SecProbe.io

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Faegre Drinker Biddle & Reath LLP

320 South Canal Street, Suite 3300

Chicago, IL 60606

www.faegredrinker.com

March 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
telephone on March 6, 2023, 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 on February 10, 2023 under the Investment Company Act
of 1940, as amended (the “1940 Act”) and Securities Act of 1933, as amended (the “1933 Act”). These follow-up
comments and responses relate to the comment letter filed by the Registrant concurrently with the Registration Statement on February 10,
2023 (the “Comment Letter”). The changes to the Fund’s disclosure discussed below are reflected in Pre-Effective Amendment
No. 2 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.

PROSPECTUS

Cover Page

 1. Comment: Please state in an appropriate location on the cover page that investments in the Fund’s Class I Shares
may be made only by eligible investors that are “accredited investors” within the meaning of Rule 501 under the 1933 Act.

Response: The Fund notes that all investors,
regardless of Share Class, are required to qualify as accredited investors within the meaning of Rule 501 under the 1933 Act

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(“Accredited Investors”). Please see the “Fund
Summary – Investor Qualification” section of the Prospectus. Accordingly, the Fund has added disclosure to the cover page
of the Prospectus indicating that investments may be made only by Accredited Investors.

Fund Summary

 2. Comment: Please confirm that no more than 15% of the Fund’s total assets will be invested at one time in private
funds that rely on the exemptions set forth in either Sections 3(c)(1) or 3(c)(7) of the Investment Company Act of 1940, as amended (the
“1940 Act”).

Response: The Fund’s investments in private
funds that rely on the exemptions set forth in either Sections 3(c)(1) or 3(c)(7) of the 1940 Act are not limited to 15% of the Fund’s
total assets. The Fund respectfully refers the Staff to the response to Comment 1 above, which indicates that all investors in the Fund
must qualify as Accredited Investors. The Fund notes that it has clarified the Accredited Investor standard in the Revised Registration
Statement.

 3. Comment: The “Investment Objective and Strategies” section refers to contingent convertible securities.
The Fund stated in response to Comment 12 of the Comment Letter that contingent convertible securities will not be a part of Fund’s
principal investment strategies. Accordingly, please remove the reference to contingent convertible securities from the principal strategy
discussion.

Response: The requested change has been made
in the Revised Registration Statement.

 4. Comment: The Fund’s principal risk factors include the following risks: (a) small and middle-market companies
risk; (b) secured debt, subordinated loans and unsecured loans risks; (c) PIK interest risk; and (d) covenant-lite loans risk. Please
disclose in the “Investment Objectives and Strategies” section that these are principal investments of the Fund.

Response: The requested changes have been made
in the Revised Registration Statement.

 5. Comment: Does the Fund have any upper limit on foreign investments or investments in emerging market countries? If so,
please disclose.

Response: The Fund confirms that it does not
have an upper limit on foreign investments or investments in emerging market countries, and accordingly no changes have been made in the
Revised Registration Statement.

 6. Comment: The Fund’s principal risk factors include currency risk. Please disclose in the “Investment Objectives
and Strategies” section that the Fund’s investments may be denominated in U.S. dollars and foreign currencies. Per the risk
factor disclosure, consider stating that the Fund will hedge foreign currency exposure.

Response: The requested changes have been made
in the Revised Registration Statement.

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 7. Comment: Please summarize the Fund’s use of leverage in the “Fund Summary” section. Please also include
a brief discussion of the Fund’s distributor, and name the custodian in the “Fund Summary” section.

Response: The requested changes have been made
in the Revised Registration Statement.

 8. Comment: Please revise the first sentence under the “Fees and Expenses – Management Fee and Incentive Fee”
section as follows: “Pursuant to the Investment Management Agreement dated December 9, 2022 (the “Investment Management Agreement”),
by and between the Fund and the Investment Manager, and in consideration of the investment management services provided by the Investment
Manager to the Fund, the Investment Manager is entitled to a fee consisting of two components – a base management fee (the “Investment
Management Fee”) and, if earned, an incentive fee (the “Incentive Fee”).

Response: The requested change has been made
in the Revised Registration Statement.

 9. Comment: The description of the Incentive Fee in the “Fees and Expenses” section states that the Incentive
Fee is calculated and payable based on “pre-incentive fee net investment income” earned on direct investments, which suggests
that income attributable to investments in "Underlying Funds," as defined in the prospectus, would not be counted towards the
Incentive Fee. However, the Incentive Fee calculation excludes only income attributable to investments in underlying private funds. Please
supplementally explain why income attributable to other types of Underlying Funds is counted towards earned income while income attributable
to private funds is not.

If only income attributable to private funds is excluded, state
explicitly in the disclosure that investment income attributable to other Underlying Funds is counted towards "pre-incentive fee
net investment income."

Response: The Fund confirms that, per the Fund’s
Investment Management Agreement, only income attributable to private funds is excluded from the calculation of pre-incentive fee net investment
income, rather than income attributable to all Underlying Funds. Accordingly, the Fund has added disclosure in the Revised Registration
Statement to state explicitly that investment income attributable to other Underlying Funds is counted towards pre-incentive fee net investment
income.

 10. Comment: The discussion of the Incentive Fee in the “Fees and Expenses” section notes that the Incentive
Fee is subject to a “hurdle rate” and a “catch-up feature”. “Hurdle rate” and “catch-up feature”
are not self-explanatory terms. To make the Incentive Fee easier to understand, please describe the Incentive Fee in plain English to
directly reflect the terms of the Incentive Fee as set forth in the Investment Management Agreement.

Response: The Fund confirms that it has revised
the Incentive Fee discussion to be in plain English in the Revised Registration Statement and further confirms that the revised discussion
directly reflects the terms of the Incentive Fee as set forth in the Investment Management Agreement.

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 11. Comment: The discussion of the Incentive Fee in the “Fees and Expenses” section states that “pre-incentive
fee net investment income” means interest income, dividend income and any other income accrued during the fiscal quarter,
minus each class’s operating expenses for the quarter and the distribution and/or shareholder servicing fees (if any) applicable
to each class accrued during the fiscal quarter. Please disclose with specificity what “other income” means in this context.
Please confirm supplementally that distributions of capital gain by Underlying Funds or capital gains on the Fund’s disposition
of investments are not included in “other income” per Section 205(a)(1) of the Investment Advisers Act of 1940, as amended.

Response: The Fund has added disclosure to the
Revised Registration Statement indicating that the “other income accrued” may include any other fees, such as commitment,
origination, structuring, diligence and consulting fees or other fees that the Fund receives from an investment. The Fund confirms that
distributions of capital gain by Underlying Funds or capital gains on the Fund’s disposition of investments are not included in
“other income.”

 12. Comment: The “Fees and Expenses” section states the following: “The Distribution and Servicing Fee
would be paid out of the Fund’s assets and would decrease the net profits or increase the net losses of the Fund.” Please
revise this statement to reflect that this fee is a class-based fee.

Response: The requested change has been made
in the Revised Registration Statement.

 13. Comment: “The Offering” section states that the minimum additional investment in the Fund by any Shareholder
is $5,000. Please supplementally confirm that the $5,000 minimum for subsequent investments is accurate with respect to Class A shares,
which have an initial minimum investment requirement of $2,500.

Response: The Fund confirms that the minimum initial investment for Class A Shares has been changed to $25,000 in the Revised Registration Statement.
The Fund further confirms that the minimum additional investment amount for all Classes is $5,000.

 14. Comment: The “Distribution Policy” section states the following: “The Fund may pay distributions from
sources that may not be available in the future and that are unrelated to the Fund’s performance, such as from offering proceeds
and/or borrowings. When distributions are paid from these sources, the amount of capital available to the Fund for purposes of investment
may be reduced.” Please disclose that distributions from offering proceeds may represent a return of capital for tax purposes.

Response: The requested disclosure has been
added to the Revised Registration Statement.

 15. Comment: Please add disclosure relating to the tax consequences of a return of capital to the “Taxes” section
of the Prospectus (i.e., distributions that represent a return of capital for tax purposes may reduce a Shareholder’s tax basis
in the Shares, which could result in the Shareholder having to pay higher taxes in the future when shares are sold, even if the Shareholder
sells the shares at a loss from the original investment).

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Response: The requested disclosure has been
added to the Revised Registration Statement.

 16. Comment: Please add a section to the “Fund Summary” section disclosing that the Fund calculates the net
asset value (“NAV”) of each class of shares on a daily basis. If the Fund intends to publicly report the daily NAV per share
on its website and/or will provide a toll-free number for information on the daily NAV, please so state and please also include a cross
reference to the “Calculation of Net Asset Value” section of the Prospectus.

Response: The Fund confirms that a section has been added to the “Fund Summary” section regarding calculation of NAV. The Fund has included
a toll-free number for information on daily NAV in this section of the Revised Registration Statement.

 17. Comment: With respect to the “Repurchase Offers” section, “Valuation Date” is defined to have
the same meaning as “Repurchase Pricing Date.” Please use one term consistently throughout the Prospectus.

Response: The Fund has replaced all references
to the Valuation Date with references to the Repurchase Pricing Date in the Revised Registration Statement.

 18. Comment: In an appropriate location in the Prospectus, please provide a definition for below investment-grade securities.

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

 19. Comment: Derivatives risk is disclosed as a principal risk of the Fund. The Fund states later in the “Principal
Risk Factors” section of the Prospectus that it may use options, swaps, futures contracts, forward agreements and reverse repurchase
agreements. Please include a discussion of the types of derivatives that the Fund expects to use in the principal strategy discussions
both in the “Fund Summary” section and later in the “Investment Objectives and Strategies” section of the Prospectus.
Additionally, the derivatives risk discussion in the “Fund Summary” describes generally what derivatives are but does not
disclose any risks. Please summarize the derivatives risks both in the risk factors in the “Fund Summary” section and in the
“Principal Risk Factors” section of the Prospectus.

Response: The requested changes have been made
in the Revised Registration Statement.

Fund Fees and Expenses

 20. Comment: Footnote (1) to the Fee Table states the following: “This table summarizes the expenses of the Fund and
is designed to help investors understand the costs and expenses they will bear, directly or indirectly, by investing in the Fund.”
Please move this sentence so that it appears as the introduction to the table instead of as Footnote (1).

Response: The requested change has been made
in the Revised Registration Statement.

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Use of Leverage

 21. Comment: Per instruction 3 to Item 8.4 of Form N-2, please disclose whether the Fund will provide prior notice to security
holders of its intention to begin using leverage.

Response: The Prospectus currently provides
notice to shareholders that the Fund may utilize leverage in the future, and accordingly, the Fund does not intend to otherwise provide
prior notice to security holders of its intention to begin using leverage in the future. The Fund has added disclose to the Prospectus
in the Revised Registration Statement noting that the Fund may utilize leverage in the future without prior notice to Shareholders.

 22. Comment: Please delete all discussion of the pre-Rule 18f-4 framework as it is not relevant for a new fund. Additionally,
if the Fund does not intend to operate as a limited derivatives user, please delete disclosure regarding limited derivatives users. Alternatively,
if the Fund will qualify as a limited derivatives user, please state that explicitly.

Response: The Fund confirms that all disclosure
regarding the pre-Rule 18f-4 regime has been removed from the Revised Registration Statement.

Principal Risk Factors

 23. Comment: Per Comment 32(b) of the Comment Letter, please supplementally confirm that within each category of risk, the
risks are ordered to prioritize risks that are most likely to adversely affect the Fund’s NAV, yield and total return. Also please
conform the general order of the presentation of risks in the “Fund Summary” section to the risks as they appear in the “Principal
Risk Factors” section.

Response: The Fund confirms that the “Fund
Summary – Risk Factors” section of the Prospectus is ordered to prioritize the most significant risks of the Fund that are
most likely to adversely affect the Fund’s NAV, yield and total return. The Fund has revised the “Principal Risk Factors”
section of the Prospectus to align with the presentation of risks in the Fund Summary in the Revised Registration Statement so that the
most significant risks are prioritized.

 24. Comment: The “Market Risk” disclosure states the following: “Many interest rates are very low and
in some cases yields are negative, and it is possible that, particularly during periods of low prevailing interest rates, the income from
portfolio securities will be reduced.” Please consider whether this statement is still true. Please also disclose actions taken
by the Federal