October 20, 2006
ING Risk Managed Natural Resources Fund
7337 East Doubletree Ranch Road
Scottsdale, AZ 85258
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attention: Brion R. Thompson, Esq.
Re: | ING Risk Managed Natural Resources Fund |
Registration Statement on Form N-2
(File Nos. 333-136495 and 811-21938)
Dear Mr. Thompson:
In accordance with Rule 461 under the Securities Act of 1933, as amended, ING Risk Managed Natural Resources Fund hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it may become effective by 10:00 a.m., New York City time, on October 24, 2006, or as soon thereafter as practicable.
Sincerely, | ||
ING RISK MANAGED NATURAL RESOURCES FUND | ||
By: | /S/ Huey P. Falgout, Jr.
| |
Huey P. Falgout, Jr. | ||
Secretary |
7337 E. Doubletree Ranch Rd. Scottsdale, AZ 85258-2034 | Tel: 480-477-3000 Fax: 480-477-2700 www.ingfunds.com | ING Investments, LLC |
CITIGROUP
388 Greenwich Street
New York, NY 10013
October 20, 2006
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4720
Attention: Brion R. Thompson
Re: | ING Risk Managed Natural Resources Fund |
Common Shares of Beneficial Interest
Registration Nos. 333-136495
811-21938
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned, as the representative of the prospective Underwriters of the above captioned securities, hereby joins in the request of the ING Risk Managed Natural Resources Fund that the effectiveness of the Registration Statement relating to such securities be accelerated so that the Registration Statement will become effective by 10:00 a.m., Eastern Time, on October 24, 2006, or as soon thereafter as practicable.
Very truly yours, | ||
CITIGROUP GLOBAL MARKETS INC. | ||
By: | /s/ Robert F. Bush, Jr. | |
Robert F. Bush, Jr. | ||
Managing Director |