The Relative Value Fund
c/o UMB Fund Services, Inc.
235 West Galena Street
Milwaukee, WI 53212
April 28, 2017
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | The Relative Value Fund (the “Fund”) | |
| (1933 Act Registration No. 333-213003)/(1940 Act Registration No. 811-23179) |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we hereby request that the effective date of the Fund’s registration statement on Form N-2 under the Securities Act, and Pre-Effective Amendment No. 1 thereto, and Amendment No. 1 to the Fund’s registration statement on Form N-2 under the Investment Company Act of 1940, as amended, be accelerated to May 1, 2017, or as soon thereafter as is reasonably practicable.
Should the Securities and Exchange Commission (the “Commission”) or staff, acting pursuant to delegated authority, declare the filing effective, the Fund acknowledges that such action does not foreclose the Commission from taking any action with respect to the filing. The Fund further acknowledges that the action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Fund from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and the Fund may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
THE RELATIVE VALUE FUND
/s/ Michael Peck
Name: Michael Peck
Title: President
FORESIDE FUND SERVICES, LLC
/s/ Mark Fairbanks
Name: Mark Fairbanks
Title: Vice President