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SEC Response Letter

Stradley Ronon Stevens & Young, LLP

1250 Connecticut Avenue, N.W., Suite 500

Washington, DC 20036

Telephone 202.822.9611

Fax 202.822.0140

www.stradley.com

 Christopher J. Zimmerman

czimmerman@stradley.com

 (202) 419-8402

 April 13, 2018

VIA EDGAR

 Dominic Minore, Esq., and Lauren
Hamilton

 Division of Investment Management

 Securities and
Exchange Commission

 100 F Street, NE

 Washington, DC 20549

Re:
NexPoint Strategic Opportunities Fund

 Post-Effective Amendment No. 2 to the
Registration Statement on Form N-2

 File Nos.
333-219983 and 811-21869

 Dear Mr. Minore and Ms. Hamilton:

 On behalf of the NexPoint Strategic Opportunities Fund (formerly, NexPoint Credit Strategies Fund) (the “Trust”),
please find transmitted herewith for filing Post-Effective Amendment No. 2 (“Amendment 2”) to the Trust’s Registration Statement on Form N-2 (the “Registration
Statement”) filed with the Securities and Exchange Commission (the “Commission”), in accordance with the Securities Act of 1933, as amended, and pursuant to Rule 101(a) of Regulation S-T promulgated thereunder.

 The Amendment 2 is being filed in response to the oral comments of the
Commission’s staff (the “Staff”) provided on March 29, 2018 from Mr. Minore and on April 3, 2018 from Ms. Hamilton to Christopher J. Zimmerman and Kevin Ercoline of Stradley Ronon Stevens &
Young, LLP with regards to the Post-Effective Amendment No. 1 filed on March 23, 2018.

 On behalf of the Trust, we respond to
the specific comments of the Staff as follows:

 Comments from Mr. Minore

1.
On the cover page of the Prospectus Supplement, please include a statement indicating that the Trust cannot state precisely the dilutive effect on the net asset value (“NAV”) of the Trust as a result of the
rights offering. Please also add a statement explaining what the dilutive effect would be on the NAV of each share of common stock as both a percentage and monetary value if the full subscription, including both primary and secondary subscriptions,
were to be utilized.

 April 13, 2018

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 2

 Response: The Trust has added the following to the cover page of the
Prospectus Supplement immediately prior to the table explaining the estimated subscription price and estimated proceeds:

 The Trust cannot
state precisely the extent of any dilutive effect if you do not exercise your Rights because the Trust does not know what the net asset value per share of common shares will be when the offer expires, or what proportion of the Rights will be
exercised. Assuming the full primary subscription and over-allotment option of secondary subscription shares (as discussed below in the “Over-Subscription Privilege” section on page 3 of the Prospectus Supplement) are exercised, the
Trust’s net asset value per share of common share would be reduced by approximately $0.92 (3.53%) per share of common shares. Actual amounts may vary due to rounding.

2.
On the cover page of the Prospectus Supplement, add the following to the second sentence of the paragraph in all caps after “AS A RESULT OF THE OFFERING”: “YOU WILL EXPERIENCE A PROPORTIONATE DECREASE
IN YOUR RELATIVE VOTING POWER AND”.

 Response: The requested comment has been implemented.

3.
On page 4 of the Prospectus Supplement, in the section entitled “Use of Proceeds,” and anywhere else in the Prospectus Supplement, Prospectus, or Statement of Additional Information that discusses “use
of proceeds,” please state the approximate dollar amount to be used to pay down the Bridge Facility.

Response: On pages 4 and 15 of the Prospectus Supplement, page 57 of the Prospectus, and page 1 of the Statement of
Additional Information, the Trust has stated that approximately $20 million will be used from the rights offering to pay down the Bridge Facility.

4.
On page 5 of the Prospectus Supplement, in the section entitled “Purpose of the Offer,” please add a statement that the Investment Adviser could expect an additional $2.1 million in investment
management fees as a result of the increase of assets due to the offering. In addition, cross-reference the “Benefits to the Investment Adviser” section.

Response: The Trust has added the following after the last sentence in the “Purpose of the Offer” section:

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 However, assuming (i) all Rights are exercised, (ii) the Trust’s average
weekly net asset value during the twelve-month period beginning June 1, 2018 is $26.03 per common share (the net asset value per common share on March 14, 2018) (iii) the Subscription Price is $22.95 per Share (95% of the last
reported sale price of the Trust’s common shares on March 14, 2018), and (iv) for purposes of this example, the Trust increases the amount of leverage outstanding while maintaining approximately the same percentage of total assets
attributable to leverage, and after giving effect to Information and Subscription Agent fees and other estimated offering expenses, the Investment Adviser would receive additional investment management fees of approximately $2,100,000 for the
twelve-month period beginning June 1, 2018, and would continue to receive additional investment management fees as a result of the Offer based on the average weekly value of the Trust’s Managed Assets attributable to the Shares issued in
the Offer and related additional leverage, thereafter. See “Benefits to the Investment Adviser.”

5.
On page 13 of the Prospectus Supplement, in the section entitled “Investment Considerations and Dilution,” please present the dilution information in a tabular format that gives full effect, in per dollar
and per percentage amount, of the primary and secondary subscriptions.

 Response: The Trust has
added the following after the first paragraph of the “Investment Considerations and Dilution” section:

 The dilution effect
utilizing the above stated assumptions is presented below in tabular form.

 Example (assumes that NAV per share is above Subscription
Price per share)1

 NAV2

$
26.03

 Subscription Price

$
22.95

 Primary Subscription ONLY - Reduction in NAV ($)3

$
0.78

 Primary Subscription ONLY - Reduction in NAV (%)3

3.01
%

 Primary Subscription and Secondary Subscription Shares - Reduction in NAV ($)4,5

$
0.92

 Primary Subscription and Secondary Subscription Shares - Reduction in NAV (%)4

3.53
%

(1)
This example assumes that the full primary subscription is exercised. Actual amounts may vary due to rounding.

(2)
 This example assumes that the Trust’s NAV on the Expiration Date is $26.03 per share of common shares (the
net asset value per common share on March 14, 2018) and

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 4

that the Trust’s market price is greater than the NAV on that date. The Subscription Price used in this example was determined based on a formula equal to 95% of the last reported sale price
of the Trust’s common shares on the NYSE on March 14, 2018.

(3)
Assumes $250,000 in estimated offering expenses.

(4)
Assumes the full primary subscription and the over-allotment option of secondary subscription shares are exercised. Actual amounts may vary due to rounding.

(5)
Assumes $20,000 in estimated additional offering expenses.

6.
On page 19 of the Prospectus Supplement, in the section entitled “Plan of Distribution,” please add the following to the end of the second sentence: “such that the exercise of all rights in any
transferable subscription rights offering will not cumulatively result in more than 33  1⁄3% increase in the Trust’s common shares outstanding.”
Please make the same revision to the “Plan of Distribution” section of the Prospectus as well.

 Response:
The requested change has been incorporated.

7.
On page 1 of the Prospectus, the sentence stating “[t]he Trust may also invest in other securities and instruments[,]” please elaborate on what “other securities” the Trust may invest in.

 Response: The Trust has clarified the specified sentence to read as follows:

The Trust may also invest in derivative instruments that have economic characteristics similar to instruments in investment categories
(i)-(vii).

8.
Rule 35d-1 under the Investment Company Act of 1940 (the “1940 Act”) prohibits, in pertinent part, an investment company from having a name suggesting that the
investment company focuses its investments in a particular type of investment or investments, unless:

 (A) the
investment company has adopted a policy to invest, under normal circumstances, at least 80% of the value of fund assets in the particular type of investments suggested by the fund’s name (the “80% Policy”); and

(B) the 80% Policy is a fundamental policy under section 8(b)(3) of the 1940 Act, or the investment company has adopted a policy to provide
the Fund’s shareholders with at least 60 days prior notice of any change in the 80% Policy.

 April 13, 2018

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 5

 The Staff notes its view that the Trust’s former name, the “NexPoint Credit
Strategies Fund” is a name that indicates a focus on a particular type of investment (i.e., “Credit”), rather than an investment strategy, and the inclusion of the word “Strategies” in the name does not affect this fact. The
Staff notes that the Trust previously had a policy pursuant to which it would invest at least 80% of its assets in: (i) secured and unsecured floating and fixed rate loans; (ii) bonds and other debt obligations; (iii) debt obligations
of stressed, distressed and bankrupt issuers; and (iv) structured products, including but not limited to, mortgage-backed and other asset- backed securities and collateralized debt obligations. But, the Trust did not include either the
fundamental policy or the non-fundamental policy to provide sixty days advanced notice as required by Rule 35d-1. The Staff notes that on March 14, 2018, the Trust
announced via publicly available press release its intent to change its name to the NexPoint Strategic Opportunities Fund and to simultaneously change its investment policy to eliminate the 80% requirement, although it would continue to invest in
the instruments previously subject to the 80% requirement. The Staff notes that the elimination of the 80% policy was effective on March 19, 2018 which is inconsistent with Rule 35d-1’s advance
notification requirements.

 Response: The Trust acknowledges receipt of the Staff’s comment. For the reasons
set forth below, however, the Trust respectfully asserts that its former name was not subject to the provisions of Rule 35d-1 because the name describes an investment strategy, not a particular type of
investment. Although the Trust is not subject to Rule 35d-1, it did adopt an 80% policy governing its investments (which was similar to that required by Rule 35d-1) in
accordance with guidance from the Securities and Exchange Commission (the “Commission” or “SEC”) that indicates that even if a Trust is not subject to the provisions of Rule 35d-1,
additional steps might be necessary to ensure its name is not misleading. Because the Trust is not subject to Rule 35d-1, the Trust was not subject to the advance notice provisions, and consequently changed
its investment policy and name in a manner consistent with its obligations to shareholders.

 Section 35(d) of the 1940 Act makes it
unlawful for “any registered investment company to adopt as a part of the name or title of such company, or of any securities of which it is the issuer, any word or words that the Commission finds are materially deceptive or misleading.”
The Section authorizes the Commission to define any names or titles as being materially deceptive or misleading under that section by rule, regulation, or order. The Commission adopted Rule 35d-1 under the
authority of this section. Rule 35d-1(a)(2) makes any name of a fund “materially deceptive and misleading” if a fund has a name “suggesting that the [f]und focuses its investments in a
particular type of investment or investments” unless a) an 80% investment policy is adopted and b) such policy is either fundamental or cannot be changed without 60 day written shareholder notice in advance of the change. The Adopting Release
on Rule 35d-1, Investment Company Act Release No. 24828 (January 17, 2001), stated clearly that “the rule does

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not apply to fund names that incorporate terms . . . that connote types of investment strategies as opposed to types of investments.” In a Staff FAQ, Frequently Asked Questions about Rule 35d-1 (Investment Company Names) (December 4, 2001) (“Names Rule FAQ”), the Staff echoed this point noting that Rule 35d-1 would not apply to a term that suggests an
investment objective or strategy rather than a type of investment. In the Names Rule FAQ, the Staff acknowledged that the usage and positioning of a term could cause its meaning to change, depending on its use. For example, use of the word
“income” could be part of an investment strategy, or could indicate a focus on a particular security, depending on its usage.

The Trust believes that its former name, “NexPoint Credit Strategies Fund,” unambiguously reflects the Trust’s focus on
investment strategies involving a variety of instruments. This view is supported by disclosure contained in the Trust’s most recent registration statement that was declared effective on January 22, 2018, which notes that the Trust will
utilize various specialized trading strategies in achieving its investment objective:

 Within the categories of obligations and securities
in which the [Trust] invests, the Investment Adviser employs various trading strategies, including capital structure arbitrage, pair trades and shorting. Capital structure arbitrage is a strategy in which the [Trust] seeks opportunities created by
mispricing in different markets of various instruments issued by one corporation. Pair trades involve matching a long position with a short position in two stocks of different issuers in the same sector, betting that the “spread” between
the two will eventually converge. Short selling (also known as shorting or going short) is a strategy in which the [Trust] sells a security it does not own in anticipation that the market price of that security will decline.

We are unaware of any formal interpretive statement by the Staff or the Commission relating to the appropriate treatment pursuant to Rule 35d-1 of the phrase “credit strategies” or a similar formulation using “credit” as a modifying adjective. We have also reviewed a number of public SEC response letters, and found a number of
instances in which funds that use “credit” in their name have no 80% policy and have not adopted the notification requirements of Rule 35d-1, or which have adopted a
non-fundamental 80% policy but have not adopted the Rule’s advance notification requirement. We found other instances in which funds have adopted both an 80% policy and the
non-fundamental advance notification policy.

 In light of the existing guidance and the fact that
the Trust’s former name used “credit” as an adjective modifying “strategy,” the Trust respectfully asserts that it is not subject to Rule 35d-1.

 April 13, 2018

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 Even though Rule 35d-1 is inapplicable to fund names
that refer to strategies, other provisions of the law such as
Section 35(d) and the anti-fraud provisions may guide such funds to take steps to ensure that their names are not confusing or misleading to shareholders. The Commission has been
very clear that funds may be required to take steps outside of Rule 35d-1 to ensure a name was not misleading to investors. It has stated:

[T]he rule does not apply to fund names that incorporate terms…that connote types of investment strategies as opposed to types of
investments. The Division will continue to scrutinize investment company names not covered by the proposed rule. In determining whether a particular name is misleading, the Division will consider whether the name would lead a reasonable investor to
conclude that the company invests in a manner that is inconsist