SunAmerica Specialty Series
SunAmerica Capital Services, Inc.
Harborside Financial Center
3200 Plaza 5
Jersey City, NJ 07311
May 24, 2012
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | SunAmerica Specialty Series |
Securities Act File No. 333-180670
Pre-Effective Amendment No. 2
Dear Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, SunAmerica Specialty Series (the “Registrant”) requests acceleration of the effective date of Pre-Effective Amendment No. 2 to its Registration Statement on Form N-14 (File No. 333-180670) (the “Amendment”) so that the Amendment is declared effective on Thursday, May 24, 2012, or as soon as practicable thereafter.
We request that we be notified of such effectiveness by a telephone call to Elliot Gluck of Willkie Farr & Gallagher LLP at (212) 728-8138, and that such effectiveness also be confirmed in writing.
The Registrant hereby acknowledges that, if the Securities and Exchange Commission (or its staff, acting pursuant to delegated authority), declares the filing effective, such action:
(i) does not foreclose the Commission from taking any action with respect to the filing;
(ii) does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
(iii) may not be asserted by the Registrant as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
May 24, 2012
Page 2
| Very truly yours, | ||
| SunAmerica Specialty Series | ||
| By: | /s/ Kathleen Fuentes | |
Kathleen Fuentes Assistant Secretary | ||
| SunAmerica Capital Services, Inc. | ||
| By: | /s/ James Nichols | |
James Nichols President | ||
