SecProbe.io

April 11, 2014
 VIA E-MAIL
 Kenneth E. Burdon, Esq. Skadden, Arps, Slate, Meagher & Flom LLP 500 Boylston Street Boston, MA  02116
Re: BlackRock Floating Rate Income Strategies Fund, Inc.
File Nos. 333-194573 & 811-21413
Dear Mr. Burdon:
We have reviewed the registration statem ent for BlackRock Floating Rate Income
Strategies Fund, Inc. (the “Fund”) filed on Fo rm N-2 on March 14, 2014 in connection with the
shelf registration of shares of common stock.  Our comments are set forth below.  For
convenience, we have used the captions, page numb ers and defined terms used in the registration
statement.

PROSPECTUS:

Item 1. Outside Front Cover (page I-1)
1. The first sentence of the second paragraph under It em 1.b. states that the Fund seeks to invest
“under normal circumstances, at least 80% of its Managed Assets (as defined herein) in
floating rate debt securities . . . .”  Please revise the parenthe tical to provide a more specific
cross-reference indicating where the te rm “Managed Assets” is defined.
 2. The second sentence of the second paragraph under Item 1.b. provide s that the Fund may
invest in debt securities and loans that are ra ted below investment grad e.  Please revise the
disclosure to explain that “bel ow investment grade” securities are commonly referred to as
“junk bonds”.
 3. The third paragraph states that the Fund may invest  directly in floating ra te debt securities or
synthetically through the use of  derivatives.  Please address each of the following:
 a. Please consider the staff observations concer ning derivatives disclosure set forth in
the letter from Barry D. Miller, Associate Di rector, Office of Legal and Disclosure, to
Karrie McMillan, General Counsel, Invest ment Company Institute dated July 30,
2010.  See http://www.sec.gov/divisions/in vestment/guidance/ici073010.pdf.

Kenneth E. Burdon, Esq.
April 11, 2014 Page 2

b. If the Fund intends to count derivatives toward the Fund’s 80% policy, please state
that the derivatives will have similar econom ic characteristics to floating rate debt
securities.  See Investment Company Act Rel ease No. 24828, at note 13 (Jan. 17,
2001).  In addition, please explain to us how  derivatives will be valued for purposes
of the 80% policy and for purposes of calcu lating Managed Assets to determine the
management fee.  We may have additiona l comments after revi ewing your response.

c. Please note that to the extent the Fund ente rs into a derivative c ontract, it must set
aside an appropriate amount of segregated assets.  See generally  Investment Company
Act Release No. 10666 (Apr. 18, 1979).  Please di sclose in an appropriate location of
the registration statement an explanation as  to how the Fund will segregate assets to
meet its obligations under Section 18 of the Investment Company Act of 1940 (the
“Investment Company Act”).  Please include an affirmative statement that if the Fund
sells credit default swaps or credit default index swaps, it will segregate the full notional value of the swap agreement.  Please also note that the Commission has issued a concept release exploring issues re lating to the use of derivatives by funds,
including whether current market practices involving derivatives are consistent with
the leverage provisions of th e Investment Company Act.  See Investment Company
Act Release No. 29776 (Aug. 31, 2011).  Acco rdingly, please be aware that the
Commission or its sta ff could issue future guidance re lated to derivatives (such as
total return swaps) and leve rage, including guidance related to coverage requirements,
which could impact the manner in which the Fund operates.

Item 3. Fee Table and Synopsis (Page I-3)
4. Please delete the parenthetical s “(including interest expense) ”, which appears after the
caption “Total annual expenses”.

5. Please delete the last two lines  of the fee table and the corr esponding footnotes.  Those lines
show the amount of a voluntary f ee waiver and the total expenses  after the fee waiver.  Only
contractual fee waivers may be presen ted in the body of the fee table.  See Instruction 3.e. to
Item 3 of Form N-1A.
 6. Page I-18 of the prospectus indi cates that the Fund may engage in short sales of securities.
Please confirm that the Fund discloses the expenses associated with short sales ( e.g., interest
and dividends paid on short sales) in the fee table as “Other Expenses.”  See AICPA Audit
and Accounting Guide: Investment  Companies ¶ 7.108.j. (May 1, 2013).

Distributions (Page I-8)

7. This section provides that the Fund intends to make monthly distributions of net investment
income and annual distributions of any capital ga ins.  If the Fund expects to make return of
capital distributions, please disclose that expectation in this se ction and explain the

Kenneth E. Burdon, Esq.
April 11, 2014 Page 3

 consequences of return of capital distributions, i.e., that the distribution is a return of the
shareholder’s original investme nt (which though not currently taxable will lower his or her
basis in the Fund, thus potential ly subjecting the shareholder to  future tax consequences in
connection with the sale of Fund shares, even if sold at a loss to the shareholder’s original
investment).

Special Risk Considerations (Page I-9)

8. This section identifies each of the risks of an  investment in the Fund.  Please provide in this
section a brief description of each prin cipal risk of investing in the Fund.

Subsidiary (Page I-20)

9. This section states that th e Fund wholly owns FRA Subsidiary, LLC, a Delaware-domiciled
entity.  This section further states  that the Subsidiary is a taxabl e entity and that its assets are
managed by the Investment Advisor subject to th e same investment policies and restrictions
that apply to the Fund.  We note that the Fund’ s shareholder report for the fiscal year ended
August 31, 2013 discloses that the financial statem ents of the Subsidia ry are consolidated
with the financial statements of the F und.  Please respond to the following comments
concerning the Subsidiary in which the Fund invests.

a. Disclose that the advisory arrangemen t among the Fund, the Subsidiary and the
Investment Advisor complies with Secti on 15 of the Investment Company Act.
Please file the advisory agreement concerni ng the Subsidiary as an exhibit to the
registration statement.

b. Disclose that the Subsidiary complies with  the provisions of the Investment Company
Act relating to affiliated transactions and custody (Section 17) and identify the
custodian of the Subsidiary.

c. Disclose in the discussion  of investment strategy th e Fund’s investment through a
wholly-owned subsidiary.  Disclose any of  the Subsidiary’s principal investment
strategies or principal risks th at constitute principal invest ment strategies or risks of
the Fund.

d. Confirm to us that the Subsidiary’s expens es, including tax expens es, are included in
the Fund’s fee table.

e. Please ensure that the Subsidiary and its board of directors sign the Fund’s
registration statement.

Item 25. Financial Statements and Exhibits (Page I-29)

10. The exhibit list indicates that an opinion and consent of counsel will be filed by amendment.

Kenneth E. Burdon, Esq.
April 11, 2014 Page 4

 Since the terms of the actual offerings from th is registration statement have not yet been
authorized by the Fund’s Board of Trustees , please confirm that the Fund will file an
unqualified legality opinion and related consent of counsel in a post-effective amendment
with each takedown from this sh elf registration statement.  See SEC Division of Corporation
Finance Staff Legal Bulletin N o. 19, text at note 26 (Oct. 14, 2011).
 11. The power of  attorney filed as Exhibit (s), wh ich relates to 81 funds identified in a table
attached to the power of attorn ey, does not appear to meet the requirement that a power of
attorney “relate to a specific filing.”  See Rule 483(b) under the S ecurities Act of 1933 (the
“Securities Act”).  If the next pre-effective amendment will be signed by power of attorney,
please file as an exhibit a new power of atto rney meeting the requirements of Rule 483(b).

GENERAL COMMENTS:
 12. Where a comment is made in one location, it is applicable to a ll similar disclosure appearing
elsewhere in the registration statement.
 13. We note that portions of the filing are incomp lete.  We may have additional comments on
such portions when you complete them in a pre- effective amendment, on disclosures made in
response to this letter, on in formation supplied supplementally, or on exhibits added in any
pre-effective amendments.

14. If you intend to omit certain information from  the form of prospectus included with the
registration statement that is declared effective in reliance on Rule 430A under the Securities
Act, please identify the omitted information to us supplementally, preferably before filing the final pre-effective amendment.

15. Please advise us if you have submitted or expect to submit an exemptive application or no-
action request in connection with  your registration statement.

16. Please state in your response letter whethe r FINRA will or has reviewed the proposed
underwriting terms and arrangements of the transaction involved in the Registration
Statement.

17. Response to this letter should be in the form of a pre-effective amen dment filed pursuant to
Rule 472 under the Securities Act.  Where no cha nge will be made in the filing in response to
a comment, please indicate this fact in a suppl emental letter and brie fly state the basis for
your position.

18. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filings reviewed by the staff to be certa in that they have provided all information
investors require for an informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Kenneth E. Burdon, Esq.
April 11, 2014 Page 5

 Notwithstanding our comments, in the event th e Fund requests accelera tion of the effective
date of the pending registration statement, it should furnish a letter, at the time of such
request, acknowledging that

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;
 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve th e Fund from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and
 the Fund may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of  the United States.
  In addition, please be advised that the Division of Enforcemen t has access to all information
you provide to the staff of the Division of I nvestment Management in connection with our
review of your filing or in respons e to our comments on your filing.

 We will consider a written request for acceleration of the effective date of the registration
statement as a confirmation of the fact that those requesting accelerat ion are aware of their
respective responsibilities.  We  will act on the request and, pursuant to delegated authority,
grant acceleration of the effective date.

* * * * * * *
If you have any questions prior to filing a pre-effective amendment, please call me at
(202) 551-6945.

Sincerely,
                /s/ John M. Ganley
   John M. Ganley
Senior Counsel
 cc: Michael J. Shaffer