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Nuveen Investments

 April 19, 2013

 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 Follow-Up Discussion

 Dear Christina:

This letter addresses your comments provided in a telephone discussion on February 13, 2013. This was a follow-up discussion to
our December 11, 2012, correspondence filing pertaining to our telephone discussion held on September 25, 2012. Each comment shown below was included in our December 11th correspondence filing and is followed by our current response. Unless otherwise noted, the responses relate to all
funds listed on Appendix A.

1)
Comment #8: The Nuveen.com website shows for leveraged Closed-End Funds (“CEFs”) two different expense ratios: one based on
“Common Shares,” the other based on “Total Fund” An example of such a table:

Total Fund

Common
Shares

Management Fees

0.59%

0.90%

Interest Expenses

0.44%

0.64%

Other Expenses

0.09%

0.13%

Total

1.12%

1.67%

 The Staff believes that it is inherently misleading for a leveraged CEF to quote expense figures using
“total fund net assets” as the denominator. First, generally accepted accounting principles (“GAAP”) specifies that expense figures be quoted using “net assets attributable to common shares” as the denominator. Second,
no shareholder, common or preferred, actually “experiences” or pays the lower expense percentages expressed as a percentage of total fund net assets, and therefore those figures do not have any concrete meaning for shareholders.
Accordingly, the Staff requests that these funds consider removing the expense figures based on total fund net assets from such tables, and include those figures in a much less prominent place, such as a footnote.

Revised Response: Nuveen understands the Staff’s position is not that the inclusion of fund-based expense figures are
necessarily invalid, but that Nuveen’s website presentation inappropriately gives those figures “equal prominence” with the GAAP-compliant, common share-asset-based expense figures, which are not properly explained and
contextualized. At the current time Nuveen is continuing to disclose such figures on its website with the disclosure modified to resemble the following (for the same fund but for a different period, so the numbers have changed slightly):

Common
Shares

Total Fund

 Management Fees

0.89%

0.59%

 Other Expenses

.10%

.07%

 Subtotal

0.99%

0.66%

 Interest Expense From Leverage

0.68%

0.48%

 Total Expenses

1.67%

1.14%

 Fund fees and expenses are presented as a percentage of both common shareholder capital and total fund
investment capital. Total investment capital includes common assets as well as assets attributable to the fund’s issuance of senior securities (e.g. preferred shares and other forms of leverage). The table’s first column presents the costs
directly and indirectly borne by common shareholders on an investment in the fund’s common shares. The table’s second column presents the costs borne by the fund on its total investment capital, which enables a common shareholder to better
understand how fund expenses impact portfolio investment returns. Interest expenses from leverage are shown separately, because they represent costs associated with the fund’s financing activities which are distinct from the costs associated
with the fund’s underlying core operations.

 Other Expenses and Total Expenses do not include interest expenses arising
from externally created inverse floating rate securities (if any) held by the fund. Interest expense arises because accounting rules require the

fund to treat interest paid by trusts issuing self-created inverse floating rate instruments (if any) held by the fund as having been paid (indirectly) by the fund. Because the fund also
recognizes a corresponding amount of additional income earned (also indirectly), the fund’s net asset value per share, net investment income and total return have not been affected by this accounting treatment. See the fund’s Annual Report
for information on the fund’s inverse floating rate investments and recognized interest expense.

 The expense ratio shown
may reflect a voluntary expense waiver by the fund’s investment adviser which can be modified or discontinued at any time without notice and may also reflect custodian fee credits and legal fee refunds. Absent the limitation, credits and
refunds, expenses would be higher and total returns would be less. See the fund’s Annual Report for information on expenses and waivers. Expense ratios do not reflect the effect of dividend payments to preferred shareholders.

Response filed on December 11th: Nuveen respectfully but strongly disagrees with any
assertion that a leveraged CEF’s expense figures quoted as a percentage of total fund net assets are “not meaningful” and/or “inherently misleading” when such figures are accompanied by expense figures quoted as a percentage
of common share net assets in equal prominence. Indeed, we believe that, for certain important purposes the total fund net asset figures are more meaningful and insightful than the common share net asset-based expense figures.

We agree with the Staff’s position that expenses expressed as a percentage of the net assets attributable to a CEF’s common
shares is a relevant and meaningful indicator of expenses, because it is the common shareholders who end up paying, and therefore “experiencing”, those expenses. However, it is Nuveen’s and the Nuveen Funds’ view – and we
believe that it is a commonly held view in the industry– that expense figures should also provide a shareholder or other investor a perspective on what proportion of a fund portfolio’s return-generating power is being reduced by the
so-called “friction” associated with expenses. In a leveraged CEF, the returns of the fund are being generated on the total amount of the fund’s assets, not just on the amount of assets attributable to the fund’s common shares.
Likewise, and perhaps more importantly to this discussion, fund expenses are by and large being generated and “experienced” at the total fund level, not at the common shareholder level. For example, management fees of the Nuveen CEFs are
computed and paid based on the fund’s total net assets, and not on assets attributable to just the common shares. Similarly, most other types of expenses (e.g., audit, custodian, legal) are incurred with respect to or by reference to the entire
fund, and not just to that portion of the fund or its assets that are attributable to common shares.

 In a simple,
non-leveraged example, a bond fund whose portfolio generates a 5% gross return and pays 1% in total expenses would experience a reduction of 20% of its return due to this “expense friction”. A fund that generates the same gross return with
less “expense friction” than another fund could be thought of as producing that gross return more “efficiently.” Thus, expense figures provide investors with important indicators of a fund’s “expense efficiency”,
and investors often wish to compare the expense efficiency of competing funds.

 In an analogous but inherently more
complicated leveraged CEF situation, quoting only expense figures (management fees, other expenses, and total expenses) based on common share net assets prevents the investor from truly being able to gauge a fund’s “expense
efficiency”, because that set of expense figures would vary between two otherwise identical funds with identical fund-level expenses but differing leverage ratios in general proportion to those leverage ratios. The more highly levered fund will
show higher expenses expressed as a percentage of common share net assets than the less levered fund, and will appear, falsely, to be less “expense efficient” than that less levered fund. And even that less-levered fund will appear to be
less “expense efficient” than a non-levered fund. For example, a levered fund having a 33.3% leverage ratio ($33.33 of leveraging instrument for every $100 of total assets) and paying a management fee equal to .50% of fund net assets would
show a management fee based on common share net assets of .75%, while a levered fund with a 20% leverage ratio and paying that same .50% management fee would show a management fee based on common share net assets of .625%, and a non-levered fund
paying that same management fee would of course show a management fee of .50%. Investors in the latter fund would believe, based on those common share net asset-based expense figures, that their fund’s investment adviser was receiving a lower
management fee than the adviser of the other funds, when in fact that was not the case.

 Indeed, quoting only common share net
asset-based expense figures without accompanying them with the CEF’s total fund net asset-based expense figures could even prove potentially misleading to investors, for example, in the circumstance where the more highly levered fund was
actually paying lower management fees, custodian fees, audit fees, etc. on fund assets than a less-levered fund or especially a non-levered fund, but would still be quoting a higher set of expense ratios, for the mathematical reasons discussed
above. Thus, providing a leveraged fund’s expense figures expressed as a percentage of total net assets (in addition to quoting its expense figures as a percentage of common share net assets) provides investors with the ability to compare the
“expense efficiency” of leveraged funds with non-leveraged funds, and to compare the “expense efficiency” of funds having different leverage levels, on an apples-to-apples basis, in the sense that it shows the expenses generated
by each dollar of assets of each of the funds being compared. So long as such total fund net asset-based expense figures are accompanied, with equal prominence, with common share net asset-based expense figures, the reader or investor cannot fairly
claim to be misled by the former figures. Therefore, we intend to continue to quote expense figures as a percentage of total fund net assets side-by-side with expense figures quoted as a percentage as common share net assets.

2)
Comment 13: Those funds that elected to retain a portion of their realized long-term capital gains disclose in their shareholder reports the
total returns including the retained gain tax credit/refund and excluding the retained gain tax credit/refund. It is the SEC staff’s position that the total returns including the retained gain tax credit/refund be removed. The SEC gave examples
of those funds, including;

•

 Nuveen Diversified Dividend and Income Fund

•

 Nuveen Global Value Opportunities Fund

Revised Response: We discussed the Staff’s questions pertaining to the response we provided in our
December 11th correspondence filing and understand
there is no further action or information being requested regarding this matter.

 Response filed on
December 11th: Set forth below is the relevant disclosure from one of the two funds cited by the staff (Nuveen Global Value Opportunities Fund (JGV)):

[Share Distributions and Price Information Section]

 The following table provides information regarding the Fund’s distributions and total return performance for the fiscal year ended December 31, 2011. This information is intended to help you
better understand whether the Fund’s returns for the specified time period were sufficient to meet the Fund’s distributions.

  As of 12/31/11

JGV

   Inception date

7/24/06

   Fiscal year (calendar year) ended December 31, 2011:

   Per share distribution:

   From net investment income

$0.83

   From long-term capital gains

0.18

   From short-term capital gains

0.28

   Return of capital

0.08

   Total per share distribution

$1.37

   Distribution rate on NAV

8.10%

   Average annual total returns:

   Excluding retained gain tax credit/refund**:

   1-Year on NAV

-10.28%

   5-Year on NAV

4.72%

   Since inception on NAV

6.04%

   Including retained gain tax credit/refund**:

   1-Year on NAV

-10.28%

   5-Year on NAV

4.89%

   Since inception on NAV

6.20%

**
The Fund elected to retain a portion of its realized long-term capital gains for the tax year ended December 31, 2007, and pay required federal corporate income
taxes on this amount. As reported on Form 2439, shareholders on record date must include their pro-rata share of these gains on their applicable federal tax returns, and are entitled to take offsetting tax credits, for their pro-rata share of the
taxes paid by the Fund. The total returns “Including retained gain tax credit/refund” include the economic benefit to shareholders on record date of these tax credits/refunds. The Fund had no retained capital gains for the tax years ended
December 31, 2011 through December 31, 2008 or for the tax year ended December 31, 2006.

 [Performance Overview Section]

 Average Annual Total Returns

 (Inception 7/24/06)

On Share Price

On NAV

 1-Year

-11.00%

-10.28%

 5-Year

5.91%

4.72%

 Since Inception

5.58%

6.04%

 Average Annual Total Returns 3

(Including retained gain tax credit/refund)

 1-Year

-11.00%

-10.28%

 5-Year

6.10%

4.89%

 Since Inception

5.74%

6.20%

 3 As previously explained in the Share Distribution and Price Information section of this report, the Fund elected to
retain a portion of its realized long-term capital gains for the tax year ended December 31, 2007, and pay required federal corporate income taxes on these amounts. These standardized total returns include the economic benefit to shareholders
of record of this tax credit/refund. The Fund had no retained capital gains for the tax years ended December 31, 2011 through December 31, 2008 or for the tax year ended December 31, 2006.

Whenever a fund retains and pays tax on a portion of its realized capital gains in a given tax year, the Internal Revenue Code provides
that the fund also should distribute a capital gain tax “credit” to the fund’s shareholders that the shareholders can use, dollar-for-dollar, to reduce their own taxes. Fund shareholders simultaneously increase their cost basis by
their ratable share of undistributed net capital gains, net of taxes paid by the fund. As a result, a fund that retains and pays tax on a net realized gain would provide virtually the same all-in “economic” (i.e., after-tax) return to its
taxable shareholders as an otherwise identical fund that distributed its net realized capital gains to its shareholders (who then either paid capital gains tax on those gains or used those gains to offset losses that might otherwise have been usable
to offset other or later gains). The tax credit that the fund distributes to its shareholders in the first instance provides a tangible and quantifiable benefit to those of its shareholders who pay taxes, but the value of that benefit is not
reflected in the total returns calculated strictly from the fund’s financial records, because that tax credit is not quantified in financial statements as a “distribution;” while the tax payment by that fund does operate to reduce
that fund’s total return figures.

 The provision of an alternatively calculated supplemental total return figure in such
instances to reflect the value to taxable shareholders of the fund’s distribution to shareholders of this sort of tax credit in addition to the fund’s cash distributions is fair, appropriate and not misleading. The shareholders did
receive that tax credit, and that credit had real, quantifiable value to taxable shareholders. Note that a fund (“Fund A”) that had distributed the capital gain to shareholders would show, under ordinary calculation methodologies, a
higher total return than an otherwise identical fund (“Fund B”) that had retained the gain, paid taxes on that gain (and thereby reduced fund assets and returns) and distributed a tax credit to shareholders, even though taxable
shareholders of both of those otherwise identica