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CORRESP
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CORRESP

 Simpson Thacher & Bartlett LLP

425 LEXINGTON AVENUE

NEW YORK, NY 10017

 TELEPHONE: + 1-212-455-7026

 FACSIMILE: + 1-212-455-2502

 Direct Dial Number

 (212) 455-7026

 E-mail Address

bissie.bonner@stblaw.com

 June 12, 2025

 VIA
EDGAR

 Yoon Choo

 U.S. Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 StepStone Private Equity Strategies Fund

 
 File Nos. 333-286960;
811-24083

 Dear Ms. Choo:

On behalf of StepStone Private Equity Strategies Fund (formerly, StepStone Private Equity Fund) (the “Fund”), this letter responds to
written comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Robert W. Long, Chief Executive Officer of StepStone Private Wealth
LLC, the Fund’s investment adviser, via e-mail to the undersigned on June 4, 2025 regarding the filing of a registration statement on Form N-2 (the
“Registration Statement”) for the Fund on May 5, 2025.

 For the convenience of the Staff, the comments regarding the
Registration Statement are set out below. We have discussed the Staff’s comments with representatives of the Fund. The Fund’s responses to the Staff’s comments are set out immediately under the restated comment. Please note that we
have not independently verified information provided by the Fund. The Fund anticipates filing any changes to the Registration Statement described below in a Pre-Effective Amendment to the
Registration Statement (the “Amendment”), which is being filed concurrently with this letter. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement and page number references are
those of the Registration Statement.

Securities and Exchange Commission

June 12, 2025

 General

1.
 We note that the Registration Statement is missing information and exhibits (e.g., amended and restated
Declaration of Trust, Bylaws, fee and expense information, and seed financial statements) and contains bracketed disclosures. 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: The Fund respectfully acknowledges the Staff’s comment. The Fund notes that it anticipates filing an additional pre-effective amendment at a later date to provide all missing information and exhibits prior to requesting acceleration of the effective date of the Registration Statement.

2.
 Where a comment is made about disclosure in one location, it is applicable to all similar disclosure
appearing elsewhere in the Registration Statement. Please make all conforming changes.

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

3.
 Please advise us if you expect to submit any exemptive application(s) or no action request(s) in connection
with the Registration Statement and the timing of any such request(s). In this regard, please inform us whether the Fund intends to request updated exemptive relief for co-investment transactions similar to
the relief recently granted to FS Credit Opportunities Corp. et al. (Feb. 20, 2025).

 Response: On
April 11, 2025, an affiliate of the Fund filed an amendment to its application seeking exemptive relief (the “New Co-Investment Relief”) to engage in transactions with certain affiliates
otherwise prohibited by Section 17(d) and Rule 17d-l of the Investment Company Act of 1940, as amended (the “1940 Act”). The New Co-Investment Relief has
not yet been granted by the Commission, but the Fund intends to be an applicant in the next amendment to the Application and to rely on the New Co-Investment Relief when, and if, granted. The Fund does not
otherwise expect to submit any exemptive applications or no action requests in connection with the Registration Statement.

Prospectus

 Cover page

4.
 We note the term “Private Equity” precedes the word “Fund” in the 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 the Fund’s name to avoid the potential for investor confusion.

Securities and Exchange Commission

June 12, 2025

 Response: The Fund respectfully submits that the term “private” refers to
private placements. However, the Fund confirms that, effective June 11, 2025, it changed its name to “StepStone Private Equity Strategies Fund,” and this new name will be reflected in the Amendment.

5.
 The Fund’s name is subject to rule 35d-1. Capital commitments
are not Assets as defined in rule 35d-1(g) and therefore should not be counted for purposes of compliance with the Fund’s 80% investment policy. Please revise the policy.

Response: The Fund notes that a number of other
1940 Act-registered closed-end funds have included capital commitments towards their 80% names rule policy (see, e.g., FS MVP Private Markets Fund
and Hamilton Lane Private Assets Fund). The Fund believes it is appropriate to include capital commitments in its 80% names rule policy because these capital commitments are irrevocable and are treated as unfunded commitment agreements for purposes of Rule 18f-4, which means that the Fund must have a reasonable belief at the time of making the particular capital commitment that it will have sufficient cash and cash equivalents to meet
its obligations with respect to all of its unfunded commitment agreements, in each case as they come due.

6.
 In an appropriate location in the Prospectus, please disclose that Shareholders will be given 60 days’
advance notice of any change to the Fund’s 80% policy. (See rule 35d-1(a)(2)(ii).).

Response: The requested disclosure will be added in the Amendment.

7.
 Please make the statement required by rule 481(b)(1) under the 1933 Act more prominent.

 Response: The requested change will be made in the Amendment.

8.
 Under Principal Investment Strategies, item (ii) specifically refers to equity or debt
investments. Please revise references to “investments” elsewhere in the statement to clarify whether investments refer to equity and/or debt.

Response: The requested change will be made in the Amendment.

9.
 Please add a prominent statement to the effect that the Fund should be considered a complex investment and
entails substantial risks, and a prospective investor should invest in the Fund only if the investor can sustain a substantial or complete loss of their investment and is unlikely to need short-term access to the amounts invested. Please also
provide prominent cross-references to the Prospectus discussion(s) of the factors that make the offering speculative or one of high risk. (See Item 1.1.j.)

Response: The requested disclosure will be added in the Amendment.

10.
 Please add or revise disclosure under the To All Investors section to cover the following:

Securities and Exchange Commission

June 12, 2025

a.
 Shareholders should not expect to be able to sell their Shares (other than through the limited repurchase
program), regardless of how the Fund performs;

 Response: The requested disclosure will be added in the
Amendment.

b.
 Shareholders should consider that they may not have access to the money they invest for an indefinite period
of time;

 Response: The requested disclosure will be added in the Amendment.

c.
 Shareholders will bear substantial direct and indirect fees and expenses in connection with their
investment; and

 Response: The requested disclosure will be added in the Amendment.

d.
 Private Equity Assets involve a high degree of business and financial risk that can result in substantial
losses.

 Response: The requested disclosure will be added in the Amendment.

Please also consider making the bullet points in the subsection more prominent.

Response: The disclosure will be updated in the Amendment.

11.
 The Prospectus states that the Fund “will ordinarily declare and pay distributions from its taxable net
investment income and distribute net realized capital gains, if any, at least once a year.” The Fund also does not have a managed distribution program or target a specific distribution rate. However, the third, fourth and fifth bullet points
suggest return of capital will be a material risk. If return of capital is expected to be material to Shareholders, please add discussions in appropriate locations in the Prospectus.

Response: The Fund respectfully submits that it does not consider return of capital to be a material risk to Shareholders under the
Fund’s distribution policy. The Fund confirms that it generally expects to fund distributions from net investment income and has added disclosure to this effect in the bullet points under “To All Investors” in the Amendment.

12.
 At the end of the last paragraph following the bullet points, please add a prominent cross-reference to the
sections of the Prospectus that discuss the Fund’s repurchase policies and attendant risks. (See Item 1.1.j.).

Response: The requested disclosure will be added in the Amendment.

Summary of Prospectus

13.
 The synopsis should provide a clear and concise description of the key features of the offering and the
Fund, with cross-references to relevant disclosures elsewhere in the Prospectus or SAI. (See Instruction to Item 3.2.) Please revise the first sentence of the introduction accordingly and ensure that each Q&A includes a cross-reference(s)
to the more detailed disclosure in the Prospectus or SAI.

Securities and Exchange Commission

June 12, 2025

 Response: The disclosure will be updated in the Amendment.

14.
 Please add a Q&A briefly addressing the types of material conflicts the Adviser anticipates and how it
will eliminate or manage conflicts to ensure the Fund is treated fairly and equitably over time.

 Response:
The requested disclosure will be added in the Amendment.

 Q: What is Stepstone Private Equity Fund?

15.
 We note the reference to “controlling ownership in the target company, project or property” under Co-Investments. Please clarify in the disclosure whether the Fund, Adviser, or their respective affiliates will control or be responsible for operating Private Equity Assets.

Response: The Fund notes that the aforementioned disclosure regarding controlling ownership refers to ownership collectively by the
Investment Manager and co-investors, including the Fund, in the target companies in which the Fund makes Co-Investments, and the Fund itself does not intend to acquire controlling ownership over or operate any
Private Equity Assets. The Fund’s Co-Investments are expected to consist of minority or non-controlling investments. The disclosure will be updated in the Amendment
accordingly.

 —Secondary Investments

16.
 The Fund will deploy capital into “[s]econdary purchases of existing investments in
(i) individual operating companies or assets [emphasis added].” Please disclose what secondary assets the Fund intends to purchase (outside of individual operating companies or Investment Funds).

 Response: The Fund will replace the references to “assets” in this disclosure with “projects or
properties” in the Amendment.

17.
 Please supplementally explain how the Fund intends to purchase and sell investments in private secondary
markets. Specifically, please highlight if there are bid/asks associated with particular investments and describe the availability and frequency of such price information. Please disclose the mechanics of secondary market investments, including any
consents or other considerations, that may impact your ability to acquire or dispose of such investments.

Response: The Fund will make purchases and sales in Secondaries through bespoke, privately-negotiated transactions. These Secondaries
will take the form of either general partner (“GP”)-led transactions (i.e., a GP wishes to sell assets of a fund before the end of its term) or limited partner
(“LP”)-led (i.e., an LP wishes to sell its interest in one or more private equity funds before the end of its/their term). Through its vast network and deep knowledge of the private markets,
StepStone is able to source potential Secondaries for the Fund. StepStone will meet with the GP or LP seeking to sell the position and will submit the Fund’s bid after conducting its diligence of the investment opportunity.

Securities and Exchange Commission

June 12, 2025

 The market for Secondaries does not function like a public secondary market in which there
are regular bid/asks associated with a given investment opportunity. Price is determined based upon mutual agreement between the parties involved in the negotiation for the purchase or sale of the investment opportunity. Typically, in LP-led secondary transactions, the GP’s consent will be required before the transaction can be finalized.

18.
 Please supplementally inform us if secondary purchase transactions generally include a commitment for future
capital calls by the Private Equity Assets or deferred payments on investments purchased.

 Response: In a
secondary transaction, the buyer will acquire an interest in existing private investment funds or individual operating companies, projects or properties and, as a result, will take on any future funding obligations in exchange for future returns and
distributions.

19.
 Please supplementally inform us if, for secondary transactions, certain parties may have a right of first
refusal on a transaction. In such cases, please describe the Fund’s accounting policy for recognizing such assets. Please cite to applicable U.S. GAAP.

Response: In certain instances, LPs may have a right of first refusal to purchase the interests in (i) the assets of a private
investment fund that the Fund seeks to purchase in a GP-led secondary transaction or (ii) a private investment fund that the Fund seeks to purchase in an LP-led
secondary transaction. However, the Fund does not consider this to be a material risk to its investment strategy since the subject interest of a given transaction has typically already been previously offered to existing LPs prior to it being made
available to the Fund for purchase. Accordingly, the Fund does not have a specific accounting policy related to right of first refusal associated with the Secondaries in which it invests. In addition, the Fund notes that any such transaction subject
to a right of first refusal would not be considered a Fund investment until the transaction has been consummated between the Fund and the relevant party.

Q: What is the Fund’s investment strategy?

20.
 Consistent with discussions of the Fund’s investment strategy on the cover page and
Investment Program—Types of Investment Structures, please add a reference to Primary Investments in the first bullet point.

Response: The requested disclosure will be added in the Amendment.

Q: How does the Fund compensate the Adviser and Sub-Adviser for the management of the underlying assets and
other administrative requirements associated with the ongoing operation of the Fund?

21.
 The Q&A discusses some of the costs of investing in the Fund but does not discuss the costs of the
Fund’s investments in Investment Funds, operating companies, and other assets, which may be significant. Please revise the question and add disclosure addressing these costs.

Securities and Exchange Commission

June 12, 2025

 Response: The disclosure will be updated in the Amendment.

Q: Will there be any limitation on the fees charged by the Fund?

22.
 Please add “or Expense Cap in effect at the time such fees and expenses were waived, reimbursed, or
paid” to the end of the last sentence.

 Response: The requested disclosure will be added in the
Amendment.

 Q: What are the principal