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March 22, 2023						vedderprice.com Cody J. Vitello Shareholder +1 312 609 7816 cvitello@vedderprice.com

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

To the Commission:

On behalf of the Registrant, this letter is in response to the comments provided telephonically by the staff of the U.S. Securities and Exchange Commission (the “Commission”) to Vedder Price P.C. on March 7, 2023, with respect to the Registrant’s Registration Statement on Form N-14 filed on January 31, 2023 (the “Registration Statement”) relating to the issuance of common shares in connection with the proposed mergers of Nuveen Senior Income Fund, Nuveen Floating Rate Income Opportunity Fund and Nuveen Short Duration Credit Opportunities Fund (each, a “Target Fund” and collectively, the “Target Funds”) into a wholly-owned subsidiary of the Registrant (the “Mergers”). The Registrant and the Target Funds are each referred to herein as a “Fund” and collectively as the “Funds.” Any capitalized terms used but not defined herein have the same meanings as given to them in the Registration Statement. Any page references refer to the initial Registration Statement. Set forth below are the staff’s comments and the Registrant’s responses. The Registrant is filing Pre-Effective Amendment No. 1 to the Registration Statement concurrently herewith to address the comments of the staff, to complete all missing information in the Joint Proxy Statement/Prospectus and Statement of Additional Information and to file exhibits in Part C of the Registration Statement.

Disclosure Comments

Response: Registrant confirms that it will fill in all blanks, brackets and otherwise missing information.

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Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore.

March 22, 2023

Page 2

Response: The Q&A is a summary of the more detailed Board considerations included in the Joint Proxy Statement/Prospectus. The Board considers net operating expenses (excluding leverage) when evaluating fund combinations because the net operating expenses (excluding leverage expenses) reflect the operational cost savings of the Mergers. Leverage costs are generally viewed as a financing cost and differences in cost among the Funds may reflect prevailing conditions when the arrangement was executed. Leverage costs are evaluated taking into account both costs and investment return. The Registrant has added cross references to the Comparative Fee Tables, which present pro forma total expense ratios including the costs of leverage.

Response: The Registrant has revised the disclosure in response to the staff’s comment.

Response: The Registrant has revised the disclosure in response to the staff’s comment.

Response: For the staff’s information, the amount of undistributed net investment income and net capital gains, if any, will not be available to the Target Funds until shortly before the closing of each respective Merger. Accordingly, the Registrant does not believe it is practical to include additional disclosure addressing the expected level of such pre-Merger distributions.

March 22, 2023

Page 3

Response: The Registrant has revised the disclosure in response to the staff’s comment.

Response: Registrant believes that the disclosures under “Reasons for the Merger” contain all material factors considered by the Board, which include potential benefits of the Mergers as well as potential adverse consequences of the Mergers.

Response: The Registrant has revised the disclosure in response to the staff’s comment.

Accounting Comments

Response: For the information of the staff, the Registrant confirms that the TFP Shares are treated as debt for accounting purposes and equity for federal income tax purposes. This treatment is aligned with the disclosures in the Registration Statement. See, for example, the “Material Federal Income Tax Consequences of the Mergers” section of the Registration Statement. The future treatment of the TFP Shares for federal tax purposes will be consistent with the historical treatment that Target Fund shareholders have experienced to date. For accounting purposes, fees and expenses of preferred shares are reflected as a liability in the financial statements incorporated by reference and in the Fees and Expense Table which is derived from the financial statements.

Response: For the information of the staff, Registrant will reflect the liquidation preference of each series of TFP shares issued in the Mergers, net of deferred offering costs, as a liability on its statement of Assets and Liabilities.

Very truly yours,

/s/ Cody J. Vitello

     Cody J. Vitello

     Shareholder