SecProbe.io

CORRESP
 1
 filename1.htm

 Chicago

 New York

 Washington, DC

 London

 San Francisco

 Los Angeles

 Singapore

 Dallas

 Miami

 vedderprice.com
 Deborah Bielicke Eades

 Shareholder

 +1 312 609 7661

 deades@vedderprice.com

 June 9, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission Division of Investment
Management 100 F Street NE Washington, DC 20549

 Attn:
 Ms. Lisa Larkin

 Mr. Brian Szilagyi

 Re:
 Nuveen Preferred & Income Opportunities
 Fund

 Registration Statement on Form N-14

 File No. 333-286736

 Dear Ms. Larkin and Mr. Szilagyi:

 On behalf of Nuveen Preferred & Income Opportunities
Fund (the "Registrant" or the "Acquiring Fund"), we are responding to the staff's comments provided telephonically
on May 9, 2025 from Mr. Szilagyi and May 22, 2025 from Ms. Larkin, regarding the Registrant's Registration Statement on Form N-14
filed on April 24, 2025 (the "Registration Statement").

 For convenience, each comment is restated below,
with the response immediately following. To the extent responses herein reflect revised or additional disclosure, such disclosure will
be reflected in Pre-Effective Amendment No. 1 to the Registration Statement, which is being filed concurrently herewith. All capitalized
terms not defined herein have the meaning assigned to them in the Registration Statement; any page references herein refer to the Joint
Proxy Statement/Prospectus and Statement of Additional Information included in the Registration Statement.

 Accounting
Comments

 1. Comment: Explain in correspondence and disclose in the Joint Proxy/Prospectus if applicable,
if the Merger will be accounted for as an asset acquisition under ASC 805-50. If it is, please disclose if assets acquired are recorded
at fair value of consideration transferred or at fair value of assets acquired and how such value will be allocated to acquired assets.
Please cite applicable provisions of U.S. GAAP. Please incorporate into the analysis the impact of the Funds' traded market prices
and discounts and premiums to NAV. Also, please explain if any day one unrealized gains and losses will result from the acquisition post-merger.

 Response:
Registrant has considered the guidance under ASC 805-50 and AICPA TQA 6910.33. Registrant believes that the fair value of the assets
acquired, as represented by the net assets of the Target Fund calculated in accordance with valuation procedures adopted by the Board
of Trustees of the Target Fund and the Acquiring Fund in accordance with Section 2(a)(41) of the 1940 Act, is more clearly evident,
more reliably measured and the terms of the Merger provide for an exchange ratio based on the relative net asset values of the
Funds. Shares of the Funds may trade at a premium or discount to NAV, therefore measuring the Acquiring Fund's common stock on
Closing Date of the Reorganization based on the closing price on the NYSE could result in unrealized gains or losses which would not
reflect the underlying economics of the transaction for shareholders. Registrant considered, among other factors, that (i) net asset
value is calculated daily and remains the primary measurement of the value of a closed-end fund's assets; (ii) substantially
all of each Fund's portfolio is comprised of Level 1 and Level 2 securities; and (iii) the Funds utilize the same valuation
procedures. Accordingly, there will not be any day one unrealized gains and losses post-merger.

 222 North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609
7500 | F +1 312 609 5005

 Vedder
Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California,
Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.

 June 9, 2025

 Page 2

 2. Comment : On page 10 of the Joint Proxy Statement/Prospectus, in the lead in paragraph to
the comparative fee table, please clarify that the 50% management fee waiver applies to the Target Fund.

 3. Response : The Registrant has made the requested change.

 4. Comment : On page 32 of the Joint Proxy/Statement Prospectus, in the pro forma adjustment
column, please move the reference to footnote 3 to the "net assets applicable to common shares" row.

 Response :
The Registrant has made the requested change.

 5. Comment : On page 32 of the Joint Proxy/Statement Prospectus, please provide the open date
in footnote 1 to the capitalization table.

 Response :
The Registrant has made the requested change.

 6. Comment : On page B-2 of the Joint Proxy/Statement Prospectus, in the financial highlights
for the Target Fund, under "Ratios to Average Net Assets Before Reimbursement" for the period ended January 31, 2024, please
confirm the 5.87% figure for Net Investment Income (Loss). That figure does not appear in the financial highlights in the Target Fund's
semi-annual report.

 Response:
Registrant confirms the figure is accurate.

 7. Comment: On page 38 of the Statement of Additional Information, please complete the open
percentage in the second paragraph.

 Response:
The Registrant has made the requested change.

 Disclosure
Comments

 8. Comment: Please supplementally address whether the Registrant or any of its affiliates has
entered into a standstill agreement with respect to the Registrant and a third party. If so, please provide us with a copy of such agreement
or direct us to where such agreement is available on EDGAR.

 Response:
The Registrant confirms that there is no standstill agreement currently in place with respect to the Registrant.

 June 9, 2025

 Page 3

 9. Comment : Beginning on page 4 of the Joint Proxy/Statement Prospectus, please consider revising
the disclosure in the "Differences" column of the table comparing the current principal investment policies and strategies
of the Target Fund and the Acquiring Fund to explain the substantive differences more clearly between the two Funds' principal investment
policies and strategies.

 Response :
The Registrant has revised the disclosure in response to the staff's comment.

 10. Comment : On page 4 of the Joint Proxy/Statement Prospectus, the disclosure under the heading
"Sector Concentration" indicates that the Target Fund will invest at least 25% of its assets in securities of issuers in the
financial services industry, and that the Acquiring Fund will invest more than 25% of its Managed Assets in the securities of companies
principally engaged in financial services. Please revise the disclosure to clarify that these investment policies relate to industries
rather than sectors.

 Response :
The Registrant has made the requested change.

 11. Comment : Beginning on page 30 of the Joint Proxy/Statement Prospectus, under the heading
"Reasons for the Merger," please explain supplementally whether the Board considered the performance of the Funds in connection
with approving the Merger and if so, please disclose as such.

 Response :
For the staff's information, the Registrant has been advised that the Boards considered certain performance data of the Funds in
connection with approving the Merger. The disclosure included under the heading "Reasons for the Merger" has been revised
as requested.

 12. Comment: On page 36 of the Joint Proxy/Statement Prospectus, in the first sentence of the
fourth paragraph, please remove the brackets and confirm, revise or remove the bracketed statement as appropriate.

 Response :
The Registrant has made the requested change.

 13. Comment : On page 36 of the Joint Proxy/Statement Prospectus, in the last sentence of the
first paragraph under the heading "Description of Common Shares to Be Issued by the Acquiring Fund-Comparison to Target Fund-General"
states that the full text of each Fund's declaration of trust and by-laws are on file with the SEC and may be obtained as described
on page 88. Please correct this statement; the discussion on page 88 of the Joint Proxy Statement/Prospectus discusses only the Funds'
by-laws.

 Response :
The Registrant has made the requested change.

 14. Comment : Please
consider adding a lead-in to the Board Members/Nominees table beginning on page 54 indicating that Board Members and Nominees are listed
in alphabetical order.

 Response :
 The Registrant has made the requested change.

 15. Comment : Please add an additional voting box on each form of proxy to allow shareholders
to instruct the named proxies on how to vote on the adjournment of the shareholder meeting or explain supplementally why such a voting
instruction is not necessary.

 June 9, 2025

 Page 4

 Response :
Each Fund has been organized under the laws of the Commonwealth of Massachusetts as a voluntary association with transferable shares,
commonly referred to as a Massachusetts business trust. The statute governing such business trusts, Chapter 182 of the General Laws of
Massachusetts, is mainly procedural in nature, and contains no provisions relating to voting by, or meetings of, the holders of beneficial
interests in the trust. Each Fund's organizational documents consist of a declaration of trust and by-laws, and matters relating
to shareholder meetings are primarily covered in the by-laws. Section 2.12 of the by-laws of the Registrant and the Target Fund provides
that: "Any meeting of Shareholders, whether or not a quorum is present, may, by announcement by the chair of the meeting, be adjourned
with respect to one or more or all matters to be considered at the meeting from time to time to a designated time and place . . . ."
Accordingly, it is the Registrant's view that no separate shareholder vote would be required under applicable state law or the Funds'
organizational documents to adjourn the Meetings regardless of whether a quorum is present.

 16. Comment: Please add Nuveen's Proxy Voting Policy in Appendix B to the Statement of
Additional Information.

 Response:
The Registrant has added Nuveen's Proxy Voting Policy in Appendix B.

 If you have any questions
regarding these responses, please contact the undersigned at (312) 609-7661 or Jacob C. Tiedt at 312-609-7697.

 Very truly yours,

 /s/ Deborah Bielicke
Eades

 Deborah Bielicke Eades

 Shareholder

CORRESP
1
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CORRESP

 

 Thomas S. Harman

 Partner

+1.202.373.6725

 thomas.harman@morganlewis.com

April 1, 2024

 VIA EDGAR

Mr. John Kernan, Esq.

 Division of Investment Management, Disclosure
Review & Accounting Office

 U.S. Securities and Exchange Commission

 100
F Street, NE

 Washington, DC 20549

Re:
  Nuveen Closed-End Funds – Sarbanes Oxley Review

 Dear Mr. Kernan:

 This letter addresses
the comments you provided in a telephone discussion on February 14, 2024, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain regulatory filings made by our clients, the
Nuveen closed-end registered investment companies listed on Appendix A, attached hereto (each, a “Fund” or “Registrant” and, collectively, the “Funds” or “Registrants”),
each of which is advised by Nuveen Fund Advisors, LLC (the “Adviser”). Each comment is shown below followed by management’s response.

1.
 Comment: In response to Item B.20 of Form N-CEN, filed for the period
ended July 31, 2023, the Nuveen Floating Rate Income Fund (”JFR”) reported a material change in method of valuation impacting CMBS, CMOs and CLOs. In correspondence, please explain the nature of the changes, the reasons for making
them and the omission of disclosure of the same pursuant to ASC 820-10-50-2.

Response: As part of an initiative to implement a single valuation policy for both the Nuveen and TIAA-CREF Fund
complexes (collectively, the “Complexes”), the Adviser reviewed the pricing conventions used by asset class given that different valuation techniques had been used historically for certain asset classes within the Complexes.

Morgan, Lewis & Bockius LLP

1111 Pennsylvania Avenue, NW

 Washington, DC 20004

 United States

+1.202.739.3000

+1.202.739.3001

 Mr. John Kernan, Esq.

 April 1,
2024

  Page
 2

 

 The Adviser determined that mid pricing was more consistent with historical
transaction prices, reflected a more precise measure of estimate and was more representative of fair value for CMBS, CMOs and CLOs. Accordingly, effective September 1, 2022, the Adviser determined to change from a bid to mid pricing convention
for CMBS, CMOs and CLOs. This change was applied prospectively consistent with accounting guidance under ASC 820-10-35-25 and ASC
820-10-35-26.

In preparing the Funds’ financial statements, including those of JFR, the Adviser considered the requirements of ASC 250-10-50-5, and determined that disclosure for the change in valuation technique from a bid to mid pricing convention for CMBS, CMOs
and CLOs was not required. The Adviser also considered the requirements of ASC 820-10-50-2 and determined that the change in
valuation technique, and the reasons for making the change, were not material to the Funds’ financial statements and therefore did not require disclosure for the following reasons:

•

 As of the periods ended July 31, 2022, and September 1, 2022, a change from bid to mid pricing convention
for CMBS, CMOs and CLOs was deemed immaterial to the NAV of JFR, as well as the NAVs of the other Funds, and therefore the Adviser concluded that the change in valuation technique was not required per ASC 820-10-50-2.

•

 The valuation disclosure within the Notes to Financial Statements does not describe in detail the valuation
techniques used for individual securities or sub-asset types as there is expected to be some variability depending on the facts and circumstances relevant for individual securities, but rather discloses the
overall valuation methodology and factors considered in how fair value estimates are determined.

•

 The inputs and assumptions of such valuation techniques used in determining both the bid and mid prices for
securities are substantially the same and the use of both bid and mid pricing conventions is reasonable for determining the fair value of these securities held in JFR, as well as the other Funds, which have been applied consistently.

•

 The use of bid or mid pricing conventions is but one factor considered by the Adviser when determining the fair value
of securities. Other considerations include but are not limited to: the pricing services used by the Fund, price exception reviews including price tolerance reports comparing the current day’s price with the prior day’s price, acid test
reports comparing executed trade levels with the pricing vendor’s price, price comparison reports comparing the primary pricing vendor’s price with that of secondary or alternative pricing vendors, and unchanged price reports, for example.

 Mr. John Kernan, Esq.

 April 1,
2024

  Page
 3

 

 For the reasons set forth above, the Adviser’s response to Item B.20 of Form N-CEN should have been “No” with respect to JFR, as well as the other Funds.

2.
 Comment: The SEC Staff notes that disclosure included in the Notes to Financial Statements titled “6. Fund
Shares” states that the fair value of JFR’s Taxable Fund Preferred Shares (“TFPs”) while in Variable Rate Mode (“VRM”) are expected to approximate their liquidation preference. Please describe the impact of heightened
interest rate and spread volatility on the fair value of TFPs during the fiscal year ended July 31, 2023. In your response, please (a) describe the valuation procedures undertaken to assess the fair value of the TFPs and provide the
results in dollars of the Adviser’s determination of the fair value of the TFPs as of January 31, 2023, and July 31, 2023, and (b) explain the omission of disclosure required by ASC 820-10-50-2E, which is applicable to assets and liabilities not measured at fair value in the Statement of Assets and Liabilities but for which fair value is disclosed,
and includes disclosure of leveling valuation techniques and inputs.

 Response: TFPs while
in VRM (“TFP-VRM”) are variable rate securities that pay a monthly dividend which is determined by a fixed spread (e.g., 1.00%) plus a short-term index (i.e., Secured Overnight Financing Rate
(SOFR)). The “holding or commitment period” of a TFP-VRM is typically very short. The holding period is initially two years and eventually converts to a 60-day
Evergreen tenor, meaning so long as either party does not initiate a tenor maturity date, the period will reset to a constant 60 days each day.

The Adviser determined that fair value of a TFP-VRM is equivalent to the liquidation
preference of a TFP-VRM for the following reasons:

•

 Variable rate: The variable rate on the security negates the impact of market interest rates. Because the base rate
used to calculate that month’s dividend rate resets each month, it is largely immune to changes in overall interest rates. The dividend rate paid will either increase or decrease each month based upon the then-current on-market rate.

•

 Credit Spread: The initial valuation of TFP-VRM is largely based upon an on-market credit spread. Since the inception of TFP-VRM, the credit spread has been stable and remained within a 0.05% to 0.15% range. A differential of 15 basis points for an
entire year would only change the valuation by ~0.1% (i.e., 99.9% or 100.1%). An on-market credit spread would only materially change in the event of material risk of
non-payment of liquidation preference (i.e., “default”). Additionally, TFP-VRM have kept a category rating of AA from

 Mr. John Kernan, Esq.

 April 1,
2024

  Page
 4

 

 Nationally Recognized Statistical Ratings Organization and maintain overall asset
coverage requirements making risk nearly non-existent.

•

 Tenor: TFP-VRM do not have a long “tenor/maturity/holding period,”
which increases the potential for having greater valuation dispersion. TFP-VRM are very short-dated, meaning that the potential for long periods of time where the current fixed spread does not approximate on-market value is remote. Additionally, under an Evergreen tenor either party has ability to take steps to re-align fixed spreads to
on-market value.

 For the reasons described above, the Adviser has
determined:

(a)
 The variance of TFP-VRM’s valuation as of January 31, 2023, and
July 31, 2023, was minimal, and, therefore, approximated its liquidation preference of $100,000,000 and $285,000,000, respectively. Because TFP-VRM is a variable rate security, its credit spread reflects
minimal overall volatility and the overall holding tenor (if there were a change to “on-market rate”) is short. As such, heightened interest rate and spread volatility did not impact the
Adviser’s determination that the fair value of TFP-VRM approximated the liquidation preference during the fiscal periods ended January 31, 2023, and July 31, 2023.

(b)
 ASC
820-10-50-2E applies to assets and liabilities not measured at fair value in the Statement of Assets and Liabilities but for
which fair value is disclosed. Here, the fair value of a TFP-VRM is equivalent to the liquidation preference of a TFP-VRM, and the liquidation preference of TFP-VRM is disclosed in the Fund’s Statement of Assets and Liabilities. Therefore, TFP-VRM are not subject to the requirements of ASC 820-10-50-2E. However, the Registrant will continue to include the following disclosure immediately below the fair value leveling tables in the “3. Investment
Valuation and Fair Value Measurements” section of the Notes to Financial Statements:

 The Funds hold
liabilities in preferred shares, where applicable, which are not reflected in the tables above. The fair values of the Funds’ liabilities for preferred shares approximate their liquidation preference. Preferred shares are generally classified
as Level 2 and further described in these Notes to Financial Statements.

 Additionally, on a prospective basis, the
disclosure in “6. Fund Shares” within the Notes to Financial Statements for the Funds that hold TFP-VRM, specifically the disclosure describing how TFP Shares may be redeemed, will include a
reference to the 60-day Evergreen tenor. In addition, the description of the fair value of TFP-VRM set forth under “6. Fund Shares” will be replaced with the
following:

 Mr. John Kernan, Esq.

 April 1,
2024

  Page
 5

 

 The fair value of TFP Shares while in VRM are expected to approximate their
liquidation preference so long as the fixed “spread” on the shares remains roughly in line with the “spread” being demanded by investors on instruments having similar terms in the current market. During the current reporting
period, the Adviser determined that the fair value of the shares approximated their liquidation preference.

 * * * * *

If you have any additional questions or comments, please do not hesitate to contact me at (202) 373-6725.

Sincerely,

/s/ Thomas S. Harman

Thomas S. Harman

cc:

 K. Michael Carlton, Esq.

 E. Scott Wickerham, Vice President and Funds’ Controller (Principal Financial Officer)

 John McCann, Vice President and Assistant Secretary of the Funds; Managing Director and Associate General
Counsel

 Brett E. Black, Chief Compliance Officer and Managing Director of the Funds

 Eric Fess, Chapman & Cutler, LLP, Counsel to the Independent members of the Board of
Directors/Trustees of the Funds

 Robert Zutz, K&L Gates LLP, Counsel to the Independent members of the Board of Directors/Trustees of the
Funds

 Mr. John Kernan, Esq.

 April 1,
2024

  Page
 6

 

 Appendix A

 CIK

File #

  Registrant Name

 FYE

 Reviewed

1

 0001137887

811-10345

 Nuveen Municipal Credit Income Fund

10/31/2023

2

 0001083839

811-09297

 Nuveen Quality Municipal Income Fund

10/31/2023

3

 0001450445

811-22253

 Nuveen AMT-Free Municipal Value Fund

10/31/2023

4

 0001195737

811-21213

 Nuveen AMT-Free Quality Municipal Income Fund

10/31/2023

5

 0000830271

811-05488

 Nuveen Municipal Income Fund, Inc.

10/31/2023

6

 0001793129

811-23489

 Nuveen Dynamic Municipal Opportunities Fund

10/31/2023

7

 0001266585

811-21449

 Nuveen Municipal High Income Opportunity Fund

10/31/2023

8

 0001774342

811-23440

 Nuveen Municipal Credit Opportunities Fund

10/31/2023

9

 0001090116

811-09475

 Nuveen AMT-Free Municipal Credit Income Fund

10/31/2023

10

 0000812801

811-05120

 Nuveen Municipal Value Fund, Inc.

10/31/2023

11

 0001861115

811-23669

 Nuveen Multi-Asset Income Fund

12/31/2022

12

 0001777482

811-23445

 Nuveen Enhanced High Yield Municipal Bond Fund

3/31/2023

13

 0000897419

811-07484

 Nuveen Massachusetts Quality Municipal Income Fund

5/31/2023

14

 0000899782

811-07616

 Nuveen Missouri Quality Municipal Income Fund

5/31/2023

15

 0001607997

811-22967

 Nuveen Minnesota Quality Municipal Income Fund

5/31/2023

16

 0000897421

811-07490

 Nuveen Virginia Quality Municipal Income Fund

5/31/2023

17

 0000838131

811-05642

 Nuveen Multi-Market Income Fund

6/30/2023

18

 0001276533

811-21494

 Nuveen Floating Rate Income Fund

7/31/2023

19

 0001547994

811-22699

 Nuveen Preferred and Income Term Fund

7/31/2023

20

 0001176433

811-21137

 Nuveen Preferred & Income Securities Fund

7/31/2023

21

 0001679033

811-23198

 Nuveen Preferred and Income Fund

7/31/2023

22

 0001865389

811-23704

 Nuveen Variable Rate Preferred & Income Fund

7/31/2023

23

 0001227476

811-21333

 Nuveen Credit Strategies Income Fund

7/31/2023

24

 0001216583

811-21293

 Nuveen Preferred & Income Opportunities Fund

7/31/2023

CORRESP
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Nuveen Preferred & Income Opportunities Fund

 Chicago

New York

Washington, DC

London

San Francisco

Los Angeles

Singapore

Dallas

Miami

June 29, 2023

vedderprice.com

 Adam S. Goldman

Associate

 +1 312
609 7731

 agoldman@vedderprice.com

 VIA EDGAR

 U.S. Securities and
Exchange Commission

 Division of Investment Management

 100 F Street NE

Washington, DC 20549

Attn:
 Ms. Valerie Lithotomos

Re:
 Nuveen Preferred & Income Opportunities Fund (the “Registrant”)

 File No. 811-21293

To the Commission:

 On behalf of the Registrant, this letter is in
response to the comments provided telephonically by the staff of the U.S. Securities and Exchange Commission to Vedder Price P.C. on June 22, 2023 with respect to the Preliminary Proxy Statement on Schedule 14A filed by the Registrant on
June 16, 2023 (the “Proxy Statement”) in connection with the proposed merger of each of Nuveen Preferred and Income Fund and Nuveen Preferred & Income Securities Fund with and into a wholly-owned subsidiary of the Registrant.
Set forth below are the staff’s comments and the Registrant’s responses. The Registrant is filing a Definitive Proxy Statement on Schedule 14A concurrently herewith to complete missing information and to address the comments of the staff.

1.
 Comment:    We note that a Form
N-14 registration statement has been filed by the Registrant in connection with the proposed mergers (the “Registration Statement”) and that the staff has provided disclosure and accounting comments
on that filing. Please ensure that changes made to the Registration Statement in response to those comments, as applicable, are also reflected in the Definitive Proxy Statement to be filed by the Registrant.

 Response:    For the staff’s information, the Registrant confirms that
appropriate conforming changes will be reflected in the Definitive Proxy Statement to be filed by the Registrant.

2.
 Comment:  Please confirm supplementally that the Registration Statement includes
an undertaking to file the executed opinion of counsel supporting the tax matters discussed in the Registration Statement with the Securities and Exchange Commission following the closing of the mergers.

 Response:  The Registrant confirms that this undertaking is provided in Item 17(3) of
Part C of the Registration Statement.

3.
 Comment:   Please ensure that references to below investment grade
securities disclose that such securities are commonly referred to as “high yield” or “junk” bonds.

 222 North LaSalle
Street  |  Chicago, Illinois 60601  |  T +1 312 609 7500   |   F +1 312 609 5005

 Vedder Price P.C. is affiliated with Vedder Price LLP, which
operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.

 June 29, 2023

  Page
 2

 Response:    The Registrant has revised the disclosures in response to the
staff’s comment.

 If you have any questions regarding this response, please contact the undersigned at (312) 609-7731 or Deborah Bielicke Eades at (312) 609-7661.

 Sincerely,

/s/ Adam S. Goldman

 Adam S. Goldman

Associate

cc:
 Deborah Bielicke Eades, Shareholder, Vedder Price P.C.

CORRESP
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CORRESP

 April 9, 2021

Ms. Megan Miller

 U.S. Securities and Exchange
Commission

 Division of Investment Management, Disclosure Review & Accounting Office

100 F Street N.E.

 Washington DC 20549

Nuveen Closed-End and Open-End Funds – Sarbanes Oxley Review

Dear Ms. Miller,

 This letter addresses the comments you
provided in a telephone discussion on March 5, 2021, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain regulatory filings made by the Nuveen closed-end and
open-end registered investment companies listed on Appendix A attached hereto, (each a “Fund” or “Registrant” and collectively, the “Funds” or “Registrants”), and advised by Nuveen Fund Advisors, LLC (the
“Adviser”). Each comment is shown below followed by management’s response.

1.
 Comment: Please include gains and losses on 17a-7 transactions going forward. Please
refer to the guidance in the January 19, 2016 AICPA expert panel meeting minutes, which provides examples of qualitative and quantitative disclosures for inter-fund transactions (under section 17a-7 of the Investment Company Act of 1940). The
SEC Staff notes Nuveen California Municipal Value Fund, Inc. (NCA) and Nuveen California AMT-Free Quality Municipal Income Fund (NKX) for reference.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds will disclose the realized
gains and losses recognized in connection with 17a-7 transactions. The gain and loss amounts will be added to the Funds’ current disclosure for 17-a transactions, which is within Note 7. Management Fees and Other Transactions with
Affiliates, Other Transactions with Affiliates of the notes to financial statements.

2.
 Comment: Please explain how the Funds met the disclosure requirements for disclosure of
distributable earnings on a tax basis in the notes to financial statements and how it aligns with what is presented in the statement of assets and liabilities as required by Accounting Standards Codification (“ASC”) 946-20-50-11,
Components of Capital and Distributable Earnings, which requires all investment companies to disclose only two components of capital on the balance sheet: shareholder capital and distributable earnings. The components of distributable earnings, on a
tax basis, shall be disclosed in a note to financial statements. This information enables investors to determine the amount of accumulated and undistributed earnings they potentially could receive in the future and on which they could be treated.
The SEC Staff notes the Nuveen California and New York closed-end Funds for reference.

 Response: The
Funds met the requirements of ASC 946-20-50-11 by disclosing the respective components of distributable earnings on a tax basis within Note 6. Income Tax Information of the notes to financial statements. The components of distributable
earnings on a tax basis consist of net unrealized appreciation/(depreciation), undistributed net tax-exempt income, undistributed net ordinary income, undistributed net long-term capital gains, and unused capital loss carry forwards, where
applicable. These amounts align with the distributable earnings on the statement of assets and liabilities after adjusting for the income distribution that

 Page 1 of 11

was declared on February 3, 2020 and paid on March 2, 2020 as disclosed in the footnote under the tax components of undistributed income table, which read as follows in the
February 29, 2020 annual report for the Nuveen California and New York closed-end Funds:

1
 Undistributed net tax-exempt income (on a tax basis) has not been reduced for the dividend declared on
February 3, 2020, and paid on March 2, 2020.

3.
 Comment: For Funds that have liabilities for inverse floaters and preferred shares,
please see ASC 820-10-50-2e or Section 7.9.7 of the 2019 Audit Guide, which requires that for each class of assets and liabilities not measured at fair value in the statement of financial position but for which the fair value is disclosed, a
reporting entity shall disclose the information required by paragraph ASC 820-10-50-2(b), (bbb)(1), and (h).

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the following disclosure will be
included within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements, and will immediately follow the tables that summarize the fair values of the Funds’ investments as of the end of the reporting
period:

 The Funds hold liabilities in floating rate obligations and preferred shares, where applicable, which are not reflected in the
tables above. The fair values of the Funds’ liabilities for floating rate obligations approximate their liquidation values. Floating rate obligations are generally classified as Level 2 and further described in Note 4. Portfolio Securities
and Investments in Derivatives. The fair values of the Funds’ liabilities for preferred shares approximate their liquidation preference. Preferred shares are generally classified as Level 2 and further described in Note 5. Fund
Shares.

4.
 Comment: The SEC Staff notes that in certain Funds’ notes to financial statements the
Funds may enter into a shortfall agreement for inverse floaters and they also describe certain commitments and contingencies for preferred shares. Please consider adding a separate line item in the statement of assets and liabilities relating to
these commitment and contingencies. Please refer to Regulation S-X (“Reg S-X”) §210.6-04.15.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, a “Commitments and
Contingencies” line item will be added to the Funds’ statement of assets and liabilities, where applicable. This line item will also direct the reader to the applicable footnote disclosure within the notes to financial statements, which
will generally read as follows, and will be updated as appropriate:

 Commitments and Contingencies

In the normal course of business, each Fund enters into a variety of agreements that may expose the Fund to some risk of loss. These could
include recourse arrangements for certain TOB Trusts and certain agreements related to preferred shares, which are each described elsewhere in these Notes to Financial Statements. The risk of future loss arising from such agreements, while not
quantifiable, is expected to be remote. As of the end of the reporting period, the Funds did not have any unfunded commitments.

 From
time to time, the Funds may be a party to certain legal proceedings in the ordinary course of business, including proceedings relating to the enforcement of the Funds’ rights under contracts. As of the end of the reporting period, the Funds are
not subject to any material legal proceedings.

 Page 2 of 11

5.
 Comment: To the extent a Fund holds positions in both long and short futures contracts,
please break them out into two separate tables. The SEC Staff notes the Nuveen Multi-Market Income Fund (JMM) and Nuveen Strategic Income Fund for reference.

Response: Beginning with the Funds’ regulatory filings dated March 31, 2021, the Funds will include a tabular
disclosure for each of the long and short futures contracts in their portfolios of investments, where applicable.

6.
 Comment: On a go forward basis, please include a reconciliation between the statement of
assets and liabilities and statement of cash flows when the statement of assets and liabilities includes more than one line item for cash or restricted cash equivalents. Please refer to ASC 230-10-50-8, Restrictions on Cash and Cash Equivalents,
which explains when cash, cash equivalents, and amounts generally described as restricted cash or restricted cash equivalents are presented in more than one line item within the statement of financial position, an entity shall, for each period that
a statement of financial position is presented, present on the face of the statement of cash flows or disclose in the notes to the financial statements, the line items and amounts of cash, cash equivalents, and amounts generally described as
restricted cash or restricted cash equivalents reported within the statement of financial position. The amounts, disaggregated by the line item in which they appear within the statement of financial position, shall sum to the total amount of cash,
cash equivalents, and amounts generally described as restricted cash or restricted cash equivalents at the end of the corresponding period shown in the statement of cash flows. This disclosure may be provided in either a narrative or a tabular
format. The SEC Staff notes the Nuveen Multi-Market Income Fund (JMM), Nuveen California High Yield Fund, Nuveen Preferred & Income Opportunities Fund (JPC), Nuveen Preferred and Income Term Fund (JPI), Nuveen Preferred & Income
Securities Fund (JPS) and Nuveen Preferred and Income 2022 Term Fund (JPT) for reference.

 Response:
Beginning with the Funds’ shareholder reports dated March 31, 2021, when cash, cash equivalents, foreign currency, and restricted cash are presented in more than one line item on the statement of assets and liabilities, a Fund will include
a reconciliation of the total in the statement of cash flows to the related captions on the statement of assets and liabilities. The following is an example of how such disclosure will appear using Nuveen Preferred & Income Opportunities
Fund’s (JPC) annual report for the fiscal year ended July 31, 2020:

 The following table provides a reconciliation of cash and
cash collateral at brokers to the statement of assets and liabilities:

JPC

   Cash

$
243,503

   Cash collateral at brokers for investments in futures

439,993

   Cash collateral at brokers for investments in
swaps

16,942,853

   Total cash and cash collateral at
brokers

$
  17,626,349

 Page 3 of 11

7.
 Comment: Please include interest payable with the value of reverse repurchase
agreements on a go forward basis as required by Reg S-X §210.4-08(m)(1). The SEC Staff notes Nuveen Mortgage and Income Fund (JLS), Nuveen Preferred & Income Opportunities Fund (JPC), and Nuveen Build American Bond Fund (NBB) for
reference.

 Response: Beginning with the Funds’ shareholder reports dated March 31, 2021,
the Funds’ reverse repurchase agreements presented on the statement of assets and liabilities will include the accrued interest payable associated with those reverse repurchase agreements. The following is an example using Nuveen
Preferred & Income Opportunities Fund’s (JPC) annual report for the fiscal year ended July 31, 2020:

 Liabilities

 Reverse repurchase agreements, including accrued interest

$
10,063,830

8.
 Comment: For Nuveen Multi-Market Income Fund (JMM), it appears that some of the Fund’s
investments may pay interest based on London Interbank Offered Rate (“LIBOR”). Please explain if the elimination of LIBOR is a principle risk of the Fund and how the discontinuation can impact the value of the Fund’s holdings. If the
discontinuation of LIBOR will impact the Fund, please update the Fund’s disclosure to discuss how this will affect the Fund’s investments. Please refer to the SEC press release dated July 12, 2019, SEC Staff Publishes Statement
Highlighting Risks for Market Participants to Consider As They Transition Away from LIBOR (the “SEC LIBOR Statement”).

Response: Management has determined that the elimination of LIBOR is not a principal risk for Nuveen Multi-Market Income Fund
(JMM), however, management is continuously evaluating the potential effect a discontinuation of LIBOR could have on the Funds’ investments. At this time, management is not anticipating any significant impacts to the Funds’ investments, and
as such, beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ will enhance their existing disclosure around LIBOR within Note 2. Significant Accounting Policies of the notes to financial statements as
follows (new disclosure underlined):

 Reference Rate Reform

In March 2020, FASB issued Accounting Standards Update (“ASU”) 2020-04, Reference Rate Reform: Facilitation of the Effects of
Reference Rate Reform on Financial Reporting. The main objective of the new guidance is to provide relief to companies that will be impacted by the expected change in benchmark interest rates, when participating banks will no longer be required to
submit London Interbank Offered Rate (LIBOR) quotes by the UK Financial Conduct Authority (FCA). The new guidance allows companies to, provided the only change to existing contracts are a change to an approved benchmark interest rate, account for
modifications as a continuance of the existing contract without additional analysis. For new and existing contracts, the Funds may elect to apply the amendments as of March 12, 2020 through December 31, 2022. Management has not yet
elected to apply the amendments, is continuously evaluating the potential effect a discontinuation of LIBOR could have on the Funds’ investments and has currently determined that it is unlikely the ASU’s adoption will have a significant
impact on the Funds’ financial statements and various filings,

 Page 4 of 11

9.
 Comment: For Funds with reverse repurchase agreements, please consider adding to the risk
disclosures that a Fund posts and receives securities and cash as collateral with a market value in excess of the repurchase price to be paid or received by a trust upon maturity of the transaction. Upon a bankruptcy or insolvency of a counterparty,
a Fund is considered to be an unsecured creditor with respect to excess collateral and as such the return of excess collateral may be delayed.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ disclosure relating to
reverse repurchase agreements that is included within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements will be enhanced to read as follows:

The Fund may enter into a reverse repurchase agreement with brokers, dealers, banks or other financial institutions that have been determined
by the Adviser to be creditworthy. In a reverse repurchase agreement, a Fund sells to the counterparty a security that it holds with a contemporaneous agreement to repurchase the same security at an agreed-upon price and date, reflecting the
interest rate effective for the term of the agreement. It may also be viewed as the borrowing of money by the Fund. Cash received in exchange for securities delivered, plus accrued interest payments to be made by the Fund to a counterparty, are
reflected as a liability on the Statement of Assets and Liabilities. Interest payments made by the Fund to counterparties are recognized as a component of “Interest expense and amortization of offering costs” on the Statement of
Operations.

 In a reverse repurchase agreement, the Fund retains the risk of loss associated with the sold security. In order to minimize
risk, the Fund pledges and/or segregates securities and cash as collateral with a fair value at least equal to its purchase obligations under these agreements (including accrued interest). Reverse repurchase agreements also involve the risk that the
purchaser fails to return the securities as agreed upon, files for bankruptcy or becomes insolvent. Upon a bankruptcy or insolvency of a counterparty, the Fund is considered to be an unsecured creditor with respect to excess collateral and as such
the return of excess collateral may be delayed. A Fund will pledge assets determined to be liquid by the Adviser to cover its obligations under reverse repurchase agreements.

10.
 Comment: Please include LIBOR transition risks in the Funds’ Form N-CSR
(“N-CSR”) filings on a go forward basis. The SEC Staff notes that there is nothing about transition risk in the Funds’ current disclosure. Please refer to the SEC LIBOR Statement. The SEC Staff notes Nuveen Senior Income Fund (NSL),
Nuveen Floating Rate Incom

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Nuveen Investments

 June 29, 2018

Mr. Jason Fox

 U.S. Securities and
Exchange Commission

 Division of Investment Management, Insured Investments Office

100 F Street N.E.

 Washington DC 20549

Re: Nuveen Closed-End and Open-End Funds – Sarbanes Oxley Review

 Dear Mr. Fox:

 This
letter addresses the comments Ms. Sheila Stout provided in a telephone discussion on April 17, 2018, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain
regulatory filings made by the Nuveen closed-end and open-end registered investment companies listed on Appendix A attached hereto, (each a “Fund” and
collectively, the “Funds”), and advised by Nuveen Fund Advisors, LLC (the “Adviser”). Each comment is shown below followed by our response.

1)
 Comment: For certain Nuveen municipal
closed-end funds (for example, Nuveen Municipal Income Opportunity Fund, Nuveen AMT-Free Municipal Value Fund and others) Note 4 within the Notes to Financial Statements
explains, “Costs incurred by the Fund in connection with its Shelf Offering were recorded as a deferred charge and recognized as a component of “Deferred offering costs” on the Statement of Assets and Liabilities. The deferred asset
is reduced during the one-year period that additional shares are sold by reducing the proceeds from such sales and recognized as a component of “Proceeds from shelf offering, net of offering costs”
on the Statement of Changes in Net Assets. Any remaining deferred charges at the end of the one-year life of the Shelf Offering period will be expensed accordingly, as well as any additional Shelf Offering
costs the Fund may incur. As Shelf Offering costs are expensed they are recognized as a component of “Other expenses” on the Statement of Operations.” Please reference the guidance under Generally Accepted Accounting Principles
(“GAAP”) for this accounting treatment.

 Response: The Funds
follow the guidance set forth in Section 8.31 of the September 2017 AICPA Audit & Accounting Guide – Investment Companies which refers to “Costs Incurred in Shelf Registration” (AICPA, Technical Questions and Answers)
Section 4110.10, which reads as follows:

 Some
closed-end funds and business development companies offer stock through shelf registration statements. According to Q&A section 4110.10, “Costs Incurred in Shelf Registration” (AICPA, Technical
Questions and Answers), legal and other fees incurred for a stock issue under a shelf registration should be capitalized as a prepaid expense. When securities are taken off the shelf and sold, a portion of the costs attributable to the securities
sold should be charged against paid-in-capital. Any subsequent costs incurred to keep the filing “alive” should be charged to expense as incurred. If the
filing is withdrawn, the related capitalized costs should be charged to expense.

 As such, the costs incurred with
registering shares are capitalized as a deferred asset and charged against paid-in-capital on a pro-rata basis as shares are
sold. Any remaining deferred asset balance associated with “unsold shares” is expensed at the end of the program period (one year from the effective date of the filing). Costs incurred in filing Form 486B, if necessary, are expensed.

2)
 Comment: A majority of the Nuveen closed-end
and open-end municipal Funds hold securities with optional call provisions, which means the bonds can be redeemed or paid off by the issuer prior to the bonds’ maturity date. Since the bonds can be called
at any time, they are more risky for investors than non-callable bonds because the investor bears the risk of loss of future interest payments. Please consider adding additional disclosure in the Funds’
prospectus and/or shareholder reports regarding such interest rate risk.

Response: We have reviewed the prospectus disclosures for a sample of municipal open-end funds and municipal closed-end Funds. We have found that the disclosure on this point in all cases was adequate. The relevant disclosure from the open-end Funds’ summary prospectuses that we found (in this case the summary prospectus for Nuveen All-American Municipal Bond Fund) was:

Call Risk — If, during periods of falling interest rates, an issuer calls higher-yielding municipal
bonds held by the Fund, the Fund may have to reinvest in securities with lower yields, which may adversely impact the Fund’s performance.

The somewhat more expansive disclosure in the open-end Funds’ full statutory
prospectus (again, for Nuveen All-American Municipal Bond Fund):

Call risk: Municipal bonds are subject to call risk. Many bonds may be redeemed at the option of the
issuer, or “called,” before their stated maturity date. In general, an issuer will call its bonds if they can be refinanced by issuing new bonds which bear a lower interest rate. A fund is subject to the possibility that during periods of
falling interest rates, a bond issuer will call its high yielding bonds. A fund would then be forced to invest the unanticipated proceeds at lower interest rates, resulting in a decline in the fund’s income.

The disclosure from a typical prospectus for a closed-end municipal fund (taken from
the January 16, 2016 prospectus from Nuveen Municipal 2021 Target Term Fund) is as follows:

 Call
Risk. The Fund may invest in securities that are subject to call risk. Debt instruments may be redeemed at the option of the issuer, or “called,” before their stated maturity or redemption date. In general, an issuer will call its debt
instruments if they can be refinanced by issuing new instruments which bear a lower interest or dividend rate. The Fund is subject to the possibility that during periods of falling interest rates, an issuer will call its high yielding debt
instruments. The Fund would then be forced to invest the unanticipated proceeds at lower interest or dividend rates, resulting in a decline in the Fund’s income.

We are reviewing the shareholder reports of the affected funds and expect to add disclosure about call risk wherever it does not already
appear. From the survey we have conducted so far, the open-end fund shareholder reports mention call risk, while closed-end fund shareholder reports do not.

3)
 Comment: For Nuveen Municipal High Income Opportunity Fund (NMZ), the Fund’s
website discloses, “No more than 10% of the fund’s managed assets may be invested in municipal securities rated at or below B3/B-, or that are unrated but judged by the manager to be of comparable
quality.” However, the Fund’s October 31, 2017 annual report indicates that more than 25% of the Fund’s total investment exposure is in non-rated securities. Please confirm that no more
than 10% of the Funds’ managed assets are invested in securities rated below single B.

 Response: As of October 31, 2017, NMZ’s portfolio
contained 7.1% (as a % of managed assets) of securities rated B3/B- or lower, plus 24.6% (as a % of managed assets) of securities that were unrated but judged by the manager to be of comparable quality, for a
total of 31.7% (as a % of managed assets). Please note that this particular policy was misstated in the October 31, 2017 annual report. In the course of documenting the proposal and approval of a change to NMZ’s investment policies at a
different part of the credit curve (the rules relating to the maximum and minimum percentages of managed assets that could or must be invested in securities that were investment grade and below-investment grade), the internal and Board memos
regarding the change misstated the policy regarding the CCC/single B dividing line. The longstanding policy of NMZ was that the Fund could invest no more than 10% of managed assets in securities rated below
B3/B-; these two memos misstated that policy to read that the Fund could invest no more than 10% of its managed assets in securities rated “at or” below B3/B-.
That misstated policy was utilized by those individuals who maintain the website and prepare the shareholder reports. We later determined that the actual “below B3/B-” policy had not actually
changed, because its inclusion (in misstated form) in the internal and Board memos was dictum – that is, it was not germane to the policy change proposal or decision, and so the Board never specifically approved the misstated B3/B- policy, so that in turn that policy, as misstated, never took effect.

4)
 Comment: The prospectus for Nuveen Short-Term Municipal Bond Fund states that,
“The Fund may utilize the following derivatives: futures contracts and options on futures contracts. The Fund may use these derivatives in an attempt to manage market risk, credit risk and yield curve risk, and to manage the effective maturity
or duration of securities in the Fund’s portfolio.” In addition, the Fund has disclosed derivatives as both a “principal investment strategy” and a “principle risk,” however, the Fund has not utilized derivatives in the
past three fiscal years. Please consider not disclosing derivative instruments as “principal” in future filings.

Response: Both Nuveen management and the Fund’s investment team consider the use of derivative instruments
to be one of the Fund’s principal investment strategies, and we respectfully decline to remove derivatives-related policies disclosures from the referenced sections of the Fund prospectus. As disclosed, the Fund may use derivatives to manage
interest rate risk, yield curve risk, and credit risk, and to manage the effective duration of securities in the Fund’s portfolio. However, market conditions over the recent years have been marked by historically low interest rates, a
relatively flat yield curve, and a relatively benign credit market. In these conditions over this period, the Fund’s investment team has generally determined that the use of all or most derivative instruments was not necessary for the
management of these risks. If and when market conditions change, however, either or both management and/or the investment team may decide to utilize derivatives for the stated purposes. As such, management continues to regard the described
derivatives to be a component of the Fund’s principal investment strategies.

5)
Comment: For Nuveen Municipal Trust, are the fee waivers/expense reimbursements received by a Fund subject to recoupment? In addition, please confirm whether the Adviser has any agreements in
place to recoup fee waivers and/or expense reimbursements.

 Response: For certain Funds,
the Adviser has an agreement in place to waive fees and/or reimburse expenses as stated in the Fund’s prospectus and/or statement of additional information. The Adviser does not have any agreements in place to recoup fee waivers/expenses
reimbursed in prior fiscal periods from any Nuveen open-end Fund (including those Funds comprising Nuveen Municipal Trust), closed-end Fund or exchange-traded Fund.

6)
 Comment: For certain municipal closed-end
Funds, Note 4 of the Notes to Financial Statements for Institutional MuniFund Term Preferred Shares (“iMTP Shares”) discloses that “costs incurred by the Fund in connection with its offering of iMTP Shares were recorded as a deferred
charge, which are

amortized over the life of the shares and are recognized as components of “Institutional MuniFund Term Preferred (“iMTP”) Shares, net of deferred offering costs” on the
Statement of Assets and Liabilities. Please ensure that the disclosure included within the Notes to Financial Statements is consistent with Financial Accounting Standards Board, Accounting Standards Update (“ASU”) 2015-03 (“ASU 2015-03”): Interest-Imputation of Interest, which requires debt issuance costs to be presented in the Statement of Assets and Liabilities as a direct
deduction from the carrying amount of the associated debt liability.

 Response: The
Statement of Assets and Liabilities recognizes a Fund’s iMTP Shares as components of “Institutional MuniFund Term Preferred (“iMTP”) Shares, net of deferred offering costs” as required by ASU
2015-03. However, we do recognize that a Fund’s outstanding iMTP shares are disclosed at their liquidation preference within Note 4 of the Notes to Financial Statements to allow a reader of the financial
statements to easily reconcile such amounts to the outstanding amount of iMTP Shares disclosed within the (1) Fund Leverage section, (2) parenthetical disclosure on the Statement of Assets and Liabilities and (3) aggregate amount
outstanding of iMTP Shares at the end of period within the Financial Highlights. To be consistent with the presentation on the Statement of Asset and Liabilities, we are adding the “Liquidation Preference, Net of Deferred Offering
Costs” amount to the disclosure describing the amount of iMTP Shares outstanding as of the end of the reporting period. Such additional disclosure will also be added to Note 4 of the Notes to the Financial Statements for any Fund impacted by
ASU 2015-03.

7)
 Comment: For Nuveen Minnesota Municipal Bond Fund, the Fund’s
May 31, 2017 annual report indicates that the Fund had more than 20% of its total investment exposure in below investment grade (“junk”) bonds. Please confirm that the Fund is in compliance with its investment
policy.

 Response: The Nuveen Minnesota Municipal Bond Fund (FMN) was indeed above the
maximum 20% of total investment exposure in below investment grade bonds as of May 31, 2017. This policy is one that applies “at time of purchase.” FMN “passively” went above the 20% threshold in November of the previous
year. FMN made no purchases of below investment grade bonds between its last purchase of below-investment grade bonds prior to climbing above the 20% threshold in November of 2016 and May 31, 2017. Therefore, FMN was in compliance with this
investment policy on May 31, 2017.

8)
 Comment: For Nuveen New Jersey Municipal Value Fund (NJV), Note 1 of the Notes to
Financial Statements within the Fund’s February 28, 2017 annual report indicates that the Fund is non-diversified, however, it appears as though the Fund has been operating as diversified. Should the
Fund be classified as diversified, and if so, shareholder approval will be required prior to the Fund changing its diversification status. [Please refer to Rule 13a-1 of the 1940 Act and the Allied Capital no-action letter.]

 Response: NJV was registered as non-diversified at its inception on April 28, 2009. The most recent quarter-end at which we found the Fund to be non-diversified
was in March of 2017, when the above-5% concentration reached 25.2%. Since that time, NJV has been generally very close to 25% in above-5% concentration, with our
Charles River Diversification status report showing it at 24.62% as of the annual report date listed in the comment (February 28, 2017). If the Fund continues to avoid exceeding the 25% threshold, we would change its classification to
“diversified” on March 31, 2020.

9)
 Comment: For Nuveen Build America Bond Fund (NBB), as of March 31, 2017 the Fund
has > 25% of its net assets investment in California municipal bonds, however the Fund’s most recent prospectus (2010) does not include any disclosure regarding the risk of investing a substantial concentration of the Fund’s
portfolio holdings in any one particular industry or state. Please consider updating the Fund’s prospectus and/or website disclosures accordingly.

 Response: NBB had greater than 25% of its net assets
invested in California obligations as of March 31, 2017 (27.4%). The Fund had at all times a policy in place to prevent a securities of issuers from a single state from constituting more than 25% of the total assets of NBB, and the 1940
Act specifications for state-related concentration are couched in terms of “total” assets, not net. See Rel. IC-9785 (May 31, 1977), which uses the term “assets”, which we believe can only
be interpreted as referring to “total assets.” On that same date, NBB had 21.15% of its total assets invested in California obligations, and thus was not in vi

CORRESP
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Correspondence

 March 6, 2017

VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Investment Management

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:

Nuveen Preferred Income Opportunities Fund

Registration Statement on Form N-14 8C

 (File No. 333-215072)

 Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby request that the effective date for Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14 8C referenced above be accelerated so that it will become effective as of March 6, 2017, or as
soon thereafter as practicable.

 [The remainder of this page has been intentionally left blank.]

    Sincerely,

NUVEEN PREFERRED INCOME
OPPORTUNITIES FUND

NUVEEN SECURITIES, LLC

By:

 /s/ Gifford R. Zimmerman

By:

 /s/ Gifford R. Zimmerman

Name:

Gifford R. Zimmerman

Name:

Gifford R. Zimmerman

Title:

Vice President and Secretary

Title:

Managing Director

CORRESP
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Correspondence

 Chicago

 New York

Washington, DC

 London

San Francisco

 Los Angeles

Singapore

 vedderprice.com

 March 6, 2017

 Nathaniel Segal

 Associate

+1 312 609 7747

 nsegal@vedderprice.com

 U.S. Securities and Exchange Commission

Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

Attn:  Ms.
Elisabeth Bentzinger, Esq.

Re:
  Nuveen Preferred Income Opportunities Fund (the “Registrant”)

  File No. 333-215072

 To the Commission:

On behalf of the Registrant, this letter is in response to discussions with the staff of the U.S. Securities and Exchange Commission with respect to the
treatment of “CoCos” for purposes of the Names Rule (as defined below). Registrant hereby undertakes as follows:

 Nuveen Preferred Income
Opportunities Fund undertakes, promptly following a determination, if any, by the staff of the Securities and Exchange Commission, notwithstanding the effectiveness of the N-14, that contingent capital securities (commonly referred to as
“CoCos”) cannot be regarded as “preferred securities” for purposes of Rule 35d-1 under the Investment Company Act of 1940 (“Names Rule”), to (i) modify the definition of “preferred securities” for
purposes of complying with the Names Rule to exclude CoCos, (ii) modify its name in order that its investment policies comply with the staff interpretation of the Names Rule, or (iii) take such other action that is necessary or sufficient
to comply with the staff’s determination with respect to the treatment of CoCos as “preferred securities” under the Names Rule.

 Please
direct your questions and/or comments regarding this filing to Deborah Bielicke Eades at (312) 609-7661 or the undersigned at (312) 609-7747.

Very truly yours,

 /s/ Nathaniel Segal

Nathaniel Segal

222 North LaSalle Street

Chicago, Illinois 60601

T +1 312 609 7500

F +1 312 609 5005

 Vedder Price P.C. is affiliated with
Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore.

 CHICAGO/#2959237.1

CORRESP
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SEC Response Letter

 Chicago

 New York

Washington, DC

 London

San Francisco

 Los Angeles

Singapore

vedderprice.com

February 7, 2017

 Nathaniel Segal

 Associate

+1 312 609 7747

 nsegal@vedderprice.com

 U.S. Securities and Exchange Commission

Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

 Attn:   Ms. Elisabeth
Bentzinger, Esq.

Re:
  Nuveen Preferred Income Opportunities Fund (the “Registrant”)

  File
No. 333-215072

 To the Commission:

 On behalf of the
Registrant, this letter is in response to the comments provided telephonically by the staff of the U.S. Securities and Exchange Commission (the “Commission”) to Vedder Price P.C. on January 12, 2017 with respect to the
Registrant’s Registration Statement on Form N-14 filed on December 13, 2016 (the “Registration Statement”) relating to the issuance of common shares in connection with the proposed
reorganization of Nuveen Flexible Investment Income Fund (the “Target Fund”) into the Registrant (the “Reorganization”). The Registrant and the Target Fund are referred to herein each as a “Fund” and collectively as the
“Funds.” Any terms not defined herein have the same meanings as given to them in the Registration Statement. Set forth below are the staff’s comments and the Registrant’s responses. All page references refer to the initial
Registration Statement. The Registrant is filing Pre-effective Amendment No. 1 to the Registration Statement concurrently herewith to address the comments of the staff, to complete all missing information
in the Proxy Statement/Prospectus and Statement of Additional Information and to file exhibits in Part C of the Registration Statement.

 General

(1)
Comment: Please update the dates used/cited throughout the Registration Statement, where applicable.

Response: Registrant has updated the dates used/cited in the Registration Statement, where appropriate.

(2)
Comment: Please clarify in the Notice of Annual Meeting of Shareholders and on page 1 of the Proxy Statement/Prospectus that, with respect to proposal 1, shareholders of the Target Fund are being solicited
to elect Board Members in the event that the Reorganization is not approved or is not otherwise consummated in a timely manner.

 February 7, 2017

 Page
 2

 Response: Registrant has added the requested disclosure.

Proxy Statement/Prospectus

(3)
Comment: On page ii of the Proxy Statement/Prospectus cover page, please disclose that proposal 2 is not a “routine” matter and, accordingly, “broker
non-votes” will be treated as votes against the Reorganization.

Response: Registrant has added the requested disclosure.

(4)
Comment: On page 10 and elsewhere in the Proxy Statement/Prospectus, when referring to the dollar range of equity securities beneficially owned by the Board Members, please provide such information as of
the most recent practicable date, pursuant to the instructions to paragraph (b)(5) of Item 22 of Schedule 14A.

Response: Registrant has revised the disclosure.

(5)
Comment: On page 23, please clarify what the word “plurality” means when describing the affirmative vote requirement to elect Board Members of the Target Fund.

Response: Registrant has added a definition of plurality.

(6)
Comment: Please revise the disclosure on page 23 to clarify the effect of “broker non-votes” on the election of Board Members in view of earlier disclosure
(on page ii) indicting that beneficial owners who do not provide proxy instructions or who do not return a proxy card may have their shares voted by broker-dealer firms in favor of proposal 1.

Response: Registrant has added clarifying disclosure that broker non-votes will affect
the determination of whether a quorum is present, but will not affect the outcome of the vote. In addition, Registrant also believes that defining the term “pluraility” (see Comment No 5 above) also clarifies the treatment of broker non-votes.

(7)
Comment: The staff notes that Item 3(b) of Form N-14 directs registrants to include at the beginning of the prospectus a synopsis of the information contained
therein and which shall be a clear and concise discussion of the key features of the transaction, the registrant and the company being acquired, among other things. Given that the synopsis included in the Proxy Statement/Prospectus begins on page 24
under proposal 2, please consider reordering the proposals.

 Response: Registrant believes that where a proxy
statement/prospectus contains multiple proposals, the inclusion of the Synopsis at the beginning of the reorganization proposal satisfies the requirements of the Form. Additionally, the structure of the Proxy Statement/Prospectus is consistent with
more than a dozen Registration Statements filed on Form N-14 on behalf of other Nuveen Funds over the past several years.

 February 7, 2017

 Page
 3

(8)
Comment: Under the section captioned “Material Federal Income Tax Consequences of the Reorganization,” please disclose an estimate of any capital gains distributions by the Fund resulting from
the sale of Target Fund portfolio securities prior to the closing of the Reorganization.

 Response: Registrant
has added the following disclosure:

 Capital gains from the portfolio sales, if any, are not expected to result in increased distributions
of net capital gain or net investment income by the Target Fund due to available capital loss carryforwards.

(9)
Comment: For the staff’s information, please provide supplementally the legal analysis as to why contingent convertible capital instruments (commonly referred to as “CoCos”) should be
characterized as preferred securities for purposes of the Acquiring Fund’s non-fundamental investment policy to invest at least 80% of its Managed Assets in preferred securities, in connection with Rule 35d-1 under the Investment Company Act of 1940, as amended (the “1940 Act”).

Response: Registrant notes that the preferred securities market has evolved and expanded its scope dramatically in the last
several years and decades. Registrant further notes that, although there is no single standard industry definition for the term “preferred securities”, that term is generally understood in the market to encompass a wide range of securities
that possess features of both bonds and common equity securities, including CoCos whose development followed the 2008-2009 financial crisis. Registrant believes that its definition of preferred securities is reasonable. CoCos are widely recognized
as preferred securities by other market participants as evidenced by recognized market indices market indices, registrations statements and other public reports of competitors, and market research and commentary. Registrant also believes that its
policy of including CoCos as preferred securities for purposes of Rule 35d-1 is clearly disclosed in the Registrant Statement. Accordingly, Registrant believes that its policy of including CoCos as
eligible assets for purposes of complying with the names rule test (80% policy) is consistent in all respects with Rule 35d-1.

The Nuveen Funds and the Adviser are in ongoing discussion with the SEC’s examination staff regarding the treatment of CoCos for purposes
of Rule 35d-1 for a number of funds, including the Registrant, and believe that a consistent approach across all funds is important. Accordingly, Registrant undertakes, upon conclusion of those discussions, to
modify its 80% policy or modify its name to the extent necessary to conform with the substantive conclusions of those discussions.

 February 7, 2017

 Page
 4

(10)
Comment: Please make clear that each Fund concentrates its investments in the financial services industry under the subsection captioned “Investment Objectives and Policies,” and confirm the
articulation of the policy.

 Response: Registrant has revised the policy to clarify that the Funds invest more
than 25% of assets in the financial services sector.

(11)
Comment: Please revise the subsection captioned “Investment Objectives and Policies” to provide a more clear and concise comparison of the Funds’ investment objectives and
policies, distribution policies and any other significant considerations, consistent with Item 3(b) of Form N-14. Consider moving any additional information and/or longer comparative discussion of the Funds to
later in the Proxy Statement/Prospectus in response to Items 5(b) and 6(b) of Form N-14 and Items 8.2 and 8.4 of Form N-2.

Response: Registrant has restructured the subsection captioned “Investment Objectives and Policies” to provide such
information in comparative chart format, and has moved more detailed information outside of the Synopsis portion of the Proxy Statement/Prospectus.

(12)
Comment: In the subsection captioned “Investment Objectives and Policies,” please reconcile the statement regarding the Target Fund’s investment in investment grade securities (at least 50%
of Managed Assets) and below investment grade securities (up to 75%).

 Response: Registrant has revised the
disclosure to clarify each Fund’s policies with respect to credit quality.

(13)
Comment: Please revise the disclosure under the subsection captioned “Portfolio Management” on page 36 to add dates to Thomas J. Ray’s biography and ensure that the biography provides the
portfolio manager’s business experience during the past 5 years, consistent with Item 9.1(c) of Form N-2.

Response: Registrant has added the requested disclosure.

(14)
Comment: Under the section captioned “Comparative Risk Information,” please qualify the second sentence of the introductory paragraph by adding disclosure clarifying whether the Target Fund is
more or less risky than the Registrant.

 Response: Registrant has added disclosure to convey that the Funds
will have different levels of exposure with respect to different types of securities and, and that each risk factor may affect each Fund to different degrees. Registrant also has added a chart showing each Fund’s exposure to the principal types
of investments of the Fund as of its most recent fiscal year end and has an added a cross reference to such chart in the lead-in paragraph preceding the enumerated risk factors.

 February 7, 2017

 Page
 5

(15)
Comment: Under the section captioned “Comparative Risk Information,” please consider adding a risk factor addressing below investment grade securities.

Response: Registrant has added the requested disclosure.

(16)
Comment: In the Fee and Expense table, referring to Item 3(a) of Form N-14, please confirm whether the fees disclosed as of July 31, 2016 on page 38 are still
current.

 Response: Registrant confirms that the fee structures and rates in effect as of July 31, 2016
remain in effect and are current.

(17)
Comment: Under the section captioned “A. Synopsis,” please include a comparison of the Funds’ distribution policies and purchase, redemption and exchange procedures.

Response: Registrant has added a section captioned “Distribution Policy” and a section captioned “Purchase of
Shares.” As a closed-end fund, the shares of the Fund are not redeemable nor is there any exchange privilege. Accordingly, those items are not applicable to a description of the shares being offered in
the Reorganization and no disclosure has been added.

(18)
Comment: For the staff’s information, please explain why the subsection captioned “General Risks of Investing in the Acquiring Fund” on page 40 includes more principal risks than those
disclosed under the section caption “Comparative Risk Information” on page 37. In addition, because Item 3(c) of Form N-14 only requires a brief discussion of the principal risk factors of investing
in the Registrant and given that the disclosure is approximately 16 pages, please consider moving parts of the disclosure to the response to Item 5(b) of Form N-14.

Response: Registrant has increased the summary risk disclosure in the Synopsis to include certain additional risks disclosed in
the section captioned “General Risks of Investing in the Acquiring Fund” beginning on page 39. Registrant notes that, because the Synopsis is a brief summary, some related risks have been grouped together in the Synopsis.

(19)
Comment: In response to Item 3(c) of Form N-14, please add disclosure briefly describing any restrictions on the Registrant’s present and future ability to pay
dividends with respect to any class of securities.

 Response: Registrant has added the requested disclosure.

 February 7, 2017

 Page
 6

(20)
Comment: In connection with the section captioned “Reasons for the Reorganization — Target Fund Board Considerations,” please confirm supplementally that the disclosure includes a discussion
of the principal factors that the Board considered that did not weigh in favor of the Reorganization.

 Response:
Registrant has been advised that the principal factors considered by the Target Fund Board in approving the Reorganization, whether positive or negative, are set forth and discussed in the section captioned “Reasons for the
Reorganization — Target Fund Board Considerations” and that such disclosure is consistent with the Board record. Such factors include both positive and less favorable factors, such as the potential for economies of scale and, as an example
of a less favorable factor, a comparison of the Funds’ distribution policies.

(21)
Comment: Please reconcile the last sentence of the answer to the question “Will the Reorganization impact Fund distributions to common shareholders?” on page iii of the Q&A, which indicates
the change from a cash flow distribution policy to an income-only distribution policy is not expected to adversely impact the combined fund’s ability to pay distributions to common shareholders, with the last sentence of the paragraph captioned
“Potential for Improved Economies of Scale Over Time and Effect on Fees, Total Expenses and Distributions” on page 61, which indicates in general terms that an income-only distribution policy may result in dividends being paid at a lower
rate than under a cash flow distribution policy.

 Response: Registrant has conformed the disclosure on page 61
to the disclosure in the Q&A.

(22)
Comment: Under the section captioned “Expenses Associated with the Reorganization,” please revise the disclosure to clarify whether the estimated total costs of the Reorganization include the
costs of soliciting shareholders to elect Board Members.

 Response: Registrant has revised the disclosure.

(23)
Comment: Please add disclosure relating to any portfolio realignment that will take place before or after consummation of the Reorganization. Specifically, please include in the disclosure: (1) the
reason for the portfolio realignment; (2) the cost of the realignment as a dollar amount and as a percentage of the Target Fund’s net asset value; (3) who will bear the cost of the realignment; (4) the percentage of the Target
Fund’s portfolio that is expected to be sold in connection with the realignment; and (5) an estimate of the related realized gains incurred as a result of any realignment sales. Please also disclose that the costs of the Reorganization do
not include realignment costs.

 February 7, 2017

 Page
 7

 Response: Registrant notes that repositioning information was not included
because the repositioning will constitute less than 5% of the assets of the Acquiring Fund. However, in light of the staff’s comment, Registrant has added the requested disclosure.

(24)
Comment: Please add the disclosure relating to additional proxy solicitation costs (the second paragraph under the section captioned “Expenses Associated with the Reorganization” on page 63) to
the disclosure under the section captioned “Expenses of Proxy Solicitation” on page 96.

 Response:
Registrant has added the requested disclosure.

(25)
Comment: If shareholders of the Target Fund have dissenters’ rights with respect to the election of Board Members, please add disclosure explaining such rights under proposal 1.

CORRESP
1
filename1.htm

Nuveen Investments

 July 21, 2015

Mr. Jason P. Fox

 U.S. Securities and Exchange
Commission

 Division of Investment Management, Insured Investments Office

100 F Street N.E.

 Washington DC 20549

Re: Nuveen Closed-End and Open-End Funds - Sarbanes Oxley Review

Dear Mr. Fox:

 This letter addresses the
comments you provided in a telephone discussion on June 18, 2015, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain regulatory filings made by closed-end and
open-end registered investment companies (“funds”) advised by Nuveen Fund Advisors, LLC (“NFAL”). Each comment is shown below followed by our response. Unless otherwise noted, the responses relate to all funds listed on Appendix
A attached hereto.

1)
 Comment: For the Nuveen Dividend Value Fund, the shareholder report cover has the incorrect ticker symbol for Class R6 Shares. The
ticker symbol is currently FFEIX and should be FFEFX. Please correct in future filings.

Response: We agree with the SEC Staff’s comment and corrected the Fund’s ticker symbol effective with the
Fund’s April 30, 2015 semi-annual report.

2)
 Comment: For those funds that invested significantly in derivatives during their fiscal year, management’s discussion of fund
performance (“MDFP”) should discuss how the derivatives affected fund performance.

Response: As we indicated to you on our recent call, we received a similar comment during the SEC Staff’s last
review in 2012, at which time we responded that we had expanded our disclosure in the MDFPs to include how a fund’s use of derivatives impacted performance during the reporting period if the fund used derivatives as a form of leverage and/or if
the fund’s use of derivatives had a material impact on its performance. Examples of the funds’ most recent derivatives disclosures are as follows:

April 30, 2015 annual report for Nuveen Short Duration High Yield Municipal Bond Fund

“We owned interest rate swaps to modestly reduce the portfolio’s duration. By relying on hedges to manage
sensitivity to changes in rates, we were able to be more deliberate about the securities we chose to own in the Fund. As expected in light of the overall drop in interest rates, however, these swaps hurt the Fund’s performance in absolute
terms.”

 March 31, 2015 annual report for Nuveen Build America Bond Fund (NBB) and Nuveen Build America
Bond Opportunity Fund (NBD)

 “However, because NBB and NBD also were using swaps to shorten long term interest
rates at a time when rates were falling, the use of swaps had a negative impact on the Funds’ total return performance for the reporting period. This impact was greater in NBD, which made greater use of derivatives.”

March 31, 2015 semi-annual report for Nuveen Tactical Market Opportunities Fund

“Throughout the reporting period, we continued to use equity, interest rate and currency futures contracts, which were
used to manage country and style exposures as well as implement various absolute return, tactical market and hedging strategies in the Fund. We also utilized equity put and call options to generate returns and manage the Fund. These put and call
options were used to implement views on the direction of implied market volatility as well as hedge against a decline or increase in the market, respectively. Overall, these derivative positions were meaningful contributors to performance during the
reporting period.”

 Page 1 of 8

 February 28, 2015 semi-annual report for Nuveen Strategy Balanced
Allocation Fund

 “Throughout the reporting period, we also tactically used equity and fixed income futures to
adjust the Fund’s mix. Due to generally higher equity prices and fluctuating interest rates, the futures contracts had a moderately negative impact on performance as gains in large- and mid-cap futures were offset by small-cap short futures
losses.”

 January 31, 2015 semi-annual report for Nuveen Senior Income Fund (NSL), Nuveen Floating Rate
Income Fund (JFR), Nuveen Floating Rate Income Opportunity Fund (JRO), Nuveen Short Duration Credit Opportunities Fund (JSD) and Nuveen Credit Strategies Income Fund (JQC)

“The Funds also used interest rate swap contracts to partially fix the interest cost of leverage, which as mentioned
previously, is through bank borrowings and/or VRTP Shares. During the reporting period, NSL, JFR, JRO and JQC unwound their respective swap contracts. JSD began the reporting period with three swap contracts, one of which matured and another was
unwound prior to the end of the reporting period. The swap contracts held by NSL, JFR, JRO and JQC had an overall negligible impact on Fund performance, while JSD’s swap contracts detracted modestly from overall Fund performance.”

December 31, 2014 semi-annual report for Nuveen Global Total Return Bond Fund

“During the reporting period, we also continued to utilize various derivative instruments. We used foreign currency
exchange contracts to gain exposure to selected foreign currencies, as well as in some cases to hedge the currency risk present in a foreign bond. The overall effect of these contracts was positive as the majority of the positions were used for
hedging purposes during the reporting period as the U.S. dollar rallied. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere
in the portfolio. We used U.S. Treasury futures and Eurodollar futures as part of an overall portfolio construction strategy to manage portfolio duration and yield curve exposure; used selected foreign bond futures to actively manage exposure to
those markets. The effect of these activities in the period was negative. These derivative exposures are integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere
in the portfolio. We used interest rate swaps as part of an overall portfolio construction strategy to manage duration and overall portfolio yield curve exposure. The swap positions detracted slightly from performance during the period. In addition,
we entered into High Yield CDX swaps as a way to take on credit risk and earn a commensurate credit spread. The effect of these activities on performance was negligible during the period, as the positions were minimal. These derivative exposures are
integrated with the overall portfolio construction and as such losses and gains may be naturally related to and/or may offset impacts elsewhere in the portfolio.”

Management continuously monitors disclosures regarding the funds’ uses of derivatives, striving to provide what we
believe to be the best explanation to readers of the funds’ financial statements.

3)
 Comment: The portfolio of investments included within the shareholder reports for several open-end funds disclose a money market
fund holding in Mount Vernon Securities Lending Trust Prime Portfolio (“Mount Vernon”). When recalculating the net asset value (“NAV”) per share of Mount Vernon as of June 30, 2014 in the Nuveen Strategic Income Fund’s
annual report, as noted in the table below, the NAV per share does not equal $1.00. Disclose the NAV of such shares or explain why the NAV is not $1.00.

Shares

Description

Value

NAV per
Share

84,532,292

Mount Vernon Securities Lending Trust Prime Portfolio

$85,180,247

$1.01

 Response: The shares disclosed as of June 30, 2014 in the Nuveen Strategic Income
Fund’s annual report were incorrect. The correct shares are $85,180,247, and as such, the NAV per share is $1.00.

4)
 Comment: Within the funds’ shareholder reports, the fair value measurements disclosures included within the notes to
financial statements do not always indicate whether or not the funds had a transfer of securities between the three-tiered hierarchy of valuation input levels (Level 1, Level 2 and/or Level 3). In future shareholder reports, the fair value
measurements disclosures should include whether or not such transfers occurred.

 Page 2 of 8

 Response: As we indicated to you on our recent call, in the preparation of
the relevant valuation footnote disclosure for a fund, we identify all of the transfers between the three-tiered hierarchy of valuation input levels (Level 1, Level 2 and/or Level 3). However, for reporting in the financial statements we have
established a de minimis floor below which we would not provide the expanded disclosures in the footnotes. In discussion with other industry participants, we believe this is a common practice followed by others in the industry. In establishing a de
minimis floor, we believe it provides the reader of the financial statements a clearer picture of significant transfers between levels. We further believe that this is consistent with GAAP which provides that accounting standards do not apply to
immaterial items. Therefore we believe our current disclosure practice provides the reader with the necessary information to conclude that no material transfers have occurred during the period.

5)
Comment: Within several of the funds’ shareholder reports, the notes to financial statements include disclosures pertaining to agreements with the adviser for which the adviser agreed to reimburse
and/or waive charges to the fund(s) for certain fees and/or expenses. Please confirm that it is not the adviser’s policy to recoup from the funds any amounts waived and/or reimbursed in prior periods during future periods.

 Response: NFAL, the funds’ adviser, does not have, and does not currently intend to have, a policy to recoup
from the funds during future fiscal years any amounts waived and/or reimbursed in prior fiscal years.

6)
Comment: Within several of the funds’ shareholder reports, the notes to financial statements include disclosures for mergers that occurred during the fiscal period. However, those funds that were
acquired have not yet completed a Form N-8F filing. Please review the funds that recently ceased operations and complete a Form N-8F filing accordingly.

Response: The SEC Staff is correct in identifying funds that have ceased operations, but had not yet completed a Form N-8F filing. We
have identified and completed a Form N-8F filing for each of the funds listed in the table below.

Fund Name

 Ticker

Symbol

CIK

 File

Number

 Date

Form N-8F

Filed with

 SEC

 Nuveen Pennsylvania Premium Income Municipal Fund 2

NPY

0000897427

811-07482

June 25, 2015

 Nuveen Pennsylvania Dividend Advantage Municipal Fund

NXM

0001087787

811-09457

June 25, 2015

 Nuveen Pennsylvania Dividend Advantage Municipal Fund 2

NVY

0001158729

811-10549

June 25, 2015

 Nuveen Massachusetts Dividend Advantage Municipal Fund

NMB

0001090120

811-09451

June 25, 2015

 Nuveen Massachusetts AMT-Free Municipal Income Fund

NGX

0001196366

811-21216

June 25, 2015

 Nuveen California Performance Plus Municipal Fund, Inc.

NCP

0000856227

811-05930

June 25, 2015

 Nuveen California Municipal Market Opportunity Fund, Inc.

NCO

0000862313

811-06081

June 25, 2015

 Nuveen California Investment Quality Municipal Fund, Inc.

NQC

0000868440

811-06177

June 25, 2015

 Nuveen California Select Quality Municipal Fund, Inc.

NVC

0000874142

811-06294

June 25, 2015

 Nuveen California Quality Income Municipal Fund, Inc.

NUC

0000879826

811-06425

June 25, 2015

 Nuveen California Premium Income Municipal Fund

NCU

0000905000

811-07720

June 25, 2015

 Nuveen New Jersey Investment Quality Municipal Fund, Inc.

NQJ

0000870778

811-06264

June 25, 2015

 Nuveen New Jersey Premium Income Municipal Fund, Inc.

NNJ

0000890898

811-07118

June 25, 2015

 Nuveen New Jersey Dividend Advantage Municipal Fund 2

NUJ

0001161070

811-10551

June 25, 2015

 Nuveen Global Income Opportunities Fund

JGG

0001359816

811-21893

June 25, 2015

 Nuveen Diversified Currency Opportunities Fund

JGT

0001390109

811-22018

June 25, 2015

 Nuveen Equity Premium Opportunity Fund

JSN

0001308658

811-21674

June 25, 2015

 Dow 30SM Premium & Dividend Income Fund Inc.

DPD

0001314128

811-21708

June 25, 2015

 Dow 30SM Enhanced Premium & Income Fund Inc.

DPO

0001390840

811-22029

June 25, 2015

 NASDAQ Premium Income & Growth Fund Inc.

QQQX

0001381186

811-21983

June 25, 2015

 Nuveen Equity Premium Advantage Fund

JLA

0001320492

811-21731

June 25, 2015

 Page 3 of 8

7)
Comment: For the Form N-SAR filing identified in the table below, the filing indicates that there was a change in auditor from Ernst & Young LLP (“EY”) to KPMG, LLP during the fiscal
period, but the letter from EY is not included as an exhibit to the filing. Amend the Form N-SAR filing to include the letter from EY.

File Number

Registrant

Date Filed

 811-09037

Nuveen Investment Trust III

December 1, 2014

 Response: Management amended the Form N-SAR filing for the Trust in the aforementioned table on
July 16, 2015, to include the letter from EY within Exhibit 77K.

 Page 4 of 8

 Appendix A

CIK or

SEC File

Registrant

Fund Name

Ticker

Series ID

Number

 1

Nuveen Investment Funds, Inc.

Nuveen Core Bond Fund

S000005548

811-05309

 2

Nuveen Investment Funds, Inc.

Nuveen Core Plus Bond Fund

S000005578

811-05309

 3

Nuveen Investment Funds, Inc.

Nuveen Dividend Value Fund

S000005579

811-05309

 4

Nuveen Investment Funds, Inc.

Nuveen Equity Index Fund

S000005580

811-05309

 5

Nuveen Investment Funds, Inc.

Nuveen Global Infrastructure Fund

S000020012

811-05309

 6

Nuveen Investment Funds, Inc.

Nuveen High Income Bond Fund

S000005544

811-05309

 7

Nuveen Investment Funds, Inc.

Nuveen Inflation Protected Securities Fund

S000005545

811-05309

 8

Nuveen Investment Funds, Inc.

Nuveen Intermediate Government Bond Fund

S000005546

811-05309

 9

Nuveen Investment Funds, Inc.

Nuveen Large Cap Growth Opportunities Fund

S000005550

811-05309

 10

Nuveen Investment Funds, Inc.

Nuveen Large Cap Select Fund

S000005551

811-05309

 11

Nuveen Investment Funds, Inc.

Nuveen Mid Cap Growth Opportunities Fund

S000005553

811-05309

 12

Nuveen Investment Funds, Inc.

Nuveen Mid Cap Index Fund

S000005555

811-05309

 13

Nuveen Investment Funds, Inc.

Nuveen Mid Cap Value Fund

S000005556

811-05309

 14

Nuveen Investment Funds, Inc.

Nuveen Minnesota Intermediate Municipal Bond Fund

S000005558

811-05309

 15

Nuveen Investment Funds, Inc.

Nuveen Minnesota Municipal Bond Fund

S000005559

811-05309

 16

Nuveen Investment Funds, Inc.

Nuveen Nebraska Municipal Bond Fund

S000005560

811-05309

 17

Nuveen Investment Funds, Inc.

Nuveen Oregon Intermediate Municipal Bond Fund

S000005562

811-05309

 18

Nuveen Investment Funds, Inc.

Nuveen Real Asset Income Fund

S000033768

811-05309

 19

Nuveen Investment Funds, Inc.

Nuveen Real Estate Securities Fund

S000005563

811-05309

 20

Nuveen Investment Funds, Inc.

Nuveen Short Term Bond Fund

S000005566

811-05309

 21

Nuveen Investment Funds, Inc.

Nuveen Short Term Municipal Bond Fund

S000005564

811-05309

 22

Nuveen Investment Funds, Inc.

Nuveen Small Cap Growth Opportunities Fund

S000005567

811-05309

 23

Nuveen Investment Funds, Inc.

Nuveen Small Cap Index Fund

S000005568

811-05309

 24

Nuveen Investment Funds, Inc.

Nuveen Small Cap Select Fund

S000005569

811-05309

 25

Nuveen Investment Funds, Inc.

Nuveen Small Cap Value Fund

S000005570

811-05309

 26

Nuveen Investment Funds, Inc.

Nuveen Strategic Income Fund

S000005573

811-05309

 27

Nuveen Investment Funds, Inc.

Nuveen Tactical Market Opportunities Fund

S000027104

811-05309

 28

Nuveen Investment Trust

Nuveen Concentrated Core Fund

S000040902

811-07619

 29

Nuveen Investment Trust

Nuveen Core Dividend Fund

S000040903

811-07619

 30

Nuveen Investment Trust

Nuveen Equity Market Neutral Fund

S000040904

811-07619

 31

Nuveen Investment Trust

Nuveen Global Tactical Opportunities Plus Fund

S000041890

81

CORRESP
1
filename1.htm

Nuveen Investments

 April 19, 2013

 Ms. Christina DiAngelo

 U.S. Securities and Exchange Commission

450
5th Street, NW

Washington, D.C. 20549

 Re: Nuveen
Closed-End and Open-End Funds - Sarbanes Oxley Review Follow-Up Discussion

 Dear Christina:

This letter addresses your comments provided in a telephone discussion on February 13, 2013. This was a follow-up discussion to
our December 11, 2012, correspondence filing pertaining to our telephone discussion held on September 25, 2012. Each comment shown below was included in our December 11th correspondence filing and is followed by our current response. Unless otherwise noted, the responses relate to all
funds listed on Appendix A.

1)
Comment #8: The Nuveen.com website shows for leveraged Closed-End Funds (“CEFs”) two different expense ratios: one based on
“Common Shares,” the other based on “Total Fund” An example of such a table:

Total Fund

Common
Shares

Management Fees

0.59%

0.90%

Interest Expenses

0.44%

0.64%

Other Expenses

0.09%

0.13%

Total

1.12%

1.67%

 The Staff believes that it is inherently misleading for a leveraged CEF to quote expense figures using
“total fund net assets” as the denominator. First, generally accepted accounting principles (“GAAP”) specifies that expense figures be quoted using “net assets attributable to common shares” as the denominator. Second,
no shareholder, common or preferred, actually “experiences” or pays the lower expense percentages expressed as a percentage of total fund net assets, and therefore those figures do not have any concrete meaning for shareholders.
Accordingly, the Staff requests that these funds consider removing the expense figures based on total fund net assets from such tables, and include those figures in a much less prominent place, such as a footnote.

Revised Response: Nuveen understands the Staff’s position is not that the inclusion of fund-based expense figures are
necessarily invalid, but that Nuveen’s website presentation inappropriately gives those figures “equal prominence” with the GAAP-compliant, common share-asset-based expense figures, which are not properly explained and
contextualized. At the current time Nuveen is continuing to disclose such figures on its website with the disclosure modified to resemble the following (for the same fund but for a different period, so the numbers have changed slightly):

Common
Shares

Total Fund

 Management Fees

0.89%

0.59%

 Other Expenses

.10%

.07%

 Subtotal

0.99%

0.66%

 Interest Expense From Leverage

0.68%

0.48%

 Total Expenses

1.67%

1.14%

 Fund fees and expenses are presented as a percentage of both common shareholder capital and total fund
investment capital. Total investment capital includes common assets as well as assets attributable to the fund’s issuance of senior securities (e.g. preferred shares and other forms of leverage). The table’s first column presents the costs
directly and indirectly borne by common shareholders on an investment in the fund’s common shares. The table’s second column presents the costs borne by the fund on its total investment capital, which enables a common shareholder to better
understand how fund expenses impact portfolio investment returns. Interest expenses from leverage are shown separately, because they represent costs associated with the fund’s financing activities which are distinct from the costs associated
with the fund’s underlying core operations.

 Other Expenses and Total Expenses do not include interest expenses arising
from externally created inverse floating rate securities (if any) held by the fund. Interest expense arises because accounting rules require the

fund to treat interest paid by trusts issuing self-created inverse floating rate instruments (if any) held by the fund as having been paid (indirectly) by the fund. Because the fund also
recognizes a corresponding amount of additional income earned (also indirectly), the fund’s net asset value per share, net investment income and total return have not been affected by this accounting treatment. See the fund’s Annual Report
for information on the fund’s inverse floating rate investments and recognized interest expense.

 The expense ratio shown
may reflect a voluntary expense waiver by the fund’s investment adviser which can be modified or discontinued at any time without notice and may also reflect custodian fee credits and legal fee refunds. Absent the limitation, credits and
refunds, expenses would be higher and total returns would be less. See the fund’s Annual Report for information on expenses and waivers. Expense ratios do not reflect the effect of dividend payments to preferred shareholders.

Response filed on December 11th: Nuveen respectfully but strongly disagrees with any
assertion that a leveraged CEF’s expense figures quoted as a percentage of total fund net assets are “not meaningful” and/or “inherently misleading” when such figures are accompanied by expense figures quoted as a percentage
of common share net assets in equal prominence. Indeed, we believe that, for certain important purposes the total fund net asset figures are more meaningful and insightful than the common share net asset-based expense figures.

We agree with the Staff’s position that expenses expressed as a percentage of the net assets attributable to a CEF’s common
shares is a relevant and meaningful indicator of expenses, because it is the common shareholders who end up paying, and therefore “experiencing”, those expenses. However, it is Nuveen’s and the Nuveen Funds’ view – and we
believe that it is a commonly held view in the industry– that expense figures should also provide a shareholder or other investor a perspective on what proportion of a fund portfolio’s return-generating power is being reduced by the
so-called “friction” associated with expenses. In a leveraged CEF, the returns of the fund are being generated on the total amount of the fund’s assets, not just on the amount of assets attributable to the fund’s common shares.
Likewise, and perhaps more importantly to this discussion, fund expenses are by and large being generated and “experienced” at the total fund level, not at the common shareholder level. For example, management fees of the Nuveen CEFs are
computed and paid based on the fund’s total net assets, and not on assets attributable to just the common shares. Similarly, most other types of expenses (e.g., audit, custodian, legal) are incurred with respect to or by reference to the entire
fund, and not just to that portion of the fund or its assets that are attributable to common shares.

 In a simple,
non-leveraged example, a bond fund whose portfolio generates a 5% gross return and pays 1% in total expenses would experience a reduction of 20% of its return due to this “expense friction”. A fund that generates the same gross return with
less “expense friction” than another fund could be thought of as producing that gross return more “efficiently.” Thus, expense figures provide investors with important indicators of a fund’s “expense efficiency”,
and investors often wish to compare the expense efficiency of competing funds.

 In an analogous but inherently more
complicated leveraged CEF situation, quoting only expense figures (management fees, other expenses, and total expenses) based on common share net assets prevents the investor from truly being able to gauge a fund’s “expense
efficiency”, because that set of expense figures would vary between two otherwise identical funds with identical fund-level expenses but differing leverage ratios in general proportion to those leverage ratios. The more highly levered fund will
show higher expenses expressed as a percentage of common share net assets than the less levered fund, and will appear, falsely, to be less “expense efficient” than that less levered fund. And even that less-levered fund will appear to be
less “expense efficient” than a non-levered fund. For example, a levered fund having a 33.3% leverage ratio ($33.33 of leveraging instrument for every $100 of total assets) and paying a management fee equal to .50% of fund net assets would
show a management fee based on common share net assets of .75%, while a levered fund with a 20% leverage ratio and paying that same .50% management fee would show a management fee based on common share net assets of .625%, and a non-levered fund
paying that same management fee would of course show a management fee of .50%. Investors in the latter fund would believe, based on those common share net asset-based expense figures, that their fund’s investment adviser was receiving a lower
management fee than the adviser of the other funds, when in fact that was not the case.

 Indeed, quoting only common share net
asset-based expense figures without accompanying them with the CEF’s total fund net asset-based expense figures could even prove potentially misleading to investors, for example, in the circumstance where the more highly levered fund was
actually paying lower management fees, custodian fees, audit fees, etc. on fund assets than a less-levered fund or especially a non-levered fund, but would still be quoting a higher set of expense ratios, for the mathematical reasons discussed
above. Thus, providing a leveraged fund’s expense figures expressed as a percentage of total net assets (in addition to quoting its expense figures as a percentage of common share net assets) provides investors with the ability to compare the
“expense efficiency” of leveraged funds with non-leveraged funds, and to compare the “expense efficiency” of funds having different leverage levels, on an apples-to-apples basis, in the sense that it shows the expenses generated
by each dollar of assets of each of the funds being compared. So long as such total fund net asset-based expense figures are accompanied, with equal prominence, with common share net asset-based expense figures, the reader or investor cannot fairly
claim to be misled by the former figures. Therefore, we intend to continue to quote expense figures as a percentage of total fund net assets side-by-side with expense figures quoted as a percentage as common share net assets.

2)
Comment 13: Those funds that elected to retain a portion of their realized long-term capital gains disclose in their shareholder reports the
total returns including the retained gain tax credit/refund and excluding the retained gain tax credit/refund. It is the SEC staff’s position that the total returns including the retained gain tax credit/refund be removed. The SEC gave examples
of those funds, including;

•

 Nuveen Diversified Dividend and Income Fund

•

 Nuveen Global Value Opportunities Fund

Revised Response: We discussed the Staff’s questions pertaining to the response we provided in our
December 11th correspondence filing and understand
there is no further action or information being requested regarding this matter.

 Response filed on
December 11th: Set forth below is the relevant disclosure from one of the two funds cited by the staff (Nuveen Global Value Opportunities Fund (JGV)):

[Share Distributions and Price Information Section]

 The following table provides information regarding the Fund’s distributions and total return performance for the fiscal year ended December 31, 2011. This information is intended to help you
better understand whether the Fund’s returns for the specified time period were sufficient to meet the Fund’s distributions.

  As of 12/31/11

JGV

   Inception date

7/24/06

   Fiscal year (calendar year) ended December 31, 2011:

   Per share distribution:

   From net investment income

$0.83

   From long-term capital gains

0.18

   From short-term capital gains

0.28

   Return of capital

0.08

   Total per share distribution

$1.37

   Distribution rate on NAV

8.10%

   Average annual total returns:

   Excluding retained gain tax credit/refund**:

   1-Year on NAV

-10.28%

   5-Year on NAV

4.72%

   Since inception on NAV

6.04%

   Including retained gain tax credit/refund**:

   1-Year on NAV

-10.28%

   5-Year on NAV

4.89%

   Since inception on NAV

6.20%

**
The Fund elected to retain a portion of its realized long-term capital gains for the tax year ended December 31, 2007, and pay required federal corporate income
taxes on this amount. As reported on Form 2439, shareholders on record date must include their pro-rata share of these gains on their applicable federal tax returns, and are entitled to take offsetting tax credits, for their pro-rata share of the
taxes paid by the Fund. The total returns “Including retained gain tax credit/refund” include the economic benefit to shareholders on record date of these tax credits/refunds. The Fund had no retained capital gains for the tax years ended
December 31, 2011 through December 31, 2008 or for the tax year ended December 31, 2006.

 [Performance Overview Section]

 Average Annual Total Returns

 (Inception 7/24/06)

On Share Price

On NAV

 1-Year

-11.00%

-10.28%

 5-Year

5.91%

4.72%

 Since Inception

5.58%

6.04%

 Average Annual Total Returns 3

(Including retained gain tax credit/refund)

 1-Year

-11.00%

-10.28%

 5-Year

6.10%

4.89%

 Since Inception

5.74%

6.20%

 3 As previously explained in the Share Distribution and Price Information section of this report, the Fund elected to
retain a portion of its realized long-term capital gains for the tax year ended December 31, 2007, and pay required federal corporate income taxes on these amounts. These standardized total returns include the economic benefit to shareholders
of record of this tax credit/refund. The Fund had no retained capital gains for the tax years ended December 31, 2011 through December 31, 2008 or for the tax year ended December 31, 2006.

Whenever a fund retains and pays tax on a portion of its realized capital gains in a given tax year, the Internal Revenue Code provides
that the fund also should distribute a capital gain tax “credit” to the fund’s shareholders that the shareholders can use, dollar-for-dollar, to reduce their own taxes. Fund shareholders simultaneously increase their cost basis by
their ratable share of undistributed net capital gains, net of taxes paid by the fund. As a result, a fund that retains and pays tax on a net realized gain would provide virtually the same all-in “economic” (i.e., after-tax) return to its
taxable shareholders as an otherwise identical fund that distributed its net realized capital gains to its shareholders (who then either paid capital gains tax on those gains or used those gains to offset losses that might otherwise have been usable
to offset other or later gains). The tax credit that the fund distributes to its shareholders in the first instance provides a tangible and quantifiable benefit to those of its shareholders who pay taxes, but the value of that benefit is not
reflected in the total returns calculated strictly from the fund’s financial records, because that tax credit is not quantified in financial statements as a “distribution;” while the tax payment by that fund does operate to reduce
that fund’s total return figures.

 The provision of an alternatively calculated supplemental total return figure in such
instances to reflect the value to taxable shareholders of the fund’s distribution to shareholders of this sort of tax credit in addition to the fund’s cash distributions is fair, appropriate and not misleading. The shareholders did
receive that tax credit, and that credit had real, quantifiable value to taxable shareholders. Note that a fund (“Fund A”) that had distributed the capital gain to shareholders would show, under ordinary calculation methodologies, a
higher total return than an otherwise identical fund (“Fund B”) that had retained the gain, paid taxes on that gain (and thereby reduced fund assets and returns) and distributed a tax credit to shareholders, even though taxable
shareholders of both of those otherwise identica

CORRESP
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Nuveen Investments

 December 11, 2012

 Ms. Christina DiAngelo

 U.S. Securities and Exchange Commission

450
5th Street, NW

Washington, D.C. 20549

 Re: Nuveen
Closed-End and Open-End Funds - Sarbanes Oxley Review

 Dear Christina:

 This letter addresses your comments provided in a telephone discussion on September 25, 2012. Each comment is shown below followed by our response. Unless otherwise noted, the responses relate to all
funds listed on Appendix A attached hereto.

1)
Comment: (a) For the following N-SAR filings, the name of the accounting firm issuing the report is missing from the following funds’
Accountants Report on Internal Control. File amended reports to include the complete Accountants Report on Internal Control.

File Number

Registrant

Date Filed

 811-21494

 Nuveen Floating Rate Income Fund

September 30, 2011

 811-21579

 Nuveen Floating Rate Income Opportunity
Fund

September 30, 2011

 811-22023

 Nuveen Managed Accounts Portfolios
Trust

September 29, 2011

 811-09571

 Nuveen Senior Income Fund

September 29, 2011

 811-22518

 Nuveen Short Duration Credit Opportunities
Fund

September 29, 2011

 811-05309

 Nuveen Investment Funds, Inc.

August 29, 2011

 811-05309

 Nuveen Investment Funds, Inc. (also missing city and
state)

February 2, 2012

 Comment: (b) For the following N-SAR filing, the city and state of the accounting
firm issuing the report is missing from the Accountants Report on Internal Control. Ensure that all future filings of this report contain the city and state of the accounting firm issuing the report. File an amended report to include the complete
Accountants Report on Internal Control.

File Number

Registrant

Date Filed

 811-07619

 Nuveen Investment Trust

August 29, 2011

 Response: We are currently in the process of taking the necessary steps to amend the filings in
the aforementioned tables. To amend these filings under our current N-SAR application, which is disc operating system (DOS) based, we would need to recreate the answer file (“answer.fil”) originally filed with the complete Accountants
Report on Internal Control. We are currently in the process of obtaining a new web based N-SAR application with RR Donnelley, which will allow us to edit the answer.fil without a complete recreation. Assuming a timely installation of this N-SAR
application, we expect to amend the filings as requested within thirty days of this response.

2)
Comment: (a) In future N-CSR filings, for Item 4 (b), (c) and (d) provide more details on what services comprise “Audit
Related Fees,” “Tax Fees,” and “Other.”

 Response: Items 4(b), (c) and
(d) of Form N-CSR are as follows:

 4 (b) Disclose, under the caption Audit-Related Fees, the aggregate fees billed
in each of the last two fiscal years for assurance and related services by the principal accountant that are reasonably related to the performance of the audit of the registrant’s financial statements and are not reported under paragraph
(a) of this Item. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

4 (c) Disclose, under the caption Tax Fees, the aggregate fees billed in each of the last two fiscal years for professional services
rendered by the principal accountant for tax compliance, tax advice, and tax planning. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

4 (d) Disclose, under the caption All Other Fees, the aggregate fees billed in each of the last two fiscal years for products and
services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

 Page 1
of 22

 In accordance with Item 4 (b), (c) and (d) of Form N-CSR, we will further
describe the nature of services comprising “Audit Related Fees,” “Tax Fees” and “All Other Fees” in our future N-CSR filings. The Nuveen funds’ current disclosures are as follows:

Item 4 (b): “Audit-Related Fees” are the aggregate fees billed for assurance and related services reasonably related to
the performance of the audit or review of financial statements that are not reported under “Audit Fees”.

Item 4(c): “Tax Fees” are the aggregate fees billed for professional services for tax advice, tax compliance, and tax
planning.

 Item 4(d) (for Nuveen open-end funds): “All Other Fees” are the aggregate fees billed for products
and services other than “Audit Fees”, “Audit-Related Fees” and “Tax Fees”.

 Item 4(d) (for
Nuveen closed-end funds): “All Other Fees” are the aggregate fees billed for products and services for agreed upon procedures engagements performed for leveraged funds.

At the current time, the Nuveen funds contemplate the following as an example of what the disclosure will resemble going forward that
will be revised as needed to reflect the actual services provided to the funds:

 Item 4 (b): “Audit-Related
Fees” are the aggregate fees billed for assurance and related services reasonably related to the performance of the audit or review of financial statements that are not reported under “Audit Fees”. These fees include leverage
offerings as well as comfort letters for seed and shelf offerings.

 Item 4(c): “Tax Fees” are the aggregate
fees billed for professional services for tax advice, tax compliance, and tax planning. These fees include: all global withholding tax services; excise and state tax reviews; and capital gain, tax equalization and taxable basis calculations
performed by the principal accountant.

 Item 4(d) (for Nuveen open- and closed-end funds): “All Other Fees” are
the aggregate fees billed for products and services other than “Audit Fees”, “Audit-Related Fees” and “Tax Fees”. These fees represent all “Agreed-Upon Procedures” engagements pertaining to preferred stock,
commercial paper and registration statements.

 Our next N-CSR filings are scheduled to be filed on or around December 6,
2012.

 Comment: (b) In future N-CSR filings, Item 4(f) of the filing should be addressed, even if
not applicable.

 Response: Item 4(f) of Form N-CSR is as follows:

(f)
If greater than 50 percent, disclose the percentage of hours expended on the principal accountant’s engagement to audit the registrant’s financial statements
for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees.

 In our experience, the answer for this response has always been “not applicable.” At the current time, the Nuveen funds contemplate the following as an example of what the disclosure will
resemble going forward:

 Less than 50 percent of the hours expended on the principal accountant’s engagement to audit the
registrant’s financial statements for the most recent fiscal year were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees.

3)
Comment: Why were the following amended filings made? In the future, include a cover sheet detailing the reason for the amended
filing. In addition, whenever amended filings are made and those filings include certifications, the certifications should be updated to the date of the amended filing, even if the amended filings are made one day later than the original
filing. For example, the Form N-Q/A filed on September 1, 2010, for Nuveen Texas Quality Income Municipal Fund contains certifications dated June 29, 2010.

 Page 2
of 22

Item

Registrant

Form

Filing Date

1.

Nuveen Investment Funds, Inc.

N-CSR/A

February 8, 2012

2.

Nuveen Diversified Dividend & Income Fund

N-CSR/A

March 14, 2012

3.

Nuveen Arizona Dividend Advantage Municipal Fund 3

N-SAR-A/A

November 1, 2011

4.

Nuveen California Dividend Advantage Municipal Fund

N-SAR-A/A

November 1, 2011

5.

Nuveen California Dividend Advantage Municipal Fund 3

N-SAR-A/A

November 1, 2011

6.

Nuveen California AMT-Free Municipal Income Fund

N-SAR-A/A

November 1, 2011

7.

Nuveen Investment Funds, Inc.

N-SAR-A/A

January 12, 2012

8.

Nuveen Municipal Trust

N-SAR-A/A

January 12, 2012

9.

Nuveen Investment Funds, Inc.

N-SAR-B/A

January 13, 2012

10.

Nuveen New Jersey Dividend Advantage Municipal Fund 2

N-SAR-A/A

January 17, 2012

11.

Nuveen New Jersey Dividend Advantage Municipal Fund

N-SAR-A/A

January 17, 2012
 2 filings

12.

Nuveen New Jersey Municipal Value Fund

N-SAR-A/A

January 17, 2012

13.

Nuveen New Jersey Premium Income Municipal Fund, Inc.

N-SAR-A/A

January 17, 2012

14.

Nuveen New Jersey Investment Quality Municipal Fund, Inc.

N-SAR-A/A

January 17, 2012

15.

Nuveen Pennsylvania Investment Quality Municipal Fund, Inc.

N-SAR-A/A

January 17, 2012

16.

Nuveen Pennsylvania Premium Income Municipal Fund 2

N-SAR-A/A

January 17, 2012

17.

Nuveen Pennsylvania Dividend Advantage Municipal Fund 2

N-SAR-A/A

January 17, 2012

18.

Nuveen Pennsylvania Dividend Advantage Municipal Fund

N-SAR-A/A

January 17, 2012

19.

Nuveen Pennsylvania Municipal Value Fund

N-SAR-A/A

January 17, 2012

20.

Nuveen Municipal Opportunity Fund Inc.

N-SAR-B/A

January 17, 2012

21.

Nuveen Dividend Advantage Municipal Income Fund

N-SAR-B/A

January 17, 2012

22.

Nuveen Quality Municipal Fund Inc.

N-SAR-B/A

January 17, 2012

23.

Nuveen AMT-Free Municipal Income Fund

N-SAR-B/A

January 17, 2012

24.

Nuveen Multi-Currency Short-Term Gov’t Income Fund

N-SAR-A/A

September 8, 2011

25.

Nuveen Municipal Trust

N-SAR-A/A

May 16, 2012

26.

Nuveen Investment Funds, Inc.

N-SAR-B/A

February 29, 2012

27.

Nuveen Texas Quality Income Municipal Fund

N-Q/A

September 1, 2010

28.

Nuveen Senior Income Fund

N-Q/A

June 30, 2011

29.

Nuveen Floating Rate Income Fund

N-Q/A

June 30, 2011

30.

Nuveen Floating Rate Income Opportunity Fund

N-Q/A

June 30, 2011

31.

Nuveen Investment Trust III

N-Q/A

August 30, 2011

32.

Nuveen Investment Funds, Inc.

N-Q/A

October 13, 2011

33.

Nuveen Investment Funds, Inc.

N-Q/A

October 13, 2011

 Response: The filings in the aforementioned table will be referred to in this response by their
“Item” number as identified in the first column. As indicated in the attached Appendix A, at the time of the Staff’s review the Nuveen Funds were comprised of approximately 230 funds with eleven fiscal year ends. Because the funds
continuously report throughout the course of the year we experience “peaks” and “valleys” in our reporting cycles. Consequently, the “peaks” in our reporting cycles lead to instances where a high volume of edits are
communicated to our staff and/or print vendors in the days immediately preceding the printing and/or filing of shareholder information. This was consequently the primary result for a majority of the amended filings questioned by the Staff. In future
amended filings, we will include an explanatory cover memo and updated certifications.

 Item #1

Form N-CSR/A filed on February 8, 2012, for Item #1 was completed to correct the total returns presented in the October 31,
2011, annual report for the Nuveen Tactical Market Opportunities Fund (“TMO”). TMO’s total returns for Class A Shares and Class C Shares were misstated in its Financial Highlights as follows:

Class A Shares: Original Total Return 6.61%; Corrected Total Return 5.95%

Class C Shares: Original Total Return 5.87%; Corrected Total Return 5.48%

As discussed with you on February 22, 2012, in addition to amending the Form N-CSR we also corrected the Fund’s shareholder
report posted on the fund’s website.

 Page 3
of 22

 Item #2

 Form N-CSR/A filed on March 14, 2012, for Item #2 was completed to include Wellington Management’s proxy voting policies and procedures that were referenced within Item 7 of the filing but
inadvertently left out by our print vendor upon their conversion of the filing from HTML to Edgar format.

 Item #3 through
#6

 Forms N-SAR-A/A filed on November 1, 2011, for Items #3 through #6 were completed to include Exhibit 77E, Legal
Proceedings, which was inadvertently excluded from each filing.

 Items #7 through #19

Forms N-SAR-A/A filed on January 12, 2012, for Items #7 and #8, Form N-SAR-B/A filed on January 13, 2012, for Item #9, and Forms
N-SAR-A/A filed on January 17, 2012, for Items #10 through #19 were completed to correct financial statement data provided in each Form’s original filing. For each item, it was discovered that a draft shareholder report, rather than the
final shareholder report, had been utilized to answer certain questions in the Form, resulting in the inclusion of incorrect financial statement data.

 We have enhanced our procedures around our N-SAR filing process to prevent a repeat of these occurrences. As part of those enhancements, we are currently in the process of obtaining a new web based N-SAR
application, which will allow for a more timely preparation and review process of the filings.

 The second Form N-SAR-A/A
filed on January 17, 2012 for Item #11, was to include Exhibit 77E, Legal Proceedings, which was inadvertently excluded from the Form N-SAR-A/A filing.

 Item #20 through Item #23

 Forms N-SAR-B/A filed on January 17, 2012,
for Items #20 through #23 were completed to correct the funds’ top ten total purchases and sales in questions 23C and 23D, respectively.

 Item #25

 Form N-SAR-A/A filed on May 16, 2012, for Item #25 was
completed to add the name of fund number two within the trust as required by question 7 C020200, which was inadvertently excluded from the filing.

 Item #26

 Form N-SAR-B/A filed on February 29, 2012, was completed to
restate certain financial statement information for Nuveen Real Estate Securities Fund for the fiscal year ended October 31, 2011, and to replace the Accountants Report on Internal Control in Exhibit 77B in conjunction with the matter.

 Item #27

 Form N-Q/A filed on September 1, 2010, for Item #27 was completed to reinsert a page that was inadvertently left out of the original Form N-Q filed by our print vendor upon their conversion of the
filing from HTML to Edgar format.

 Items #28 through #31

Forms N-Q/A filed on June 30, 2011, for Items #28 through #30 and August 30, 2011, for Item #31 were completed to reflect edits
our print vendor was unable to incorporate into the filing prior to the 4:30 p.m. CT filing deadline. The filings were amended immediately upon receipt of the completed edits.

Items #32 and #33

 Forms N-Q/A filed on October 13, 2011, for Items #32 and #33 were completed to correct the funds’ Accounting Standards Codification 820 (“ASC 820”) fair value measurement
disclosures included within the portfolios of investments. The review of the ASC 820 disclosures included within the original filing was performed by an individual other than the Fund Administration – Financial Reporting manager typically
responsible for overseeing the ASC 820 review process, as he was out of the office on holiday immediately preceding and on the original filing date. Upon his return, he re-performed the ASC 820 review and identified differences we believed should be
corrected. We have since then enhanced our overall ASC 820 procedures by familiarizing other higher level individuals within the Financial Reporting department with such reviews.

4)
Comment: For those Nuveen closed-end funds that had lawsuits related to Auction Rate Preferred Shares (“ARPS”), the SEC staff did not
observe the filed complaints as required by Section 33 of the 1940 Act.

 Response: Twenty-three
of the affected funds filed the relevant Complaint with the Securities and Exchange Commission (“SEC”) on August 20, 2010, in paper form. We can provide you with versions that are receipt-stamped by the SEC staff if you desire.
Following the submissions by those funds, the plaintiffs named an additional eleven funds to the matter, but for which Section 33 filings were inadvertently omitted. Upon final disposition of the

CORRESP
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CORRESP

       February 17, 2012

 Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

Attn:    Mr. Kieran Brown

Re:
 Nuveen New York Dividend Advantage Municipal Fund (811-09135); Nuveen New York Dividend Advantage Municipal Fund 2 (811-10253); Nuveen New York
Investment Quality Municipal Fund, Inc. (811-06178); Nuveen New York Municipal Value Fund, Inc. (811-05238); Nuveen New York Municipal Value Fund 2 (811-22271); Nuveen New York Performance Plus Municipal Fund, Inc. (811-05931); Nuveen New
York Quality Income Municipal Fund, Inc. (811-06424); Nuveen New York Select Quality Municipal Fund, Inc. (811-06295); Nuveen New York Dividend Advantage Municipal Income Fund (811-09473); Nuveen New York Premium Income Municipal Fund, Inc.

(811-06619); Nuveen New York AMT-Free Municipal Income Fund (811-21211); Nuveen Core Equity Alpha Fund (811-22003); Nuveen Real Estate Income Fund (811-10491); Nuveen Diversified Dividend and Income Fund (811-21407); Nuveen Equity Premium and
Growth Fund (811-21809); Nuveen Equity Premium Advantage Fund (811-21731); Nuveen Equity Premium Income Fund (811-21619); Nuveen Equity Premium Opportunity Fund (811-21674); Nuveen Quality Preferred Income Fund (811-21082); Nuveen Quality Preferred
Income Fund 2 (811-21137); Nuveen Quality Preferred Income Fund 3 (811-21242); Nuveen Tax-Advantaged Total Return Strategy Fund (811-21471); Nuveen Tax-Advantaged Dividend Growth Fund (811-22058); Nuveen Global Government Enhanced Income Fund
(811-21893); Nuveen Global Value Opportunities Fund (811-21903); Nuveen Mortgage Opportunity Term Fund (811-22329); Nuveen Mortgage Opportunity Term Fund 2 (811-22374); Nuveen Multi-Currency Short-Term Government Income Fund (811-22018); Nuveen
Multi-Strategy Income and Growth Fund (811-21293); Nuveen Multi-Strategy Income and Growth Fund 2 (811-21333); Dow
30SM Premium & Dividend Income Fund Inc.
(811-21708); Global Income & Currency Fund Inc. (811-21791); NASDAQ Premium Income & Growth Fund Inc. (811-21983); and Dow 30SM Enhanced Premium & Income Fund Inc. (811-22029) (each, a “Registrant” and together, the
“Registrants”)

 Securities and Exchange Commission

 February 17, 2012

 Page 2

 To The Commission:

 On behalf of the Registrants this letter is in response to
the comments you provided on February 13, 2012 during our telephone conference regarding the preliminary proxy materials filed for each Registrant on February 2, 2012. Any terms not defined herein have the same meanings as given in the preliminary
proxy statement.

 1. Comment: Please clarify why the Affected Municipal Funds would likely incur further expenses to solicit
additional shareholder participation if shareholders do not approve the elimination of the fundamental investment policy and/or do not approve a new investment policy?

 Response: The Affected Municipal Funds would likely incur further expenses to solicit additional shareholder participation because, as part of Nuveen’s efforts to ensure that all of its
municipal bond closed-end fund policies are uniform, Nuveen may re-solicit shareholders until the proposal is approved if it is determined that further solicitation is reasonable and in the best interest of the shareholders.

2. Comment: In the Notice to Shareholders, please clarify that implementation of the new investment policy for each Affected Municipal Fund
is contingent on shareholders approving the elimination of their current investment policy.

 Response: The
following language has been added in each Registrant’s Notice to Shareholders in response to the staff’s request:

Proposals 2(b)(i) and 2(b)(ii) are contingent on shareholder approval of proposals 2(a)(i) and 2(a)(ii), respectively.

3. Comment: With respect to the Board Nominees/Board Members table on page 10 of each Registrant’s proxy statement, please revise the
last column heading to “Other Directorships Held By Board Member During the Past Five Years.”

Response: The heading in the table has been revised accordingly in each Registrant’s proxy statement.

4. Comment: With respect to the proposal relating to the change of fundamental investment policy for each Affected Municipal Fund, please
provide additional risk disclosure.

 Response: The following disclosure concerning principal risks of the New
Fundamental Loan Policy has been added in response to the staff’s request:

 Securities and Exchange Commission

 February 17, 2012

 Page 3

Loans to issuers in distress; however involve risks. It is possible a Fund could lose its entire investment with an issuer as well as the
amount loaned.

 Please direct your questions regarding this filing to the undersigned at (312) 609-7732.

 Sincerely,

 /s/Jennifer M. Goodman

CORRESP
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    VEDDER PRICE P.C.

    222 NORTH LASALLE STREET

    CHICAGO, ILLINOIS 60601

    312-609-7500

    FAX: 312-609-5005

    CHICAGO • NEW YORK CITY • WASHINGTON, D.C.

    September 16, 2011

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Kieran Brown

    Re:

     Nuveen Multi-Strategy Income and Growth Fund (JPC), File No. 811-21293;

Nuveen Multi-Strategy Income and Growth Fund 2 (JQC), File No. 811-21333

To The Commission:

     On behalf of the Nuveen Multi-Strategy Income and Growth Fund and Nuveen Multi-Strategy Income
and Growth Fund 2 (each, a “Registrant” and together, the “Registrants”) this letter is in response
to the comments you provided on September 12, 2011 during our telephone conference regarding the
preliminary proxy materials filed for each Registrant on September 2, 2011. Any terms not defined
herein have the same meanings as given in the preliminary proxy statement.

1. Comment: For each Registrant, in the Q&A, please add additional language as to what components
of the Repositioning Plan may or may not take effect if shareholders do not approve the proposal(s)
in response to the question, “What happens if shareholders do not approve [the/these] proposals?”

     Response: Language has been added in each Registrant’s proxy statement in response to the
staff’s request.

2. Comment: For each Registrant, please clarify its address in the proxy statement.

     Response: Language has been added in each Registrant’s proxy statement in response to the
staff’s request.

3. Comment: With respect to JPC, in the section “Summary of Current and Proposed Sub-Advisory
Agreements,” please move the relevant information from the Appendices to the section.

     Response: The relevant information has been relocated in JPC’s proxy statement in response to
the staff’s request.

Securities and Exchange Commission

September 16, 2011

Page 2

4. Comment: With respect to JPC, were any sub-advisers other than NWQ and NAM considered?

     Response: In connection with the proposed repositioning of JPC, the Board received and
considered the investment process of various potential sub-advisers, including non-affiliated
investment managers, as discussed under the heading “Board Considerations in Approving the Proposed
Sub-Advisory Agreements.” In reviewing potential sub-advisers for JPC, the Board reviewed an
analysis of different combinations of sub-advisers and took into account the goal of
differentiating JPC from other existing Nuveen preferred securities funds while offering investors
access to investment managers with distinctive, complementary approaches to the preferred
securities market.

     Please direct your questions and/or comments regarding this filing to the undersigned at (312)
609-7796 or Deborah Bielicke Eades at (312) 609-7661.

Sincerely,

/s/ Abigail J. Murray

333 West Wacker Drive

Chicago, Illinois 60606

September 16, 2011

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

Attn: Mr. Kieran Brown

    Re:

     Nuveen Multi-Strategy Income and Growth Fund (JPC), File No. 811-21293;

Nuveen Multi-Strategy Income and Growth Fund 2 (JQC), File No. 811-21333

To the Commission:

     This letter is provided to the Securities and Exchange Commission (the “Commission”) in
connection with a response being made on behalf of the Nuveen Multi-Strategy Income and Growth Fund
and Nuveen Multi-Strategy Income and Growth Fund 2 (each, a “Registrant” and together, the
“Registrants”) to comments that you provided with respect to each Registrant’s preliminary proxy
statement filed with the Commission on September 2, 2011.

     Each Registrant acknowledges that the adequacy and accuracy of the disclosure in the filings
is the responsibility of the Registrant. Each Registrant acknowledges that any comments or changes
to disclosure in the filings reviewed by the Commission staff, acting pursuant to delegated
authority, do not foreclose the Commission from taking any action with respect to the filings and
each Registrant represents that it will not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

Nuveen Investment Trust

    By:

/s/ Kevin J. McCarthy

    Kevin J. McCarthy

    Vice President and Secretary

CORRESP
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SEC Response Letter

 April 16, 2010

Ms. Christina DiAngelo

 U.S. Securities
and Exchange Commission

 450
5th Street, NW

Washington, D.C. 20549

 Re: Nuveen
Closed-End and Open-End Funds - Sarbanes Oxley Review

 Dear Christina:

This letter addresses your comments provided in a telephone discussion on September 29, 2009. Each comment is shown below followed by our response.
Unless otherwise noted, the responses relate to all funds listed on Appendix A attached hereto.

1)
Comment: (a) 479 Letters – Nuveen was recently sent 479 letters regarding de-registering funds no longer in existence. Please
de-register funds identified within letter.

 Response: 1(a) We have received the
correspondence from the staff and we have prepared and submitted correspondence to the U.S. Securities and Exchange Commission (“SEC”) via IDEA seeking to withdraw the Securities Act registration statements that were pending for the funds
identified by the staff. In addition, we have also identified several others funds for which we filed to withdraw pending registration statements prior to filing a Form N-8F for each of those funds. Finally, we have filed a Form N-8F for each of the
funds covered by the staff’s correspondence as well as the additional funds identified by us as detailed in the table below.

 Fund Name

CIK

Date
withdrawal
filed with SEC

Date N-8F
filed with
SEC

 Nuveen North Carolina Municipal Value Fund

0001461194

12-3-2009

3-9-2010

 Nuveen High Income Municipal Fund

0001464620

12-3-2009

3-9-2010

 Nuveen Virginia Municipal Value Fund

0001461195

12-3-2009

3-9-2010

 Nuveen Ohio Municipal Value Fund

0001461196

12-3-2009

3-9-2010

 Nuveen Massachusetts Municipal Value Fund

0001461193

12-3-2009

3-9-2010

 Nuveen Maryland Municipal Value Fund

0001461192

12-3-2009

3-9-2010

 Nuveen Connecticut Municipal Value Fund

0001461191

12-3-2009

3-9-2010

 Nuveen High Grade Municipal Income Fund

0001461189

12-3-2009

3-9-2010

 Fund Name

CIK

Date
withdrawal
filed with SEC

Date N-8F
filed with
SEC

 Nuveen Multistate Shell Trust

0001018970

12-17-2009

3-9-2010

 Nuveen Investment Trust IV

0001071680

12-3-2009

3-9-2010

 Nuveen Credit Strategies Fund

0001412349

12-3-2009

3-9-2010

 Nuveen Symphony Market Neutral Fund

0001209540

12-3-2009

3-9-2010

 Nuveen Connecticut Municipal Income Opportunity Fund

0001424452

12-3-2009

3-9-2010

 Nuveen Multi-Currency Income Fund

0001400390

12-3-2009

3-9-2010

 Nuveen Municipal High Income Advantage Fund, formerly called Nuveen Municipal High Income Opportunity Fund 3

0001424214

12-3-2009

3-9-2010

 Nuveen Washington Premium Income Fund

0000897420

N/A

12/16/2009

 Nuveen Floating Rate Fund

0001093189

N/A

1/27/2010

Comment: (b) Two Nuveen funds – Nuveen Floating Rate Fund (Reg. No. 811-09553) and Nuveen Washington
Premium Income Municipal Fund (Reg. No. 811-07488) – have apparently ceased operations, but in fact have continued to file their semi-annual reports on Form N-SARs, although they have not continued to file their annual report of proxy
votes on Form N-PX. Assuming that these funds in fact have ceased operations, the SEC staff requests that these funds do two things:

a.
File for termination of their 1940 Act registration on Form N-8F; and

b.
File all the missed Form N-PXs.

Response: 1(b) The SEC staff is correct that each of these funds ceased operations, the former on May 28, 2003, and the
latter on September 9, 1999. We have obtained the necessary data and filed a Form N-8F for each of these funds as outlined in the table below. In addition we will also file the Form N-PXs for each fund going back to the date of the first
required filing under that Form after its adoption.

 Fund Name

CIK

Date N-8F
filed with
SEC

 Nuveen Washington Premium Income Fund

0000897420

12/16/2009

 Nuveen Floating Rate Fund

0001093189

1/27/2010

 2

2)
Comment: Amendments to filings made pursuant to Rule 17g-1 on Form 40-17/G should be identified on EDGAR with the filing type 40-17G/A.

 Response: The funds will identify such filings in the future as requested.

3)
Comment: Item 8 of Form N-CSR requires that closed-end funds, in their annual N-CSR filing, describe the compensation structure for all named
Portfolio Managers of the fund or funds included in the filing. Specifically, Item 8(a)(3) reads in pertinent part as follows:

Describe the structure of, and the method used to determine, the compensation of each Portfolio Manager . . . . For each type of
compensation (e.g., salary, bonus, deferred compensation, retirement plans and arrangements), describe with specificity the criteria on which that type of compensation is based, for example, whether compensation is fixed, whether (and, if so, how)
compensation is based on the registrant’s pre- or after-tax performance over a certain time period, and whether (and, if so, how) compensation is based on the value of assets held in the registrant’s portfolio. For example, if compensation
is based solely or in part on performance, identify any benchmark used to measure performance and state the length of the period over which performance is measured.

Instruction 3 to Item 8(a)(3) reads, in pertinent part:

This description must clearly disclose any differences between the method used to determine the Portfolio Manager’s compensation
with respect to the registrant and other accounts, e.g., if the Portfolio Manager receives part of an advisory fee that is based on performance with respect to some accounts but not the registrant, this must be disclosed.

The SEC staff stated that the disclosure about the structure of Portfolio Manager compensation for several funds was inadequate, and
needed more detail. The staff gave examples of several of those funds, including:

•

 Nuveen Diversified Dividend and Income Fund (JDD)

•

 Nuveen Tax-Advantaged Total Return Strategy Fund (JTA)

•

 Nuveen Floating Rate Income Fund (JFR)

•

 Nuveen Floating Rate Income Opportunity Fund (JRO)

•

 Nuveen Senior Income Fund (NSL)

•

 Nuveen Equity Premium Income Fund (JPZ)

•

 Nuveen Equity Premium Opportunity Fund (JSN)

•

 Nuveen Equity Premium Advantage Fund (JLA)

•

 Nuveen Equity Premium and Growth Fund (JPG)

Response: We have initiated a review of the Portfolio Manager compensation disclosure in our N-CSRs and Statements of
Additional Information. As various types of filings for these and other Nuveen funds are made, we have undertaken to revise and expand the Portfolio Manager compensation discussion where appropriate and we will continue to do so as new filings are
made.

 Although we are near the beginning of the twelve-month cycle over which this disclosure will be reviewed and revised, we
have found already that it is often not easy to expand the disclosure in a meaningful way, despite the specificity of the Form requirements quoted above. For example, in October we reviewed the Portfolio Manager compensation disclosure for several
equity funds managed by Nuveen affiliate, Symphony Asset Management (“SAM”). We held several lengthy

 3

discussions with the staff of SAM to better understand their compensation-setting process, and to turn our understanding into disclosure that fully responded to the Form requirements. In that
discussion, it became clear to the lawyers responsible for drafting the disclosure that SAM’s actual compensation-setting mechanism was highly subjective, and was not really susceptible to the sort of criteria-specific disclosure required by
the Form. For example, investment performance relative to a benchmark is not a specific criterion for compensation-setting by SAM. So, while we did revise and expand the disclosure in an attempt to respond to the Form requirements and to provide the
reader with some additional insight into the compensation-setting process, it does not contain all the specific items mentioned in the rule and the instructions thereto, simply because those items do not apply in that case. That disclosure,
contained in the post-effective amendment filing on November 2, 2009, for Nuveen Investment Trust, SEC Accession No. 0001193125-09-219820, is as follows:

SAM investment professionals receive competitive base salaries and annual bonus payments. Base salaries are determined by SAM’s
senior management and reviewed periodically to ensure competitiveness with comparable positions at similar asset management firms. The bonus pool is based in part on SAM’s aggregate management fees which include asset based fees and, for
some firm clients (other than mutual funds) performance fees. An investment professional’s bonus compensation is not based on any fixed formula, but is determined by senior management on a discretionary basis, based on senior
management’s assessment of the individual professional’s contribution to the firm’s revenue, as well as his or her individual work performance, contribution to the investment team, strategy performance, and overall firm
performance. In addition, SAM’s investment professionals may participate in long-term incentive plans which are tied to ongoing year-over-year firm performance, profitability and growth.

One complicating factor for the Nuveen funds and this Portfolio Manager compensation disclosure is that the Nuveen funds, of which there
are over 200, are managed by fourteen different advisory entities, including affiliates Nuveen Asset Management, Symphony Asset Management, Santa Barbara Asset Management, NWQ Investment Management Company, Tradewinds Global Investors, LLC, Winslow
Capital Management, Nuveen Investment Solutions, and Nuveen HydePark Group; and non-affiliates Spectrum Asset Management, Institutional Capital Corporation, Gateway Investment Advisers LLC, Wellington Management Company, LLP, Security Capital
Research and Management, Inc., and INTECH Investment Management. Each of these entities has their own compensation-setting arrangements, which are in effect entirely independent of each other, and those arrangements vary widely from firm to firm
(and sometimes there are variances between or among different investment teams within an organization). Therefore, there will be little or no commonality between and among the compensation disclosures for each of these entities.

4)
Comment: In the Annual Investment Management Agreement Approval Process sections of shareholder reports, consider increasing the specificity as
to what the Board is approving and whether they believe such approvals to be reasonable/satisfactory.

Response: In the next annual approval of each fund’s investment management agreement, we will work with counsel to the
independent trustees of the funds to prepare and submit with the next shareholder report for each fund more specific information as to the factors considered and deemed

 4

relevant by the trustees. The process for the trustees’ consideration of the next annual contract renewals began earlier this spring, with a final determination expected to be made by the
Board at a regular scheduled meeting at the end of May. The updated disclosure will then be included in the next succeeding shareholder report issued by each fund.

5)
Comment: In the prospectuses for the Nuveen mutual funds, custodian fee credits should not be presented as a separate line item within the fee
tables.

 Response: Custodian fee credits have been removed from the fee table presentations.

6)
Comment: In the Symphony International Equity Fund prospectus dated November 28, 2009, footnote 9 states that “Other Expenses”
have been restated. Please explain what has been restated and why.

 Response: Nuveen Symphony
International Equity Fund commenced operations on May 30, 2008; therefore, the expense ratios presented in the annual report represented only 63 days of operations. “Other Expenses” and “Total Annual Fund Operating Expenses”
were restated to better reflect anticipated expenses of the Fund. “Custodian Fee Credits” were not presented and “Fee Waivers and Expense Reimbursements” were restated in order to reflect the impact of the restated
“Other Expenses” while keeping “Total Annual Fund Operating Expenses – Net” at the Fund’s expense limit of 1.13% (plus class specific 12b-1 fees where applicable) which is in effect through November 30, 2011.

7)
Comment: In the prospectuses for the Nuveen mutual funds (for example, on page 3 of the prospectus for the funds that are a series of Nuveen
Municipal Trust), the Class C Shares are described, in footnote 10, as being subject to a contingent deferred sales charge (“CDSC”) of 1% if redeemed “within less than one year of purchase,” but in the 1-Year line in the expense
example the CDSC is not reflected in the expense figure. Please explain why the 1-Year CDSC is not reflected in the 1-Year expense figure in that table.

Response: As discussed during the call, the CDSC for the Nuveen mutual funds operates such that if a shareholder’s
holding period prior to a redemption is for an entire period in question (in this case, one year), the CDSC percentage that applies to the redemption is reduced to the percentage applicable to the next longest holding period. In the case of Class C
Shares, which imposes a CDSC where the holding period is within one year but not for longer periods, once the shares are held for an entire year there is no CDSC.

8)
Comment: In the semi-annual report dated January 31, 2009, for Enhanced Multi-Strategy Managed Accounts Portfolio, the Fund’s
portfolio of investments has more than 60% invested in mortgage-backed securities. Consider enhancing prospectus disclosures regarding policies around investment concentration.

Response: The following disclosure was added to the Fund’s prospectus under the heading “Principal Investment
Strategies” during the most recently completed annual update (see post-effective amendment filing on November 27, 2009, for Nuveen Managed Accounts Portfolios Trust, SEC Accession No. 0001193125-09-243275):

 5

 “In addition, the Portfolio may invest a substantial portion of its assets in
mortgage-backed securities, including U.S. agency mortgage-backed securities and commercial mortgage-backed securities.”

In addition, the risk disclosure discussing the risk related to mortgage-backed securities has been revised to indicate that a substantial
portion of the fund’s assets may be invested in such securities.

9)
Comment: In the semi-annual report dated March 31, 2009, for Nuveen High Yield Bond Fund, the Statement of Operations shows a $9.4 million
loss from an interest rate swap. When we reviewed the prospectus for that fund, we did not see the expected high level of disclosure about the risks associated with the fund’s significant exposure to derivatives in general and specifically to
interest rate swaps. Please explain how you intend to enhance the prospectus disclosure about the fund’s use of derivatives and the risks associated therewith, or alternatively explain why such enhancements to the existing disclosure is not
necessary.

 Response: Disclosure regarding the fund’s use of derivatives and the risks
associated therewith was enhanced during the fund’s most recently completed annual update (see post-effective amendment filing on February 1, 2010, for Nuveen Investment Trust III, SEC Accession No. 0001193125-10-017408). The two
paragraphs below appear in the fund’s summary prospectus dated January 30, 2010, and are marked to show changes from the prior year’s prospectus dated January 30, 2009:

“In an effort to hedge risk, enhance returns, or as a substitute for a position in the underlying asset, the fund also may invest in
futures, options, interest rate or total return swaps, credit derivatives or other fixed income derivative instruments. In doing so, the fund may, in certain circumstances, invest a substantial portion of its assets in such
derivative instruments.”

 “The fund may, in certain circumstances, invest a substantial portion of its assets
in derivative instruments, incl

CORRESP
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corresp

JENNIFER M. GOODMAN

312-609-7732

jgoodman@vedderprice.com

May 16, 2008

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Jim O’Connor

    Re:

    Nuveen New York Dividend Advantage Municipal Fund, Nuveen New York Dividend
Advantage Municipal Fund 2, Nuveen New York Investment Quality Municipal Fund, Inc.,
Nuveen New York Municipal Value Fund, Inc., Nuveen New York Performance Plus
Municipal Fund, Inc., Nuveen New York Quality Income Municipal Fund, Inc., Nuveen New
York Select Quality Municipal Fund, Inc., Nuveen Insured Dividend Advantage Municipal
Fund, Nuveen Insured Municipal Opportunity Fund, Inc., Nuveen Insured Premium Income
Municipal Fund 2, Nuveen Insured Quality Municipal Fund, Inc., Nuveen Insured
Tax-Free Advantage Municipal Fund, Nuveen Insured New York Dividend Advantage
Municipal Fund, Nuveen Insured New York Premium Income Municipal Fund, Inc., Nuveen
Insured New York Tax-Free Advantage Municipal Fund, Nuveen Premier Insured Municipal
Income Fund, Inc., Nuveen Core Equity Alpha Fund, Nuveen Real Estate Income Fund,
Nuveen Diversified Dividend and Income Fund, Nuveen Equity Premium and Growth Fund,
Nuveen Equity Premium Advantage Fund, Nuveen Equity Premium Income Fund, Nuveen
Equity Premium Opportunity Fund, Nuveen Quality Preferred Income Fund, Nuveen Quality
Preferred Income Fund 2, Nuveen Quality Preferred Income Fund 3, Nuveen
Tax-Advantaged Total Return Strategy Fund, Nuveen Tax-Advantaged Dividend Growth
Fund, Nuveen Global Government Enhanced Income Fund, Nuveen Global Value
Opportunities Fund, Nuveen Multi-Currency Short-Term Government Income Fund, Nuveen
Multi-Strategy Income and Growth Fund and Nuveen Multi-Strategy Income and Growth
Fund 2

    (each a “Registrant” or a “Fund”)

To the Commission:

     On behalf of each above Registrant, this letter is in response to the comment you provided on
May 5, 2008 during our telephone conference regarding the preliminary proxy of each Registrant
filed on [or about] April 25, 2008.

     Comment: With respect to the expenses of proxy solicitation for the change in fundamental
polices, please explain why the expenses are being borne by the Funds, as contrasted to the
proposals that
are set forth in the preliminary proxy statement filed on April 25, 2008 by other Nuveen
registrants that are being, in part, paid for by the investment adviser of those funds.

Securities and Exchange Commission

May 16, 2008

Page 2

     Response: The Board of Trustees/Directors of each Fund (the “Boards”) determined that the
expenses of proxy solicitation for the proposals relating to the change in fundamental policies
should be borne by the Funds because each Board believed that such changes would be beneficial to
the shareholders by enhancing the Fund’s ability to meet its investment objective and also allowing
the Fund to be fully invested. In contrast, the proposals presented in the proxy statement with
respect to the other Nuveen funds, filed on April 25, 2008 are, in part, being paid for by the
investment adviser of those funds pursuant to an understanding negotiated between the investment
adviser and the Boards of those funds. The Boards felt that the investment adviser would also
benefit from the proposals to change the structure of those funds because it would be an improved
investment product and thus more assets would likely be gained.

    Sincerely,

    /s/ Jennifer M. Goodman

    Jennifer M. Goodman

Nuveen Investments, Inc.

333 West Wacker Drive

Chicago, Illinois 60606

May 15, 2008

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

    Re:

    Definitive Proxy Materials and Proxy Statement Files Nos.:

    Nuveen New York Dividend Advantage Municipal Fund (811-09135), Nuveen New York
Dividend Advantage Municipal Fund 2 (811-10253), Nuveen New York Investment
Quality Municipal Fund, Inc. (811-06718), Nuveen New York Municipal Value Fund,
Inc. (811-05238), Nuveen New York Performance Plus Municipal Fund, Inc.
(811-05931), Nuveen New York Quality Income Municipal Fund, Inc. (811-06424),
Nuveen New York Select Quality Municipal Fund, Inc. (811-06295), Nuveen Insured
Dividend Advantage Municipal Fund (811-09475), Nuveen Insured Municipal
Opportunity Fund, Inc. (811-06379), Nuveen Insured Premium Income Municipal Fund 2
(811-07792), Nuveen Insured Quality Municipal Fund, Inc. (811-06206), Nuveen
Insured Tax-Free Advantage Municipal Fund (811-21213), Nuveen Insured New York
Dividend Advantage Municipal Fund (811-09473), Nuveen Insured New York Premium
Income Municipal Fund, Inc. (811-06619), Nuveen Insured New York Tax-Free
Advantage Municipal Fund (811-21211), Nuveen Premier Insured Municipal Income
Fund, Inc. (811-06457), Nuveen Core Equity Alpha Fund (811-22003), Nuveen Real
Estate Income Fund (811-10491), Nuveen Diversified Dividend and Income Fund
(811-21407), Nuveen Equity Premium and Growth Fund (811-21809), Nuveen Equity
Premium Advantage Fund (811-21731), Nuveen Equity Premium Income Fund (811-21619),
Nuveen Equity Premium Opportunity Fund (811-21674), Nuveen Quality Preferred
Income Fund (811-21802), Nuveen Quality Preferred Income Fund 2 (811-21137),
Nuveen Quality Preferred Income Fund 3 (811-21242), Nuveen Tax-Advantaged Total
Return Strategy Fund (811-21471), Nuveen Tax-Advantaged Dividend Growth Fund
(811-22058), Nuveen Global Government Enhanced Income Fund (811-21893), Nuveen
Global Value Opportunities Fund (811-21903), Nuveen Multi-Currency Short-Term
Government Income Fund (811-22018), Nuveen Multi-Strategy Income and Growth Fund
(811-21293) and Nuveen Multi-Strategy Income and Growth Fund 2 (811-21333) (each a
“Registrant”).

Ladies and Gentlemen:

     This letter is provided to the Securities and Exchange Commission (the “Commission”) in
connection with a response being made on behalf of the Registrant to comments that you provided
with respect to the Registrant’s preliminary proxy statement filed with the Commission on or about
April 25, 2008.

VIA EDGAR

Securities and Exchange Commission

May 15, 2008

Page 2

     The Registrant acknowledges that the adequacy and accuracy of the disclosure in the filings is
the responsibility of the Registrant. The Registrant acknowledges that any comments or changes to
disclosure in the filings reviewed by the Commission staff, acting pursuant to delegated authority,
do not foreclose the Commission from taking any action with respect to the filings and the
Registrant represents that it will not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

Nuveen Investments, Inc.

    By:
    /s/ Kevin J. McCarthy

    Kevin J. McCarthy

    Vice President and Secretary