Aim International Mutual Funds CORRESPCorrespondence with SEC

All securities, including foreign exchange transactions, and foreign exchange rates used for translation between local currency of an asset or liability and operating currency are valued within the Funds financial statements in accordance with US GAAP.  ASC 830-20-30-1 states “At the date a foreign currency transaction is recognized, each asset, liability, revenue, expense, gain, or loss arising from the transaction shall be measured initially in the functional currency of the recording entity by use of the exchange rate in effect at that date.”  The starting point for Invesco’s foreign currency valuation/translation is the spot rate provided daily by a third-party pricing service.  The Adviser’s valuation team performs due diligence on the third-party pricing vendor in accordance with requirements under SEC Rule 2a-5 and the Adviser’s Valuation Policy.  In addition, robust controls exist within the Adviser’s valuation process to identify, and where applicable, challenge and override foreign exchange rates which are not reliable or reflective of where transactions could be settled. This type of override would require approval by the Adviser’s Valuation Committee.  Factors such as broker quotations or bids, executed transactions and other third-party vendor provided foreign exchange rates are utilized by the Adviser’s valuation team to evaluate the reliability of vendor-provided foreign exchange rates and formulate a recommendation to the Adviser’s Valuation Committee should the valuation team determine that the rates provided are not reliable or reflective of where transactions could be settled.

Differences between onshore and offshore foreign exchange rates for specific currencies exist and reflect the difference in repatriation rates that an “onshore” or “offshore” investor would expect to receive when repatriating foreign currency to the operating currency of the Fund. A determination is made, partially based on the Fund’s domicile as to whether the Fund is an onshore or offshore investor for a particular market, and the Adviser then instructs the Fund’s third-party administrator to apply the appropriate foreign exchange rate (onshore or offshore).  Additionally, the Adviser’s valuation team utilizes the Fund’s independent third-party administrator to ensure consistency in rate determination (onshore vs offshore) where applicable, across the third-party Fund Administrator’s client base.  The foreign exchange rate determination (onshore vs offshore) and ongoing rate monitoring are subject to the aforementioned controls and oversight process performed by the Adviser’s valuation team and overseen by the Adviser’s Valuation Committee. Throughout the Funds’ fiscal year, the Adviser’s valuation team continued to observe pricing transparency across all foreign exchange rates and did not make any recommendations to override the vendor provided foreign exchange rates to the Adviser’s Valuation Committee.