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    DLA Piper LLP (US)

    One Atlantic Center

    1201 West Peachtree Street

    Suite 2900

    Atlanta, Georgia 30309-3449

    www.dlapiper.com

    Tanya L. Boyle

    tanya.boyle@us.dlapiper.com

    T 404.736.7863

    F 404.682.7863

May 22, 2024

VIA EDGAR
==========
Alberto H. Zapata
Division of Investment Management
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549

 RE: Beacon Pointe Multi-Alternative Fund; File Nos. 333-276064 and 811-23921

Dear Mr. Zapata,

On December 15, 2023, Beacon Pointe Multi-Alternative
Fund (the “Fund” or the “Registrant”) filed a registration statement under the Securities Act of 1933 on Form
N-2 (the “Registration Statement”). On January 16, 2024, you provided written comments regarding the Registration Statement
(the “Letter”). On April 25, 2024, the Registrant filed pre-effective amendment 1 to the Registration Statement (the “Amendment”)
to address your comments in the Letter. On May 6, 2024, Brian Szilagyi provided oral accounting comments on the Amendment. On May 15,
2024, you provided oral comments on the Amendment. Please find below your comments and the accounting comments and the Registrant's responses,
which the Registrant has authorized us to make on behalf of the Registrant.

Comment 1. In “Principal Investment
Strategies”, in the first paragraph, please qualify the statement “references to the investments of the Underlying Funds described
below also describe the possible Co-Investments” with “as applicable” or “as context requires.”

Response. The Registrant has revised
the disclosure as requested.

Comment 2. In “Principal Investment
Strategies”, in the first paragraph, it mentions investments in various geographic markets. Please provide further clarification
regarding what is meant by various geographic markets. Specifically, whether the Fund will invest in foreign underlying funds or if underlying
fund investments will include foreign issuers. Please also disclose if the fund intends to focus on any particular region or regions when
commence operations.

Response. The Registrant has further
clarified that the investments in various security types, asset classes, and geographic areas is through its investment in Underlying
Funds, not the underlying Funds themselves. The Registrant has added disclosure noting the Fund does not intend to focus on any particular
geographic region.

Comment 3. In “Use of Proceeds”,
please add further disclosure pursuant to Item 7(2) of Form N-2 and guide 1 to Form N-2.

Response. The existing disclosure already,
in accordance with Item 7(2) of Form N-2, addresses (i) how long it is expected to take to fully invest net proceeds in accordance with
the Registrant’s investment objectives and policies, (ii) does not include the reasons for any anticipated lengthy delay in investing
the net proceeds because it is not

applicable,
and (iii) the consequences of any delay. The Registrant as add “which would be in less than three months after receipt” after
“as soon as practicable after receipt” to further clarify the time frame for investment per Guide 1 to Form N-2 for the avoidance
of doubt.

Comment 4. In Item 9, please clarify
in the disclosure whether the various investment types will be through the Underlying Funds or if the Fund will invest in these directly.
Please also clarify if the Co-Investments may include investments in these investment types.

Response. The Registrant has revised
the disclosure as requested.

Comment 5. In “Other Information
Regarding Investment Strategy”, please clarify what is meant by “other cases” in the third sentence.

Response. The Registrant has revised
the disclosure to remove the reference to “other cases”.

Comment 6. In “Risk Factors –
Foreign and Emerging Markets Risk” and “Risk Factors – Derivatives Risk”, please clarify in the risk disclosure
if investments references are to be made by the Fund directly or through Underlying Funds.

Response. The risk disclosure for foreign
and emerging markets already clearly states in multiple places that the investments would be made by the Underlying Funds. The Registrant
has revised the disclosure as requested for derivates risk in the one place that inadvertently referenced the Fund instead of Underlying
Funds as it does throughout the rest of the risk disclosure.

Follow up Comments to the Letter

Comment 7. Your response to comment
5(a) was “The Adviser has confirmed to the Registrant that investments in the pooled investment vehicles listed above are not a
principal investment strategy of the Fund. The Registrant also disagrees with the inclusion of pooled investment vehicles that rely on
the exclusions from the definition of investment company in section 3(c)(5) in the comment above, and it is inconsistent with prior positions
taken by the SEC’s staff.”

If it is not a principal strategy of the Fund
to invest in funds that are exempt from registration pursuant to Section 3(c)(1), 3(c)(7), and 3(c)(5) of the 1940 Act, then please explain
which exclusions underlying funds would be relying on. Please clarify in your response the types of private funds in which the Fund will
invest, if any. If the Fund will invest in any 3(c)(1) or 3(c)(7) funds, then the Staff would expect disclosure saying that such investments
will be limited to 15% of the Fund.

Response. The Fund will primarily invest
in other registered closed-end interval funds. Investments in fund relying on the exemptions under 3(c)(1) or 3(c)(7) are not a principal
strategy, so the Fund has not included the 15% limitation in the disclosure as it could be misleading to investors with respect to the
amount expected to be invested in those vehicles.

Comment 8. Your response to
comment 5(c) was “The Underlying Funds could include both interval funds that are offered to accredited investors only as well
as publicly registered closed-end interval funds that are not so limited. The Registrant also disagrees with the staff’s note
that registered interval funds do not typically invest in such investments (and if they do, would provide only limited exposure to
such investments) as there are many publicly registered closed-end interval funds that invest in the types of investments enumerated
above without limitation and without any accreditation standard.”

Please supplementally provide the Staff with
examples of funds referenced in your response that invest in excess of 15% the types of investments noted.

Response. Some examples include StepStone
Private Infrastructure Fund, Bluerock Total Income plus Real Estate Fund, Versus Cap Multi-Manager Real Estate Income Fund, Goldman Sachs
Real Estate Diversified Income Fund, and Principal Real Asset Fund.

Comment 9. Your response to
comment 5(e) was “Any credit facility entered into by the Fund would not be in place before effectiveness of the Registration
Statement.”

Please confirm supplementally that any credit
facility will be filed as exhibit in the future once obtained.

Response. The Registrant so confirms.

Accounting
Comments

Comment 10. In the Fee Table, add
line for dividend reinvestment plan fees after the management fee line and add fn re the basis on which such fees are imposed.

Response. The Registrant has added the
line item under sales load as set forth in Form N-2. The Registrant has not added a footnote as there are no such fees.

Comment 11. In the Fee Table, in
the caption for Annual Expenses (as a percentage of net assets attributable to shares), add “Class I” before shares.

Response. The Registrant has revised
the disclosure as requested.

Comment 12. In the Fee Table, add a
line item for interest on borrowed funds if applicable.

Response. The Registrant has not added
the line item because there isn’t applicable but will add it in the future if it becomes applicable.

Comment 13. Please supplementally
confirm if offering costs are included in other expenses line item.

Response. The Registrant confirms that
offering costs are included in the other expenses line item.

Comment 14. In the expense example,
in the last lead in paragraph, it references a two year term, but the term reference in footnote 3 to the fee table says the term
ends on 5/31/2. Please reconcile the time frames and revise the introductory paragraph or example numbers as needed as the numbers
presented are for a two year term.

Response. The Registrant has revised
the expiration date of the expense limitation agreement to reference May 31, 2026, which is in two years.

 SAI

Comment 15. In the financial statements,
in the Statement of Assets and Liabilities, please replace “Unlimited number of shares $0 Par Value” with
“(unlimited shares authorized: no par value)”.

Response. The Registrant has made the revision
requested.

Part C

Comment 16. In the audit
consent filed with the Amendment, the incorrect pre-effective amendment number is referenced in once place. Please confirm the
correct one will be referenced in the next filing.

Response. The Registrant so
confirms.

*	*	*

If you have any questions or comments, please
contact the undersigned at 404-736-7863. Thank you in advance for your consideration.

Sincerely,

/s/ Tanya L. Boyle

Tanya L. Boyle