SEC Company Response from GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (GOF) (CIK 0001380936) (GOF) — Jan 10, 2018

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (GOF) (CIK 0001380936)
Date: Jan. 10, 2018 · CIK: 0001380936 · Accession: 0000891804-18-000018

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Confidence

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File numbers found in text: 333-221873, 811-21982

Date

January 10, 2018

Author

/s/ Kevin T. Hardy

Form

CORRESP

Company

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (GOF) (CIK 0001380936)

Letter

Division of Investment Management Securities and Exchange Commission RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 (File Nos. 333-221873 and 811-21982)

Dear Ms. Mokodean:

Thank you for your telephonic comment received on December 27, 2017 regarding the registration statement on Form N-2 (the "Registration Statement") filed by Guggenheim Strategic Opportunities Fund (the "Fund"), on December 1, 2017. On behalf of the Fund, we have articulated your comment to the best of our understanding and provided our response below.

Comment 1

Please confirm that the Fund has no present intention to issue preferred shares in the next twelve months.

Response

The Fund confirms that it has no present intention to issue preferred shares in the next twelve months.

Should you have any additional comments or concerns, please do not hesitate to contact me at (312) 407-0641.

Sincerely,
/s/ Kevin T. Hardy

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CORRESP
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[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP]

January 10, 2018

Angela Mokodean

Senior Counsel

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

RE:

Guggenheim Strategic Opportunities Fund

Registration Statement on Form N-2

(File Nos. 333-221873 and 811-21982)

Dear Ms. Mokodean:

Thank you for your telephonic comment received on December 27, 2017 regarding the registration statement on Form N-2 (the "Registration Statement") filed by Guggenheim Strategic Opportunities Fund (the "Fund"), on December 1, 2017. On behalf of the Fund, we have articulated your comment to the best of our understanding and provided our response below.

Comment 1

 Please confirm that the Fund has no present intention to issue preferred shares in the next twelve months.

Response

The Fund confirms that it has no present intention to issue preferred shares in the next twelve months.

Should you have any additional comments or concerns, please do not hesitate to contact me at (312) 407-0641.

Sincerely,

/s/ Kevin T. Hardy

Kevin T. Hardy

SecProbe.io