Skadden, Arps, Slate, Meagher & Flom llp
FOUR TIMES SQUARE
NEW YORK 10036-6522
VIA EDGAR
Ms. Laura E. Hatch
Staff Accountant
Division of Investment Management
Securities and Exchange Commission
Washington, D.C. 20549
Ladies and Gentlemen
On behalf of the Fund, transmitted herewith for filing is Form UNDER, pursuant to which the Fund
has made a supplemental undertaking related to its Registration Statement on N-2.
Provided that the undertaking is satisfactory, the Fund hereby requests acceleration of the
effective date of the Fund’s Pre-Effective Amendment No. 1 to the Registration Statement so that it
may become effective 10:00 AM (Eastern Time) on
July 27, 2011, or as soon as practicable
thereafter.
Should you have any questions or comments regarding the filing, please do not hesitate to contact
the undersigned at the number above.
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Very truly yours,
Zev Wexler
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VIA EDGAR:
Ms. Laura E. Hatch
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549
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Re: The Gabelli Convertible and Income Securities Fund Inc. — File Nos. 333-174294 and 811-05715 |
Dear Ms. Hatch:
This letter is in regard to the Registration Statement of the Fund, which was filed on
May 17,
2011, and amended on
July 22, 2011.
The Registrant hereby undertakes that it will file a post-effective amendment to its Registration
Statement if it determines to conduct a rights offering while such Registration Statement is
effective.
This undertaking supplements Undertaking No. 3 to Item 34 of Part C of the above referenced
Registration Statement.
If you have any questions concerning this filing, please contact Zev Wexler, Esq. at
212-735-2775.
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