SecProbe.io

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Faegre Drinker Biddle & Reath LLP

One Logan Square, Suite 2000

Philadelphia, PA 19103

www.faegredrinker.com

February 10, 2023

Via EDGAR Transmission

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Yoon Choo

Re:     	Nomura Alternative Income Fund (the “Fund”)

Initial Registration Statement on Form N-2

File Nos. 333-267402 and 811-23826

Dear Ms. Choo,

The following responds to the comments provided via
email on October 13, 2022, in connection with the Securities and Exchange Commission (“SEC”) staff’s review of a registration
statement (the “Registration Statement”) filed by the Fund on Form N-2 under the Investment Company Act of 1940, as amended
(the “1940 Act”) and Securities Act of 1933. The changes to the Fund’s disclosure discussed below are reflected in Pre-Effective
Amendment No. 1 to the Fund’s Registration Statement (the “Revised Registration Statement”).

For your convenience, we have repeated each
comment below, and the Fund’s responses follow your comments. Capitalized terms not otherwise defined herein shall have the meaning
ascribed to them in the Registration Statement, unless otherwise indicated.

GENERAL

 1. Comment: We note that the Registration Statement is missing information and exhibits and contains numerous sections
that indicate that they will be added, completed or updated by amendment. Please expect comments on such portions when you add, complete
or update them in any pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally,
or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: The Fund confirms that all missing
information and all exhibits will be filed in a pre-effective amendment to the Registration Statement. The Fund further acknowledges that
the Staff may have additional comments after such information and exhibits are provided.

 2. Comment: Where a comment is made with regard to disclosure in one location, it is applicable to all similar disclosure
appearing elsewhere in the Registration Statement. Please make all conforming changes.

Response: The Fund has made all conforming changes.

 3. Comment: We note that the Registration Statement discloses a number of requests for exemptive relief (e.g.,
multi-class and co-investment relief). Please advise us as to the status of each of the applications disclosed in the Registration Statement
and whether you have submitted or expect to submit any other exemptive applications or no-action requests in connection with the Registration
Statement.

Response: The Fund intends to file exemptive applications for multi-class and co-investment relief but has not done so as of the date of this letter.
The Fund has not and does not expect to submit any other exemptive applications or no-action requests in connection with the Registration
Statement.

 4. Comment: Please tell us if you have presented or will present any “test the waters” materials to potential
investors in connection with this offering. If so, please provide us with copies of such materials.

Response: The Fund confirms that it has not
presented, and will not present, any “test-the-water” materials to potential investors in connection with this offering.

PROSPECTUS

Cover page

 5. Comment: Please disclose that the Fund may invest in below investment grade debt securities (commonly referred to as
“high yield” securities or “junk bonds”), including securities of stressed and distressed issuers.

Response: The Fund has added the requested disclosure
in the Revised Registration Statement.

 6. Comment: The Prospectus indicates that the Fund will use leverage. Please note this on the cover and identify the form(s)
the leverage is expected to take (e.g., credit facilities, reverse repurchase agreements etc...). Please add a cross reference
to the Prospectus disclosure regarding the risks associated with a leveraged capital structure. [Item 1.1.j and Guidelines to Form N-2,
Guide 6.] In the Fund Summary, please add a brief discussion regarding use of leverage, the form(s) the leverage is expected to
take, the risks related to the Fund’s use of leverage, and a cross reference(s) to the more fulsome discussion of leverage in the
Prospectus.

Response: Although the Fund does not expect
to utilize leverage in its first year of operations, the Fund may utilize leverage in the future, and accordingly, the following disclosure
has been added to the Cover Page of the Revised Registration Statement:

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“The Fund does not currently anticipate utilizing leverage
within its first year of operations, however in the future, the Fund may use leverage to provide additional funds to support its investment
activities, including by entering into credit agreements and other loan transactions with financial institutions such as banks. Under
the Investment Company Act, the Fund’s aggregate amount of indebtedness, regardless of the form it takes, is limited to up to 33
1/3% of the Fund’s total assets (including the assets subject to, and obtained with the proceeds of, such indebtedness) immediately
after entering into any type of financing transaction. Leverage magnifies volatility and will decrease the Fund’s return if the
Fund fails to earn as much on its investment purchased with borrowed funds as it pays for the use of those funds. The Fund’s leverage
strategy may not work as planned or achieve its goal. The Fund may also enter into derivatives or other
transactions that may provide leverage. See “Additional Risks of the Fund — Borrowing; Use of Leverage” in the
Prospectus.”	 To the extent the Fund utilizes leverage in the future, it will disclose the other required items under Form N-2 related to its use
of leverage.

 7. Comment: In the paragraph that begins “[t]his Prospectus concisely provides information that you should
know . . .” please provide the information required by the fourth and fifth sentences of Item 1.1.d.

Response: The paragraph has been updated as
follows in the Revised Registration Statement:

“This Prospectus concisely provides
information that you should know about the Fund before investing. You are advised to read this Prospectus carefully and to retain it for
future reference. Additional information about the Fund, including the Fund’s statement of additional information (the “SAI”),
dated [ ], has been filed with the SEC. You may request a free copy of this Prospectus, the SAI, annual and semi-annual reports, when
available, and other information about the Fund, and make inquiries without charge by writing to the Fund, c/o Ultimus Fund Solutions,
LLC, P.O. Box 541150, Omaha, NE 68154 or overnight mail at 4221 N. 203rd Street, Suite 100, Elkhorn, NE 68022, by calling the Fund toll-free
at (833) 836-0206, or by accessing the [Fund’s] website at [ ]. The information on the Fund’s website is not incorporated
by reference into this Prospectus and investors should not consider it a part of this Prospectus. The SAI is incorporated by reference
into this Prospectus in its entirety. You may also obtain copies of the SAI, and the annual and semi-annual reports of the Fund, when
available, as well as other information about the Fund on the SEC’s website (www.sec.gov). The address of the SEC’s internet
site is provided solely for the information of prospective investors and is not intended to be an active link.”

 8. Comment: Please revise the discussion relating to repurchase offers to address the following comments:

 a. that the repurchase offers will be made subject to certain conditions;

 b. the intervals between deadlines for repurchase requests, pricing and repayment; and

 c. when the Fund expects to make its initial repurchase offer.

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Please also consider disclosing the current expected percentage
of shares to be repurchased.

Response: The above-referenced disclosure has
been updated as follows in the Revised Registration Statement:

“The Fund is a closed-end investment company operating
as an “interval fund” and, as such, has adopted a fundamental policy to make quarterly repurchase offers, subject to certain
conditions, at per-class net asset value, of not less than 5% nor more than 25% of the Fund’s outstanding Shares on the Repurchase
Request Deadline (as defined below). If the value of Shares tendered for repurchase exceeds the value the Fund intended to repurchase,
the Fund may determine to repurchase less than the full number of Shares tendered. In such event, Shareholders will have their Shares
repurchased on a pro rata basis, and tendering Shareholders will not have all of their tendered Shares repurchased by the Fund.

Notices of each repurchase offer are sent to shareholders
at least 21 days before the “Repurchase Request Deadline” (i.e., the date by which Shareholders can tender their Shares in
response to a repurchase offer). The Fund determines the net asset value applicable to repurchases no later than the 14th day
after the Repurchase Request Deadline (or the next business day, if the 14th day is not a business day) (the “Repurchase Pricing
Date”). The Fund expects to distribute payment to Shareholders between one and three business days after the Repurchase Pricing
Date and will distribute payment no later than 7 calendar days after such date. The Fund expects its initial repurchase offer to commence
in the third quarter of 2023 (see “Repurchase Offers” beginning on page 11 and “REPURCHASE OFFERS; LIMITED LIQUIDITY”
beginning on page 19).”

 9. Comment: The last bullet point states “[a]ll or a portion of an annual distribution may consist solely of a return
of capital ...” Please supplementally explain why an annual distribution would consist solely of a return of capital or revise the
disclosure.

Response: The Fund has removed the last bullet
point.

Fund Summary

The Fund and the Shares

 10. Comment: The disclosure states that “[t]he Fund has applied for and expects to receive an exemptive order from
the SEC with respect to the Fund’s multi-class structure.” Please revise the Registration Statement here and elsewhere to
remove language regarding the Fund’s expectations with respect to the SEC’s issuance of exemptive relief or assumptions that
exemptive relief will be granted (e.g., see Note 4 to the Fund Fees and Expenses table).

In each instance, please ensure that the disclosure includes
the statement that there is no assurance that the Fund will be granted the exemptive order.

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Response: The Fund has revised the above-referenced
disclosure as requested in the Revised Registration Statement.

Investment Objectives and Strategies

 11. Comment: The disclosure states that the Fund may invest “through investment vehicles (“Underlying Funds).”
“Underlying Funds” are defined in Risk Factors as “mutual funds (including money market funds), BDCs, closed-end
funds, ETFs and other registered and private investment companies.” Please disclose the types of investment vehicles that constitute
the defined term “Underlying Funds” the first time the term is used, and use the defined term consistently throughout the
Registration Statement.

Response: The above-referenced disclosure has
been revised as requested in the Revised Registration Statement.

 12. Comment: The Fund may invest in convertible securities (“CoCos”) as part of its principal investment strategy.
Please supplementally inform us of the amount the Fund currently intends to invest in CoCos. If CoCos will be a principal type of investment,
please provide a description of CoCos and appropriate risk disclosure in the Prospectus.

Response: Although investing in CoCos will not
be a part of the Fund’s principal investment strategy, the Investment Adviser may invest in CoCos as part of its non-principal investment
strategy. Accordingly, the following disclosure has been added to the “Additional Risks of the Fund” section of the Prospectus
in the Revised Registration Statement:

“ CONTINGENT CONVERTIBLE SECURITIES RISK. CoCos,
sometimes referred to as contingent convertible securities, are debt or preferred securities with loss absorption characteristics built
into the terms of the security for the benefit of the issuer, for example, an automatic write-down of principal or a mandatory conversion
into common stock of the issuer under certain circumstances, such as the issuer’s capital ratio falling below a certain level. CoCos
may be subject to an automatic write-down (i.e., the automatic write-down of the principal amount or value of the securities, potentially
to zero, and the cancellation of the securities) under certain circumstances, which could result in the Fund losing a portion or all of
its investment in such securities. In addition, the Fund may not have any rights with respect to repayment of the principal amount of
the securities that has not become due or the payment of interest or dividends on such securities for any period from (and including)
the interest or dividend payment date falling immediately prior to the occurrence of such automatic write-down. An automatic write-down
could also result in a reduced income rate if the dividend or interest payment is based on the security’s par value. If a CoCo provides
for mandatory conversion of the security into common shares of the issuer under certain circumstances, such as an adverse event, the Fund
could experience a reduced income rate, potentially to zero, as a result of the issuer’s common shares not paying a dividend. In
addition, a conversion event would likely be the result of or related to the deterioration of the issuer’s financial condition (e.g.,
a decrease in the issuer’s capital ratio) and status as a going concern, so the market price of the issuer’s common shares
received by the Fund may have declined, perhaps

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substantially, and may continue to decline, which may adversely
affect the Fund’s NAV. Further, the issuer’s common shares would be subordinate to the issuer’s other security classes
and therefore worsen the Fund’s standing in a bankruptcy proceeding. In addition, most CoCos are considered to be “high yield”
or “junk” securities and are therefore subject to the risks of investment in below investment grade securities.

 It will often be difficult to predict when, if at all,
an automatic write-down or conversion event will occur. Accordingly, the trading behavior of CoCos may not follow the trading behavior
of other types of debt and preferred securities. Any indication that an automatic write-down or conversion event may occur can be expected
to have a material adverse effect on the market price of the CoCos. CoCos are a relatively new form of security and the full effects
of an automatic write-down or conversion event have not been experienced broadly in the marketplace. The occurrence of an automatic write-down
or conversion event may be unpredictable and the potential effects of such event on the Fund’s yield or NAV may be adverse.”

 13. Comment: The disclosure states that “the Fund normally will have a short to intermediate average portfolio duration”.
Please specify how “average portfolio duration” is measured (e.g., market weighted average duration). In an appropriate
location later in the Prospectus, please explain the term and provide an example.

Response: The above-referenced disclosure has
been updated as follows in the Revised Registration Statement:

“It is expected that the Fund normally will have a short
to intermediate average portfolio duration (i.e., within a zero to ten year range), as calculated by the Investment Manager, although
it may be shorter or longer at any time or from time to time depending on market conditions and other factors. In comparison to maturity
(which is the date on which a debt instrument ceases and the issuer is obligated to repay the principal amount), duration is a measure
of the price volatility of a debt instrument as a result of changes in market rates of interest, based o