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ADAM T. TEUFEL
adam.teufel@dechert.com +1 202 261 3464 Direct +1 202 261 3164 Fax |
December 31, 2020
VIA EDGAR
Anu Dubey
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | PIMCO Income Strategy Fund |
Files Nos. 333-249435 and 811-21374 |
Dear Ms. Dubey:
This letter is in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) received from you via telephone regarding the Registration Statement on Form N-2 (the “Registration Statement”) of PIMCO Income Strategy Fund (the “Fund”), which was filed with the SEC on November 24, 2020.
The following sets forth the Staff’s comments and the Fund’s responses thereto.
Comment 1: Please revise the “Short-Term Investments / Temporary Defensive Strategies” section on page 88 of the SAI to match the language contained in the prospectus.
Response: The Fund will update the disclosure at the next opportunity.
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We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at (202) 261-3464 if you wish to discuss this correspondence further.
Sincerely,
/s/ Adam T. Teufel
Adam T. Teufel
cc: | Ryan Leshaw, Pacific Investment Management Company LLC |
| Anu Dubey December 31, 2020 Page 2 |
Timothy Bekkers, Pacific Investment Management Company LLC |
Nathan Briggs, Ropes & Gray LLP |