![]() |
Steben & Company, Inc. | 240.631.7600 T | |
9711 Washingtonian Blvd., Suite 400 | 240.631.9595 F | ||
Gaithersburg, MD 20878 | www.steben.com |
November 27, 2013
VIA EDGAR
Anu Dubey
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4720
Re: |
Request for Acceleration Steben Select Multi-Strategy Fund Pre-Effective Amendment No. 5 File Nos. 333-187847 and 811-22824 |
Dear Ms. Dubey:
Pursuant to Rule 461 of Regulation C under the Securities Act of 1933, as amended (“1933 Act”), Steben Select Multi-Strategy Fund (the “Fund”) hereby requests that effectiveness under the 1933 Act of the above-captioned Pre-Effective Amendment to its registration statement on Form N-2 (“Registration Statement”) be accelerated to November 27, 2013. Pre-Effective Amendment No. 5 was filed on November 27, 2013 under the 1933 Act and the Investment Company Act of 1940, as amended. The Fund is aware of its obligations under the 1933 Act.
In support of its request for acceleration, the Fund acknowledges that:
1. | Should the Securities and Exchange Commission (“SEC”) or the SEC staff, acting pursuant to delegated authority, declare the Registration Statement effective, such action does not foreclose any action by the SEC with respect to the filing; | |
2. | The action of the SEC or the SEC staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Fund from its full responsibility for the adequacy and accuracy of the filing; and | |
3. | The Fund will not assert the SEC staff's acceleration of effectiveness of the filing as a defense in any proceeding initiated by the SEC or any other person under the federal securities laws. |
Sincerely,
Steben Select Multi-Strategy Fund
/s/ Francine J. Rosenberger
Francine J. Rosenberger
Secretary
Foreside Fund Services, LLC
Three Canal Plaza
Suite 100
Portland, Maine 04101
November 27, 2013
VIA EDGAR
Anu Dubey
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4720
Re: |
Request for Acceleration Steben Select Multi-Strategy Fund Pre-Effective Amendment No. 5 File Nos. 333-187847 and 811-22824 |
Dear Ms. Dubey:
As the distributor of the above-captioned fund (the “Fund”), the undersigned hereby joins in the request of the Fund, pursuant to Rule 461 of Regulation C under the Securities Act of 1933, as amended (“1933 Act”), that effectiveness under the 1933 Act of Pre-Effective Amendment No. 4 to the Fund’s registration statement on Form N-2, be accelerated to November 27, 2013. Pre-Effective Amendment No. 5 was filed on November 27, 2013 under the 1933 Act and the Investment Company Act of 1940, as amended. The undersigned is aware of its obligations under the 1933 Act.
Foreside Fund Services, LLC |
By: /s/ Mark Fairbanks |
Name: Mark Fairbanks |
Title: President |
M