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1095 Avenue of the Americas |
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www.dechert.com |
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STEPHEN H. BIER |
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stephen.bier@dechert.com |
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+1 212 698 3889 Direct |
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+1 202 261 3092 Fax |
December 22, 2017
VIA EDGAR
Ms. Megan Miller
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re: Aberdeen Income Credit Strategies Fund (formerly, Avenue Income Credit Strategies Fund) (the “Fund”)
File Number 811-22485
Dear Ms. Miller:
On behalf of the above-referenced Fund, the following are the responses to the Securities and Exchange Commission (“SEC”) staff’s (the “Staff”) comments on the Fund’s Form N-CSR filing, as filed by the Fund on January 6, 2017, for the fiscal year ended October 31, 2016. For your convenience, a summary of the Staff’s comments is set forth below, and each comment is followed by the Fund’s response.
1. Comment: In the Statement of Operations, please confirm that any other category of income which exceeds 5% of the total investment income has been stated separately. See Rule 6-07.1 of Regulation S-X.
Response: The Fund will incorporate this comment in future filings on Form N-CSR, as applicable.
2. Comment: In the Notes to Financial Statements, please disclose the terms of any collateral received or pledged pursuant to any master netting arrangement, including whether collateral that is received or pledged is restricted or can be re-pledged, resold or re-hypothecated. See ASC 210-20-55-14.
Response: The Fund will incorporate this comment in future filings on Form N-CSR, as applicable.