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    787 Seventh Avenue

New York, NY 10019-6099

Tel: 212 728 8000

Fax: 212 728 8111

July 18, 2023

VIA EDGAR

Kimberly Browning

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    Proxy
    Materials on Schedule 14A for the Funds Listed on Appendix A hereto

Dear Ms. Browning:

On behalf of the funds listed on Appendix A hereto (collectively,
the “Funds”), this letter responds to (1) comments provided by the staff of the Division of Investment Management
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned by telephone
on June 26, 2023 regarding the preliminary proxy materials filed with the Commission on June 16, 2023 (the
 “Preliminary Proxy Materials”) by each Fund and (2) comments provided by the Staff to the undersigned and Hannah
Fiest by telephone on July 14, 2023 and to the undersigned by telephone on July 17, 2023 regarding the draft definitive proxy
materials (the “Definitive Proxy Materials”) and draft of this letter provided to the Staff on July 12, 2023.

The Staff’s
comments to the Preliminary Proxy Materials are summarized below in italicized text in Part A of this letter, and the Staff’s
comments to the draft Definitive Proxy Materials are summarized below in italicized text in Part B of this letter. We have
discussed the Staff’s comments with representatives of the Funds. Each Fund’s response to each comment is set out immediately
under the restated comment. Please note that we have not independently verified information provided by the Funds. Defined terms, unless
otherwise defined herein, have the meanings given them in the Preliminary Proxy Materials and Definitive Proxy Materials, as applicable.

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    July 18, 2023
 Page 2

Part A: Staff Comments to Preliminary Proxy Materials

General

    Comment No. 1:
    The Staff’s comments relate to the Preliminary Proxy Materials filed by Credit Suisse Asset Management Income Fund, Inc. and Credit Suisse High Yield Bond Fund (the “Closed-End Fund Preliminary Proxy Materials”) and apply equally to the Preliminary Proxy Materials filed by Credit Suisse Commodity Strategy Funds, Credit Suisse Opportunity Funds and Credit Suisse Trust (the “Open-End Fund Preliminary Proxy Materials”).  Please confirm that the Open-End Fund Preliminary Proxy Materials are identical to the Closed-End Fund Preliminary Proxy Materials.  In addition, the Staff’s comments apply globally wherever the relevant disclosure appears in the Preliminary Proxy Materials.

    Response:
    The Funds confirm that the Open-End Fund Preliminary Proxy Materials are identical to the Closed-End Fund Preliminary Proxy Materials.  The Funds acknowledge that all comments provided by the Staff apply to both sets of Preliminary Proxy Materials and will address the Staff’s comments in each instance where the relevant disclosure appears in the Preliminary Proxy Materials.

    Shareholder Letter

    Comment No. 2:
    Please clarify that the following statement refers to the Funds’ principal investment strategies: “Even though there will be no change in the portfolio managers or the investment strategies of your Fund . . . .”  Also, please consider expanding this statement to refer to each Fund’s investment objective, fundamental and non-fundamental investment restrictions, principal investment policies and principal risks.

    Response:
    The requested changes will be made.

    Comment No. 3:
    Please clarify what is meant by the statement that “the closing of the Transaction may be deemed to have caused a technical termination of the Funds’ investment advisory agreements with Credit Suisse, as well as the sub-advisory agreement between Credit Suisse and Credit Suisse UK with respect to Credit Suisse Strategic Income Fund.” This statement is ambiguous and should be revised to be more specific as to why the closing of the Transaction resulted in a termination of the Funds’ investment advisory and sub-advisory agreements, including a discussion of the assignment of such agreements.

    Response:
    The requested change will be made.

    Comment No. 4:
    Please consider using the defined term “Merger” as opposed to “Transaction” to align with the description of the merger of Credit Suisse Group AG with and into UBS Group AG.

    Response:
    The requested change will be made.

    Comment No. 5:
    In the Joint Proxy Statement, please include representations that the Funds will comply with the requirements of Section 15(f) of the Investment Company Act of 1940, as amended (the “1940 Act”).

    July 18, 2023
 Page 3

    Response:
    The requested change will be made.

    Comment No. 6:
    The statement that “it is expected that the investment advisory services that Credit Suisse and Credit Suisse UK provide to the Funds will be transitioned (through merger of entities or transfer of services) to asset management affiliates of UBS Group within one year of the closing of the Transaction, subject to any approvals deemed necessary” is vague.  Please clarify what approvals are contemplated by “subject to any approvals deemed necessary,” and also clarify timing of the transition to the extent possible. Also, please clarify whether “asset management affiliates of UBS Group” refers to advisers and sub-advisers.

    Response:
    The Funds cannot further clarify the timing of the transition of investment advisory services, as the exact timing of the transition has not yet been determined. Otherwise, the requested changes will be made.

    Comment No. 7:
    Please include a statement that the Board believes the new investment advisory and sub-advisory agreements are in the best interests of the Funds and their shareholders, as applicable.

    Response:
    The requested change will be made.

    Comment No. 8:
    Please explain the contractual expense limitation agreements to which the Open-End Funds are party and disclose if there are any recoupment rights under such agreements.  Also, please describe any voluntary waivers of any Fund’s management fees.  Please discuss whether the contractual expense limitation agreements and any voluntary waivers will remain in place and the Board’s consideration of such arrangements in approving the new investment advisory agreements.

    Response:
    The requested changes will be made.

    Question and Answers (“Q&A”)

    Comment No. 9:
    On page ii, the response to “How do the new investment advisory agreement and new sub-advisory agreement, as applicable, differ from my Fund’s current agreement(s)?” states that “[t]he new agreements will be substantially identical to the current agreements, except for the dates of execution, effectiveness and termination and certain non-material changes.” The use of the phrase “substantially identical” is vague as to whether there are material differences between the new and current agreements.  If there are any material differences, please disclose those differences as required by Item 22(c)(8) of Schedule 14A. If there are no material differences, revise this sentence to remove the word “substantially” before “identical.” In addition, please supplementally confirm that current and pro forma fee information required by Item 22(a)(3)(iv) of Schedule 14A is not required to be disclosed.

    July 18, 2023
 Page 4

    Response:
    The above-referenced disclosure will be revised to delete the word “substantially.”  Each Fund confirms that the current and pro forma fee information required by Item 22(a)(3)(iv) of Schedule 14A is not required to be disclosed because the approval of each Fund’s new investment advisory agreement and, in the case of Credit Suisse Strategic Income Fund, the new sub-advisory agreement would not, directly or indirectly, establish a new fee or increase any existing fee or expense to be paid by the Fund or its shareholders.

    Comment No. 10:
    On page iii, the phrasing of the response to the question “Will the new investment advisory and sub-advisory agreements result in any changes in the portfolio management, investment objective or investment strategy of my Fund?” is vague because of the use of phrases such as “no immediate changes” and “are currently anticipated.”  Please clarify the response to this question.

    Response:
    The requested change will be made.

    Comment No. 11:
    Please clarify that shareholders of each Fund will vote separately on the new investment advisory agreements and that shareholders will be entitled to vote only with respect to approval of the new investment advisory agreement(s) for the Fund(s) of which they held shares on the Record Date.

    Response:
    The requested changes will be made.

    Comment No. 12:
    In the response to “What else is happening with Credit Suisse and the Funds?”, please use the same terminology that was used in the application for an exemption from Section 9(a) of the 1940 Act filed by Credit Suisse, Credit Suisse UK and certain of their affiliates on June 7, 2023 with the Commission, and also include the date that the Consent Order and Final Judgment was filed with the New Jersey Superior Court.  In addition, please remove the  following language from the end of the first paragraph of the response: “, including with respect to Credit Suisse’s view (as supported by outside counsel to the Funds) that the Consent Judgment was not disqualifying.”

    Response:
    The Funds respectfully note that the language at the end of the first paragraph is accurate.  Nevertheless, the Funds will delete the language in response to the Staff’s request and make the other requested changes.

    Comment No. 13:
    In the response to the question “What happens if new investment advisory and sub-advisory agreements are not approved for my Fund?”, please add a cross-reference to the discussion of the interim investment advisory agreements and interim investment sub-advisory agreement in the Joint Proxy Statement.  Please revise the comparison of the interim agreements and the prior agreements to align with the requirements of Rule 15a-4 under the 1940 Act.

    July 18, 2023
 Page 5

    Response:
    The requested changes will be made.  The Funds note that the discussion of the interim investment advisory agreements and interim sub-advisory agreement will be moved to the response to a new question in the Q&A (“Given that the Prior Advisory Agreements terminated on the Closing Date, is there any investment advisory agreement currently in place for my Fund?”) and the requested cross-reference will be added in such response.

    Comment No. 14:
    Please add disclosure addressing whether the approval of one Fund’s investment advisory agreement is contingent upon the approval of another Fund’s investment advisory agreement.  In addition, please add disclosure that Proposal 2 is contingent upon the approval of Proposal 1 by shareholders of Credit Suisse Strategic Income Fund.

    Response:
    The requested changes will be made.

    Comment No. 15:
    On page iii, please move the discussion of the Open-End Funds’ contractual expense limitation agreements into its own Q&A and add the detail regarding such agreements and any voluntary waivers requested by the Staff in Comment No. 8 above.

    Response:
    The requested changes will be made.

    Comment No. 16:
    On page iii, in the response to the question “Will there be any changes to my Fund’s custodian or other service providers as a result of the Transaction”, please clarify that the Funds’ service providers will continue to provide the applicable services to the Funds at the same rate and that the Funds’ other expenses will not change.

    Response:
    The requested changes will be made.

    Comment No. 17:
    In the Joint Proxy Statement, please revise the disclosure regarding Credit Suisse’s bearing the expenses of the proxy statement and proxy solicitation to state that all costs will be borne by Credit Suisse “out of its own legitimate profits.”  Please supplementally confirm to the Staff whether Credit Suisse will seek reimbursement of the costs of the proxy solicitation and, if so, please add disclosure to this effect.

    Response:
    The requested change will be made.  The Funds confirm that Credit Suisse will not seek reimbursement of the costs of the proxy solicitation.

    July 18, 2023
 Page 6

    Notice of Joint Special Meeting of Shareholders

    Comment No. 18:
    Please bold or move to a separate paragraph the disclosure regarding a shareholder’s ability to revoke its proxy in both the Notice of Joint Special Meeting of Shareholders and the Joint Proxy Statement.

    Response:
    The requested change will be made.

    Joint Proxy Statement

    Comment No. 19:
    On page 4, please revise the second paragraph of the subsection entitled “Background—Interim Agreements” under the section entitled “Proposal 1 and Proposal 2—Approval of a New Investment Advisory Agreement with Credit Suisse and, with Respect to the Strategic Income Fund Only, Approval of a New Sub-Advisory Agreement Between Credit Suisse and Credit Suisse UK” (such section, the “Proposal Discussion”) to describe how the Interim Advisory Agreements comply with Rule 15a-4 under the 1940 Act, rather than describing the requirements of Rule 15a-4.  In addition, please revise the comparison of the Interim Advisory Agreements and the Prior Advisory Agreements in (iv) of this paragraph to align with the requirements of Rule 15a-4.  Finally, please add disclosure to this paragraph clarifying how the advisory fees held in escrow are paid out pursuant to Rule 15a-4 depending on whether or not a Fund’s shareholders approve the applicable New Advisory Agreement(s).

    Response:
    The requested changes will be made.

    Comment No. 20:
    On page 4, in the first paragraph of the subsection entitled “Background—Interim Agreements” under the Proposal Discussion, please revise the discussion of each Board’s approval of the applicable Interim Advisory Agreement(s) to align with the Board approval requirement in Rule 15a-4(b)(2)(iv) under the 1940 Act.  Also, please supplementally confirm to the Staff that the Board satisfies the condition in Rule 15a-4(b)(2)(vii).

    Response:
    The requested change will be made.  Each Fund confirms that its Board satisfies the condition in Rule 15a-4(b)(2)(vii) (i.e., the Board satisfies the fund governance standards defined in Rule 0-1(a)(7) under the 1940 Act).

    Comment No. 21:
    On pages 7-8, in the subsection entitled “Comparison of the Prior Advisory Agreements and the New Advisory Agreements” under the Proposal Discussion, please clarify whether the advisory fee rates payable under the New Advisory Agreements are the same as those payable under the Prior Advisory Agreements.

    Response:
    The requested change will be made to the above-referenced subsection.  In addition, Appendix G and the references thereto will be revised to clarify that Appendix G sets out the advisory fee rates payable under both the Prior Advisory Agreements and the New Advisory Agreements.

    July 18, 2023
 Page 7

    Comment No. 22:
    On page 8, please revise the subsection entitled “Board Review and Approval of the New Advisory Agreements—Investment Advisory Fee Rates and Expenses” under the Proposal Discussion to break up the discussion into subsections or bullet points. Please also discuss any expense limitations or waivers separately in this subsection.  In addition, please state that each Fund’s Board considered the advisory fee rates payable under both the Fund’s Prior Advisory Agreement(s) and the Fund’s New Advisory Agreement(s).

    Response:
    The requested changes will be made.

    Comment No. 23:
    On page 8, in the subsection entitled  “Board