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            Stradley Ronon Stevens & Young, LLP

            2005 Market Street

            Suite 2600

            Philadelphia, PA  19103

            Telephone  215.564.8000

            Fax  215.564.8120

            www.stradley.com

    July 14, 2021

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Investment Management

    100 F Street, N.E.

    Washington, D.C.  20549-9303

            Attention:

            Ms. Jaea Hahn

            Mr. David Manion

            Re:

            Invesco Dynamic Credit Opportunity Fund (the “Registrant”)

            File No. 333-256541

    Dear Ms. Hahn and Mr. Manion:

    Set forth below are the Registrant’s responses to the comments conveyed telephonically by Mr. Manion on June 17, 2021 and by Ms. Hahn on June 23, 2021, to Registrant’s counsel with
      regard to the Registrant’s registration statement on Form N-14 8C (the “Registration Statement”) relating to the proposed reorganization of the Invesco Dynamic Credit Opportunities Fund into the Registrant.  The Registration Statement was filed with
      the U.S. Securities and Exchange Commission (“SEC”) on May 27, 2021, under the Securities Act of 1933 (the “Securities Act”).

    Below we have included your comments (in bold) and the Registrant’s response to each comment.  These responses will be incorporated into the first pre-effective amendment to the Registration Statement.
      Capitalized terms not otherwise defined in this letter have the meanings assigned to such terms in the Registration Statement.

            Accounting Comments

            Prospectus/Proxy Statement

            1.

            Comment:  Regarding the Fee and Expense Table
                (the “Expense Table”) on page 9 of the Registration Statement, explain supplementally why the management fees of the Acquiring Fund are less than the Target Fund.  Is the

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            Acquiring Fund assuming a smaller asset base and lower fee breakpoints will apply?

            Response:  As disclosed in the Registration Statement, on June 7, 2021, all outstanding preferred shares of the Target Fund were redeemed in full, and that the
              Acquiring Fund at launch will obtain financial leverage through the use of a credit facility rather than through the issuance of preferred shares resulting in cost savings to the Acquiring Fund. Further, the overall percentage of portfolio
              leverage in the Acquiring Fund at launch is expected to be lower than the Target Fund’s current leverage ratio, resulting in a smaller total asset base on which the Acquiring Fund’s management fee is calculated.  In addition, as noted in the
              Registration Statement, the Target Fund has announced that it expects to conduct a tender offer which is expected to reduce Fund assets prior to the closing of the Reorganization. As a result of these and other factors, the Acquiring Fund’s
              management fee is expected to be lower than the management fee paid by the Target Fund during its most recent fiscal year.

            2.

            Comment:  Confirm the accuracy of the footnote
                2 to the Expense Table on page 9, especially in light of the listed management fee of 1.81%.

            Response:  The Registrant confirms the accuracy of the above-referenced footnote, which states the Target Fund’s currently effective contractual management fee
              rate as well as the impact of the Target Fund’s portfolio leverage on the Fund’s management fee as of the most recent fiscal year end.  The advisory fee rate is a result of the way the fee is defined as a percentage of the Fund’s average
              daily managed assets which is the average daily total asset value of the Target Fund minus the sum of the accrued liabilities other than the aggregate liquidation preference of any preferred shares and/or the aggregate amount of any
              borrowings for investment purposes.  Because the contractual rate is applied to a leveraged asset base that includes proceeds from the Fund’s credit facility and preferred shares, the Fund’s management fee exceeds 1.25%.

            3.

            Comment:  Do Acquired Fund Fees and Expenses
                (“AFFE”) need to be shown in the Expense Table on page 9?  Either add a sub-caption to the table or confirm supplementally that AFFE does not exceed  one basis point (0.01%) and may be included in the sub-caption “Other Expenses.”

            Response:  The Registrant supplementally confirms AFFE does not exceed one basis point and accordingly, is not required to be separately captioned in the table.

            4.

            Comment:  Footnotes 4 and 5 to the Expense
                Table on page 9 appear to be transposed.

            Response:  The Registrant has revised the ordering of the footnotes accordingly.

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            5.

            Comment:  Add a brief explanation to the
                footnote regarding Interest Payment on Borrowed Funds in the Expense Table on page 9 addressing why the Acquiring Fund’s interest payments on borrowed funds is lower than the Target Fund.

            Response:  The above-referenced footnote has been revised as requested as follows:

            As discussed in additional detail herein, it is expected that when the Acquiring Fund commences operations, the Acquiring Fund will initially obtain portfolio leverage
              through the use of a revolving credit facility instead of issuing preferred shares, and will employ less leverage as a percentage of its portfolio than the Target Fund.  This difference is anticipated to result in lower costs on borrowed
              funds, including lower estimated interest expenses for the Acquiring Fund as shown above.

            Comment:  Regarding the “Other Expenses”
                subcaption of the Expense Table on page 9, explain supplementally why Other Expenses of the Acquiring Fund are higher than the Target Fund.

            Response:  Estimated Other Expenses to be incurred by the Acquiring Fund in its initial fiscal year of operations are higher than the Target Fund due to
              organizational costs, as well as a reduction in Fund assets following the proposed tender offer expected to precede the Reorganization.  In addition, the Acquiring Fund is expected to incur certain ongoing additional operational expenses
              related to its interval fund structure, including in connection with quarterly repurchase offerings.

            6.

            Text:  The third sentence under the section titled “Expense Example” on page 10 states:

            The example assumes that you invest $1,000 in the Fund for the time periods indicated and for the Acquiring Fund only, the Fund repurchases all of your Shares at the
              end of those periods.

            Comment:  The reference to $1,000 should be
                changed to $10,000.

            Response:  The reference to $1,000 will be changed to $10,000.

            7.

            Text:   The first sentence of the fifth paragraph under the section titled “How do the management, investment adviser and other service
              providers of the Funds compare” on page 11 states:

            During the fiscal year ended February 28, 2021, the Adviser received compensation of 1.80% of the Target Fund’s average daily net assets, after fee waivers and/or
              expense reimbursements, if any.

            Comment:  Confirm the accuracy of the
                sentence.  The expense table lists the management fee as 1.81%.

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            Response:  The Registrant confirms the above-cited disclosures are accurate. The Registrant notes that management fee listed in the fee table differs from the
              compensation received by the Adviser for the most recent fiscal year due to the effect of a waiver of certain advisory fees incurred in connection with the Target Fund’s investment in an affiliated money market fund.

            8.

            Comment:  In the next pre-effective amendment filing, remember to include references to
                the auditor and the auditor’s consent.

            Response:  References to the auditor and the auditor’s consent will be included in the next pre-effective amendment.

            Disclosure Comments

            Prospectus/Proxy Statement

            9.

            Text:  The third sentence of first full paragraph under “What are the Reasons for the proposed Reorganization” on page 6 states:

            The interval fund structure provides a less costly process for a shareholder to sell his or her shares.

            Comment:  Explain why the interval fund structure provides a less costly process for a
                shareholder to sell his shares (e.g., lower transaction costs or sold at net asset value).

            Response:  The disclosure has been revised as requested as follows:

            The interval fund structure provides a less costly process for a shareholder to sell his or her shares.  For example, shareholders will have the ability to redeem
              shares directly with the Acquiring Fund rather than selling shares on the secondary market through a brokerage account, and no other transaction or redemption fee is imposed by the Acquiring Fund on redemptions, resulting in overall lower
              transaction costs, such as commissions, when redeeming Acquiring Fund shares as compared to sales of Target Fund shares

            10.

            Text:  The first sentence of second full paragraph on page 6 under “What are the Reasons for the proposed Reorganization?” states:

            In addition, by reorganizing into the Acquiring Fund, shareholders will experience a reduction in the total expense ratio paid by shareholders.

            Comment:  Explain whether the reduction in
                total expense ratio will be immediate or will be over time.  If reduction will take time, elaborate on the circumstances that need to occur for the fee reduction to happen.

            Response:  As reflected in the Expense Table, the reduction in total expense ratio is intended to be realized immediately after the Reorganization in light of
              the

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            Acquiring Fund’s lower management fees and estimated borrowing costs, among other factors.

            11.

            Comments:

            a.

            Move the section on page 7 titled “What will happen if shareholders do not approve the Reorganization?” so that it immediately
              follows the section titled “What will happen the Reorganization is approved?” on page 6.

            b.

            Add a summary of the disclosure found on page 21 under the section titled “Other Risks that Apply to the Acquiring Fund and Not
              the Target Fund” and highlight that (1) the shares of the Acquiring Fund are not listed on an exchange and are not liquid; and (2) that an interval fund repurchases shares quarterly so a shareholder may have to wait to sell his shares and
              that not all of the tendered shares will be repurchased.

            c.

            Address whether shareholders must pay a repurchase fee under any repurchase plan or in a tender offer.

            d.

            Move up the question and answer titled: “How does the Target Fund, which operates as a traditional closed-end fund, differ from
              the Acquiring Fund which will operate as a closed-end interval fund?” so that it follows the section titled “What will happen if shareholders approve the Reorganization?”

            e.

            Consider whether any negative consequences of the Reorganization need to be added to provide balance.

            f.

            Disclose whether there will be any changes in the management of the Acquiring Fund that differs from the Target Fund.

            Response:  With respect to items (a), (b) and (d) above, the disclosure has been revised as requested.  With respect to Item (c), disclosure has been added to
              indicate there will be no repurchase fee under any repurchase plan or in a tender offer. Additionally, with respect to item (e), the Registrant has considered the comment and respectfully declines to revise the disclosure at this time, as the
              Registrant believes the discussion in the combined proxy statement/prospectus of the differences between the respective fund structures and the attendant risks of investment in each Fund as well as the costs and expected benefits of the
              Reorganization, including the Board’s considerations in recommending shareholder approval, are accurately disclosed.  In this regard to providing a balanced discussion, the Registrant notes that in response to comment (b), the Registrant has
              highlighted that the shares of the Acquiring Fund are not listed on an exchange and are not liquid; and that an interval fund repurchases shares quarterly so a shareholder may have to wait to sell his
              shares and that not all of the tendered shares will be repurchased.  The Registrant has also added a cross-reference to the section titled “Principal Risks of Investing in the Funds- Principal Investment that Apply to the Acquiring Fund but
              not the Target Fund” and “Other Risks that Apply to the Acquiring Fund but not the Target Fund.”  With respect to Item (f), the

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            Registrant believes that the differences in management have already been highlighted in the section titled “How do the Funds’ investment objectives, principal
              investment strategies ad risks compare?”  Namely, the primary difference in management between the Target Fund and the Acquiring Fund is non-diversified but the Target Fund is diversified.

            12.

            Text:  The response to the question “What will happen if shareholders do not approve the Reorganization?” on page 7 states:

            If the shareholders of the Target Fund do not approve the Reorganization, the Target Fund will not reorganize into the Acquiring Fund and the Target Fund Board will
              consider other possible courses of action for the Target Fund.

            Comment:  State what some of the other possible
                courses of action may be.  Also address how the shareholders’ failure to approve the Reorganization will impact the Standstill Agreement.

            Response:   The disclosure has been revised to add the following:

            If the Reorganization is not approved by shareholders, the Target Fund Board would then consider such alternatives as it determines to be in the best interests of
              shareholders, including further solicitation of shareholders or re-proposing the Reorganization. In addition, if the Reorganization is not approved, certain obligations in the Standstill Agreement would terminate that would otherwise prevent
              Saba from presenting certain shareholder proposals at the Target Fund’s 2022 and 2023 annual shareholder meetings, including, for example, shareholder proposals regarding additional tender offers, nominating their own candidate(s) for
              election to the board, termination of the Target Fund’s advisory agreement with the Adviser, or liquidation of the Target Fund.

            13.

            Text:  The last sentence of the paragraph under “How does the Target Fund, which operates as a traditional closed-end fund, differ from the
              Acquiring Fund which will operate as a closed-end interval fund?” on page 8 states:

            An investment in the Acquiring Fund, unlike the Target Fund, is not a liquid investment.

            Comment:  Bold the sente