CORRESP 1 filename1.htm The Gabelli Convertible and Income Securities Fund Inc.
SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
500 BOYLSTON STREET
BOSTON, MASSACHUSETTS 02116

 

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617-573-4836

DIRECT FAX

617-305-4836

EMAIL ADDRESS

KENNETH.BURDON@SKADDEN.COM

  

 

TEL: (617) 573-4800

FAX: (617) 573-4822

www.skadden.com

  

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August 11, 2021

  

VIA EDGAR

David Orlic

Mindy Rotter

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

RE: The Gabelli Convertible and Income Securities Fund Inc.

(File Nos.: 333-257573; 811-05715)                                

Dear Mr. Orlic and Ms. Rotter:

Thank you for your oral comments provided on July 23, 2021 and July 29, 2021 regarding your review of the registration statement on Form N-2 filed on June 30, 2021 (the “Registration Statement”) by The Gabelli Convertible and Income Securities Fund Inc. (the “Fund”) with the U.S. Securities and Exchange Commission (the “SEC”). The Fund has considered your comments and authorized us to respond on its behalf as set forth below. Changes to the Registration Statement will be reflected in Pre-Effective Amendment No. 1 (the “Amendment”) to the Registration Statement, which the Fund intends to file on or about the date hereof, and will be marked to show all changes made since the initial filing of the Registration Statement.

Your oral comments are summarized in bold to the best of our understanding, followed by the Fund’s responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.


David Orlic

Mindy Rotter

August 11, 2021

Page 2

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Summary of Fund Expenses

 

1.

Please confirm that the fees presented in the fee table represent current fees.

The Fund confirms that the line items in the fee table have been updated to reflect current fees.

Prospectus

 

2.

In the section entitled “Incorporation by Reference,” please check the link for “the Financial Highlights in our annual report on Form N-CSR for the fiscal year ended December 31, 2015, filed with the SEC on March 9, 2016.” It appears to lead the reader to the Fund’s proxy statement on Form DEF 14A filed on March 29, 2021.

The Fund has updated the link accordingly.

General

 

3.

Please confirm that live links will be provided for all documents incorporated by reference.

The Fund confirms that live links have been provided for all documents incorporated by reference.

 

4.

The 12/31/2020 financial statements will be stale on 9/2/2021. Please provide an estimated timeframe for when effectiveness is expected to be requested. If it is subsequent to 9/2/2021, the amendment will need to incorporate by reference the semi-annual financial statements.

The Fund expects to request effectiveness in August 2021.

 

5.

The staff respectfully reminds the registrant that the staff will need to perform a review of the open financial information items provided prior to declaring the registration statement effective. We may have additional comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits added in any amendments.

The Fund acknowledges that the staff may have additional comments after reviewing this response letter.


David Orlic

Mindy Rotter

August 11, 2021

Page 3

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Should you have any additional comments or concerns, please do not hesitate to contact me at (617) 573-4836 or Tom DeCapo at (617) 573-4814.

 

  Best regards,
 

/s/ Kenneth E. Burdon

  Kenneth E. Burdon