CORRESP 5 filename5.txt Highland Credit Strategies Fund Two Galleria Tower 13455 Noel Road, Suite 800 Dallas, Texas 75240 April 16, 2008 Dominic Minore Office of Investment Company Regulation Division of Investment Management United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Request for Acceleration Highland Credit Strategies Fund Pre Effective Amendment No. 1 to Registration Statement on Form N-14 File Nos. 333-149424 and 811-21869 Dear Mr. Minore: Pursuant to Rule 461 of Regulation C under the Securities Act of 1933, as amended ("1933 Act"), the undersigned, on behalf of the above-referenced Registrant, hereby requests that effectiveness under the 1933 Act of Pre Effective Amendment No. 1 to the registration statement on Form N-14 be accelerated so that it may become effective by 4:00 p.m. Eastern Time on Friday, April 18, 2008, or as soon thereafter as practicable. Sincerely, /s/ M. Jason Blackburn Name: M. Jason Blackburn Title: Secretary Highland Credit Strategies Fund