CORRESP 11 filename11.htm

 

  Steben & Company, Inc. 240.631.7600 T
9711 Washingtonian Blvd., Suite 400 240.631.9595 F
Gaithersburg, MD 20878 www.steben.com

 

July 26, 2017

 

VIA EDGAR

 

Ashley Vroman-Lee

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

Post-Effective Amendment No. 2

File Nos. 333-211724 and 811-22824

 

Dear Ms. Vroman-Lee:

 

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 Post-Effective Amendment (“PEA 2”) to its registration statement on Form N-2 (“Registration Statement”) be accelerated to July 28, 2017.  PEA 2 was filed on July 26, 2017 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

 

July 26, 2017

 

VIA EDGAR

 

Ashley Vroman-Lee

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

Post-Effective Amendment No. 2

File Nos. 333-211724 and 811-22824

 

Dear Ms. Vroman-Lee:

 

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 Post-Effective Amendment No. 2 to the Fund’s registration statement on Form N-2 (“PEA 2”), be accelerated to July 28, 2017. PEA 2 was filed on July 26, 2017 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: Vice President