0001104659-20-058473.txt : 20200716 0001104659-20-058473.hdr.sgml : 20200716 20200508100420 ACCESSION NUMBER: 0001104659-20-058473 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20200508 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TEKLA LIFE SCIENCES INVESTORS CENTRAL INDEX KEY: 0000884121 IRS NUMBER: 043147016 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177728515 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: H&Q LIFE SCIENCES INVESTORS DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Tekla World Healthcare Fund CENTRAL INDEX KEY: 0001635977 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: (617) 772-8515 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Tekla Healthcare Opportunities Fund CENTRAL INDEX KEY: 0001604522 IRS NUMBER: 465317248 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 617-772-8500 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: Tekla Healthcare Growth & Income Fund DATE OF NAME CHANGE: 20140402 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TEKLA HEALTHCARE INVESTORS CENTRAL INDEX KEY: 0000805267 IRS NUMBER: 046564285 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177728515 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET STREET 2: 19TH FLOOR CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: H&Q HEALTHCARE INVESTORS DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm

Tekla Healthcare Investors
Tekla Life Sciences Investors		100 Federal Street, 19th Floor
Tekla Healthcare Opportunities Fund		Boston, Massachusetts 02110
Tekla World Healthcare Fund		Tel: (617) 772-8500

May 8, 2020

Via EDGAR

Jeff Long
U.S. Securities and Exchange Commission
Division of Investment Management

Office of Disclosure Review and Accounting
100 F Street, NE
Washington, DC 20549

Re: Tekla Healthcare Investors (“HQH”) (811-04889), Tekla Life Sciences Investors (“HQL”) (811-06565), Tekla Healthcare Opportunities Fund (“THQ”) (811-22955) and Tekla World Healthcare Fund (“THW”) (811-23037) (HQH, HQL, THQ, and THW, together, the “Funds”) — Review of Annual Report Disclosures

Dear Mr. Long:

This letter responds to comments you provided to me in a telephonic conversation on Tuesday, April 28, 2020, with respect to your review pursuant to the Sarbanes-Oxley Act of 2002 of the annual report of the Funds relating to the fiscal year ended September 30, 2019. We have reproduced your comments below, followed by our responses.

Comment: In the footnotes to the financial statements, please disclose the counterparty for open option contracts written.

Response: We currently use exchange traded options and therefore do not have a counterparty to disclose. The Funds will incorporate your comment in future filings where applicable.

Comment: In the footnotes to the financial statements, please separately disclose on the Statement of Operations the realized gain or loss on forward foreign currency contracts.

Response: The Funds will incorporate your comment in future filings.

Comment: On the N-2, Item 4.3., loans outstanding should be considered senior securities on the financial highlights and therefore additional disclosures such as amount outstanding and asset coverage should be shown going forward for each year presented.

Response: The Funds will incorporate your comment in future filings.

We will endeavor to incorporate the applicable comments discussed above as soon as reasonably practicable.

May 8, 2020

Page 2

Very truly yours,

Laura Woodward,
Chief Compliance Officer, Secretary and Treasurer

cc: Daniel R. Omstead, Ph.D.

Christopher P. Harvey

Kaitlin McGrath