Correspondence 0001839882-25-000655 from Nuveen Enhanced CLO Income Fund (CIK 0002035726)
Nuveen Enhanced CLO Income Fund (CIK 0002035726)
Date: Jan. 6, 2025 · CIK: 0002035726 · Accession: 0001839882-25-000655
AI Filing Summary & Sentiment
File numbers found in text: 333-281856, 811-23999
Letter
VIA EDGAR Division of Investment Management, Disclosure Review and Accounting Office Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Nuveen Enhanced CLO Income Fund File Numbers: 333-281856; 811-23999
Dear Mr. Eskildsen:
You previously provided accounting comments on the registration statement on Form N-2 (the “Registration Statement”) filed with respect to the Nuveen Enhanced CLO Income Fund (the “Registrant”). On December 26, 2024, we supplementally provided unaudited financial statements for the Predecessor Fund and the Master Fund (the “Unaudited Financial Statements”). On December 31, 2024, you provided comments to the Unaudited Financial Statements and, therefore, I am writing to respond to those comments. For convenience, your comments are repeated below, with the responses immediately following. Capitalized terms not defined in this letter have the meanings ascribed to them in the Registration Statement.
1. Comment: Please confirm that all investments with a coupon rate are not variable rate securities that would require additional disclosures by footnote 4 of Rule 12-12 of Regulation S-X.
Response: The Registrant has added the required footnote.
2. Comment: Please confirm that none of the disclosed investments are restricted securities that would require additional disclosures by footnote 8 of Rule 12-12 of Regulation S-X.
Pennsylvania • New Jersey • Delaware • DC • New York • Illinois • California
A Pennsylvania Limited Liability Partnership
Response: The Registrant confirms that there were no restricted securities held as of the date of the Unaudited Financial Statements.
3. Comment: Certain investments do not disclose a coupon rate. Please confirm if those investments are income producing securities. If they are not income producing securities, please identify each of those with an appropriate symbol in accordance with footnote 7 of Rule 12-12 of Regulation S-X.
Response: The Registrant confirms that there were no non-income producing securities held as of the date of the Unaudited Financial Statements.
4. Comment: Certain holdings identified in the Unaudited Financial Statements, specifically in Note 4, are identified as Level 3 assets. In the Schedule of Investments, please indicate by an appropriate symbol any investments that were valued based on unobservable inputs in accordance with footnote 9 of Rule 12-12 of Regulation S-X.
Response: The Registrant has added the required footnote.
* * * * * *
We believe that this information responds to all of your comments. If you should require additional information, please call me at 215.564.8528 or, in my absence, Stephen LaChine at 312.964.3522.
Sincerely,
/s/ Joel D. Corriero
Show Raw Text
CORRESP
1
filename1.htm
Stradley Ronon Stevens & Young, LLP
2005 Market Street, Suite 2600
Philadelphia, PA 19103
Telephone 215.564.8000
Fax 215.564.8120
www.stradley.com
Joel D Corriero
Partner
jcorriero@stradley.com
215.564.8528
VIA EDGAR
January 6, 2025
Chad Eskildsen
Staff Accountant
Division of Investment Management, Disclosure Review and Accounting Office
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Nuveen Enhanced CLO Income Fund
File Numbers: 333-281856; 811-23999
Dear Mr. Eskildsen:
You previously provided accounting
comments on the registration statement on Form N-2 (the “Registration Statement”) filed with respect to the Nuveen Enhanced
CLO Income Fund (the “Registrant”). On December 26, 2024, we supplementally provided unaudited financial statements for the
Predecessor Fund and the Master Fund (the “Unaudited Financial Statements”). On December 31, 2024, you provided comments to
the Unaudited Financial Statements and, therefore, I am writing to respond to those comments. For convenience, your comments are repeated
below, with the responses immediately following. Capitalized terms not defined in this letter have the meanings ascribed to them in the
Registration Statement.
1. Comment: Please confirm that all investments with a coupon
rate are not variable rate securities that would require additional disclosures by footnote 4 of Rule 12-12 of Regulation S-X.
Response: The Registrant
has added the required footnote.
2. Comment: Please confirm that none of the disclosed investments
are restricted securities that would require additional disclosures by footnote 8 of Rule 12-12 of Regulation S-X.
Pennsylvania • New Jersey • Delaware
• DC • New York • Illinois • California
A Pennsylvania Limited Liability Partnership
Response: The Registrant
confirms that there were no restricted securities held as of the date of the Unaudited Financial Statements.
3. Comment: Certain investments do not disclose a coupon rate.
Please confirm if those investments are income producing securities. If they are not income producing securities, please identify each
of those with an appropriate symbol in accordance with footnote 7 of Rule 12-12 of Regulation S-X.
Response: The Registrant
confirms that there were no non-income producing securities held as of the date of the Unaudited Financial Statements.
4. Comment: Certain holdings identified in the Unaudited Financial
Statements, specifically in Note 4, are identified as Level 3 assets. In the Schedule of Investments, please indicate by an appropriate
symbol any investments that were valued based on unobservable inputs in accordance with footnote 9 of Rule 12-12 of Regulation S-X.
Response: The Registrant
has added the required footnote.
* * * * * *
We believe that this information
responds to all of your comments. If you should require additional information, please call me at 215.564.8528 or, in my absence, Stephen
LaChine at 312.964.3522.
Sincerely,
/s/ Joel D. Corriero
Joel D. Corriero
Enclosures
Copies (w/encl.) to
M. Winget
E. Fess
E. Purple
S. Lachine