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Simpson Thacher & Bartlett LLP

425 LEXINGTON AVENUE

NEW YORK, NY 10017-3954

TELEPHONE: +1-212-455-2851

September 18, 2023

Via EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20529

Attn: Karen Rossotto

  Re:
  Coller Secondaries Private Equity Fund (the “Fund”)

  File Nos. 811-23879; 333-272265

Ladies and Gentlemen:

On behalf of Coller
Secondaries Private Equity Fund (the “Fund”), we write to respond to the comments received from the staff (the “Staff”)
of the Division of Investment Management of the U.S. Securities and Exchange Commission (the “Commission”) by email on June
30, 2023 (the “Comment Letter”) relating to the Fund’s registration statement on Form N-2 under the Securities Act of
1933, as amended (the “1933 Act”) and the Investment Company Act of 1940, as amended (the “1940 Act”), filed with
the Commission on May 30, 2023 (the “Registration Statement”). The Fund intends to file Pre-Effective Amendment No. 1 (the
“Amendment”) to the Registration Statement, which will include revisions in response to the Comment Letter and revisions to
otherwise update disclosure. A draft of the Amendment is attached herewith.

In addition, on behalf
of the Fund, we are providing the following responses to the Comment Letter. For convenience of reference, the Staff’s comments
have been reproduced herein. All capitalized terms used but not defined in this letter have the meanings given to them in the Registration
Statement. Where the Fund will revise disclosure in the Registration Statement in response to a comment, additions are underlined
and deletions are struck.

General

 1. Staff Comment: We note that portions of the Registration Statement are incomplete.
We may have additional comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response
to this letter, on information supplied supplementally, or on exhibits added in any amendments.

Response: The Fund respectfully acknowledges
the Staff’s comment.

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 2. Staff Comment: We also note you have filed two exemptive applications on behalf
of C-SPEF. The applications relate to C-SPEF’s ability to offer multiple classes of shares and to engage in certain co-investments
alongside the Adviser’s affiliates. Please let us know in the response letter if C-SPEF intends to request any additional exemptive
or no-action relief. In addition, please update us on the status of your exemptive applications during the course of our review.

Response: The Fund filed an application
for a co-investment exemptive order on March 24, 2023 (the “Co-Investment Application”), which is under review by the Staff
as of the date of this correspondence. The undersigned received comments on the Co-Investment Application from the Staff via email in
a letter dated August 23, 2023. The Fund intends to file an amendment to the Co-Investment Application that includes revisions in response
to the Staff’s comments.

In addition, the Fund filed an application
for a multi-class exemptive order on May 30, 2023 (the “Multi-Class Application”). In a telephone call with Trace Rakestraw
on June 7, 2023, the Staff separately communicated its preference that the Multi-Class Application be withdrawn and re-filed upon the
completion of the registration of the Fund’s investment adviser, Coller Private Market Secondaries Advisors, LLC (the “Adviser”),
under the Investment Advisers Act of 1940, as amended. The Adviser has filed its initial Form ADV and its registration is pending as of
the date of this correspondence. The Fund intends to re-file the Multi-Class Application following the effectiveness of the Adviser’s
registration with the Commission. The Fund does not currently anticipate filing any other applications for exemptive or no-action relief
in connection with the Registration Statement.

 3. Staff Comment: We note the term Private Equity precedes the word “Fund”
in your name. We believe the use of this term as written is misleading because the term Private Equity Fund connotes a specific type of
unregistered investment fund, which a registered fund is not regardless of whether it provides access to private equity. Please revise
your name to avoid the potential for investor confusion.

In addition, the name includes the word
“Secondaries” which the staff believes suggests a specific type of investment. If the word “Secondaries” remains
in the name, the Fund’s 80% test should be modified so that it is specific to secondaries investments (i.e., it should not
include investments in newly formed private funds, Direct Investments or Co-Investments). In addition, please confirm the calculation
of the Fund’s 80% test will not include capital commitments that have not yet been called by an underlying fund.

Response: Notwithstanding the following
discussion, in response to the Staff’s comment and to avoid any potential investor confusion, the Fund will change its name to “Coller
Secondaries Private Equity Opportunities Fund.” The Fund believes that the new name appropriately informs investors that both “private
equity” and “secondaries” are key characteristics of the investment strategy that will be pursued by the Fund.

With respect to the first part of the Staff’s
comment, the Fund respectfully disagrees with the Staff’s view that the use of the term “private equity” in the Fund’s
name is misleading. The term “private equity” is commonly understood to refer to a type of investment strategy

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that is effectuated through the use of
various types of investments across many different industries. Investment decisions based on a “private equity” strategy may
cause a fund to have exposure to many types of investments, including portfolio funds, direct equity investments in operating companies,
co-investments and other types of investments.

With respect to the second part of the
Staff’s comment, the Fund respectfully submits that the term “secondaries” refers to the Fund’s investment strategy
of acquiring various types of investments from third-party investors through privately negotiated transactions (i.e., “secondaries
transactions” or “secondaries”). A “secondaries transaction” generally involves the acquisition of an investment
or portfolio of investments from an existing third-party investor, rather than through a primary transaction directly with the issuer.
In a “secondaries” transaction, the buyer of the existing interest agrees to take on future funding obligations in exchange
for future returns and distributions. The acquisition of an investment through a secondaries transaction will often take place at a discount
to the investment’s net asset value. Because a “secondaries transaction” may result in the acquisition of many different
types of investments, the term “secondaries” does not suggest a focus on a particular type of investment or investments. Instead,
the term “secondaries” is commonly understood to refer to an investment strategy of acquiring various types of investments
through secondaries transactions with third-party investors, as opposed acquiring such investments through primary transactions directly
with the issuer.

Under Rule 35d-1(a)(2), a fund needs to
adopt an 80% policy if it has a name suggesting that the fund focuses on a particular type of investment or investments, or in investments
in a particular industry or group of industries. Rule 35d-1 under the 1940 Act also does not apply to terms that suggest an investment
objective or strategy (see Frequently Asked Questions about Rule 35d-1 (Investment Company Names), at Question 9, available at
www.sec.gov/divisions/investment/guidance/rule35d-1faq.htm). The Fund respectfully submits that the term “secondaries”
is not implicated by Rule 35d-1(a)(2), as the term “secondaries” in the Fund’s name refers to an investment strategy
and not to a specific type of investment or investments or industry or group of industries. As used in the Fund’s name, the term
“secondaries” refers to the Fund’s investment strategy of acquiring various types of Private Equity Investments, including
existing interests in Portfolio Funds, Direct Investments and Co-Investments from third-party investors through privately negotiated transactions.
Investment decisions based on a “secondaries” strategy may cause the Fund to have exposure to many types of investments, including
Portfolio Funds, Direct Investments and Co-Investments.

For the foregoing reasons, the Fund respectfully
submits that the use of the term “secondaries” in the Fund’s name does not require the Fund to establish a policy of
investing at least 80% of its assets in “secondaries,” nor does it dictate the language used to describe any such policy that
the Fund might otherwise choose to adopt. The Fund will revise the disclosure throughout the Registration Statement to further clarify
the nature of “secondaries” as an investment strategy.

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With respect to the third part of the Staff’s
comment, the Fund confirms that the calculation of the Fund’s 80% test will not include capital commitments that have not yet been
called by a Portfolio Fund.

 4. Staff 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, we may have additional comments.

Response: The Fund confirms that
it does not currently intend to present any “test the waters” materials to potential investors in connection with its offering
of Shares.

 5. Staff Comment: Please confirm that the Fund does not intend to issue debt
securities or preferred shares within a year from the effective date of the registration statement. If the Fund plans to issue preferred
shares within a year from the effectiveness of the registration statement, please include additional disclosure of risks to shareholders
in the event of a preferred shares offering.

Response: The Fund confirms that
it does not intend to issue debt securities or preferred shares within a year from the effective date of the Registration Statement.

 6. Staff Comment: The registration statement appears to contemplate a transaction
with the Predecessor Fund that will occur after your decision to become registered as an investment company. Please tell us how this transaction
will be structured to comply with section 17 of the 1940 Act, including any no-action relief upon which you intend to rely.

Response: Simultaneously with the
Fund beginning to accept offers to purchase Shares (“Commencement of Operations”), the Adviser expects that the Predecessor
Fund, if any, will reorganize with and become a wholly-owned subsidiary of the Fund in a transaction conducted in reliance on Guidestone
Financial, et al., SEC Staff No-Action Letter (pub. avail. Dec. 27, 2006) (the “Guidestone Letter”). The Fund confirms
that any such reorganization will be effected in accordance with the conditions of the Guidestone Letter, including the terms of paragraphs
(b), (c), (d), (e), (f) and (g) of Rule 17a-7 under the 1940 Act and the provisions of Rule 17a-8 under the 1940 Act (as these provisions
apply to a reorganization involving an unregistered fund that is eligible to rely on Rule 17a-8 and a registered investment company).
In addition, as contemplated by the conditions of the Guidestone Letter:

 i. the Fund will be a shell portfolio as of the time of the reorganization;

 ii. the assets of the Predecessor Fund will consist of securities or commitments to acquire
securities that are appropriate, in type and amount, for investment by the Fund in light of its investment objectives and policies;

 iii. the holder(s) of interests in the Predecessor Fund (the “Predecessor Fund Interests”)
will transfer such interests to the Fund in exchange for Shares of the Fund having a net asset value equal to the net asset value of the
Predecessor Fund Interests;

 iv. the Fund and the Predecessor Fund will have the same procedures for determining their
net asset values and will follow those procedures in determining the amount of Shares to be issued in the reorganization;

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 v. the transfer of the Predecessor Fund Interests to the Fund in exchange for Shares
of the Fund will be effected simultaneously with the issuance of Shares of the Fund in connection with the Fund’s Commencement of
Operations;

 vi. the Fund will comply with the recordkeeping requirements described in the Guidestone
Letter;

 vii. the Adviser will, consistent with its fiduciary duties, disclose to the trustees
of the Fund who are not “interested persons,” as defined in Section 2(a)(19) of the 1940 Act (the “Independent Trustees”),
the existence of, and all of the material facts relating to, any conflicts of interests between the Adviser and the Fund with regard to
the reorganization to facilitate the ability of the Independent Trustees to evaluate and approve the reorganization; and

 viii. The Adviser will bear the costs associated with the reorganization.

In response to the Staff’s comment,
the Fund has revised the above-referenced disclosure to clarify that the reorganization of the Predecessor Fund into the Fund is contingent
on approval by the Board and the Predecessor Fund’s board of directors.

Prospectus

Cover

 7. Staff Comment: The Cover prominently discloses that Coller Capital is “First
in Secondaries”. Please supplementally provide support for this disclosure and explain why it is not misleading.

Response: The Fund respectfully
disagrees with the Staff’s view that the statement “First in Secondaries” embedded in the global logo of Coller Capital
Limited (“Coller Capital”) included on the Cover is misleading. The Fund notes that the above-referenced statement is part
of Coller Capital’s global brand and does not refer to the historical performance or returns of any pooled investment vehicles or
strategies managed and/or sponsored by Coller Capital or its affiliates.

The Fund respectfully submits that the
“First in Secondaries” statement is not misleading because it accurately reflects Coller Capital’s role as a pioneer
in the investment strategy of acquiring interests in private assets through privately negotiated transactions (i.e., “secondaries
transactions” or “secondaries”). For example, at Coller Capital’s launch in 1990, it became Europe’s first
dedicated private equity secondaries manager; Coller International Partners II was the first private equity secondaries fund with a global
mandate; at its final close in 2022, Coller Credit Opportunities I was the largest private credit secondaries fund ever raised; and Coller
Capital has been providing investors with access to the secondaries market longer than any other investment adviser that advises a registered
investment company that focuses on the secondaries market. For the foregoing reasons, the Fund believes that disclosure of the above-referenced
statement in Coller Capital’s global logo included on the Cover is appropriate and not misleading.

 8. Staff Comment: On the Cover, please specify C-SPEF’s principal strategies
that are speculative (e.g., use of leverage/derivatives, high yield/distressed debt and emerging markets investment) and include a cross-reference
to the disclosure regarding the risks associated with these strategies. See Form N-2, Item 1.1.j. and the Guidelines to Form N-2,
Guide 6.

    Simpson Thacher & Bartlett LLP

    U.S. Securities a