787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 |
May 10, 2012
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: | SunAmerica Specialty Series |
Pre-Effective Amendment No. 1 to Registration Statement on Form N-14
Ladies and Gentlemen:
On behalf of SunAmerica Specialty Series (“Registrant”), we hereby transmit for filing with the Securities and Exchange Commission Registrant’s Pre-Effective Amendment No. 1 (the “Amendment”) to Registrant’s Registration Statement on Form N-14 (File No. 333-180670) filed on April 11, 2012 (the “Registration Statement”) relating to the proposed acquisition by the SunAmerica Focused Alpha Large-Cap Fund (the “Alpha Large-Cap Fund”), a series of Registrant, of all of the assets and liabilities of the Focused Growth and Income Portfolio, a series of SunAmerica Series, Inc., in exchange for Class A and Class C shares of the Alpha Large-Cap Fund. The Amendment is being filed solely to delay the effectiveness of the Registration Statement.
Should members of the Staff have any questions regarding the enclosed materials, they should call the undersigned at (212) 728-8138.
Sincerely,
/s/ Elliot J. Gluck
Elliot J. Gluck
Enclosures
cc: | Kathleen Fuentes, SunAmerica Asset Management Corp. |
Margery K. Neale, Willkie Farr & Gallagher LLP
Diana N. Huffman, Esq., Willkie Farr & Gallagher LLP
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