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CORRESP
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CORRESP

 COLUMBIA CREDIT INCOME OPPORTUNITIES FUND

290 Congress Street

Boston, MA 02210

 February 28, 2025

 VIA EDGAR

 Mr. Matthew Williams

U.S. Securities and Exchange Commission

 Division of Investment
Management, Disclosure Review Office

 100 F Street, N.E.

Washington, D.C. 20549

  RE:  Columbia Credit Income Opportunities Fund

 Registration Statement on Form N-2

File Nos. 333-283461 and 811-24028

 Dear Mr. Williams:

 This
letter responds to comments received from the staff (Staff) of the Securities and Exchange Commission on December 26, 2024 for the filing filed by and on behalf of Columbia Credit Income Opportunities Fund (the Registrant or the Fund). Comments
and responses are outlined below.

Comment 1:

We note that the registration statement is missing information and exhibits (e.g., seed financial statements of the Fund, investment advisory agreements) and contains bracketed disclosures (e.g., fee table and expense
example). We may have comments on such portions when you complete them in any pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits
filed in any pre-effective amendment. Please plan accordingly.

Response:

Understood.

Comment 2:

Please tell us if you have presented any test-the-waters materials to potential investors in connection with this offering. If so, please contact us to
discuss how to provide us with copies of such materials.

Response:

We have not presented any test-the-waters materials to potential investors in connection with this offering.

Comment 3:

Please address whether a party other than the Fund’s sponsor or one of its affiliates is providing the Fund’s initial (seed) capital. If yes, please supplementally identify the party providing the seed capital and describe
its relationship with the Fund.

Response:

Initial (seed) capital for the Fund is anticipated to be provided by the Fund’s investment adviser, Columbia Management Investment Advisers, LLC.

Comment 4:

Please advise us if you have submitted or intend to submit any exemptive applications or no-action requests in connection with the registration statement. We note that the Fund intends to
issue two separate classes of shares: Class A and Class Institutional (Class Inst) Shares and intends to file an application for multi-class exemptive relief. All references to an intention to rely on exemptive relief should be accompanied
with further disclosure explaining that the Commission has not granted such relief and there is no assurance that such relief will be granted.

Response:

The Fund has filed an application for multi-class exemptive relief on December 31, 2024 and an amended application on February 12, 2025 and an application for co-investment exemptive
relief on January 7, 2025. We do not anticipate submitting other exemptive applications or no-action requests at this time in connection with the registration statement.

All references within the registration statement to an intention to rely on exemptive relief have been revised with further disclosure explaining that the Commission has not granted such relief and there is no assurance that such
relief will be granted.

COVER PAGE

Comment 5:

The cover page includes disclosure that the Fund is an interval fund and will make periodic repurchase offers for its securities, subject to certain conditions. Please also disclose on the cover page the anticipated timing of the
Fund’s initial repurchase offer.

Response:

The cover page has been revised as requested.

Comment 6:

The cover page is over four pages long and includes detailed principal investment strategy disclosure. Consider providing a more concise summary of this disclosure on the cover page, and providing cross-references to where investors
can find more detailed information in the prospectus.

Response:

The cover page disclosure was revised to provide a more concise summary.

Comment 7:

Disclosure indicates that a substantial portion of the Fund’s assets may be invested in securities rated below investment grade. Please briefly note here the types of investments in which those assets are generally held
(e.g., CLOs, Alternative Lending ABS, and other securitized instruments), and disclose that such investments may be difficult to value and may be illiquid. Please also include a cross-reference to sections in the registration statement
discussing applicable risks. Finally, please place this text in bold-faced type. See Item 1.1.j.

Response:

The requested revisions have been made.

Comment 8:

The fifth sentence of footnote 1 states: “The minimum initial investment for Class A and Class Inst Shares is $[___] and $[__] per account, respectively, except that the minimum investment may be modified for certain
investors.” Please explain these modifications or include an applicable cross-reference.

Response:

This disclosure has been revised to delete “, respectively, except that the minimum investment may be modified for certain investors.”

Comment 9:

Please review Item 2.3 and, if applicable, include the disclosure required by Rule 481(e) under the Securities Act of 1933 (“Securities Act”) regarding prospectus delivery obligations.

Response:

The Fund prospectus back cover has been revised to include all disclosure required by Rule 481(e) under the Securities Act.

 PROSPECTUS

 Summary of the Fund (p. 3)

Fees and Expenses of the Fund

Comment 10:

Please supplementally confirm that an estimate of the interest and dividend expenses of short sales will be included in the fee table, if applicable. We note that short selling is included in the Fund’s principal investment
strategies.

Response:

So confirmed.

Comment 11:

Disclosure in footnote (c) to the fee table states that the Fund reserves the right to amend its Dividend Investment Plan to include a service charge. Please disclose the maximum service charge the Fund may impose for
participation in the Fund’s Dividend Investment Plan.

Response:

The Fund will not charge such a fee and has no plans to do so. As such, this disclosure has been removed.

Comment 12:

Disclosure in footnote (d) to the fee table states, in brackets, that the Fund’s management fee is [_]% of the Fund’s average daily Managed Assets (which means the net asset value of Fund’s outstanding Shares
plus the liquidation preference of any issued and outstanding preferred stock of the Fund). Please confirm that the Fund’s management fee disclosed in the table is disclosed as a percentage of net assets. If based on some other measure, please
convert to net assets and include an explanation in the footnote.

Response:

Confirmed, and the Fund has determined to base its fee on “net” assets rather than “Managed” Assets.

Comment 13:

Disclosure in this section states that the Fund reserves the right to reject a purchase order for any reason. Similarly, disclosure on pages 39 and 99 states, “The Fund and the Distributor will have the sole right to accept
orders to purchase Shares and reserve the right to reject any order in whole or in part.” Please reconcile with disclosure on page 102 stating: “The Fund and the Distributor each reserves the right . . . to reject any purchase order, in
whole or in part, when, in the judgement of management, such . . . rejection is in the best interests of the Fund.”

Response:

Thank you for bringing the apparent inconsistency in disclosure to the Fund’s attention. The disclosures have been reconciled.

Prospectus Summary

Comment 14:

We note that the Fund will calculate the NAV of its Shares on a daily basis in accordance with Rule 23c-3(b)(7)(iii) under the Investment Company Act of 1940 (the “1940 Act”), as
shares of the Fund will be continuously offered under the Securities Act. 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, so state. Please also
include a cross reference to “Determination of Net Asset Value.”

Response:

The requested revisions have been made.

Principal Investment Strategies

Comment 15:

We note that there are several types of principal investment strategies that do not appear to have corresponding principal risk disclosure (e.g., reperforming loans, mortgage pass-through securities, delayed funding loans and
revolving credit facilities). Please review the Fund’s

principal risk disclosure and consider whether any risks associated with the Fund’s principal investments are adequately disclosed.

Response:

The Fund’s Principal Risks have been reviewed in the above regard and disclosure enhancements have been made.

Comment 16:

Disclosure indicates that the Fund may originate or acquire loans, including, without limitation, residential and/or commercial real estate or mortgage-related loans, consumer and corporate asset loans or other types of loans.
Please also disclose the following with respect to loans originated by the Fund:

 a.  Any limits on loan origination by the Fund (e.g., the amount of loans originated
as a percentage of net assets);

b. A description of the overall loan selection process;

c. A description of the Fund’s underwriting standards for these loans; and

d. Whether the Fund will be involved in servicing the loans and, if so, a description of its servicing obligations.

Please also confirm supplementally whether the Alternative Lending ABS in which the Fund intends to invest are sourced by, or sold through, online marketplace lending platforms. We may have further questions.

Response:

The Fund does not currently intend to originate loans. As such, Fund prospectus and SAI disclosure with respect to the Fund originating loans has been removed.

The Alternative Lending ABS in which the Fund intends to invest are not sourced by, or sold through, online marketplace lending platforms. The disclosure in this regard has been revised accordingly.

Comment 17:

Disclosure in this section states: “To the extent consistent with the liquidity requirements applicable to interval funds under Rule 23c-3 under the Investment Company Act of 1940, as
amended (the 1940 Act), the Fund may invest without limit in illiquid securities.” Please supplementally confirm that the Fund has adopted written procedures “reasonably designed” to ensure that the Fund’s assets are sufficiently
liquid to allow it to comply with: (i) its fundamental policy on repurchases and (ii) the rule’s liquidity requirements. See Rule 23c-3(d).

Response:

So confirmed.

Comment 18:

Disclosure notes that the Fund may invest in convertible debt and equity securities, including synthetic convertible securities. If the Fund invests or expects to invest in contingent convertible securities (“CoCos”),
please consider what, if any, disclosure is appropriate regarding the risks of CoCos. The type and location of disclosure will depend on, among other things, the extent to which the Fund invests in CoCos and the characteristics of the CoCos (e.g.,
the credit quality and conversion triggers). If CoCos are, or will be, a principal type of investment, the Fund should provide a description of them and should provide appropriate risk disclosure.

Response:

The Fund does not intend to invest principally in synthetic convertible securities or CoCo’s and, as such, these investments have been removed from the Fund’s Principal Investment Strategies and Principal Risks.

Comment 19:

Please consider combining the Fund’s “Pay-in-kind Securities” disclosure with the “Zero Coupon, Deferred Interest, Pay-In-Kind, and Capital Appreciation Bonds” disclosure later in this subsection.

Response:

The disclosure has been revised as suggested.

Comment 20:

Disclosure in this section states that the Fund may make investments in Alternative Lending ABS directly through one or more wholly-owned subsidiaries (“Subsidiaries”). With respect to each Subsidiary, please address the
following comments in an appropriate location in the registration statement:

 a.  Disclose that the Fund complies with the provisions of the 1940 Act governing
investment policies (Section 8) on an aggregate basis with the Subsidiary;

 Response: The requested disclosure has been added.

 b. Disclose that the Fund complies with the provisions of 1940 Act governing capital
structure and leverage (Section 18) on an aggregate basis with the Subsidiary so that the Fund treats the Subsidiary’s debt as its own for purposes of Section 18;

 Response: The requested disclosure has been added.

 c.  Disclose that any investment adviser to the Subsidiary complies with provisions of
the 1940 Act relating to investment advisory contracts (Section 15) as if it were an investment adviser to the Fund under Section 2(a)(20) of the 1940 Act. Any investment advisory agreement between the Subsidiary and its investment adviser is a
material contract that should be included as an exhibit to the registration statement;

 Response: The requested disclosure has been added.

 If the same person is the adviser to both the Fund and the Subsidiary, then, for purposes of complying with
Section 15(c), the reviews of the Fund’s and the Subsidiary’s investment advisory agreements may be combined;

 Response: Noted.

 d. Disclose that each Subsidiary complies with provisions relating to affiliated
transactions and custody (Section 17). Identify the custodian of the Subsidiary, if any;

 Response: The requested disclosure has been added.

 e.  Disclose any of the Subsidiary’s principal investment strategies or principal
risks that constitute principal investment strategies or risks of the Fund. The principal investment strategies and principal risk disclosures of a Fund that invests in a Subsidiary should reflect aggregate operations of the Fund and the
Subsidiary;

 Response: The Fund’s principal investment strategies and principal risk disclosures reflect aggregate
operations of the Fund and the Subsidiary.

 f.  Supplementally confirm that any Subsidiary’s management fee (including any
performance fee), if any, will be included in “Management Fees,” and the Subsidiary’s expenses will be included in “Other Expenses” in the Fund’s fee table;

 Response: So confirmed.

 g. Supplementally explain whether the financial statements of the Subsidiaries will be
consolidated with those of the Fund. If not, please explain why not.

 Response: The financial statements of the Subsidiaries will be consolidated with those of the
Fund.

 h. Supplementally confirm that each Subsidiary, and any board of directors it has, will
agree to inspection by the staff of the Subsidiary’s books and records, which will be maintained in accordance with section 31 of the 1940 Act and the rules thereunder;

 Response: So confirmed.

 and

 i.  Please disclose that the Fund does not intend to create or acquire primary control
of any entity which primarily engages in investment activities in securities or other assets, other than entities wholly-owned by the Fund. In this context, “primary control” means (1) the Fund controls the unregistered entity within
the meaning of Section 2(a)(9) of the 1940 Act, and (2) the Fund’s control of the unregistered entity is greater than that of any other person.

 Response: The requested disclosure has been added.

Response:

Our responses are reflected above, immediately following each question/comment above.

Comment 21:

We note that the Fund may have principal investments in foreign securities, including in emerging markets. Please provide a basis to assess the expertise and experience of the Adviser with respect to foreign investments. See
Guide 9. Please also clarify whether there is any limit or target to the amount of the Fund’s net assets that may be invested in foreign investments. Finally, please also consider whether the foreign securities risks enumerated in Guide 9 are
concisely addressed in the prospectus. See also IM Accounting and Disclosure Information 2020-11, Registered Funds’ Ri