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Nuveen Investments

 June 29, 2018

Mr. Jason Fox

 U.S. Securities and
Exchange Commission

 Division of Investment Management, Insured Investments Office

100 F Street N.E.

 Washington DC 20549

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

 Dear Mr. Fox:

 This
letter addresses the comments Ms. Sheila Stout provided in a telephone discussion on April 17, 2018, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain
regulatory filings made by the Nuveen closed-end and open-end registered investment companies listed on Appendix A attached hereto, (each a “Fund” and
collectively, the “Funds”), and advised by Nuveen Fund Advisors, LLC (the “Adviser”). Each comment is shown below followed by our response.

1)
 Comment: For certain Nuveen municipal
closed-end funds (for example, Nuveen Municipal Income Opportunity Fund, Nuveen AMT-Free Municipal Value Fund and others) Note 4 within the Notes to Financial Statements
explains, “Costs incurred by the Fund in connection with its Shelf Offering were recorded as a deferred charge and recognized as a component of “Deferred offering costs” on the Statement of Assets and Liabilities. The deferred asset
is reduced during the one-year period that additional shares are sold by reducing the proceeds from such sales and recognized as a component of “Proceeds from shelf offering, net of offering costs”
on the Statement of Changes in Net Assets. Any remaining deferred charges at the end of the one-year life of the Shelf Offering period will be expensed accordingly, as well as any additional Shelf Offering
costs the Fund may incur. As Shelf Offering costs are expensed they are recognized as a component of “Other expenses” on the Statement of Operations.” Please reference the guidance under Generally Accepted Accounting Principles
(“GAAP”) for this accounting treatment.

 Response: The Funds
follow the guidance set forth in Section 8.31 of the September 2017 AICPA Audit & Accounting Guide – Investment Companies which refers to “Costs Incurred in Shelf Registration” (AICPA, Technical Questions and Answers)
Section 4110.10, which reads as follows:

 Some
closed-end funds and business development companies offer stock through shelf registration statements. According to Q&A section 4110.10, “Costs Incurred in Shelf Registration” (AICPA, Technical
Questions and Answers), legal and other fees incurred for a stock issue under a shelf registration should be capitalized as a prepaid expense. When securities are taken off the shelf and sold, a portion of the costs attributable to the securities
sold should be charged against paid-in-capital. Any subsequent costs incurred to keep the filing “alive” should be charged to expense as incurred. If the
filing is withdrawn, the related capitalized costs should be charged to expense.

 As such, the costs incurred with
registering shares are capitalized as a deferred asset and charged against paid-in-capital on a pro-rata basis as shares are
sold. Any remaining deferred asset balance associated with “unsold shares” is expensed at the end of the program period (one year from the effective date of the filing). Costs incurred in filing Form 486B, if necessary, are expensed.

2)
 Comment: A majority of the Nuveen closed-end
and open-end municipal Funds hold securities with optional call provisions, which means the bonds can be redeemed or paid off by the issuer prior to the bonds’ maturity date. Since the bonds can be called
at any time, they are more risky for investors than non-callable bonds because the investor bears the risk of loss of future interest payments. Please consider adding additional disclosure in the Funds’
prospectus and/or shareholder reports regarding such interest rate risk.

Response: We have reviewed the prospectus disclosures for a sample of municipal open-end funds and municipal closed-end Funds. We have found that the disclosure on this point in all cases was adequate. The relevant disclosure from the open-end Funds’ summary prospectuses that we found (in this case the summary prospectus for Nuveen All-American Municipal Bond Fund) was:

Call Risk — If, during periods of falling interest rates, an issuer calls higher-yielding municipal
bonds held by the Fund, the Fund may have to reinvest in securities with lower yields, which may adversely impact the Fund’s performance.

The somewhat more expansive disclosure in the open-end Funds’ full statutory
prospectus (again, for Nuveen All-American Municipal Bond Fund):

Call risk: Municipal bonds are subject to call risk. Many bonds may be redeemed at the option of the
issuer, or “called,” before their stated maturity date. In general, an issuer will call its bonds if they can be refinanced by issuing new bonds which bear a lower interest rate. A fund is subject to the possibility that during periods of
falling interest rates, a bond issuer will call its high yielding bonds. A fund would then be forced to invest the unanticipated proceeds at lower interest rates, resulting in a decline in the fund’s income.

The disclosure from a typical prospectus for a closed-end municipal fund (taken from
the January 16, 2016 prospectus from Nuveen Municipal 2021 Target Term Fund) is as follows:

 Call
Risk. The Fund may invest in securities that are subject to call risk. Debt instruments may be redeemed at the option of the issuer, or “called,” before their stated maturity or redemption date. In general, an issuer will call its debt
instruments if they can be refinanced by issuing new instruments which bear a lower interest or dividend rate. The Fund is subject to the possibility that during periods of falling interest rates, an issuer will call its high yielding debt
instruments. The Fund would then be forced to invest the unanticipated proceeds at lower interest or dividend rates, resulting in a decline in the Fund’s income.

We are reviewing the shareholder reports of the affected funds and expect to add disclosure about call risk wherever it does not already
appear. From the survey we have conducted so far, the open-end fund shareholder reports mention call risk, while closed-end fund shareholder reports do not.

3)
 Comment: For Nuveen Municipal High Income Opportunity Fund (NMZ), the Fund’s
website discloses, “No more than 10% of the fund’s managed assets may be invested in municipal securities rated at or below B3/B-, or that are unrated but judged by the manager to be of comparable
quality.” However, the Fund’s October 31, 2017 annual report indicates that more than 25% of the Fund’s total investment exposure is in non-rated securities. Please confirm that no more
than 10% of the Funds’ managed assets are invested in securities rated below single B.

 Response: As of October 31, 2017, NMZ’s portfolio
contained 7.1% (as a % of managed assets) of securities rated B3/B- or lower, plus 24.6% (as a % of managed assets) of securities that were unrated but judged by the manager to be of comparable quality, for a
total of 31.7% (as a % of managed assets). Please note that this particular policy was misstated in the October 31, 2017 annual report. In the course of documenting the proposal and approval of a change to NMZ’s investment policies at a
different part of the credit curve (the rules relating to the maximum and minimum percentages of managed assets that could or must be invested in securities that were investment grade and below-investment grade), the internal and Board memos
regarding the change misstated the policy regarding the CCC/single B dividing line. The longstanding policy of NMZ was that the Fund could invest no more than 10% of managed assets in securities rated below
B3/B-; these two memos misstated that policy to read that the Fund could invest no more than 10% of its managed assets in securities rated “at or” below B3/B-.
That misstated policy was utilized by those individuals who maintain the website and prepare the shareholder reports. We later determined that the actual “below B3/B-” policy had not actually
changed, because its inclusion (in misstated form) in the internal and Board memos was dictum – that is, it was not germane to the policy change proposal or decision, and so the Board never specifically approved the misstated B3/B- policy, so that in turn that policy, as misstated, never took effect.

4)
 Comment: The prospectus for Nuveen Short-Term Municipal Bond Fund states that,
“The Fund may utilize the following derivatives: futures contracts and options on futures contracts. The Fund may use these derivatives in an attempt to manage market risk, credit risk and yield curve risk, and to manage the effective maturity
or duration of securities in the Fund’s portfolio.” In addition, the Fund has disclosed derivatives as both a “principal investment strategy” and a “principle risk,” however, the Fund has not utilized derivatives in the
past three fiscal years. Please consider not disclosing derivative instruments as “principal” in future filings.

Response: Both Nuveen management and the Fund’s investment team consider the use of derivative instruments
to be one of the Fund’s principal investment strategies, and we respectfully decline to remove derivatives-related policies disclosures from the referenced sections of the Fund prospectus. As disclosed, the Fund may use derivatives to manage
interest rate risk, yield curve risk, and credit risk, and to manage the effective duration of securities in the Fund’s portfolio. However, market conditions over the recent years have been marked by historically low interest rates, a
relatively flat yield curve, and a relatively benign credit market. In these conditions over this period, the Fund’s investment team has generally determined that the use of all or most derivative instruments was not necessary for the
management of these risks. If and when market conditions change, however, either or both management and/or the investment team may decide to utilize derivatives for the stated purposes. As such, management continues to regard the described
derivatives to be a component of the Fund’s principal investment strategies.

5)
Comment: For Nuveen Municipal Trust, are the fee waivers/expense reimbursements received by a Fund subject to recoupment? In addition, please confirm whether the Adviser has any agreements in
place to recoup fee waivers and/or expense reimbursements.

 Response: For certain Funds,
the Adviser has an agreement in place to waive fees and/or reimburse expenses as stated in the Fund’s prospectus and/or statement of additional information. The Adviser does not have any agreements in place to recoup fee waivers/expenses
reimbursed in prior fiscal periods from any Nuveen open-end Fund (including those Funds comprising Nuveen Municipal Trust), closed-end Fund or exchange-traded Fund.

6)
 Comment: For certain municipal closed-end
Funds, Note 4 of the Notes to Financial Statements for Institutional MuniFund Term Preferred Shares (“iMTP Shares”) discloses that “costs incurred by the Fund in connection with its offering of iMTP Shares were recorded as a deferred
charge, which are

amortized over the life of the shares and are recognized as components of “Institutional MuniFund Term Preferred (“iMTP”) Shares, net of deferred offering costs” on the
Statement of Assets and Liabilities. Please ensure that the disclosure included within the Notes to Financial Statements is consistent with Financial Accounting Standards Board, Accounting Standards Update (“ASU”) 2015-03 (“ASU 2015-03”): Interest-Imputation of Interest, which requires debt issuance costs to be presented in the Statement of Assets and Liabilities as a direct
deduction from the carrying amount of the associated debt liability.

 Response: The
Statement of Assets and Liabilities recognizes a Fund’s iMTP Shares as components of “Institutional MuniFund Term Preferred (“iMTP”) Shares, net of deferred offering costs” as required by ASU
2015-03. However, we do recognize that a Fund’s outstanding iMTP shares are disclosed at their liquidation preference within Note 4 of the Notes to Financial Statements to allow a reader of the financial
statements to easily reconcile such amounts to the outstanding amount of iMTP Shares disclosed within the (1) Fund Leverage section, (2) parenthetical disclosure on the Statement of Assets and Liabilities and (3) aggregate amount
outstanding of iMTP Shares at the end of period within the Financial Highlights. To be consistent with the presentation on the Statement of Asset and Liabilities, we are adding the “Liquidation Preference, Net of Deferred Offering
Costs” amount to the disclosure describing the amount of iMTP Shares outstanding as of the end of the reporting period. Such additional disclosure will also be added to Note 4 of the Notes to the Financial Statements for any Fund impacted by
ASU 2015-03.

7)
 Comment: For Nuveen Minnesota Municipal Bond Fund, the Fund’s
May 31, 2017 annual report indicates that the Fund had more than 20% of its total investment exposure in below investment grade (“junk”) bonds. Please confirm that the Fund is in compliance with its investment
policy.

 Response: The Nuveen Minnesota Municipal Bond Fund (FMN) was indeed above the
maximum 20% of total investment exposure in below investment grade bonds as of May 31, 2017. This policy is one that applies “at time of purchase.” FMN “passively” went above the 20% threshold in November of the previous
year. FMN made no purchases of below investment grade bonds between its last purchase of below-investment grade bonds prior to climbing above the 20% threshold in November of 2016 and May 31, 2017. Therefore, FMN was in compliance with this
investment policy on May 31, 2017.

8)
 Comment: For Nuveen New Jersey Municipal Value Fund (NJV), Note 1 of the Notes to
Financial Statements within the Fund’s February 28, 2017 annual report indicates that the Fund is non-diversified, however, it appears as though the Fund has been operating as diversified. Should the
Fund be classified as diversified, and if so, shareholder approval will be required prior to the Fund changing its diversification status. [Please refer to Rule 13a-1 of the 1940 Act and the Allied Capital no-action letter.]

 Response: NJV was registered as non-diversified at its inception on April 28, 2009. The most recent quarter-end at which we found the Fund to be non-diversified
was in March of 2017, when the above-5% concentration reached 25.2%. Since that time, NJV has been generally very close to 25% in above-5% concentration, with our
Charles River Diversification status report showing it at 24.62% as of the annual report date listed in the comment (February 28, 2017). If the Fund continues to avoid exceeding the 25% threshold, we would change its classification to
“diversified” on March 31, 2020.

9)
 Comment: For Nuveen Build America Bond Fund (NBB), as of March 31, 2017 the Fund
has > 25% of its net assets investment in California municipal bonds, however the Fund’s most recent prospectus (2010) does not include any disclosure regarding the risk of investing a substantial concentration of the Fund’s
portfolio holdings in any one particular industry or state. Please consider updating the Fund’s prospectus and/or website disclosures accordingly.

 Response: NBB had greater than 25% of its net assets
invested in California obligations as of March 31, 2017 (27.4%). The Fund had at all times a policy in place to prevent a securities of issuers from a single state from constituting more than 25% of the total assets of NBB, and the 1940
Act specifications for state-related concentration are couched in terms of “total” assets, not net. See Rel. IC-9785 (May 31, 1977), which uses the term “assets”, which we believe can only
be interpreted as referring to “total assets.” On that same date, NBB had 21.15% of its total assets invested in California obligations, and thus was not in vi