SecProbe.io

August 20, 2007    Joseph V. Del Raso, Esq. Pepper Hamilton LLP 3000 Two Logan Square 18
th and Arch Streets
Philadelphia, Pennsylvania 19103  Re: The Herzfeld Caribbean Basin Fund  File Nos. 333-144838 and 811-6445  Dear Mr. Del Raso:   On July 24, 2007, you filed a registration statement on Form N-2 for The Herzfeld Caribbean Basin Fund in connection with a proposed non-transferable  rights offering.
For convenience, we generally organized our  comments using headings, page numbers,
and defined terms from the registration statement.
Prospectus

Outside Cover Page

1. Please state whether the fund makes available its statemen t of additional information
and annual and semi-annual reports, free of charge, on or through the fund’s Web site
at a specified Internet addr ess.  If the fund does not make its SAI and shareholder
reports available in this manner, disclo se the reasons why it does not do so.  See Item
1.d to Form N-2.

Information Regarding the Fund, page 6

2. The disclosure states that the fund invests in a “broad range  of securities” of issuers
that conduct substantial trade or derive substantial revenue from operations in Caribbean Basin Countries.  Please add a brief description of the t ypes of securities in
which the fund invests and the risks a ssociated with these securities.  See Instruction
to Item 3.2 of Form N-2.

Use of Proceeds, page 22

3. The disclosure states that the fund will invest the net proceeds of the Offer in
accordance with its investment  objectives and policies.  Disclosure earlier in the
section entitled Purpose of the Offer , however, discloses additional purposes for
which the proceeds of the Offer may be used. For example, the disclosure states that
the Offer may be used by the fund to ma ke a large capital ga ins distribution to
shareholders in order to pr eserve its status as a “re gulated investment company”
under Subchapter M of the Internal Re venue Code.  Accordingly, please add
disclosure stating the principal purposes for which the net proceeds of the Offer are
intended to be used and the approximat e amount intended to be used for each
purpose.  See Item 7.1 and related Inst ructions to Form N-2.
 The disclosure states further that the Advi ser anticipates that it will take no longer
than six months to invest the proceeds from  this rights offering.  Since the time period
for investment of the proceeds is expected to  exceed three months, please disclose the
reasons for the delay.  See Guide 1 of Form N-2.

Committees of the Board, page 40

4. Please disclose the number of meetings that the Nominating Committee held during
the fund’s last fiscal year.  See Item 18.5(c) of Form N-2.

Portfolio Manager, page 43

5. Please disclose the length of service of Th omas J. Herzfeld as the fund’s portfolio
manager.  See  Item 9.c of Form N-2.

General Comments

6. Where a comment is made in one location, it is applicable to a ll similar disclosure
appearing elsewhere in the registration statement.

7. We note that portions of the filing are incomplete.  We may have additional
comments on such portions when you complete them in pre-effective amendments, on
disclosures made in response to this le tter, on information you supply to us, or on
exhibits added in any pre-effective amendments.

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8. If you intend to omit certain information fr om the form of prospectus included with
the registration statement that is declared  effective, in reliance on Rule 430A under
the Securities Act, please identify the omitted information to us, preferably before
filing the final pre-effective amendment.

9. Please advise us if you have submitted or expect to submit exemptive applications or no-action requests in connection w ith your registration statement.

10. Responses to this letter should be in th e form of a pre-eff ective amendment filed
pursuant to Rule 472 under the Securities Act.   Where no change will be made in the
filing in response to a comment, please indicate this fact in a letter to us and briefly
state the basis for your position.
 11. We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing review ed by the staff to be certain that they have provided all
information investors require to make an informed decision.  Since the fund and its
management are in possession of all facts re lating to the fund’s di sclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  Notwithstanding our comments, in the ev ent the fund requests acceleration of the
effective date of the pending registration statem ent, it should furnish a letter, at the time
of such request, acknowledging that
 ‚ should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;
‚ the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing ef fective, does not relieve  the fund from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and
‚ the fund may not assert this  action as a defense in a ny proceeding initiated by the
Commission or any person under the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Division of Investment Management in
connection with our review of your filing or  in response to our comments on your filing.

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 4We will consider a written request for acceleration of the effective date of the
registration statement as a confirmation of th e fact that those reque sting acceleration are
aware of their respective responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.

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 Please direct any questions you may have re garding the filing or this letter to me
at 202.551.6956.

        S i n c e r e l y ,           Brion R. Thompson       Senior Counsel