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SEC Company Response from Cornerstone Strategic Investment Fund, Inc. (CLM) (CIK 0000814083) (CLM) — Jun 9, 2017

Cornerstone Strategic Investment Fund, Inc. (CLM) (CIK 0000814083)
Date: June 9, 2017 · CIK: 0000814083 · Accession: 0001398344-17-007518

AI Filing Summary & Sentiment

File numbers found in text: 811-05150

Date
June 9, 2017
Author
/s/ Courtney B. Schrenko
Form
CORRESP
Company
Cornerstone Strategic Investment Fund, Inc. (CLM) (CIK 0000814083)

Letter

Phone:

(212)885-5234

Fax:

(917)898-1392

Email:

cschrenko@blankrome.com

June 9, 2017

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re:

Cornerstone Strategic Value Fund, Inc. (File Number: 811-05150)

Registration Statement on Form N-2

Request for Selective Review

To Whom It May Concern:

The above-referenced filing (the “Registration Statement”) of our client, Cornerstone Strategic Value Fund, Inc. (the “Fund”), being filed on June 9, 2017, is based on and is substantially similar to the registration statement on Form N-2 of the Fund which was reviewed and declared effective by the Staff on September 16, 2016. Please accept this letter as a request under the selective review procedures discussed below with respect to the Staff’s review of the Registration Statement.

In this regard, the Staff follows certain selective review procedures for registration statements, set forth in Securities Act Release No. 6510 (Feb. 15, 1984), which are applicable to all management investment company registration statements. The Staff may determine not to review a registration statement (or portions of a registration statement) based on similarity to prior filings that have been reviewed by the Staff. Based on these procedures, a registrant may identify portions of prior filings similar or identical to, and intended to serve as precedent for, a current filing.

The Registration Statement represents a “rights offering” of the Fund’s shares, the terms and conditions of which are substantially similar to those contained in the registration statement of the Fund referenced above.

Please contact me at (212) 885-5234 or Thomas R. Westle at (212) 885-5239 with any questions you may have or for any further information you may desire.

Securities and Exchange Commission

June 9, 2017

Page 2

Very truly yours,
/s/ Courtney B. Schrenko

Show Raw Text
CORRESP
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filename1.htm

Phone:

(212)885-5234

Fax:

(917)898-1392

Email:

cschrenko@blankrome.com

June 9, 2017

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

 Washington, D.C. 20549

Re:

Cornerstone Strategic Value Fund, Inc. (File Number: 811-05150)

Registration Statement on Form N-2

Request for Selective Review

To Whom It May Concern:

The above-referenced filing (the “Registration Statement”) of our client, Cornerstone Strategic Value Fund, Inc. (the “Fund”), being filed on June 9, 2017, is based on and is substantially similar to the registration statement on Form N-2 of the Fund which was reviewed and declared effective by the Staff on September 16, 2016. Please accept this letter as a request under the selective review procedures discussed below with respect to the Staff’s review of the Registration Statement.

In this regard, the Staff follows certain selective review procedures for registration statements, set forth in Securities Act Release No. 6510 (Feb. 15, 1984), which are applicable to all management investment company registration statements. The Staff may determine not to review a registration statement (or portions of a registration statement) based on similarity to prior filings that have been reviewed by the Staff. Based on these procedures, a registrant may identify portions of prior filings similar or identical to, and intended to serve as precedent for, a current filing.

The Registration Statement represents a “rights offering” of the Fund’s shares, the terms and conditions of which are substantially similar to those contained in the registration statement of the Fund referenced above.

Please contact me at (212) 885-5234 or Thomas R. Westle at (212) 885-5239 with any questions you may have or for any further information you may desire.

Securities and Exchange Commission

June 9, 2017

Page 2

Very truly yours,

/s/ Courtney B. Schrenko

Courtney B. Schrenko