3000 Two Logan Square

Eighteenth and Arch Streets

Philadelphia, PA 19103-2799

215.981.4000

Fax 215.981.4750

John P. Falco

direct dial: (215) 981- 4659

direct fax: (866) 422 - 2114

falcoj@pepperlaw.com

June 8, 2018

Ladies and Gentlemen:

On behalf of the Herzfeld Caribbean Basin Fund, Inc. (the “Company”), and in accordance with the requirements of the Securities Act of 1933, as amended (the “1933 Act”), and the Investment Company Act of 1940, as amended (the “1940 Act”), electronically transmitted herewith is Pre-Effective Amendment No. 1 to the Company’s Registration Statement on Form N-2 (the “Amendment”) with respect to the proposed offering by the Company of additional common shares of beneficial interest, par value $.001 per share (the “Shares”) on an immediate, delayed or continuous basis in reliance on Rule 415 under the 1933 Act. The Company is registering $88,000,000 of Shares.

The Amendment is being filed in order to respond to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission on June 4, 2018 regarding the above-referenced Registration Statement, make such other changes as the Company has deemed appropriate and file any remaining exhibits.

In accordance with Rule 111 under the 1933 Act, the Company paid a registration fee of $10,956 in connection with the initial filing of the Registration Statement.

Concurrently with the filing of the Amendment, the Company expects to submit in writing to the Staff of the Commission a request for the acceleration of effectiveness of the Registration Statement.

U.S. Securities and Exchange Commission

Page 2

June 8, 2018

Please direct any questions concerning this letter to my attention at 215.981.4659 or, in my absence, to John M. Ford, Esq. of this office at 215.981.4009.