May 27, 2025

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Megan F. Miller

Re: 408 SOX Review -- BNY Mellon Family of Funds Listed in Appendix A

Ladies and Gentlemen:

On behalf of the funds in the BNY Mellon Family of Funds listed in Appendix A hereto (each, a "Fund"), transmitted for filing as EDGAR correspondence are the Funds' responses to the comments of the accounting staff (the "Staff") of the Securities and Exchange Commission (the "Commission"), provided by Megan F. Miller, Staff Accountant, to the undersigned by telephone on February 26, 2025 and May 1, 2025. The Staff's comments related to the three-year review of the audited financial statements of the Funds for the fiscal years ended on the respective dates noted in Appendix A, included in the Funds' annual reports on Form N-CSR as filed with the Commission, pursuant to Rule 408(c) of the Sarbanes-Oxley Act of 2002.

Set forth below is a summary of the Staff's comments, and the Funds' responses thereto.

BNY Bond Market Index Fund

Comment 1:  Please confirm that the disclosure for TBA investments aligns with Regulation S-X 6-07.7 (see AICPA Expert Panel Minutes, November 13, 2023).

Response 1:  Fund management confirms that going forward realized and unrealized TBA will be broken out to align with Regulation S-X 6-07.7.

Comment 2:  Please consider updating the disclosure for caption "Statement of Operations" to state securities lending income is presented net of any rebates or fees paid to Borrowers.

Response 2:  Fund management confirms that going forward the Statement of Operations will state securities lending income net of any rebates or fees paid to Borrowers and will update applicable notes.

BNY Mellon Yield Enhancement Strategy Fund

Comment 3:  Please confirm Financial Highlights include to the extent required a footnote stating that "Ratio of net investment income" does not reflect proportionate share of income of the Underlying Funds in which the Fund invests. (See ASC 946-205-50-16.)

Response 3:  Included in the Items 7-11, "Annual Financials and Other Information" dated October 31, 2024, is a footnote that reads "excludes expenses of underlying funds", and such footnote will be included, as applicable, for the fund going forward.

BNY Mellon Natural Resources Fund

Comment 4:  Please note, the S&P Global Natural Resources Index was incorrectly tagged in XBRL as the "broad based" index.

Response 4:  Going forward, the broad-based index will be correctly tagged in XBRL. The order in which each index was disclosed was switched, which caused an inadvertent tagging error.

BNY Mellon Funds Trust – Municipal Funds

Comment 5:  Please consider including a "Total'" for "accumulated earnings" in Table 1 -- Components of Accumulated Earnings.

Response 5:  Going forward, the word "Total" will be included in Table 1, as requested.

Funds that Engage in Securities Lending

Comment 6:  Please explain why securities lending income is not noted as "affiliate" on Statement of Operations.

Response 6  Going forward, securities lending income will include the word "affiliate", as requested.

All Relevant Funds

Comment 7:  Please explain how Item 10 of N-CSR meets the requirement to disclose aggregate remuneration paid by the Company during the period covered by the report if payments are disclosed in multiple locations in Item 7 (e.g., Item 10 reflects payment to Trustees, Line 7 states payable to CCO) (See TSR FAQ No.3).

Response 7:   For those Funds that have relevant payments disclosed in multiple locations in Item 7, Item 10 of N-CSR, the disclosure will be revised going forward to include the aggregate dollar amount of relevant remuneration paid by the Fund during the period covered by the report. Examples of the revised disclosure:

For Funds without unitary fee:

Each board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets. The fund is charged for services performed by the fund's Chief Compliance Officer. Compensation paid by the fund during the period to the board members and the Chief Compliance Officer are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and expenses and Chief Compliance Officer fees, respectively. The aggregate amount of Directors'[/Trustees'] fees and expenses and Chief Compliance Officer fees paid by the fund during the period was $_____. 

For Funds with unitary fee:

Each board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets. The Adviser reimburses the fund for the fees and expenses of the non-interested board members. Compensation paid by the fund to the board members and board member fees reimbursed by the Adviser during the period are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and Directors'[/Trustees'] fees reimbursed by BNY Mellon Investment Adviser, Inc., respectively.

BNY Mellon Municipal Income and BNY Mellon Strategic Municipal Bond Fund

Comment 8:  Please confirm that description of Debt in Notes to Financial Statements includes the effective interest rate in addition to the stated rate (See ASC 835-30-45-2).

Response 8:  The description of debt in Note 1(e) includes the effective interest rate in addition to the stated rate.

All Relevant Funds

Comment 9:  Please explain why overdraft fees are netted with interest income as opposed to an expense to the Fund (see Note in Statement of Operations). Specifically, the rationale for netting overdraft fees from interest income.

Response 9:  Per the rule, expenses are only broken out if expenses exceeded 5% of total expenses or total income. The rationale for netting is because the amounts were immaterial.

Unitary Fee Funds

Comment 10:  Please confirm what fees and expenses are excluded from the management fee (e.g., are loan commitment fees, interest expense and securities lending fees paid by the Fund).

Response 10:  Fees and expenses excluded from the unitary management fee are: 12b-1 fees, if applicable, shareholder services fees, if applicable, loan commitment fee from borrowings and interest expense as well as any extraordinary expenses.

* * * * *

Should you have any questions or comments, please feel free to contact me at 212.540.4569 (dstephens@stradley.com) .

Very truly yours,

/s/ DAVID STEPHENS
David Stephens

cc: Sarah Kelleher

 Amanda Quinn

APPENDIX A¹

¹  As provided by Megan F. Miller of the Staff.