Accordant ODCE Index Fund

Company response: 1 . The Registrant acknowledges the staff’s comment. In future filings, the line graph will be updated to reflect the minimum initial investment for the relevant share Class as reflected in the Registrant’s registration statement. response letter →

Company response: 2 . The Registrant inadvertently omitted the S&P 500 Index from the Form N-CSR. The Registrant believes that this index is responsive to the requirement for an appropriate broad-based securities market index. The Registrant will include the performance of that index in future filings. response letter →

Company response: 3 . The Registrant confirms that its benchmark has not changed. The NFI-ODCE Net Total Return Index serves as the Registrant’s performance index because the Adviser believes it is representative of the Registrant’s investment strategy. The Registrant inadvertently omitted the S&P 500 Index from the Form N-CSR. This index serves as the Registrant’s regulatory index and provides a broad measure of market performance. The Bloomberg Barclays U.S. Aggregate Bond Index serves as a supplemental index for the Registrant. The Registrant will include the performance of these indices and the rationale for the inclusion of each of these indices in its next Form N-CSR filing. response letter →

Company response: 4 . The Registrant will revise the Schedule of Investments in future filings to disclose the cost of each restricted private real estate investment in accordance with footnote 8 of Article 12-12 under Regulation S-X. response letter →

Company response: 5 . The Registrant synchronizes the frequency that the receivable from the Adviser is settled with the settlement terms of payments to the Adviser, such that such payments will be made on a monthly basis. The Registrant notes that as of December 31, 2025, the receivable due from the Adviser has decreased to approximately $168,000 from approximately $606,000 as of June 30, 2025. response letter →

Company response: 6 . To comply with ASC 820-10-50-6A, the Registrant discloses: – 2 – 1. The valuation method used (practical expedient)—i.e., net asset value per share reported by each private fund. 2. Circumstances under which the practical expedient may not be appropriate (e.g., redemption suspensions or stale pricing). 3. Qualitative and quantitative disclosures on price transparency, redemption frequency, and any restrictions. 4. A statement that valuation levels were not adjusted unless further validation was required. In future filings, the Registrant will update the valuation disclosures to reference ASC 820 explicitly and include each required component. response letter →

Company response: 7 . In future filings, the Registrant will revise the disclosure to specify that the Registrant’s chief operating decision maker is the Adviser’s Executive Committee (comprising the CEO, CFO, General Counsel and COO), which regularly evaluates performance and resource allocation decisions for the Registrant. response letter →

Company response: 8 . The Registrant will include the rate(s) paid to the sub-adviser in the notes to financial statements in future filings. response letter →

Company response: 9 . The Registrant allocates income, expenses, and gains on a class-by-class basis in proportion to the relative net asset value of each share class at the start of the period, consistent with ASC 946-235-50-2. The Registrant will include this disclosure in the notes to financial statements in future filings. response letter →

Company response: 10 . The Registrant will disclose tax basis information for the two most recent fiscal year ends in future filings, in accordance with ASC 946-505-50-5. response letter →

Company response: 11 . Going forward, the Registrant will remove or replace terms such as “yield” and “dividends” to describe the Registrant’s distributions, including on the Registrant’s website and in marketing materials and regulatory disclosures, to accurately reflect that distributions include a return of capital. response letter →

Company response: 12 . The Registrant will include the information required by instructions 4(e) and (f) to Item 24 under Form N-2 in future filings. response letter →

Company response: 13 . In future filings, the Registrant will expand the disclosures regarding Board considerations to include specific qualitative and quantitative factors. response letter →

Company response: 14 . In future filings, the Registrant will revise the response to Item 11 to refer to the disclosure included under Item 1. response letter →

Company response: 15 . If tax fees are required to be disclosed in future filings, the Registrant will provide a narrative describing the nature of those services. response letter →

Company response: 16 . In future filings, the Registrant will include the information required by Item 13(a)(1) as of the date the report is filed, consistent with the instruction. response letter →

Company response: 17 . The Registrant will ensure future filings clearly state that all data required by Items 13(a)(3) and (4) reflect the most recently completed fiscal year-end, as required. response letter →

Company response: 18 . The Registrant acknowledges this comment and will include this information in its next Form N-CSR annual report and Form N-CEN filings. response letter →

Company response: 19 . The Registrant confirms that Item C.7(n)(v) should have been checked with respect to unfunded commitment agreements. response letter →

Company response: 21 . The Registrant acknowledges the staff’s comment. The Registrant’s investment adviser and sub-adviser are Accordant Investments LLC and IDR Investment Management, LLC, respectively. The Registrant will correct this disclosure in future Form N-CEN filings. response letter →

Company response: 22 . The Registrant confirms that a market price should not have been disclosed in response to Item D.10. The Registrant will revise this disclosure in future Form N-CEN filings. response letter →

Company response: 23 . The Registrant will remove the “delaying amendment” language from the cover page. response letter →

Company response: 24 . The Registrant will add a line to reflect gross expenses before fee waivers and reimbursements in the Summary of Fund Expenses table. response letter →

Company response: 25 . The Registrant will include an acquired fund fees and expenses line item in the fees and expenses table. The Registrant confirms that the hypothetical expense examples were calculated using the correct acquired fund fees and expenses and, as a result, has not made any changes to such examples. response letter →

Company response: 26 . The Registrant notes that the current footnote was intended to communicate that the one-year expense example reflects application of the Operating Expense Limitation Agreement. The Registrant further notes that the lead-in paragraph to the expense example also communicates this point by stating that it reflects “application of the Operating Expense Limitation Agreement through October 30, 2026.” In order to avoid confusion as to the fee rate that is used to calculate the expense example, the Registrant will retain the statement in the lead-in paragraph to the expense example but will remove the footnote. response letter →