Aim Tax Exempt Funds CORRESPCorrespondence with SEC

Each of Invesco Gold & Special Minerals Fund, Invesco American Franchise Fund, International BuyBack Achievers ETF and Invesco MSCI Global Timber ETF, continues to qualify as a non-diversified fund.  The compliance department of the respective Funds’ adviser monitors the diversification status of each Fund on a daily basis. If, in the future, a Fund were to operate in a diversified manner continuously for a three-year period, we confirm that such Fund would seek shareholder approval prior to changing its operating status back to non-diversified, unless the Fund could rely on the no-action letter issued to Stradley Ronon Stevens & Young, LLP on June 24, 2019.

The Registrant’s policy is to record foreign tax reclaims when they satisfy the “more likely than not” criteria under Accounting Standards Codification No. 740. In the event that tax refunds received during the year exceed the foreign withholding taxes paid by a Fund for the year, and the Fund previously passed foreign tax credits on to its shareholders, the Funds intend to enter into closing agreements with the IRS in order to pay the associated tax liability on behalf of the Funds’ shareholders. The Funds disclose the following  with respect to foreign tax reclaims: (i) presenting separately tax reclaims in accordance with Regulation S-X 6-07, IRS closing agreement fees, if any, as contra-income and any associated fees as Professional fees within the Statement of Operations, (ii) presenting a receivable for the refunds and payable for any fees, if any, within the Statement of Assets and Liabilities and (iii) including footnote disclosure regarding impacts to total return and/or net investment income ratios/per share values within the Financial Highlights, if deemed material.

Invesco Equity and Income Fund and Invesco Growth and Income Fund followed the disclosure practice outlined above. The tax refunds received did exceed foreign withholding taxes paid for the year, however neither Fund entered into an IRS closing agreement because they did not previously pass foreign tax credits on to its shareholders for the years related to the refund. Additionally, no professional or compliance fees were incurred.

The Registrant confirms that the Receivable for Investments Matured line item represents securities which have yet to return principal amounts and have exceeded their stated maturity date prior to financial statement date. All but one of the securities were in a default status and were no longer accruing interest income. One security was not considered to be in a default status and continued to accrue interest income as the issuer had not missed any interest payments. With respect to these securities, the practice is to disclose the value of such securities as a receivable for investments matured until final principal payments are received. The securities continue to be marked to market but are no longer included on the Schedule of Investments as they have reached their maturity date.  Additionally, the securities continue to be monitored for collectability of both principal and interest.  If any future payments of principal and/or interest are

deemed to be uncollectable, the Registrant will write off any remaining interest receivables or principal balances.

The Registrants have reviewed the applicable accounting guidance including the requirements of Regulation S-X 5-02(19)(b) and since any domestic and foreign currency overdrafts incurred by the Funds during the applicable fiscal years were not significant, we respectfully do not believe any additional disclosure is required.

The Registrant has added the requested disclosure.

The Registrants note that the historical practice followed by the Registrants when reporting under Form N-CEN Item B.22 Net asset value error corrections, was to report any NAV error over $0.01 which resulted in the over-reporting of NAV errors in Form N-CEN in that errors were reported that did not result in reimbursement to shareholders or accounts being reprocessed. Effective with the December 31, 2022, Form N-CEN reporting, the Registrants revised this policy to only report NAV errors resulting in reimbursement to shareholders or accounts being reprocessed, in accordance with Form N-CEN Item B.22 instructions. With respect to the NAV errors for the Funds listed below, the NAV error did not breach the threshold outlined in the Registrants’ NAV error correction policy requiring account reprocessing or payments to shareholders, however a pay-in was made to each Fund to reimburse the Fund for any net loss in accordance with the Registrants’ NAV error correction policy. For each instance, controls were reviewed and determined to be reasonable and were reinforced and/or enhanced to prevent recurrence, if needed. In accordance with Accounting Standards Codification No. 946, the Funds disclose amounts and circumstances of payments by affiliates to reimburse the Fund for losses on investment transactions in the financial statements, the notes to financial statements and the

effect on total return on the financial highlights, if material.  None of the NAV errors listed below met the foregoing materiality threshold for disclosure.

The NAV errors reported within Form N-CEN for Invesco SteelPath MLP Alpha Fund, Invesco SteelPath MLP Alpha Plus Fund, Invesco SteelPath MLP Income Fund and Invesco SteelPath MLP Select 40 Fund were in connection with an NAV error and related remediation plan originally discussed in the Funds’ November 30, 2018 Amended Form N-CSR filed on March 30, 2020. Management determined that a material weakness related to the determination of the valuation allowance on deferred tax assets in accordance with Accounting Standards Codification No. 740, Income Taxes existed and resulted in a material NAV error.  As disclosed in the November 30, 2020 Form N-CSR, Management strengthened the Funds’ internal control over financial reporting and concluded that the material weakness was fully remediated. Although this error occurred in a prior year, the payments to impacted shareholders occurred during fiscal year ended November 30, 2021 and therefore were disclosed in the November 30, 2021 Form N-CEN to align with the instructions to include a response of Yes, if payments were made to shareholders during the period.

The Registrant confirms that the unfunded commitments meet the accrual standard in accordance with Accounting Standards Codification No. 450, due to meeting the conditions of; availability of information before the financial statements are issued; probability that a liability has been incurred; and the amount can be reasonably estimated. The Notes to Financial Statements disclose the nature of the contingency as well as the amount and location of the

accrued liability recorded in the Statement of Assets and Liabilities. With respect to management fees, the advisory agreement defines “Managed assets” as the Trust’s net assets, plus assets attributable to outstanding preferred shares and the amount of any borrowings incurred for the purposes of leverage (whether or not such borrowed amounts are reflected in the Trust’s financial statements for purposes of generally accepted accounting principles). The management fee calculation using the definition of Managed assets above are paid on the Trust’s net assets, which would result in the same fee whether the unfunded commitments were booked on a gross or net basis.

The Registrants confirm that although the investments are not registered under the Investment Company Act of 1940, as amended (“1940 Act”), per their organizational documents and strategy mandate they must comply with Rule 2a-7 as if they were registered investment companies operating as money market funds. As such, the Registrants view such private Rule 2a-7 compliant vehicles as satisfying Rule 18f-4’s requirement that collateral from securities lending activity be invested in cash or cash equivalents.  Additionally, we have determined that these private Rule 2a-7 compliant vehicles have a readily determinable fair value, as the Registrants trade daily at Net Asset Value. As the Net Asset Value of each private Rule 2a-7 compliant vehicle is not published publicly, we determined the requirements necessary to be classified as Level 1 under Accounting Standards Codification No. 820 are not met, and therefore the Registrants consider such private vehicle as Level 2.

Only Funds that engaged in or plan to engage in “derivatives transactions”, “reverse repurchase agreements or similar financing transactions”, “unfunded commitment agreements” or transactions in securities on a “when-issued or forward-settling basis, or with a non-standard settlement cycle” (as such terms are used in Rule 18f-4 under the 1940 Act) check Item C.7.n. of Form N-CEN to indicate reliance on Rule 18f-4 during the reporting period.  Funds that did not engage in or do not plan to engage in these transactions over the reporting period do not check Item C.7.n. because they have not relied on Rule 18f-4.

If a Fund relied on Rule 18f-4 during the reporting period, its responses to Item C.7.n.i. through vi. will depend on the nature of the Fund’s relevant transactions and reliance on the rule:

the limited derivatives user exemption (generally, an adjusted gross notional amount of such transactions, excluding certain hedging transactions, that does not exceed 10% of net assets).

With respect to each of Invesco American Franchise Fund, Invesco Discovery Fund, Invesco S&P 500 High Dividend Low Volatility ETF, and Invesco S&P SmallCap Information Technology ETF, the Funds did not engage in “derivatives transactions”, “reverse repurchase agreements or similar financing transactions”, “unfunded commitment agreements” or transactions in securities on a “when-issued or forward-settling basis, or with a non-standard settlement cycle” (as such terms are used in Rule 18f-4 under the 1940 Act during the reporting period and therefore C.7.n was not checked for these Funds. With respect to Invesco Short Duration High Yield Municipal Fund, the Fund did engage in such transactions during the reporting period and therefore checked both C.7.n and C.7.n.iv.