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CORRESP
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 CORRESP

 Simpson Thacher & Bartlett LLP
 425 L EXINGTON A VENUE
 N EW Y ORK , NY 10017

 TELEPHONE : + 1-212-455-2000
 FACSIMILE : + 1-212-455-2502

 Direct Dial Number (212) 455-7026

 E-mail Address
 bissie.bonner@stblaw.com
 July 21, 2025 VIA
EDGAR Yoon Choo Jeffrey Long
 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 and Mr. Long: On behalf
of StepStone Private Equity Strategies Fund (the “ Fund ”), this letter responds to telephonic comments provided by the staff of the Division of Investment Management (the “ Staff ”) of the Securities and Exchange
Commission (the “ Commission ”) to the undersigned on June 30, 2025 and July 3, 2025 regarding Pre-Effective Amendment No. 1 to the Fund’s registration statement on Form N-2 (the “ Registration
Statement ”) and the letter responding to the Staff’s comments on the initial Registration Statement (the “ Comment Letter ”), each filed with the Commission on June 12, 2025.
 For the convenience of the Staff, the comments regarding the Registration Statement and Comment Letter 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 No. 2 to the Registration Statement (the “ Amendment ”), which will be filed at a later date.
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.
 Accounting Staff Comments (Received on June 30, 2025)

 1.
 With respect to the response to Comment No. 19 in the Comment Letter regarding the accounting treatment
of transactions subject to a right of first refusal, please confirm supplementally whether the Fund treats such transactions as unfunded commitments.

 Securities and Exchange Commission

 July 21, 2025
 Response : The Fund would not treat transactions subject to a right of first refusal as
unfunded commitments. The Fund would not record a commitment until the Fund has received a signed acceptance letter from the underlying fund’s general partner that the Fund has been admitted to the underlying fund.

 2.
 The Staff notes that the Fund is party to an Expense Limitation and Reimbursement Agreement with the
Adviser. In Pre-Effective Amendment No. 1 to the Registration Statement, the fee table provides that the Expense Cap is 1.00% of net assets, but the Annual Net Expense ratio for each class exceeds 1.00% of net assets and the fees waived amount
only to 0.25% of net assets. Please supplementally explain which expenses are excluded from the Expense Cap.
 Response : As indicated in footnote 7 to the fee table in Post-Effective Amendment No. 1 to the Registration Statement, certain
Specified Expenses are excluded from the Expense Cap. With respect to the Fund’s expenses shown in the fee table, the Management Fee, fees associated acquisition or disposition of an investment, credit facility fees, distribution and
shareholder servicing fees, and taxes are the primary expenses excluded from the Expense Cap. Disclosure Staff Comments (Received on July 3,
2025) Prospectus
 General

 3.
 We reiterate Comment 5 in the Comment Letter. Rule 35d-1 under the 1940 Act is an asset-based test. As such,
unfunded commitments cannot be counted towards the 80% policy. Response : The Fund will revise its 80% policy
to read as follows: “Under normal circumstances, the Fund invests at least 80% of its net assets, plus the amount of any borrowings for investment purposes, in Private Equity Assets.” The Fund intends to count the value of any money market
funds, cash, cash equivalents or U.S. Treasury securities with remaining maturities of one year or less that cover unfunded commitments to invest in Private Equity Assets that the Fund reasonably expects to be called in the future as qualifying
Private Equity Assets for purposes of its 80% policy, and the Fund will add disclosure to this effect in the Amendment. In addition, the
Fund will add the following disclosure to the discussions of the Fund’s investment strategies in the Amendment: “The Secondary Investments and Co-Investments the Fund makes typically will include an unfunded portion where the Fund commits
to invest equity in the Private Equity Asset in the future, as will the Fund’s Primary Investments. These unfunded commitments can be drawn at the discretion of the general partner of the Private Equity Asset subject to certain conditions
(e.g., notice provisions). At times, the Fund expects that a significant portion of its assets will be invested in money market funds or other cash items, pending the calling of these unfunded commitments.”

 Securities and Exchange Commission

 July 21, 2025
 Cover Page

 4.
 The response to Comment 50 in the Comment Letter appears to indicate that there are no sales charge
variations available through the Fund, the placement agent or selling agents. If so, please revise the disclosure relating to sales loads throughout the prospectus to indicate that shareholders will be charged a sales load. Please also remove
references to “maximum” sales load throughout the Registration Statement. Response : The requested
changes will be made in the Amendment. Summary of Prospectus

 5.
 In an appropriate location in the Q&A, please add the asset allocation targets disclosed under
“Investment Program—Portfolio Allocation.” Response : The requested disclosure will be added in
the Amendment.

 6.
 In Pre-Effective Amendment No. 1 to the Registration Statement, the Staff notes the addition of
disclosure in the response to “What are the Fund’s other expenses?” regarding the Fund indirectly bearing operating expenses of the Investment Funds. If the Fund expects to bear ongoing expenses in connection with investments in other
types of Private Equity Assets besides Investment Funds, please disclose those expenses here and provide examples if possible.
 Response : As the Fund may bear management fees and partnership expenses relating to other types of Private Equity Assets in addition to
Investment Funds, the Fund will revise the above-referenced disclosure regarding the Fund indirectly bearing operating expenses as follows:
 The Fund will also indirectly bear operating expenses of the
 Investment
Funds Private Equity Assets (e.g., management fees,
administration fees and professional and other direct, fixed fees and expenses of the Investment Funds Private Equity Assets ). See “Summary of Fees and Expenses —Expenses of Fund Investments .”

 Securities and Exchange Commission

 July 21, 2025
 Summary of Fees and Expenses

 7.
 Other Expenses is the second largest line item in the fee table after the management fee. Footnote 5
describing Other Expenses refers only to administrative and offering costs. Please disclose the other material components of the Other Expenses line item.
 Response : The Fund will revise the first sentence of footnote 5 to the fee table in the Amendment as follows:
 Other Expenses include all other expenses incurred by the Fund, such as
 certain administrative
costs professional fees relating to legal, tax and audit expenses; Fund operating expenses such as
transfer agency fees, custody fees, administration fees, trustee fees, and non-interest related credit facility fees (amortization of debt acquisition costs and undrawn fees); and expenses
relating to the offering and sale of Shares. Investment Program
 Investment Strategies

 8.
 In response to Comment 29 in the Comment Letter, the Fund confirmed that Primary Investments are a principal
component of the Fund’s investment strategy. Please add references to Primary Investments here and elsewhere in the Prospectus, as appropriate.
 Response : The requested disclosure will be added in the Amendment.

 9.
 Please explain the Fund’s over-commitment strategy in the Fund’s investment strategy disclosure.
Please also disclose whether this over-commitment strategy applies only to Primary Investments or also to Secondaries and Co-Investments.
 Response : The Fund will revise the disclosure regarding the over-commitment strategy in the Amendment as follows:
 The commitment strategy will aim to keep the Fund substantially invested and to minimize cash drag where possible by making commitments based
on anticipated future distributions from investments. The Fund will employ an “over-commitment” strategy,
 whereby the Fund may commit to making investments in Secondaries, Co-Investments and Primary Investments in an amount
that exceeds the ability of the Fund to contribute in full at the time of making the commitment, which could result in an insufficient cash supply to fund unfunded commitments to the applicable Investment Funds. See “Risk Factors—Principal
Risks Related to Private Equity Assets—Commitment Strategy.” The commitment strategy will also take other anticipated cash flows into account, such as those relating to new subscriptions, the redemption of Shares by Shareholders and
distributions to Shareholders. To forecast portfolio cash flows, the Advisers will utilize a proprietary model that incorporates historical data, actual portfolio observations, insights, and forecasts by the Advisers.

 Securities and Exchange Commission

 July 21, 2025

 10.
 Further to the Fund’s response to Comment 30 in the Comment Letter, please explain supplementally
whether selling assets at a discount would result in the Fund marking down any retained portion of the asset. If so, please add disclosure addressing this point and its impact on the Fund’s NAV or performance.
 Response : An adjustment to the fair value of the retained portion of an asset of which a portion is sold at a discount would be
dependent on the circumstances of the sale. If the discounted sales price was reflective of the market value determined at arm’s length or part of a tender offer with other third-party participants, the retained portion would be marked at the
sales price. The reduction in value would be reflected in the change in unrealized gain/loss of the Fund’s NAV. Likewise, if a portion was sold at a premium and the premium was reflective of the market value determined at arm’s length or
part of a tender offer with other third-party participants, the retained portion would be marked up. If the sales price was negotiated privately and discounted solely to account for or address liquidity needs, the retained portion would not be
marked down to the discounted price. The Fund will add the following disclosure to the “Calculation of Net Asset Value” section
in the Amendment: To enhance the Fund’s liquidity, particularly in times of possible net outflows through the repurchase of Shares,
the Advisers may from time to time determine to sell certain of the Fund’s assets in the secondary market, which could potentially result in the assets, or a portion thereof, being sold at a discounted value. If the Fund sells a portion of an
asset at a discounted value and the discounted value was reflective of the market value determined at arm’s length or part of a tender offer with other third-party participants, the retained portion would be marked at the sales price. The
reduction in value would be reflected in the change in unrealized gain/loss of the Fund’s NAV. Likewise, if a portion of an asset was sold at a premium and the premium was reflective of the market value determined at arm’s length or part
of a tender offer with other third-party participants, the retained portion would be marked up. If the sales price was negotiated privately and discounted solely to account for or address liquidity needs, the retained portion would not be marked
down to the discounted price. Types of Investment Structures
 — Secondary Investments

 11.
 We reiterate the portions of Comment 32 in the Comment Letter to explain in plain English terms:
(a) the impact of these unrealized gains on the Fund’s NAV and investment performance; (b) any attendant risks to the mark-up to NAV; and (c) any tax impact to Shareholders. If any component of this comment does not warrant
additional disclosure, please supplementally explain the reason.

 Securities and Exchange Commission

 July 21, 2025
 Response : The Fund will revise the disclosure regarding acquisitions of Secondary
Investments at a discount to the Investment Fund’s NAV in the “Investment Program—Types of Investment Structures—Secondary Investments” section of the Amendment as follows:
 Secondary Investments may be acquired at a discount to the Investment Fund’s NAV. As a result, Secondary Investments acquired at a discount may result in unrealized gains at the
time will be marked up to the most recent NAV reported by the applicable Investment Manager
when the Fund next calculates determines its daily NAV . , resulting in an
unrealized gain. Such unrealized gains will increase the Fund’s NAV and performance by the difference between the most recent NAV reported by the Investment Manager and the negotiated purchase price. Risks associated with an Investment
Manager’s reported valuations are included in “Risk Factors—Principal Risks Related to Private Equity Assets—Valuation of the Fund’s Interests in Investment Funds.” To the extent any gains on the Secondary Investment,
including the gains resulting from negotiated purchases at a discount, are realized, the tax impact to shareholders is disclosed in “Tax Aspects.”
 Leverage

 12.
 Further to Comment 33 in the Comment Letter, please supplementally confirm that any credit agreement will be
filed as an exhibit to the Registration Statement. Response : The Fund is not party to any credit agreement as
of the date of this letter and does not expect to be party to any credit agreement at the time the Amendment is filed. The Fund currently expects to be party to a credit agreement at the time it requests acceleration of the effective date of the
Registration Statement. The Fund confirms that if it becomes party to a credit agreement between the date the Amendment is filed and the effective date of the Registration Statement, following effectiveness of the Registration Statement the Fund
will include disclosure regarding any such credit agreement in the definitive prospectus filed pursuant to Rule 424(b)(3) Securities Act of 1933, as amended (the “Securities Act”), and will file the credit agreement as an exhibit in a
post-effective amendment to the Registration Statement solely to add exhibits pursuant to Rule 462(d) under the Securities Act. Risk Factors
 Principal Risks Related to Private Equity Assets—Valuations Subject to Adjustment

 13.
 The Fund’s response to Comment 48 in the Comment Letter indicates that the Fund will typically receive
updates from GPs with respect to the valuation of the Fund’s investments within 45-60 days after the end of each quarter. Please add this information to the risk factor.

 Securities and Exchange Commission

 July 21, 2025
 Response : The Fund will revise the first sentence of the above-referenced risk factor
in the Amendment as follows: The Fund determines its NAV daily based upon the quarterly valuations reported by the Investment Managers typically within 45-60 days of each quarter-end , which may not reflect
market or other events occurring subsequent to the quarter-end. The Fund will also add the following disclosure to the discussion
of fair valuation of Private Equity Assets in the “Calculation of Net Asset Value” section of the Prospectus: The Fund expects
that it will typically receive quarterly valuations of Private Equity Assets from the Investment Managers within 45-60 days after