September 27, 2022
VIA EDGAR
Mr. Chad Eskildsen
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Ms. Ashley Vroman-Lee
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Response to Comments on the proxy statements/prospectuses filed on Form N-14 (each, a “Proxy Statement/Prospectus” and collectively, “Proxy Statements/Prospectuses”) by the following funds (each an “Acquiring Fund” and, collectively the “Acquiring Funds”) on August 11, 2022:
abrdn Global Dynamic Dividend Fund
Securities Act File No. 333-266796
abrdn Global Infrastructure Income Fund
Securities Act File No. 333-266798
abrdn Income Credit Strategies Fund
Securities Act File No. 333-266799
Mr. Eskildsen and Ms. Vroman-Lee:
This letter responds to comments on the Proxy Statements/Prospectuses with respect to the proposed reorganizations as shown below that the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided telephone conversation with Ashley Vroman-Lee and Brooke Clark of Dechert LLP on September 27, 2022.
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Acquired Funds (each an “Acquired Fund”) |
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Acquiring Funds |
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Delaware Enhanced Global Dividend and Income Fund |
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into |
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abrdn Global Dynamic Dividend Fund |
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Delaware Investments® Dividend and Income Fund, Inc. |
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Macquarie Global Infrastructure Income Fund Inc. |
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into |
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abrdn Global Infrastructure Income Fund |
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Delaware Ivy High Income Opportunities Fund |
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into |
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abrdn Income Credit Strategies Fund |
On behalf of the Acquiring Funds, your comments and our responses to them are provided below. All defined terms in this letter have the same meaning as in the Proxy Statements/Prospectuses, except as defined herein.
Comments applicable to each Proxy Statement/Prospectus
Comment 1: With respect to previous Comment 3 provided on September 2, 2022, please confirm any material considerations adverse to the Reorganization proposal are disclosed and fairly described. Please see Items 3(b) and 4(a) of Form N-14 and Item 22(c)(11) of Schedule 14A.
Response: Additional disclosure has been added in response to the Staff’s comment.
Comment 2: With respect to previous Comment 4 provided on September 2, 2022, and with respect to the disclosure discussing the possibility of converting to an open-end fund, please revise the disclosure to reflect that the Acquiring Funds have no plans to convert to an open-end fund structure or please consider removing the disclosure.