Ivy High Income Opportunities Fund
6300 Lamar Avenue
Shawnee Mission, Kansas 66202-4200
April 3, 2013
BY EDGAR
Ms. Mary Cole
Senior Counsel
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re: | Ivy High Income Opportunities Fund | |||
1933 Act. No. 333-186489 | ||||
1940 Act No. 811-22800 | ||||
Registration Statement on Form N-2 |
Dear Ms. Cole:
On behalf of the Ivy High Income Opportunities Fund, formerly the Ivy Credit Opportunities Fund (the “Fund”), we hereby make the below representations in connection with a response being made on behalf of the Fund to comments that you provided with respect to the Fund’s initial Registration Statement under the Securities Act of 1933, as amended, on Form N-2, which was filed with the Securities and Exchange Commission (the “Commission”) on February 6, 2013. Responses to your comments were incorporated into Pre-Effective Amendment No. 1 to the Fund’s Registration Statement, which was filed on the same day as indicated above (the “Filing”).
(i) The Fund is responsible for the adequacy and accuracy of the disclosure in the Filing;
(ii) Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the Filing; and
(iii) The Fund may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws of the United States.
IVY HIGH INCOME OPPORTUNITIES FUND | ||
By: | /s/ Mara D. Herrington | |
Name: | Mara D. Herrington | |
Title: | Vice President and Secretary |