SEC letter

ROPES & GRAY LLP

PRUDENTIAL TOWER

800 BOYLSTON STREET

BOSTON, MA 02199-3600

WWW.ROPESGRAY.COM


May 12, 2025				Ryan Murphy
				T +1 415 315 1285
				Ryan.Murphy@ropesgray.com

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-0505

Re:

PIMCO Municipal Income Fund II

Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14

(File Nos. 333-286391)

Ladies and Gentlemen:

On behalf of PIMCO Municipal Income Fund II, a Massachusetts business trust (“PML”), we are today filing via EDGAR Pre-Effective Amendment No. 1 (the “Amendment”) to a registration statement on Form N-14 (the “Registration Statement”). The Registration Statement relates to the proposed reorganizations of PIMCO Municipal Income Fund and PIMCO Municipal Income Fund III with and into PML, as described in the Registration Statement.

This Amendment to the Registration Statement is being filed for the purpose of responding to comments from the staff of the Securities and Exchange Commission and to make certain other changes.

Registration fees have been paid in connection with this filing. Please direct any questions or comments regarding this filing to me at (415) 315-1285 or to Chelsea M. Childs at (415) 315-6374. Thank you for your attention in this matter.

Very truly yours,

/s/ Ryan Murphy

Ryan Murphy

cc:

Ryan G. Leshaw, Esq.

Timothy Bekkers, Esq.

Jaime Dinan, Esq.

David C. Sullivan, Esq.

Chelsea M. Childs, Esq.