The Gabelli Convertible and Income Securities Fund Inc.
One Corporate Center
Rye, New York 10580-1422
(914) 921-5100
July 27, 2011
VIA EDGAR:
Ms. Laura E. Hatch
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549
Re: The Gabelli Convertible and Income Securities Fund Inc. File Nos.
333- 174294 and 811-05715
Dear Ms. Hatch:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, (the 1933 Act) The Gabelli Convertible and Income Securities Fund Inc.(the
Fund) hereby requests acceleration of the effective date of the Funds Pre-Effective Amendment
No. 1 to the Registration Statement (File Nos. 333-174294 and 811-05715) so that it may become
effective 10:00 AM (Eastern Time) on July 28, 2011, or as soon as practicable thereafter.
The Fund acknowledges that (i) the Fund is responsible for the adequacy and accuracy of the
disclosure in the filing; (ii) should the Securities and Exchange Commission (the Commission) or
the staff of the Commission (the Staff), acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect to the
filing; (iii) 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 (iv) the Fund may not assert the
declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.
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We request oral notification of such effectiveness by a telephone call to our counsel using
the following contact information:
Zev Wexler
Skadden, Arps, Slate, Meagher & Flom LLP
Phone: 212-735-2775
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Sincerely,
THE GABELLI CONVERTIBLE AND INCOME SECURITIES
FUND INC.
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By: |
/s/ Agnes Mullady
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Agnes Mullady |
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Treasurer and Secretary |
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