SEC Company Response from RiverNorth (OPP) — Sep 23, 2016

RiverNorth/DoubleLine Strategic Opportunity Fund, Inc. (OPP, OPP-PA, OPP-PB, OPP-PC) (CIK 0001678130)
Date: Sept. 23, 2016 · CIK: 0001678130 · Accession: 0001398344-16-018803

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AI Filing Summary & Sentiment

File numbers found in text: 333-212400, 811-23166

Date

September 23, 2016

Author

Not clearly detected

Form

CORRESP

Company

RiverNorth/DoubleLine Strategic Opportunity Fund, Inc. (OPP, OPP-PA, OPP-PB, OPP-PC) (CIK 0001678130)

Letter

Via EDGAR Correspondence Filing Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 File Nos. 333-212400, 811-23166

Re: RiverNorth/DoubleLine Strategic Opportunity Fund, Inc. (the “Fund”)

Dear Mr. Minore:

In advance of filing Pre-effective Amendment No. 5 to the Registration Statement on Form N-2 for the Fund, which is anticipated for September 26, 2016, the Fund submits for your review the following exhibits to be included in such filing:

• By-Laws of the Fund;

• Dividend Reinvestment Plan;

• Management Agreement;

• Form of Subadvisory Agreement;

• Form of Underwriting Agreement;

• Form of Master Selected Dealers Agreement;

• Form of Master Agreement Among Underwriters;

• Form of Structuring Fee Agreement with various banks;

• Form of Sales Incentive Fee Agreement;

• Amended Distribution Agreement with TSC Distributors, LLC;

• Form of License Agreement;

• Subscription Agreement;

• Form of Custody Agreement;

• Form of Master Services Agreement;

• Draft Opinion of Fund counsel;

• Draft Opinion of Maryland counsel;

• Joint RiverNorth Capital Management, LLC and Fund Code of Ethics; and

• DoubleLine Capital LP Code of Ethics;

If you have any questions or comments or would like to discuss the items submitted for your review, please feel free to contact Walt Draney at (312) 845-3273 or the undersigned at (312) 845-3850

Very truly yours,
Chapman and Cutler LLP

Show Raw Text

CORRESP
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filename1.htm

September 23, 2016

Via EDGAR Correspondence Filing

Dominic Minore, Esq.

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:
RiverNorth/DoubleLine Strategic Opportunity Fund, Inc. (the “Fund”)

File Nos. 333-212400, 811-23166

Dear Mr. Minore:

•
By-Laws of the Fund;

•
Dividend Reinvestment Plan;

•
Management Agreement;

•
Form of Subadvisory Agreement;

•
Form of Underwriting Agreement;

•
Form of Master Selected Dealers Agreement;

•
Form of Master Agreement Among Underwriters;

•
Form of Structuring Fee Agreement with various banks;

•
Form of Sales Incentive Fee Agreement;

•
Amended Distribution Agreement with TSC Distributors, LLC;

•
Form of License Agreement;

•
Subscription Agreement;

•
Form of Custody Agreement;

•
Form of Master Services Agreement;

•
Draft Opinion of Fund counsel;

•
Draft Opinion of Maryland counsel;

•
Joint RiverNorth Capital Management, LLC and Fund Code of Ethics; and

•
DoubleLine Capital LP Code of Ethics;

If you have any questions or comments or would like to discuss the items submitted for your review, please feel free to contact Walt Draney at (312) 845-3273 or the undersigned at (312) 845-3850

Very truly yours,

Chapman and Cutler LLP

/s/ E. Roy Kim

E. Roy Kim, Esq.

cc:
Morrison Warren, Esq., Chapman and Cutler LLP;

Walter L. Draney, Esq., Chapman and Cutler LLP

Marcus L. Collins, Esq., RiverNorth Capital Management, LLC

SecProbe.io