
811-21265
Invesco Biotechnology & Genome ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003023
811-21265
Invesco Bloomberg MVP Multi-factor ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003040
811-21265
Invesco Building & Construction ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013127
811-21265
Invesco Dorsey Wright Basic Materials Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013128
811-21265
Invesco Dorsey Wright Consumer Cyclicals Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
8

S000013129
811-21265
Invesco Dorsey Wright Consumer Staples Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013101
811-21265
Invesco Dorsey Wright Energy Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013102
811-21265
Invesco Dorsey Wright Financial Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013104
811-21265
Invesco Dorsey Wright Healthcare Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013105
811-21265
Invesco Dorsey Wright Industrials Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013110
811-21265
Invesco Dorsey Wright Technology Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003046
811-21265
Invesco Dorsey Wright Utilities Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003041
811-21265
Invesco Energy Exploration & Production ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003027
811-21265
Invesco Food & Beverage ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000011995
811-21265
Invesco FTSE RAFI US 1000 ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013120
811-21265
Invesco FTSE RAFI US 1500 Small-Mid ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003054
811-21265
Invesco Large Cap Growth ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003055
811-21265
Invesco Large Cap Value ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003028
811-21265
Invesco Leisure and Entertainment ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000012109
811-21265
Invesco NASDAQ Internet ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003030
811-21265
Invesco Next Gen Connectivity ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003029
811-21265
Invesco Next Gen Media and Gaming ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003043
811-21265
Invesco Oil & Gas Services ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003031
811-21265
Invesco Pharmaceuticals ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013106
811-21265
Invesco S&P 100 Equal Weight ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000032768
811-21265
Invesco S&P 500 GARP ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060791
811-21265
Invesco S&P 500 Pure Growth ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060792
811-21265
Invesco S&P 500 Pure Value ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060793
811-21265
Invesco S&P 500 Top 50 ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000032769
811-21265
Invesco S&P 500 Value with Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060795
811-21265
Invesco S&P MidCap 400 Pure Growth ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060796
811-21265
Invesco S&P MidCap 400 Pure Value ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
9

S000003056
811-21265
Invesco S&P MidCap Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000013108
811-21265
Invesco S&P MidCap Quality ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003057
811-21265
Invesco S&P MidCap Value with Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060799
811-21265
Invesco S&P SmallCap 600 Pure Growth ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060800
811-21265
Invesco S&P SmallCap 600 Pure Value ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003024
811-21265
Invesco S&P SmallCap Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003025
811-21265
Invesco S&P SmallCap Value with Momentum ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000003032
811-21265
Invesco Semiconductors ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060804
811-21265
Invesco Zacks Mid-Cap ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000060805
811-21265
Invesco Zacks Multi-Asset Income ETF
Invesco Exchange-Traded Fund Trust
4/30/2025
S000058751
811-21977
Invesco 0-5 Yr US TIPS ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000019411
811-21977
Invesco California AMT-Free Municipal Bond ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000027370
811-21977
Invesco CEF Income Composite ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000060828
811-21977
Invesco China Technology ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000020450
811-21977
Invesco Dorsey Wright Developed Markets Momentum ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000020451
811-21977
Invesco Dorsey Wright Emerging Markets Momentum ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000037586
811-21977
Invesco Dorsey Wright SmallCap Momentum ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019229
811-21977
Invesco Emerging Markets Sovereign Debt ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000019225
811-21977
Invesco Equal Weight 0-30 Year Treasury ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000074294
811-21977
Invesco ESG S&P 500 Equal Weight ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019521
811-21977
Invesco Floating Rate Municipal Income ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019230
811-21977
Invesco Fundamental High Yield Corporate Bond ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000033429
811-21977
Invesco Fundamental Investment Grade Corporate Bond ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000015279
811-21977
Invesco Global Clean Energy ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000040915
811-21977
Invesco Global ex-US High Yield Corporate Bond ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000015278
811-21977
Invesco Global Water ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000043789
811-21977
Invesco International BuyBack Achievers ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
10

S000019231
811-21977
Invesco International Corporate Bond ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000034530
811-21977
Invesco KBW Bank ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030361
811-21977
Invesco KBW High Dividend Yield Financial ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030362
811-21977
Invesco KBW Premium Yield Equity REIT ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030363
811-21977
Invesco KBW Property & Casualty Insurance ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000034533
811-21977
Invesco KBW Regional Banking ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000085579
811-21977
Invesco MSCI Global Climate 500 ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000060818
811-21977
Invesco MSCI Global Timber ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000071549
811-21977
Invesco MSCI Green Building ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000080910
811-21977
Invesco MSCI North American Climate ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000058746
811-21977
Invesco MSCI USA ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000083070
811-21977
Invesco Nasdaq Free Cash Flow Achievers ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019245
811-21977
Invesco National AMT-Free Municipal Bond ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019412
811-21977
Invesco New York AMT-Free Municipal Bond ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019228
811-21977
Invesco Preferred ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000012561
811-21977
Invesco RAFI Developed Markets ex- US ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000015260
811-21977
Invesco RAFI Developed Markets ex-US Small Mid ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000015263
811-21977
Invesco RAFI Emerging Markets ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000047524
811-21977
Invesco Russell 1000 Equal Weight ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000050156
811-21977
Invesco S&P 500 Enhanced Value ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000048721
811-21977
Invesco S&P 500 ex-Rate Sensitive Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030963
811-21977
Invesco S&P 500 High Beta ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000083071
811-21977
Invesco S&P 500 High Dividend Growers ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000038520
811-21977
Invesco S&P 500 High Dividend Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030967
811-21977
Invesco S&P 500 Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000058135
811-21977
Invesco S&P 500 Minimum Variance ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000050154
811-21977
Invesco S&P 500 Momentum ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000072318
811-21977
Invesco S&P 500 QVM Multi-factor ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
11

S000034749
811-21977
Invesco S&P Emerging Markets Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000034748
811-21977
Invesco S&P Emerging Markets Momentum ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000060819
811-21977
Invesco S&P Global Water Index ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000034747
811-21977
Invesco S&P International Developed Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000034746
811-21977
Invesco S&P International Developed Momentum ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000015280
811-21977
Invesco S&P International Developed Quality ETF
Invesco Exchange-Traded Fund Trust II
10/31/2024
S000072319
811-21977
Invesco S&P MidCap 400 QVM Multi-factor ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030966
811-21977
Invesco S&P MidCap Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000072320
811-21977
Invesco S&P SmallCap 600 QVM Multi-factor ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028294
811-21977
Invesco S&P SmallCap Consumer Discretionary ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028296
811-21977
Invesco S&P SmallCap Consumer Staples ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028297
811-21977
Invesco S&P SmallCap Energy ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028298
811-21977
Invesco S&P SmallCap Financials ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028299
811-21977
Invesco S&P SmallCap Health Care ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000055539
811-21977
Invesco S&P SmallCap High Dividend Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028300
811-21977
Invesco S&P SmallCap Industrials ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028301
811-21977
Invesco S&P SmallCap Information Technology ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000030965
811-21977
Invesco S&P SmallCap Low Volatility ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028302
811-21977
Invesco S&P SmallCap Materials ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000056849
811-21977
Invesco S&P SmallCap Quality ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000028295
811-21977
Invesco S&P SmallCap Utilities & Communication Services ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000058347
811-21977
Invesco S&P SmallCap600 GARP ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000031053
811-21977
Invesco Senior Loan ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000055054
811-21977
Invesco Short Term Treasury ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000019246
811-21977
Invesco Taxable Municipal Bond ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000045020
811-21977
Invesco Variable Rate Preferred ETF
Invesco Exchange-Traded Fund Trust II
8/31/2025
S000081673
811-23304
Invesco BulletShares 2031 High Yield Corporate Bond ETF
Invesco Exchange-Traded Self-Indexed Fund Trust
8/31/2025
12

S000081672
811-23304
Invesco BulletShares 2033 Corporate Bond ETF
Invesco Exchange-Traded Self-Indexed Fund Trust
8/31/2025
S000081674
811-23304
Invesco BulletShares 2033 Municipal Bond ETF
Invesco Exchange-Traded Self-Indexed Fund Trust
8/31/2025
CEF0013130
811-05769
Invesco High Income Trust II
Invesco High Income Trust II
2/28/2025
S000045836
811-22957
Invesco Conservative Income Fund
Invesco Management Trust
8/31/2025
CEF0013684
811-05597
Invesco Municipal Income Opportunities Trust
Invesco Municipal Income Opportunities Trust
2/28/2025
CEF0013421
811-06567
Invesco Municipal Opportunity Trust
Invesco Municipal Opportunity Trust
2/28/2025
CEF0014524
811-06362
Invesco Municipal Trust
Invesco Municipal Trust
2/28/2025
CEF0014311
811-07398
Invesco Pennsylvania Value Municipal Income Trust
Invesco Pennsylvania Value Municipal Income Trust
2/28/2025
CEF0014966
811-06591
Invesco Quality Municipal Income Trust
Invesco Quality Municipal Income Trust
2/28/2025
CEF0013156
811-08743
Invesco Senior Income Trust
Invesco Senior Income Trust
2/28/2025
CEF0013768
811-05845
Invesco Senior Loan Fund
Invesco Senior Loan Fund
2/28/2025
CEF0014984
811-06471
Invesco Trust for Investment Grade Municipals
Invesco Trust for Investment Grade Municipals
2/28/2025
CEF0015091
811-06537
Invesco Trust for Investment Grade New York Municipals
Invesco Trust for Investment Grade New York Municipals
2/28/2025
CEF0014465
811-06590
Invesco Value Municipal Income Trust
Invesco Value Municipal Income Trust
2/28/2025
S000000220
811-02729
Invesco Government & Agency Portfolio
Short-Term Investments Trust
8/31/2025
S000000221
811-02729
Invesco Treasury Obligations Portfolio
Short-Term Investments Trust
8/31/2025
S000000224
811-02729
Invesco Treasury Portfolio
Short-Term Investments Trust
8/31/2025

13