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Nuveen Investments

 December 11, 2012

 Ms. Christina DiAngelo

 U.S. Securities and Exchange Commission

450
5th Street, NW

Washington, D.C. 20549

 Re: Nuveen
Closed-End and Open-End Funds - Sarbanes Oxley Review

 Dear Christina:

 This letter addresses your comments provided in a telephone discussion on September 25, 2012. Each comment is shown below followed by our response. Unless otherwise noted, the responses relate to all
funds listed on Appendix A attached hereto.

1)
Comment: (a) For the following N-SAR filings, the name of the accounting firm issuing the report is missing from the following funds’
Accountants Report on Internal Control. File amended reports to include the complete Accountants Report on Internal Control.

File Number

Registrant

Date Filed

 811-21494

 Nuveen Floating Rate Income Fund

September 30, 2011

 811-21579

 Nuveen Floating Rate Income Opportunity
Fund

September 30, 2011

 811-22023

 Nuveen Managed Accounts Portfolios
Trust

September 29, 2011

 811-09571

 Nuveen Senior Income Fund

September 29, 2011

 811-22518

 Nuveen Short Duration Credit Opportunities
Fund

September 29, 2011

 811-05309

 Nuveen Investment Funds, Inc.

August 29, 2011

 811-05309

 Nuveen Investment Funds, Inc. (also missing city and
state)

February 2, 2012

 Comment: (b) For the following N-SAR filing, the city and state of the accounting
firm issuing the report is missing from the Accountants Report on Internal Control. Ensure that all future filings of this report contain the city and state of the accounting firm issuing the report. File an amended report to include the complete
Accountants Report on Internal Control.

File Number

Registrant

Date Filed

 811-07619

 Nuveen Investment Trust

August 29, 2011

 Response: We are currently in the process of taking the necessary steps to amend the filings in
the aforementioned tables. To amend these filings under our current N-SAR application, which is disc operating system (DOS) based, we would need to recreate the answer file (“answer.fil”) originally filed with the complete Accountants
Report on Internal Control. We are currently in the process of obtaining a new web based N-SAR application with RR Donnelley, which will allow us to edit the answer.fil without a complete recreation. Assuming a timely installation of this N-SAR
application, we expect to amend the filings as requested within thirty days of this response.

2)
Comment: (a) In future N-CSR filings, for Item 4 (b), (c) and (d) provide more details on what services comprise “Audit
Related Fees,” “Tax Fees,” and “Other.”

 Response: Items 4(b), (c) and
(d) of Form N-CSR are as follows:

 4 (b) Disclose, under the caption Audit-Related Fees, the aggregate fees billed
in each of the last two fiscal years for assurance and related services by the principal accountant that are reasonably related to the performance of the audit of the registrant’s financial statements and are not reported under paragraph
(a) of this Item. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

4 (c) Disclose, under the caption Tax Fees, the aggregate fees billed in each of the last two fiscal years for professional services
rendered by the principal accountant for tax compliance, tax advice, and tax planning. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

4 (d) Disclose, under the caption All Other Fees, the aggregate fees billed in each of the last two fiscal years for products and
services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

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 In accordance with Item 4 (b), (c) and (d) of Form N-CSR, we will further
describe the nature of services comprising “Audit Related Fees,” “Tax Fees” and “All Other Fees” in our future N-CSR filings. The Nuveen funds’ current disclosures are as follows:

Item 4 (b): “Audit-Related Fees” are the aggregate fees billed for assurance and related services reasonably related to
the performance of the audit or review of financial statements that are not reported under “Audit Fees”.

Item 4(c): “Tax Fees” are the aggregate fees billed for professional services for tax advice, tax compliance, and tax
planning.

 Item 4(d) (for Nuveen open-end funds): “All Other Fees” are the aggregate fees billed for products
and services other than “Audit Fees”, “Audit-Related Fees” and “Tax Fees”.

 Item 4(d) (for
Nuveen closed-end funds): “All Other Fees” are the aggregate fees billed for products and services for agreed upon procedures engagements performed for leveraged funds.

At the current time, the Nuveen funds contemplate the following as an example of what the disclosure will resemble going forward that
will be revised as needed to reflect the actual services provided to the funds:

 Item 4 (b): “Audit-Related
Fees” are the aggregate fees billed for assurance and related services reasonably related to the performance of the audit or review of financial statements that are not reported under “Audit Fees”. These fees include leverage
offerings as well as comfort letters for seed and shelf offerings.

 Item 4(c): “Tax Fees” are the aggregate
fees billed for professional services for tax advice, tax compliance, and tax planning. These fees include: all global withholding tax services; excise and state tax reviews; and capital gain, tax equalization and taxable basis calculations
performed by the principal accountant.

 Item 4(d) (for Nuveen open- and closed-end funds): “All Other Fees” are
the aggregate fees billed for products and services other than “Audit Fees”, “Audit-Related Fees” and “Tax Fees”. These fees represent all “Agreed-Upon Procedures” engagements pertaining to preferred stock,
commercial paper and registration statements.

 Our next N-CSR filings are scheduled to be filed on or around December 6,
2012.

 Comment: (b) In future N-CSR filings, Item 4(f) of the filing should be addressed, even if
not applicable.

 Response: Item 4(f) of Form N-CSR is as follows:

(f)
If greater than 50 percent, disclose the percentage of hours expended on the principal accountant’s engagement to audit the registrant’s financial statements
for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees.

 In our experience, the answer for this response has always been “not applicable.” At the current time, the Nuveen funds contemplate the following as an example of what the disclosure will
resemble going forward:

 Less than 50 percent of the hours expended on the principal accountant’s engagement to audit the
registrant’s financial statements for the most recent fiscal year were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees.

3)
Comment: Why were the following amended filings made? In the future, include a cover sheet detailing the reason for the amended
filing. In addition, whenever amended filings are made and those filings include certifications, the certifications should be updated to the date of the amended filing, even if the amended filings are made one day later than the original
filing. For example, the Form N-Q/A filed on September 1, 2010, for Nuveen Texas Quality Income Municipal Fund contains certifications dated June 29, 2010.

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Item

Registrant

Form

Filing Date

1.

Nuveen Investment Funds, Inc.

N-CSR/A

February 8, 2012

2.

Nuveen Diversified Dividend & Income Fund

N-CSR/A

March 14, 2012

3.

Nuveen Arizona Dividend Advantage Municipal Fund 3

N-SAR-A/A

November 1, 2011

4.

Nuveen California Dividend Advantage Municipal Fund

N-SAR-A/A

November 1, 2011

5.

Nuveen California Dividend Advantage Municipal Fund 3

N-SAR-A/A

November 1, 2011

6.

Nuveen California AMT-Free Municipal Income Fund

N-SAR-A/A

November 1, 2011

7.

Nuveen Investment Funds, Inc.

N-SAR-A/A

January 12, 2012

8.

Nuveen Municipal Trust

N-SAR-A/A

January 12, 2012

9.

Nuveen Investment Funds, Inc.

N-SAR-B/A

January 13, 2012

10.

Nuveen New Jersey Dividend Advantage Municipal Fund 2

N-SAR-A/A

January 17, 2012

11.

Nuveen New Jersey Dividend Advantage Municipal Fund

N-SAR-A/A

January 17, 2012
 2 filings

12.

Nuveen New Jersey Municipal Value Fund

N-SAR-A/A

January 17, 2012

13.

Nuveen New Jersey Premium Income Municipal Fund, Inc.

N-SAR-A/A

January 17, 2012

14.

Nuveen New Jersey Investment Quality Municipal Fund, Inc.

N-SAR-A/A

January 17, 2012

15.

Nuveen Pennsylvania Investment Quality Municipal Fund, Inc.

N-SAR-A/A

January 17, 2012

16.

Nuveen Pennsylvania Premium Income Municipal Fund 2

N-SAR-A/A

January 17, 2012

17.

Nuveen Pennsylvania Dividend Advantage Municipal Fund 2

N-SAR-A/A

January 17, 2012

18.

Nuveen Pennsylvania Dividend Advantage Municipal Fund

N-SAR-A/A

January 17, 2012

19.

Nuveen Pennsylvania Municipal Value Fund

N-SAR-A/A

January 17, 2012

20.

Nuveen Municipal Opportunity Fund Inc.

N-SAR-B/A

January 17, 2012

21.

Nuveen Dividend Advantage Municipal Income Fund

N-SAR-B/A

January 17, 2012

22.

Nuveen Quality Municipal Fund Inc.

N-SAR-B/A

January 17, 2012

23.

Nuveen AMT-Free Municipal Income Fund

N-SAR-B/A

January 17, 2012

24.

Nuveen Multi-Currency Short-Term Gov’t Income Fund

N-SAR-A/A

September 8, 2011

25.

Nuveen Municipal Trust

N-SAR-A/A

May 16, 2012

26.

Nuveen Investment Funds, Inc.

N-SAR-B/A

February 29, 2012

27.

Nuveen Texas Quality Income Municipal Fund

N-Q/A

September 1, 2010

28.

Nuveen Senior Income Fund

N-Q/A

June 30, 2011

29.

Nuveen Floating Rate Income Fund

N-Q/A

June 30, 2011

30.

Nuveen Floating Rate Income Opportunity Fund

N-Q/A

June 30, 2011

31.

Nuveen Investment Trust III

N-Q/A

August 30, 2011

32.

Nuveen Investment Funds, Inc.

N-Q/A

October 13, 2011

33.

Nuveen Investment Funds, Inc.

N-Q/A

October 13, 2011

 Response: The filings in the aforementioned table will be referred to in this response by their
“Item” number as identified in the first column. As indicated in the attached Appendix A, at the time of the Staff’s review the Nuveen Funds were comprised of approximately 230 funds with eleven fiscal year ends. Because the funds
continuously report throughout the course of the year we experience “peaks” and “valleys” in our reporting cycles. Consequently, the “peaks” in our reporting cycles lead to instances where a high volume of edits are
communicated to our staff and/or print vendors in the days immediately preceding the printing and/or filing of shareholder information. This was consequently the primary result for a majority of the amended filings questioned by the Staff. In future
amended filings, we will include an explanatory cover memo and updated certifications.

 Item #1

Form N-CSR/A filed on February 8, 2012, for Item #1 was completed to correct the total returns presented in the October 31,
2011, annual report for the Nuveen Tactical Market Opportunities Fund (“TMO”). TMO’s total returns for Class A Shares and Class C Shares were misstated in its Financial Highlights as follows:

Class A Shares: Original Total Return 6.61%; Corrected Total Return 5.95%

Class C Shares: Original Total Return 5.87%; Corrected Total Return 5.48%

As discussed with you on February 22, 2012, in addition to amending the Form N-CSR we also corrected the Fund’s shareholder
report posted on the fund’s website.

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 Item #2

 Form N-CSR/A filed on March 14, 2012, for Item #2 was completed to include Wellington Management’s proxy voting policies and procedures that were referenced within Item 7 of the filing but
inadvertently left out by our print vendor upon their conversion of the filing from HTML to Edgar format.

 Item #3 through
#6

 Forms N-SAR-A/A filed on November 1, 2011, for Items #3 through #6 were completed to include Exhibit 77E, Legal
Proceedings, which was inadvertently excluded from each filing.

 Items #7 through #19

Forms N-SAR-A/A filed on January 12, 2012, for Items #7 and #8, Form N-SAR-B/A filed on January 13, 2012, for Item #9, and Forms
N-SAR-A/A filed on January 17, 2012, for Items #10 through #19 were completed to correct financial statement data provided in each Form’s original filing. For each item, it was discovered that a draft shareholder report, rather than the
final shareholder report, had been utilized to answer certain questions in the Form, resulting in the inclusion of incorrect financial statement data.

 We have enhanced our procedures around our N-SAR filing process to prevent a repeat of these occurrences. As part of those enhancements, we are currently in the process of obtaining a new web based N-SAR
application, which will allow for a more timely preparation and review process of the filings.

 The second Form N-SAR-A/A
filed on January 17, 2012 for Item #11, was to include Exhibit 77E, Legal Proceedings, which was inadvertently excluded from the Form N-SAR-A/A filing.

 Item #20 through Item #23

 Forms N-SAR-B/A filed on January 17, 2012,
for Items #20 through #23 were completed to correct the funds’ top ten total purchases and sales in questions 23C and 23D, respectively.

 Item #25

 Form N-SAR-A/A filed on May 16, 2012, for Item #25 was
completed to add the name of fund number two within the trust as required by question 7 C020200, which was inadvertently excluded from the filing.

 Item #26

 Form N-SAR-B/A filed on February 29, 2012, was completed to
restate certain financial statement information for Nuveen Real Estate Securities Fund for the fiscal year ended October 31, 2011, and to replace the Accountants Report on Internal Control in Exhibit 77B in conjunction with the matter.

 Item #27

 Form N-Q/A filed on September 1, 2010, for Item #27 was completed to reinsert a page that was inadvertently left out of the original Form N-Q filed by our print vendor upon their conversion of the
filing from HTML to Edgar format.

 Items #28 through #31

Forms N-Q/A filed on June 30, 2011, for Items #28 through #30 and August 30, 2011, for Item #31 were completed to reflect edits
our print vendor was unable to incorporate into the filing prior to the 4:30 p.m. CT filing deadline. The filings were amended immediately upon receipt of the completed edits.

Items #32 and #33

 Forms N-Q/A filed on October 13, 2011, for Items #32 and #33 were completed to correct the funds’ Accounting Standards Codification 820 (“ASC 820”) fair value measurement
disclosures included within the portfolios of investments. The review of the ASC 820 disclosures included within the original filing was performed by an individual other than the Fund Administration – Financial Reporting manager typically
responsible for overseeing the ASC 820 review process, as he was out of the office on holiday immediately preceding and on the original filing date. Upon his return, he re-performed the ASC 820 review and identified differences we believed should be
corrected. We have since then enhanced our overall ASC 820 procedures by familiarizing other higher level individuals within the Financial Reporting department with such reviews.

4)
Comment: For those Nuveen closed-end funds that had lawsuits related to Auction Rate Preferred Shares (“ARPS”), the SEC staff did not
observe the filed complaints as required by Section 33 of the 1940 Act.

 Response: Twenty-three
of the affected funds filed the relevant Complaint with the Securities and Exchange Commission (“SEC”) on August 20, 2010, in paper form. We can provide you with versions that are receipt-stamped by the SEC staff if you desire.
Following the submissions by those funds, the plaintiffs named an additional eleven funds to the matter, but for which Section 33 filings were inadvertently omitted. Upon final disposition of the