Wildermuth Endowment Strategy Fund
11525 Park Woods Circle, Ste. 200
Alpharetta, Georgia 30005
December 19, 2014
VIA EDGAR TRANSMISSION
United States Securities and Exchange Commission
100 F Street, N.E.
Division of Investment Management
Washington, DC 20549
Attn: Amy W. Miller
Re: | ACCELERATION OF EFFECTIVENESS REQUEST Wildermuth Endowment Strategy Fund (the “Fund”) Registration File Numbers: 333-191152 & 811-22888 |
Dear Ms. Miller:
On behalf of the Fund, we hereby request acceleration of the registration statement that was filed on December 17, 2014 on Form N-2 under the Securities Act of 1933, as amended (the “1933 Act”), as Pre-Effective Amendment No. 3 (the “amendment”), and the Investment Company Act of 1940, as amended (the “1940 Act”), so the registration statement on Form N-2 would be declared effective on December 22, 2014. Pursuant to the U.S. Securities and Exchange Commission’s authority under Rule 461(a) under the 1933 Act, we have attached a separate letter from Realty Capital Securities, LLC, the Fund’s principal underwriter, requesting that effectiveness of the amendment to the registration statement be accelerated to Monday, December 22, 2014 or as soon as practicable thereafter.
The Fund acknowledges that (i) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any actions with respect to the filing, (ii) the action of the Commission or the 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 disclosure in the filing, and (iii) the Fund may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please direct any questions you may have with respect to the foregoing to David J. Baum (at 202-239-3346) of Alston & Bird LLP.
Very truly yours,
By: /s/Daniel Wildermuth
Daniel Wildermuth
President and Chief Executive Officer
Wildermuth Endowment Strategy Fund
Enclosure
REALTY CAPITAL SECURITIES, LLC
December 19, 2014
VIA EDGAR TRANSMISSION
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Ladies and Gentlemen:
Wildermuth Endowment Strategy Fund
REQUEST FOR ACCELERATION. As the principal underwriter of the Wildermuth Endowment Strategy Fund (the “Fund”), and pursuant to the U.S. Securities and Exchange Commission’s authority under Rule 461(a) under the Securities Act of 1933, we request that effectiveness of the Registration Statement that was filed on Form N-1A on behalf of the Fund on December 17, 2014, be accelerated to Monday, December 22, 2014 or as soon as practicable thereafter.
Very truly yours,
Realty Capital Securities, LLC
/s/Louisa Quarto
Louisa Quarto
President
405 Park Avenue
New York, New York 10022