SEC Company Response from Nuveen Preferred & Income Opportunities Fund (JPC) (CIK 0001216583) (JPC) — Mar 6, 2017
Nuveen Preferred & Income Opportunities Fund (JPC) (CIK 0001216583)
Date: March 6, 2017 · CIK: 0001216583 · Accession: 0001193125-17-071876
AI Filing Summary & Sentiment
File numbers found in text: 333-215072
Letter
Correspondence
Chicago
New York
Washington, DC
London
San Francisco
Los Angeles
Singapore
vedderprice.com
March 6, 2017
Nathaniel Segal
Associate
+1 312 609 7747
nsegal@vedderprice.com
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Ms. Elisabeth Bentzinger, Esq.
Re: Nuveen Preferred Income Opportunities Fund (the “Registrant”)
File No. 333-215072
To the Commission:
On behalf of the Registrant, this letter is in response to discussions with the staff of the U.S. Securities and Exchange Commission with respect to the treatment of “CoCos” for purposes of the Names Rule (as defined below). Registrant hereby undertakes as follows:
Nuveen Preferred Income Opportunities Fund undertakes, promptly following a determination, if any, by the staff of the Securities and Exchange Commission, notwithstanding the effectiveness of the N-14, that contingent capital securities (commonly referred to as “CoCos”) cannot be regarded as “preferred securities” for purposes of Rule 35d-1 under the Investment Company Act of 1940 (“Names Rule”), to (i) modify the definition of “preferred securities” for purposes of complying with the Names Rule to exclude CoCos, (ii) modify its name in order that its investment policies comply with the staff interpretation of the Names Rule, or (iii) take such other action that is necessary or sufficient to comply with the staff’s determination with respect to the treatment of CoCos as “preferred securities” under the Names Rule.
Please direct your questions and/or comments regarding this filing to Deborah Bielicke Eades at (312) 609-7661 or the undersigned at (312) 609-7747.
Very truly yours,
/s/ Nathaniel Segal
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CORRESP 1 filename1.htm Correspondence Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com March 6, 2017 Nathaniel Segal Associate +1 312 609 7747 nsegal@vedderprice.com U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Attn: Ms. Elisabeth Bentzinger, Esq. Re: Nuveen Preferred Income Opportunities Fund (the “Registrant”) File No. 333-215072 To the Commission: On behalf of the Registrant, this letter is in response to discussions with the staff of the U.S. Securities and Exchange Commission with respect to the treatment of “CoCos” for purposes of the Names Rule (as defined below). Registrant hereby undertakes as follows: Nuveen Preferred Income Opportunities Fund undertakes, promptly following a determination, if any, by the staff of the Securities and Exchange Commission, notwithstanding the effectiveness of the N-14, that contingent capital securities (commonly referred to as “CoCos”) cannot be regarded as “preferred securities” for purposes of Rule 35d-1 under the Investment Company Act of 1940 (“Names Rule”), to (i) modify the definition of “preferred securities” for purposes of complying with the Names Rule to exclude CoCos, (ii) modify its name in order that its investment policies comply with the staff interpretation of the Names Rule, or (iii) take such other action that is necessary or sufficient to comply with the staff’s determination with respect to the treatment of CoCos as “preferred securities” under the Names Rule. Please direct your questions and/or comments regarding this filing to Deborah Bielicke Eades at (312) 609-7661 or the undersigned at (312) 609-7747. Very truly yours, /s/ Nathaniel Segal Nathaniel Segal 222 North LaSalle Street Chicago, Illinois 60601 T +1 312 609 7500 F +1 312 609 5005 Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore. CHICAGO/#2959237.1