SEC Company Response from Nuveen S&P 500 Dynamic Overwrite Fund (SPXX) (CIK 0001338561) (SPXX) — Jul 21, 2015
Nuveen S&P 500 Dynamic Overwrite Fund (SPXX) (CIK 0001338561)
Date: July 21, 2015 · CIK: 0001338561 · Accession: 0001193125-15-257870
AI Filing Summary & Sentiment
File numbers found in text: 811-05309, 811-05930, 811-06081, 811-06177, 811-06264, 811-06294, 811-06425, 811-07118, 811-07482, 811-07619, 811-07720, 811-09037, 811-09451, 811-09457, 811-10549, 811-10551, 811-21216, 811-21674, 811-21708, 811-21731, 811-21893, 811-21983, 811-22018, 811-22029
Letter
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 you provided in a telephone discussion on June 18, 2015, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain regulatory filings made by closed-end and open-end registered investment companies (“funds”) advised by Nuveen Fund Advisors, LLC (“NFAL”). Each comment is shown below followed by our response. Unless otherwise noted, the responses relate to all funds listed on Appendix A attached hereto.
1) Comment: For the Nuveen Dividend Value Fund, the shareholder report cover has the incorrect ticker symbol for Class R6 Shares. The ticker symbol is currently FFEIX and should be FFEFX. Please correct in future filings.
Response: We agree with the SEC Staff’s comment and corrected the Fund’s ticker symbol effective with the Fund’s April 30, 2015 semi-annual report.
2) Comment: For those funds that invested significantly in derivatives during their fiscal year, management’s discussion of fund performance (“MDFP”) should discuss how the derivatives affected fund performance.
Response: As we indicated to you on our recent call, we received a similar comment during the SEC Staff’s last review in 2012, at which time we responded that we had expanded our disclosure in the MDFPs to include how a fund’s use of derivatives impacted performance during the reporting period if the fund used derivatives as a form of leverage and/or if the fund’s use of derivatives had a material impact on its performance. Examples of the funds’ most recent derivatives disclosures are as follows:
April 30, 2015 annual report for Nuveen Short Duration High Yield Municipal Bond Fund
“We owned interest rate swaps to modestly reduce the portfolio’s duration. By relying on hedges to manage sensitivity to changes in rates, we were able to be more deliberate about the securities we chose to own in the Fund. As expected in light of the overall drop in interest rates, however, these swaps hurt the Fund’s performance in absolute terms.”
March 31, 2015 annual report for Nuveen Build America Bond Fund (NBB) and Nuveen Build America Bond Opportunity Fund (NBD)
“However, because NBB and NBD also were using swaps to shorten long term interest rates at a time when rates were falling, the use of swaps had a negative impact on the Funds’ total return performance for the reporting period. This impact was greater in NBD, which made greater use of derivatives.”
March 31, 2015 semi-annual report for Nuveen Tactical Market Opportunities Fund
“Throughout the reporting period, we continued to use equity, interest rate and currency futures contracts, which were used to manage country and style exposures as well as implement various absolute return, tactical market and hedging strategies in the Fund. We also utilized equity put and call options to generate returns and manage the Fund. These put and call options were used to implement views on the direction of implied market volatility as well as hedge against a decline or increase in the market, respectively. Overall, these derivative positions were meaningful contributors to performance during the reporting period.”
Page 1 of 8
February 28, 2015 semi-annual report for Nuveen Strategy Balanced Allocation Fund
“Throughout the reporting period, we also tactically used equity and fixed income futures to adjust the Fund’s mix. Due to generally higher equity prices and fluctuating interest rates, the futures contracts had a moderately negative impact on performance as gains in large- and mid-cap futures were offset by small-cap short futures losses.”
January 31, 2015 semi-annual report for Nuveen Senior Income Fund (NSL), Nuveen Floating Rate Income Fund (JFR), Nuveen Floating Rate Income Opportunity Fund (JRO), Nuveen Short Duration Credit Opportunities Fund (JSD) and Nuveen Credit Strategies Income Fund (JQC)
“The Funds also used interest rate swap contracts to partially fix the interest cost of leverage, which as mentioned previously, is through bank borrowings and/or VRTP Shares. During the reporting period, NSL, JFR, JRO and JQC unwound their respective swap contracts. JSD began the reporting period with three swap contracts, one of which matured and another was unwound prior to the end of the reporting period. The swap contracts held by NSL, JFR, JRO and JQC had an overall negligible impact on Fund performance, while JSD’s swap contracts detracted modestly from overall Fund performance.”
December 31, 2014 semi-annual report for Nuveen Global Total Return Bond Fund
“During the reporting period, we also continued to utilize various derivative instruments. We used foreign currency exchange contracts to gain exposure to selected foreign currencies, as well as in some cases to hedge the currency risk present in a foreign bond. The overall effect of these contracts was positive as the majority of the positions were used for hedging purposes during the reporting period as the U.S. dollar rallied. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio. We used U.S. Treasury futures and Eurodollar futures as part of an overall portfolio construction strategy to manage portfolio duration and yield curve exposure; used selected foreign bond futures to actively manage exposure to those markets. The effect of these activities in the period was negative. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio. We used interest rate swaps as part of an overall portfolio construction strategy to manage duration and overall portfolio yield curve exposure. The swap positions detracted slightly from performance during the period. In addition, we entered into High Yield CDX swaps as a way to take on credit risk and earn a commensurate credit spread. The effect of these activities on performance was negligible during the period, as the positions were minimal. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio.”
Management continuously monitors disclosures regarding the funds’ uses of derivatives, striving to provide what we believe to be the best explanation to readers of the funds’ financial statements.
3) Comment: The portfolio of investments included within the shareholder reports for several open-end funds disclose a money market fund holding in Mount Vernon Securities Lending Trust Prime Portfolio (“Mount Vernon”). When recalculating the net asset value (“NAV”) per share of Mount Vernon as of June 30, 2014 in the Nuveen Strategic Income Fund’s annual report, as noted in the table below, the NAV per share does not equal $1.00. Disclose the NAV of such shares or explain why the NAV is not $1.00.
Shares
Description
Value
NAV per Share
84,532,292
Mount Vernon Securities Lending Trust Prime Portfolio
$85,180,247
$1.01
Response: The shares disclosed as of June 30, 2014 in the Nuveen Strategic Income Fund’s annual report were incorrect. The correct shares are $85,180,247, and as such, the NAV per share is $1.00.
4) Comment: Within the funds’ shareholder reports, the fair value measurements disclosures included within the notes to financial statements do not always indicate whether or not the funds had a transfer of securities between the three-tiered hierarchy of valuation input levels (Level 1, Level 2 and/or Level 3). In future shareholder reports, the fair value measurements disclosures should include whether or not such transfers occurred.
Page 2 of 8
Response: As we indicated to you on our recent call, in the preparation of the relevant valuation footnote disclosure for a fund, we identify all of the transfers between the three-tiered hierarchy of valuation input levels (Level 1, Level 2 and/or Level 3). However, for reporting in the financial statements we have established a de minimis floor below which we would not provide the expanded disclosures in the footnotes. In discussion with other industry participants, we believe this is a common practice followed by others in the industry. In establishing a de minimis floor, we believe it provides the reader of the financial statements a clearer picture of significant transfers between levels. We further believe that this is consistent with GAAP which provides that accounting standards do not apply to immaterial items. Therefore we believe our current disclosure practice provides the reader with the necessary information to conclude that no material transfers have occurred during the period.
5) Comment: Within several of the funds’ shareholder reports, the notes to financial statements include disclosures pertaining to agreements with the adviser for which the adviser agreed to reimburse and/or waive charges to the fund(s) for certain fees and/or expenses. Please confirm that it is not the adviser’s policy to recoup from the funds any amounts waived and/or reimbursed in prior periods during future periods.
Response: NFAL, the funds’ adviser, does not have, and does not currently intend to have, a policy to recoup from the funds during future fiscal years any amounts waived and/or reimbursed in prior fiscal years.
6) Comment: Within several of the funds’ shareholder reports, the notes to financial statements include disclosures for mergers that occurred during the fiscal period. However, those funds that were acquired have not yet completed a Form N-8F filing. Please review the funds that recently ceased operations and complete a Form N-8F filing accordingly.
Response: The SEC Staff is correct in identifying funds that have ceased operations, but had not yet completed a Form N-8F filing. We have identified and completed a Form N-8F filing for each of the funds listed in the table below.
Fund Name
Ticker
Symbol
CIK
File
Number
Date
Form N-8F
Filed with
SEC
Nuveen Pennsylvania Premium Income Municipal Fund 2
NPY
811-07482
June 25, 2015
Nuveen Pennsylvania Dividend Advantage Municipal Fund
NXM
811-09457
June 25, 2015
Nuveen Pennsylvania Dividend Advantage Municipal Fund 2
NVY
811-10549
June 25, 2015
Nuveen Massachusetts Dividend Advantage Municipal Fund
NMB
811-09451
June 25, 2015
Nuveen Massachusetts AMT-Free Municipal Income Fund
NGX
811-21216
June 25, 2015
Nuveen California Performance Plus Municipal Fund, Inc.
NCP
811-05930
June 25, 2015
Nuveen California Municipal Market Opportunity Fund, Inc.
NCO
811-06081
June 25, 2015
Nuveen California Investment Quality Municipal Fund, Inc.
NQC
811-06177
June 25, 2015
Nuveen California Select Quality Municipal Fund, Inc.
NVC
811-06294
June 25, 2015
Nuveen California Quality Income Municipal Fund, Inc.
NUC
811-06425
June 25, 2015
Nuveen California Premium Income Municipal Fund
NCU
811-07720
June 25, 2015
Nuveen New Jersey Investment Quality Municipal Fund, Inc.
NQJ
811-06264
June 25, 2015
Nuveen New Jersey Premium Income Municipal Fund, Inc.
NNJ
811-07118
June 25, 2015
Nuveen New Jersey Dividend Advantage Municipal Fund 2
NUJ
811-10551
June 25, 2015
Nuveen Global Income Opportunities Fund
JGG
811-21893
June 25, 2015
Nuveen Diversified Currency Opportunities Fund
JGT
811-22018
June 25, 2015
Nuveen Equity Premium Opportunity Fund
JSN
811-21674
June 25, 2015
Dow 30SM Premium & Dividend Income Fund Inc.
DPD
811-21708
June 25, 2015
Dow 30SM Enhanced Premium & Income Fund Inc.
DPO
811-22029
June 25, 2015
NASDAQ Premium Income & Growth Fund Inc.
QQQX
811-21983
June 25, 2015
Nuveen Equity Premium Advantage Fund
JLA
811-21731
June 25, 2015
Page 3 of 8
7) Comment: For the Form N-SAR filing identified in the table below, the filing indicates that there was a change in auditor from Ernst & Young LLP (“EY”) to KPMG, LLP during the fiscal period, but the letter from EY is not included as an exhibit to the filing. Amend the Form N-SAR filing to include the letter from EY.
File Number
Registrant
Date Filed
811-09037
Nuveen Investment Trust III
December 1, 2014
Response: Management amended the Form N-SAR filing for the Trust in the aforementioned table on July 16, 2015, to include the letter from EY within Exhibit 77K.
Page 4 of 8
Appendix A
CIK or
SEC File
Registrant
Fund Name
Ticker
Series ID
Number
Nuveen Investment Funds, Inc.
Nuveen Core Bond Fund
S000005548
811-05309
Nuveen Investment Funds, Inc.
Nuveen Core Plus Bond Fund
S000005578
811-05309
Nuveen Investment Funds, Inc.
Nuveen Dividend Value Fund
S000005579
811-05309
Nuveen Investment Funds, Inc.
Nuveen Equity Index Fund
S000005580
811-05309
Nuveen Investment Funds, Inc.
Nuveen Global Infrastructure Fund
S000020012
811-05309
Nuveen Investment Funds, Inc.
Nuveen High Income Bond Fund
S000005544
811-05309
Nuveen Investment Funds, Inc.
Nuveen Inflation Protected Securities Fund
S000005545
811-05309
Nuveen Investment Funds, Inc.
Nuveen Intermediate Government Bond Fund
S000005546
811-05309
Nuveen Investment Funds, Inc.
Nuveen Large Cap Growth Opportunities Fund
S000005550
811-05309
Nuveen Investment Funds, Inc.
Nuveen Large Cap Select Fund
S000005551
811-05309
Nuveen Investment Funds, Inc.
Nuveen Mid Cap Growth Opportunities Fund
S000005553
811-05309
Nuveen Investment Funds, Inc.
Nuveen Mid Cap Index Fund
S000005555
811-05309
Nuveen Investment Funds, Inc.
Nuveen Mid Cap Value Fund
S000005556
811-05309
Nuveen Investment Funds, Inc.
Nuveen Minnesota Intermediate Municipal Bond Fund
S000005558
811-05309
Nuveen Investment Funds, Inc.
Nuveen Minnesota Municipal Bond Fund
S000005559
811-05309
Nuveen Investment Funds, Inc.
Nuveen Nebraska Municipal Bond Fund
S000005560
811-05309
Nuveen Investment Funds, Inc.
Nuveen Oregon Intermediate Municipal Bond Fund
S000005562
811-05309
Nuveen Investment Funds, Inc.
Nuveen Real Asset Income Fund
S000033768
811-05309
Nuveen Investment Funds, Inc.
Nuveen Real Estate Securities Fund
S000005563
811-05309
Nuveen Investment Funds, Inc.
Nuveen Short Term Bond Fund
S000005566
811-05309
Nuveen Investment Funds, Inc.
Nuveen Short Term Municipal Bond Fund
S000005564
811-05309
Nuveen Investment Funds, Inc.
Nuveen Small Cap Growth Opportunities Fund
S000005567
811-05309
Nuveen Investment Funds, Inc.
Nuveen Small Cap Index Fund
S000005568
811-05309
Nuveen Investment Funds, Inc.
Nuveen Small Cap Select Fund
S000005569
811-05309
Nuveen Investment Funds, Inc.
Nuveen Small Cap Value Fund
S000005570
811-05309
Nuveen Investment Funds, Inc.
Nuveen Strategic Income Fund
S000005573
811-05309
Nuveen Investment Funds, Inc.
Nuveen Tactical Market Opportunities Fund
S000027104
811-05309
Nuveen Investment Trust
Nuveen Concentrated Core Fund
S000040902
811-07619
Nuveen Investment Trust
Nuveen Core Dividend Fund
S000040903
811-07619
Nuveen Investment Trust
Nuveen Equity Market Neutral Fund
S000040904
811-07619
Nuveen Investment Trust
Nuveen Global Tactical Opportunities Plus Fund
S000041890
Show Raw Text
CORRESP 1 filename1.htm Nuveen Investments July 21, 2015 Mr. Jason P. 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 you provided in a telephone discussion on June 18, 2015, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain regulatory filings made by closed-end and open-end registered investment companies (“funds”) advised by Nuveen Fund Advisors, LLC (“NFAL”). Each comment is shown below followed by our response. Unless otherwise noted, the responses relate to all funds listed on Appendix A attached hereto. 1) Comment: For the Nuveen Dividend Value Fund, the shareholder report cover has the incorrect ticker symbol for Class R6 Shares. The ticker symbol is currently FFEIX and should be FFEFX. Please correct in future filings. Response: We agree with the SEC Staff’s comment and corrected the Fund’s ticker symbol effective with the Fund’s April 30, 2015 semi-annual report. 2) Comment: For those funds that invested significantly in derivatives during their fiscal year, management’s discussion of fund performance (“MDFP”) should discuss how the derivatives affected fund performance. Response: As we indicated to you on our recent call, we received a similar comment during the SEC Staff’s last review in 2012, at which time we responded that we had expanded our disclosure in the MDFPs to include how a fund’s use of derivatives impacted performance during the reporting period if the fund used derivatives as a form of leverage and/or if the fund’s use of derivatives had a material impact on its performance. Examples of the funds’ most recent derivatives disclosures are as follows: April 30, 2015 annual report for Nuveen Short Duration High Yield Municipal Bond Fund “We owned interest rate swaps to modestly reduce the portfolio’s duration. By relying on hedges to manage sensitivity to changes in rates, we were able to be more deliberate about the securities we chose to own in the Fund. As expected in light of the overall drop in interest rates, however, these swaps hurt the Fund’s performance in absolute terms.” March 31, 2015 annual report for Nuveen Build America Bond Fund (NBB) and Nuveen Build America Bond Opportunity Fund (NBD) “However, because NBB and NBD also were using swaps to shorten long term interest rates at a time when rates were falling, the use of swaps had a negative impact on the Funds’ total return performance for the reporting period. This impact was greater in NBD, which made greater use of derivatives.” March 31, 2015 semi-annual report for Nuveen Tactical Market Opportunities Fund “Throughout the reporting period, we continued to use equity, interest rate and currency futures contracts, which were used to manage country and style exposures as well as implement various absolute return, tactical market and hedging strategies in the Fund. We also utilized equity put and call options to generate returns and manage the Fund. These put and call options were used to implement views on the direction of implied market volatility as well as hedge against a decline or increase in the market, respectively. Overall, these derivative positions were meaningful contributors to performance during the reporting period.” Page 1 of 8 February 28, 2015 semi-annual report for Nuveen Strategy Balanced Allocation Fund “Throughout the reporting period, we also tactically used equity and fixed income futures to adjust the Fund’s mix. Due to generally higher equity prices and fluctuating interest rates, the futures contracts had a moderately negative impact on performance as gains in large- and mid-cap futures were offset by small-cap short futures losses.” January 31, 2015 semi-annual report for Nuveen Senior Income Fund (NSL), Nuveen Floating Rate Income Fund (JFR), Nuveen Floating Rate Income Opportunity Fund (JRO), Nuveen Short Duration Credit Opportunities Fund (JSD) and Nuveen Credit Strategies Income Fund (JQC) “The Funds also used interest rate swap contracts to partially fix the interest cost of leverage, which as mentioned previously, is through bank borrowings and/or VRTP Shares. During the reporting period, NSL, JFR, JRO and JQC unwound their respective swap contracts. JSD began the reporting period with three swap contracts, one of which matured and another was unwound prior to the end of the reporting period. The swap contracts held by NSL, JFR, JRO and JQC had an overall negligible impact on Fund performance, while JSD’s swap contracts detracted modestly from overall Fund performance.” December 31, 2014 semi-annual report for Nuveen Global Total Return Bond Fund “During the reporting period, we also continued to utilize various derivative instruments. We used foreign currency exchange contracts to gain exposure to selected foreign currencies, as well as in some cases to hedge the currency risk present in a foreign bond. The overall effect of these contracts was positive as the majority of the positions were used for hedging purposes during the reporting period as the U.S. dollar rallied. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio. We used U.S. Treasury futures and Eurodollar futures as part of an overall portfolio construction strategy to manage portfolio duration and yield curve exposure; used selected foreign bond futures to actively manage exposure to those markets. The effect of these activities in the period was negative. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio. We used interest rate swaps as part of an overall portfolio construction strategy to manage duration and overall portfolio yield curve exposure. The swap positions detracted slightly from performance during the period. In addition, we entered into High Yield CDX swaps as a way to take on credit risk and earn a commensurate credit spread. The effect of these activities on performance was negligible during the period, as the positions were minimal. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio.” Management continuously monitors disclosures regarding the funds’ uses of derivatives, striving to provide what we believe to be the best explanation to readers of the funds’ financial statements. 3) Comment: The portfolio of investments included within the shareholder reports for several open-end funds disclose a money market fund holding in Mount Vernon Securities Lending Trust Prime Portfolio (“Mount Vernon”). When recalculating the net asset value (“NAV”) per share of Mount Vernon as of June 30, 2014 in the Nuveen Strategic Income Fund’s annual report, as noted in the table below, the NAV per share does not equal $1.00. Disclose the NAV of such shares or explain why the NAV is not $1.00. Shares Description Value NAV per Share 84,532,292 Mount Vernon Securities Lending Trust Prime Portfolio $85,180,247 $1.01 Response: The shares disclosed as of June 30, 2014 in the Nuveen Strategic Income Fund’s annual report were incorrect. The correct shares are $85,180,247, and as such, the NAV per share is $1.00. 4) Comment: Within the funds’ shareholder reports, the fair value measurements disclosures included within the notes to financial statements do not always indicate whether or not the funds had a transfer of securities between the three-tiered hierarchy of valuation input levels (Level 1, Level 2 and/or Level 3). In future shareholder reports, the fair value measurements disclosures should include whether or not such transfers occurred. Page 2 of 8 Response: As we indicated to you on our recent call, in the preparation of the relevant valuation footnote disclosure for a fund, we identify all of the transfers between the three-tiered hierarchy of valuation input levels (Level 1, Level 2 and/or Level 3). However, for reporting in the financial statements we have established a de minimis floor below which we would not provide the expanded disclosures in the footnotes. In discussion with other industry participants, we believe this is a common practice followed by others in the industry. In establishing a de minimis floor, we believe it provides the reader of the financial statements a clearer picture of significant transfers between levels. We further believe that this is consistent with GAAP which provides that accounting standards do not apply to immaterial items. Therefore we believe our current disclosure practice provides the reader with the necessary information to conclude that no material transfers have occurred during the period. 5) Comment: Within several of the funds’ shareholder reports, the notes to financial statements include disclosures pertaining to agreements with the adviser for which the adviser agreed to reimburse and/or waive charges to the fund(s) for certain fees and/or expenses. Please confirm that it is not the adviser’s policy to recoup from the funds any amounts waived and/or reimbursed in prior periods during future periods. Response: NFAL, the funds’ adviser, does not have, and does not currently intend to have, a policy to recoup from the funds during future fiscal years any amounts waived and/or reimbursed in prior fiscal years. 6) Comment: Within several of the funds’ shareholder reports, the notes to financial statements include disclosures for mergers that occurred during the fiscal period. However, those funds that were acquired have not yet completed a Form N-8F filing. Please review the funds that recently ceased operations and complete a Form N-8F filing accordingly. Response: The SEC Staff is correct in identifying funds that have ceased operations, but had not yet completed a Form N-8F filing. We have identified and completed a Form N-8F filing for each of the funds listed in the table below. Fund Name Ticker Symbol CIK File Number Date Form N-8F Filed with SEC Nuveen Pennsylvania Premium Income Municipal Fund 2 NPY 0000897427 811-07482 June 25, 2015 Nuveen Pennsylvania Dividend Advantage Municipal Fund NXM 0001087787 811-09457 June 25, 2015 Nuveen Pennsylvania Dividend Advantage Municipal Fund 2 NVY 0001158729 811-10549 June 25, 2015 Nuveen Massachusetts Dividend Advantage Municipal Fund NMB 0001090120 811-09451 June 25, 2015 Nuveen Massachusetts AMT-Free Municipal Income Fund NGX 0001196366 811-21216 June 25, 2015 Nuveen California Performance Plus Municipal Fund, Inc. NCP 0000856227 811-05930 June 25, 2015 Nuveen California Municipal Market Opportunity Fund, Inc. NCO 0000862313 811-06081 June 25, 2015 Nuveen California Investment Quality Municipal Fund, Inc. NQC 0000868440 811-06177 June 25, 2015 Nuveen California Select Quality Municipal Fund, Inc. NVC 0000874142 811-06294 June 25, 2015 Nuveen California Quality Income Municipal Fund, Inc. NUC 0000879826 811-06425 June 25, 2015 Nuveen California Premium Income Municipal Fund NCU 0000905000 811-07720 June 25, 2015 Nuveen New Jersey Investment Quality Municipal Fund, Inc. NQJ 0000870778 811-06264 June 25, 2015 Nuveen New Jersey Premium Income Municipal Fund, Inc. NNJ 0000890898 811-07118 June 25, 2015 Nuveen New Jersey Dividend Advantage Municipal Fund 2 NUJ 0001161070 811-10551 June 25, 2015 Nuveen Global Income Opportunities Fund JGG 0001359816 811-21893 June 25, 2015 Nuveen Diversified Currency Opportunities Fund JGT 0001390109 811-22018 June 25, 2015 Nuveen Equity Premium Opportunity Fund JSN 0001308658 811-21674 June 25, 2015 Dow 30SM Premium & Dividend Income Fund Inc. DPD 0001314128 811-21708 June 25, 2015 Dow 30SM Enhanced Premium & Income Fund Inc. DPO 0001390840 811-22029 June 25, 2015 NASDAQ Premium Income & Growth Fund Inc. QQQX 0001381186 811-21983 June 25, 2015 Nuveen Equity Premium Advantage Fund JLA 0001320492 811-21731 June 25, 2015 Page 3 of 8 7) Comment: For the Form N-SAR filing identified in the table below, the filing indicates that there was a change in auditor from Ernst & Young LLP (“EY”) to KPMG, LLP during the fiscal period, but the letter from EY is not included as an exhibit to the filing. Amend the Form N-SAR filing to include the letter from EY. File Number Registrant Date Filed 811-09037 Nuveen Investment Trust III December 1, 2014 Response: Management amended the Form N-SAR filing for the Trust in the aforementioned table on July 16, 2015, to include the letter from EY within Exhibit 77K. Page 4 of 8 Appendix A CIK or SEC File Registrant Fund Name Ticker Series ID Number 1 Nuveen Investment Funds, Inc. Nuveen Core Bond Fund S000005548 811-05309 2 Nuveen Investment Funds, Inc. Nuveen Core Plus Bond Fund S000005578 811-05309 3 Nuveen Investment Funds, Inc. Nuveen Dividend Value Fund S000005579 811-05309 4 Nuveen Investment Funds, Inc. Nuveen Equity Index Fund S000005580 811-05309 5 Nuveen Investment Funds, Inc. Nuveen Global Infrastructure Fund S000020012 811-05309 6 Nuveen Investment Funds, Inc. Nuveen High Income Bond Fund S000005544 811-05309 7 Nuveen Investment Funds, Inc. Nuveen Inflation Protected Securities Fund S000005545 811-05309 8 Nuveen Investment Funds, Inc. Nuveen Intermediate Government Bond Fund S000005546 811-05309 9 Nuveen Investment Funds, Inc. Nuveen Large Cap Growth Opportunities Fund S000005550 811-05309 10 Nuveen Investment Funds, Inc. Nuveen Large Cap Select Fund S000005551 811-05309 11 Nuveen Investment Funds, Inc. Nuveen Mid Cap Growth Opportunities Fund S000005553 811-05309 12 Nuveen Investment Funds, Inc. Nuveen Mid Cap Index Fund S000005555 811-05309 13 Nuveen Investment Funds, Inc. Nuveen Mid Cap Value Fund S000005556 811-05309 14 Nuveen Investment Funds, Inc. Nuveen Minnesota Intermediate Municipal Bond Fund S000005558 811-05309 15 Nuveen Investment Funds, Inc. Nuveen Minnesota Municipal Bond Fund S000005559 811-05309 16 Nuveen Investment Funds, Inc. Nuveen Nebraska Municipal Bond Fund S000005560 811-05309 17 Nuveen Investment Funds, Inc. Nuveen Oregon Intermediate Municipal Bond Fund S000005562 811-05309 18 Nuveen Investment Funds, Inc. Nuveen Real Asset Income Fund S000033768 811-05309 19 Nuveen Investment Funds, Inc. Nuveen Real Estate Securities Fund S000005563 811-05309 20 Nuveen Investment Funds, Inc. Nuveen Short Term Bond Fund S000005566 811-05309 21 Nuveen Investment Funds, Inc. Nuveen Short Term Municipal Bond Fund S000005564 811-05309 22 Nuveen Investment Funds, Inc. Nuveen Small Cap Growth Opportunities Fund S000005567 811-05309 23 Nuveen Investment Funds, Inc. Nuveen Small Cap Index Fund S000005568 811-05309 24 Nuveen Investment Funds, Inc. Nuveen Small Cap Select Fund S000005569 811-05309 25 Nuveen Investment Funds, Inc. Nuveen Small Cap Value Fund S000005570 811-05309 26 Nuveen Investment Funds, Inc. Nuveen Strategic Income Fund S000005573 811-05309 27 Nuveen Investment Funds, Inc. Nuveen Tactical Market Opportunities Fund S000027104 811-05309 28 Nuveen Investment Trust Nuveen Concentrated Core Fund S000040902 811-07619 29 Nuveen Investment Trust Nuveen Core Dividend Fund S000040903 811-07619 30 Nuveen Investment Trust Nuveen Equity Market Neutral Fund S000040904 811-07619 31 Nuveen Investment Trust Nuveen Global Tactical Opportunities Plus Fund S000041890 81