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CORRESP
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CORRESP

 Troutman Pepper Locke LLP

 111 South Wacker
Drive

 Suite 4100

 Chicago, IL 60606

 March 4, 2025

 United
States Securities and Exchange Commission

 Division of Investment Management

Office of Accounting

 100 F Street NE

Washington, D.C. 20549

 Attn: Ashley Vroman-Lee

Re:
 ABL Longevity Growth and Income Fund

Amendment No. 10 to Registration Statement on Form N-2

Filed January 15, 2025

Securities Act File No. 333-274405

Investment Company Act File No. 811-23900

Dear Ashley Vroman-Lee:

 On behalf of our
client, ABL Longevity Growth and Income Fund (the “Fund”), we are writing to submit the Fund’s (a) responses to certain oral and written comments provided by the staff of the Division of Investment Management (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) on January 15, 2025 and February 28, 2025, with respect to the above-referenced Amendment No. 10 to the Registration Statement on Form N-2 and Statement of Additional Information (the “Registration Statement”) and (b) the responses submitted in our letters to the Staff (the “Comment Response Letters”).

Concurrently with the submission of this letter, the Fund is publicly filing Amendment No. 11 to the Registration Statement (the
“Revised Registration Statement”). Capitalized terms used but not otherwise defined herein shall have the meanings ascribed thereto in the Revised Registration Statement. For the convenience of the Staff, we have reproduced the
Staff’s comments in bold and have followed each comment with the Fund’s response thereto.

I.
 SEC Accounting Comments Received February 10, 2025 to Comment Response Letter dated
January 15, 2025

1.
 Please explain whether Lapetus is a service provider.

As disclosed on pages 3 and 31 of the Revised Registration Statement, Lapetus is a third-party service provider that develops life expectancy
reports with respect to the named insured in Mortality Contracts. Life expectancy is a significant, but one of the numerous, factors that are part of the determination of the fair value of a Longevity Asset. We note for clarity, however, that
Lapetus is not a pricing service provider as described in SEC Rule 2a-5. Instead, Lapetus develops life expectancy reports for longevity assets using its own resources. On its public website, Lapetus states:

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 “Lapetus founders created the scientific field of biodemography in 1992, which is now an
internationally recognized scientific discipline designed to understand, measure, and predict the combined biological and social determinants of health and longevity in populations and individuals. Our longevity scientists have close to 40
years of experience evaluating survival data and have a deep understanding of how to access its predictive power.

 In addition to our
biodemographers, we have over 30 board-certified physicians with expertise in gerontology, disease management and end-of-life care. Our clinical panel uses the
latest research in diagnosis and treatment and their consequence on survival.”

 We note further that an affiliate of the Manager,
Abacus Life Inc., holds a one-million-dollar ($1,000,000) convertible promissory note issued by Lapetus Solutions, Inc. (the “LSI Note”). If the LSI Note were to convert into shares of Lapetus
Series A-2 Preferred Stock in accordance with its terms, Abacus Life’s resulting ownership interest in Lapetus would represent less than a 5% equity stake in Lapetus on a fully diluted basis. Both the LSI
Note and Abacus Life’s potential ownership level in Lapetus are immaterial to Abacus Life and would not grant Abacus Life any influence or control over Lapetus’ governance or business decisions.

2.
 The Staff believes that you set forth the requirements of the SubChapter M but did not describe with
specificity how the fund intends to comply with SubChapter M.

a)
 Please supplementally explain how the Fund intends to qualify to be treated as a RIC under Subchapter M of
the IRC,

b)
 Do the Fund’s holdings/strategies present any unique risks with maintaining RIC status for purposes of
subchapter M.

c)
 In your response, please describe what controls and/or structures have been established to manage and
mitigate potential Sub-Chapter M qualification status compliance risks,

d)
 Discuss the unique aspects of this asset class and how the fund will meet the Subchapter M threshold, and

e)
 finally, discuss the level of tax expertise possessed by the persons responsible for conducting and
overseeing tax-related functions.

 Please include in the response whether
the Fund’s holdings and strategies present any unique risks with maintaining RIC status for purposes of subchapter M. Please include in your response a description of what controls and/or structures have been established to maintain and
mitigate potential subchapter M qualification status compliance risks.

 Discuss the level of tax expertise possessed by the persons
responsible for conducting and overseeing tax related functions. If anything related to unique aspects of the asset class, please include in the response.

In summary, a regulated investment company (“RIC”) is an electing domestic corporation that either meets (or is excepted
from) (i) registration requirements under the Investment Company Act of 1940, (ii) that elects to be treated as a RIC, (iii) that derives at least 90 percent of its ordinary income from specified sources of passive investment income,
(iv) that has a portfolio of investments that meet mandated diversification requirements, and (v) distributes at least 90% of the sum of its “investment company taxable income.”

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1.
 The Fund plans to meet the requirements to be treated as an Investment Company by (i) investing not less
than forty-five (45%) percent of the value of its assets (exclusive of Government securities and cash items) in securities, and (ii) earning not less than forty-five (45%) percent of its net income after taxes from investments in securities. We
note that fixed longevity assets, including fixed Mortality Contracts and Fixed Annuities will not qualify as “securities” for purpose of the Investment Company Act.

If and to the extent that the Fund’s other assets would not meet the forty-five (45%) percent of the value of its assets test above, the
Fund may hold the fixed Longevity Assets in a controlled foreign corporation (“CFC”), thereby converting the status of those assets into securities by holding the interests of the CFC(s) rather than directly holding the fixed Longevity
Assets.

2.
 The Fund plans to make an election to be treated as a RIC with its first annual tax filing by filing its
federal income tax return on Form 1120-RIC.

3.
 The Fund expects to derive at least 90% of its gross income for each taxable year from dividends, interest,
payments with respect to securities loans, and gains from the sale or other disposition of securities or foreign currencies, or other income derived with respect to its business of investing in securities or those currencies, in each case as defined
in IRC 851(b)(2). Specifically,

•

 Income from investments in variable Mortality Contracts, variable annuities, structured finance products, and
bonds which are securities, qualify as income from securities for purposes of IRC 851(b)(2).

•

 Income from fixed Annuity Contracts will qualify as interest income for purposes of IRC 851(b)(2).

•

 The Fund will also purchase fixed life insurance policies which are not considered securities. If and to the
extent required to meet the RIC 90% income test, fixed Mortality Contracts may be held in CFC(s) so that the distributions from the CFC(s) relating to income from the fixed Mortality Contracts will be treated as income from securities in accordance
with IRS private letter ruling 20113033.

 As detailed above, the Fund anticipates that it will meet the RIC 90% gross
income test to maintain RIC status, while adhering to its investment strategy.

4.
 Generally, the asset diversification test can be broken into two percentage tests: (i) the 50% test and
the (ii) 25% test.

a.
 Under the 50% test, at least 50% of the value of a RIC’s total assets must consist of cash and cash items,
U.S. government securities, securities of other regulated investment companies, and securities of other issuers as to which (a) the RIC has not invested more than 5% of the value of its total assets in securities of the issuer and (b) the
RIC does not hold more than 10% of the outstanding voting securities of the issuer.

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 The Fund plans to meet the requirements of the 50% test while adhering to its investment
strategy by investing at least forty-five (45%) percent of the value of its assets in securities of other issues (e.g., variable Longevity Assets) and at least five (5%) percent of its assets in cash and cash, cash items, and U.S. government
securities (e.g., cash for repurchase obligations). As noted in the Revised Registration Statement, it is a fundamental policy of the Fund to hold at least 5% of the Fund’s net assets in cash or cash equivalents to meet the Fund’s
liquidity requirements under Rule 23c-3(b)(10). The Manager will monitor to ensure that the Fund does not invest more than 5% of fifty (50%) percent of assets in securities of one issuer, and to the extent
that the Fund invests in any assets with voting rights (such as Mortality Contracts issues by mutual or fraternal insurers which may have nominal voting rights), the Fund has a policy of not voting such proxies.

b.
 Under the 25% test, no more than 25% of the value of the RIC’s total assets may be invested in the
securities of (1) any one issuer (other than U.S. government securities and securities of other regulated investment companies), (2) two or more issuers that the RIC controls and which are engaged in the same or similar trades or businesses, or
(3) one or more qualified publicly traded partnerships (including master limited partnerships). The Manager has developed a compliance program to monitor for, and guard against tripping any of the limitations set forth under the 25%
test. We note that the Fund has limited its investment in CFCs to comply with the diversification limits set forth in the 25% test.

We believe that the Fund’s investment strategy poses little risk of the Fund breaching either of the RIC diversification thresholds.

5.
 As disclosed beginning on page 39 of the Revised Registration Statement, to qualify under Subchapter M of the
Internal Revenue Code for treatment as a RIC, the Fund expect to distribute to its Partners each taxable year at least 90% of the sum of (i) its “Investment Company Taxable Income” (as that term is defined in the Code, but without
regard to the deduction for dividends paid) and (ii) its net tax-exempt income (the excess of its gross tax-exempt interest income over certain disallowed
deductions).

 The Manager plans to implement a RIC compliance program that will monitor the Fund’s investments for
compliance with the above RIC income and asset diversification requirements on a quarterly basis. Following each quarterly review, the Manager will either confirm compliance or timely rebalance the Fund’s holdings to conform with the RIC income
and asset diversification tests described above. Annually, the Manager will confirm the Fund’s (i) status as an Investment Company, (ii) election as a RIC on Form 1120-RIC, and (iii) ensure
that the Fund has distributed at least ninety (90%) percent of its taxable income as required by IRC 851(b)(2). The Manager will report on the Fund’s compliance and any corrective actions taken to comply with RIC regulations to the Board at its
regular quarterly meetings.

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 The Manager has engaged Deloitte’s tax team to provide tax expertise to assist the Fund
with it tax reporting obligations, including Regulation M filings. The Manager has also engaged Deloitte’s RIC specialists to assist the Fund in reviewing and maintaining its investments for compliance with the RIC investment and asset
diversification tests.

 Except as set forth above, we do not believe that the Fund’s investment strategy presents any unique risks to
maintain RIC status. We note, however, that the Fund has included disclosures and risk factors related to maintaining RIC status as well as certain consequences associated with failing to maintain RIC status under the section entitled “Certain
U.S. Federal Income Tax Matters” beginning on page 51 of the Revised Registration Statement. As described above, the Fund has a strategy to invest the Fund’s assets in a way that will maintain RIC status. The Manager will monitor the
Fund’s assets for compliance therefore on a monthly basis and share results of these reviews with the Board at Board meetings. The Manager has also engaged Deloitte tax and RIC specialists who have the necessary tax and RIC expertise to oversee
the Fund’s compliance with the foregoing.

II.
 SEC Legal Comments Received February 14, 2025 to Comment Response Letter dated
January 15, 2025

3.
 Response number 6 states that the Mortality Contracts will not be registered for resale under the federal
securities laws, please supplementally explain if the response using the term “Mortality Contracts” was meant to refer to both variable and non-variable life insurance contracts, as defined in the N-2, or if this was only meant to refer to non-variable life insurance contracts.

The Fund confirms that no Mortality Contracts will be registered for resale under the federal securities laws, whether variable policies
(securities) or fixed polices (not securities). Due to the nature of an insurance policy and applicable state laws, mortality contracts do not lend themselves for registration for resale.

4.
 Under Investment Strategy, the Fund states that: “The Fund may invest in short-dated treasury bills and
money market funds for cash management purposes.” Please move this sentence to the Prospectus Summary section on Page 1, rather than under Investment Strategy.

Please see page 2 of the Revised Registration Statement where this disclosure is included in the “Prospectus Summary” section.

5.
 Please specifically disclose the structured finance products the Fund intends to invest in, including
whether these products will be securities or not, and also include corresponding risk disclosure.

 The Fund may
invest in certain structured finance products, which are securities. In keeping with the Fund’s investment thesis, the assets underlying the structured finance products are expected to be Mortality Contracts.

Structured finance products are privately constructed pools of assets that generally are not registered securities. As such, the Fund does not
expect that any structured finance product in which it invests would be registered under the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended.

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 Since the structured financial products are not registered for trading on an exchange, they
are less liquid than registered securities and as such these structured finance products may carry greater risk than those that trade on an exchange. In addition, the Fund would bear any risks associated with the underling investments that are held
in the structured finance product. As the underlying assets for the structured finance products will be Mortality Contracts, the risk disclosure with respect to the underlying assets will be the same as that for the Mortality Contract in which the
Fund invests directly. Please see page 38 of the Revised Registration Statement where the Fund has added the following risk factor related to investments in structured finance products:

“The Fund may invest in certain structured finance products, which principally will have Mortality Contracts as their underlying
investments. Holders of structured products bear risks of the unde