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CORRESP
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CORRESP

 April 9, 2021

Ms. Megan Miller

 U.S. Securities and Exchange
Commission

 Division of Investment Management, Disclosure Review & Accounting Office

100 F Street N.E.

 Washington DC 20549

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

Dear Ms. Miller,

 This letter addresses the comments you
provided in a telephone discussion on March 5, 2021, 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” or “Registrant” and collectively, the “Funds” or “Registrants”), and advised by Nuveen Fund Advisors, LLC (the
“Adviser”). Each comment is shown below followed by management’s response.

1.
 Comment: Please include gains and losses on 17a-7 transactions going forward. Please
refer to the guidance in the January 19, 2016 AICPA expert panel meeting minutes, which provides examples of qualitative and quantitative disclosures for inter-fund transactions (under section 17a-7 of the Investment Company Act of 1940). The
SEC Staff notes Nuveen California Municipal Value Fund, Inc. (NCA) and Nuveen California AMT-Free Quality Municipal Income Fund (NKX) for reference.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds will disclose the realized
gains and losses recognized in connection with 17a-7 transactions. The gain and loss amounts will be added to the Funds’ current disclosure for 17-a transactions, which is within Note 7. Management Fees and Other Transactions with
Affiliates, Other Transactions with Affiliates of the notes to financial statements.

2.
 Comment: Please explain how the Funds met the disclosure requirements for disclosure of
distributable earnings on a tax basis in the notes to financial statements and how it aligns with what is presented in the statement of assets and liabilities as required by Accounting Standards Codification (“ASC”) 946-20-50-11,
Components of Capital and Distributable Earnings, which requires all investment companies to disclose only two components of capital on the balance sheet: shareholder capital and distributable earnings. The components of distributable earnings, on a
tax basis, shall be disclosed in a note to financial statements. This information enables investors to determine the amount of accumulated and undistributed earnings they potentially could receive in the future and on which they could be treated.
The SEC Staff notes the Nuveen California and New York closed-end Funds for reference.

 Response: The
Funds met the requirements of ASC 946-20-50-11 by disclosing the respective components of distributable earnings on a tax basis within Note 6. Income Tax Information of the notes to financial statements. The components of distributable
earnings on a tax basis consist of net unrealized appreciation/(depreciation), undistributed net tax-exempt income, undistributed net ordinary income, undistributed net long-term capital gains, and unused capital loss carry forwards, where
applicable. These amounts align with the distributable earnings on the statement of assets and liabilities after adjusting for the income distribution that

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was declared on February 3, 2020 and paid on March 2, 2020 as disclosed in the footnote under the tax components of undistributed income table, which read as follows in the
February 29, 2020 annual report for the Nuveen California and New York closed-end Funds:

1
 Undistributed net tax-exempt income (on a tax basis) has not been reduced for the dividend declared on
February 3, 2020, and paid on March 2, 2020.

3.
 Comment: For Funds that have liabilities for inverse floaters and preferred shares,
please see ASC 820-10-50-2e or Section 7.9.7 of the 2019 Audit Guide, which requires that for each class of assets and liabilities not measured at fair value in the statement of financial position but for which the fair value is disclosed, a
reporting entity shall disclose the information required by paragraph ASC 820-10-50-2(b), (bbb)(1), and (h).

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the following disclosure will be
included within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements, and will immediately follow the tables that summarize the fair values of the Funds’ investments as of the end of the reporting
period:

 The Funds hold liabilities in floating rate obligations and preferred shares, where applicable, which are not reflected in the
tables above. The fair values of the Funds’ liabilities for floating rate obligations approximate their liquidation values. Floating rate obligations are generally classified as Level 2 and further described in Note 4. Portfolio Securities
and Investments in Derivatives. The fair values of the Funds’ liabilities for preferred shares approximate their liquidation preference. Preferred shares are generally classified as Level 2 and further described in Note 5. Fund
Shares.

4.
 Comment: The SEC Staff notes that in certain Funds’ notes to financial statements the
Funds may enter into a shortfall agreement for inverse floaters and they also describe certain commitments and contingencies for preferred shares. Please consider adding a separate line item in the statement of assets and liabilities relating to
these commitment and contingencies. Please refer to Regulation S-X (“Reg S-X”) §210.6-04.15.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, a “Commitments and
Contingencies” line item will be added to the Funds’ statement of assets and liabilities, where applicable. This line item will also direct the reader to the applicable footnote disclosure within the notes to financial statements, which
will generally read as follows, and will be updated as appropriate:

 Commitments and Contingencies

In the normal course of business, each Fund enters into a variety of agreements that may expose the Fund to some risk of loss. These could
include recourse arrangements for certain TOB Trusts and certain agreements related to preferred shares, which are each described elsewhere in these Notes to Financial Statements. The risk of future loss arising from such agreements, while not
quantifiable, is expected to be remote. As of the end of the reporting period, the Funds did not have any unfunded commitments.

 From
time to time, the Funds may be a party to certain legal proceedings in the ordinary course of business, including proceedings relating to the enforcement of the Funds’ rights under contracts. As of the end of the reporting period, the Funds are
not subject to any material legal proceedings.

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5.
 Comment: To the extent a Fund holds positions in both long and short futures contracts,
please break them out into two separate tables. The SEC Staff notes the Nuveen Multi-Market Income Fund (JMM) and Nuveen Strategic Income Fund for reference.

Response: Beginning with the Funds’ regulatory filings dated March 31, 2021, the Funds will include a tabular
disclosure for each of the long and short futures contracts in their portfolios of investments, where applicable.

6.
 Comment: On a go forward basis, please include a reconciliation between the statement of
assets and liabilities and statement of cash flows when the statement of assets and liabilities includes more than one line item for cash or restricted cash equivalents. Please refer to ASC 230-10-50-8, Restrictions on Cash and Cash Equivalents,
which explains when cash, cash equivalents, and amounts generally described as restricted cash or restricted cash equivalents are presented in more than one line item within the statement of financial position, an entity shall, for each period that
a statement of financial position is presented, present on the face of the statement of cash flows or disclose in the notes to the financial statements, the line items and amounts of cash, cash equivalents, and amounts generally described as
restricted cash or restricted cash equivalents reported within the statement of financial position. The amounts, disaggregated by the line item in which they appear within the statement of financial position, shall sum to the total amount of cash,
cash equivalents, and amounts generally described as restricted cash or restricted cash equivalents at the end of the corresponding period shown in the statement of cash flows. This disclosure may be provided in either a narrative or a tabular
format. The SEC Staff notes the Nuveen Multi-Market Income Fund (JMM), Nuveen California High Yield Fund, Nuveen Preferred & Income Opportunities Fund (JPC), Nuveen Preferred and Income Term Fund (JPI), Nuveen Preferred & Income
Securities Fund (JPS) and Nuveen Preferred and Income 2022 Term Fund (JPT) for reference.

 Response:
Beginning with the Funds’ shareholder reports dated March 31, 2021, when cash, cash equivalents, foreign currency, and restricted cash are presented in more than one line item on the statement of assets and liabilities, a Fund will include
a reconciliation of the total in the statement of cash flows to the related captions on the statement of assets and liabilities. The following is an example of how such disclosure will appear using Nuveen Preferred & Income Opportunities
Fund’s (JPC) annual report for the fiscal year ended July 31, 2020:

 The following table provides a reconciliation of cash and
cash collateral at brokers to the statement of assets and liabilities:

JPC

   Cash

$
243,503

   Cash collateral at brokers for investments in futures

439,993

   Cash collateral at brokers for investments in
swaps

16,942,853

   Total cash and cash collateral at
brokers

$
  17,626,349

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7.
 Comment: Please include interest payable with the value of reverse repurchase
agreements on a go forward basis as required by Reg S-X §210.4-08(m)(1). The SEC Staff notes Nuveen Mortgage and Income Fund (JLS), Nuveen Preferred & Income Opportunities Fund (JPC), and Nuveen Build American Bond Fund (NBB) for
reference.

 Response: Beginning with the Funds’ shareholder reports dated March 31, 2021,
the Funds’ reverse repurchase agreements presented on the statement of assets and liabilities will include the accrued interest payable associated with those reverse repurchase agreements. The following is an example using Nuveen
Preferred & Income Opportunities Fund’s (JPC) annual report for the fiscal year ended July 31, 2020:

 Liabilities

 Reverse repurchase agreements, including accrued interest

$
10,063,830

8.
 Comment: For Nuveen Multi-Market Income Fund (JMM), it appears that some of the Fund’s
investments may pay interest based on London Interbank Offered Rate (“LIBOR”). Please explain if the elimination of LIBOR is a principle risk of the Fund and how the discontinuation can impact the value of the Fund’s holdings. If the
discontinuation of LIBOR will impact the Fund, please update the Fund’s disclosure to discuss how this will affect the Fund’s investments. Please refer to the SEC press release dated July 12, 2019, SEC Staff Publishes Statement
Highlighting Risks for Market Participants to Consider As They Transition Away from LIBOR (the “SEC LIBOR Statement”).

Response: Management has determined that the elimination of LIBOR is not a principal risk for Nuveen Multi-Market Income Fund
(JMM), however, management is continuously evaluating the potential effect a discontinuation of LIBOR could have on the Funds’ investments. At this time, management is not anticipating any significant impacts to the Funds’ investments, and
as such, beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ will enhance their existing disclosure around LIBOR within Note 2. Significant Accounting Policies of the notes to financial statements as
follows (new disclosure underlined):

 Reference Rate Reform

In March 2020, FASB issued Accounting Standards Update (“ASU”) 2020-04, Reference Rate Reform: Facilitation of the Effects of
Reference Rate Reform on Financial Reporting. The main objective of the new guidance is to provide relief to companies that will be impacted by the expected change in benchmark interest rates, when participating banks will no longer be required to
submit London Interbank Offered Rate (LIBOR) quotes by the UK Financial Conduct Authority (FCA). The new guidance allows companies to, provided the only change to existing contracts are a change to an approved benchmark interest rate, account for
modifications as a continuance of the existing contract without additional analysis. For new and existing contracts, the Funds may elect to apply the amendments as of March 12, 2020 through December 31, 2022. Management has not yet
elected to apply the amendments, is continuously evaluating the potential effect a discontinuation of LIBOR could have on the Funds’ investments and has currently determined that it is unlikely the ASU’s adoption will have a significant
impact on the Funds’ financial statements and various filings,

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9.
 Comment: For Funds with reverse repurchase agreements, please consider adding to the risk
disclosures that a Fund posts and receives securities and cash as collateral with a market value in excess of the repurchase price to be paid or received by a trust upon maturity of the transaction. Upon a bankruptcy or insolvency of a counterparty,
a Fund is considered to be an unsecured creditor with respect to excess collateral and as such the return of excess collateral may be delayed.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ disclosure relating to
reverse repurchase agreements that is included within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements will be enhanced to read as follows:

The Fund may enter into a reverse repurchase agreement with brokers, dealers, banks or other financial institutions that have been determined
by the Adviser to be creditworthy. In a reverse repurchase agreement, a Fund sells to the counterparty a security that it holds with a contemporaneous agreement to repurchase the same security at an agreed-upon price and date, reflecting the
interest rate effective for the term of the agreement. It may also be viewed as the borrowing of money by the Fund. Cash received in exchange for securities delivered, plus accrued interest payments to be made by the Fund to a counterparty, are
reflected as a liability on the Statement of Assets and Liabilities. Interest payments made by the Fund to counterparties are recognized as a component of “Interest expense and amortization of offering costs” on the Statement of
Operations.

 In a reverse repurchase agreement, the Fund retains the risk of loss associated with the sold security. In order to minimize
risk, the Fund pledges and/or segregates securities and cash as collateral with a fair value at least equal to its purchase obligations under these agreements (including accrued interest). Reverse repurchase agreements also involve the risk that the
purchaser fails to return the securities as agreed upon, files for bankruptcy or becomes insolvent. Upon a bankruptcy or insolvency of a counterparty, the Fund is considered to be an unsecured creditor with respect to excess collateral and as such
the return of excess collateral may be delayed. A Fund will pledge assets determined to be liquid by the Adviser to cover its obligations under reverse repurchase agreements.

10.
 Comment: Please include LIBOR transition risks in the Funds’ Form N-CSR
(“N-CSR”) filings on a go forward basis. The SEC Staff notes that there is nothing about transition risk in the Funds’ current disclosure. Please refer to the SEC LIBOR Statement. The SEC Staff notes Nuveen Senior Income Fund (NSL),
Nuveen Floating Rate Incom