HIGHLAND FUNDS I
300 Crescent Court, Suite 700
Dallas, Texas 75201
June 15, 2020
VIA EDGAR
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4720
Attn: Ryan Sutcliffe
| Re: | Highland Funds I (File No. 333-235285) |
Pre-Effective Amendment No. 3 to Registration Statement on Form N-14 |
Dear Mr. Sutcliffe:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “1933 Act”), Highland Funds I (the “Registrant”) hereby requests that the staff of the Division of Investment Management accelerate the effective date of the Registrant’s Registration Statement on Form N-14, as amended, related to the proposed reorganization of Highland Long/Short Equity Fund with and into Highland Merger Arbitrage Fund to as soon as possible on June 15, 2020.
In support of its request for acceleration, the Registrant acknowledges that:
| 1. | The Registrant is responsible for the accuracy and adequacy of the disclosures in the filing; |
| 2. | Should the Commission or the staff acting pursuant to delegated authority declare the Registration Statement effective, such action does not foreclose any action by the Commission with respect to the filing; |
| 3. | The action of the Commission or the staff acting pursuant to delegated authority in declaring the filing effective does not relieve the Registrant of responsibility for the adequacy and accuracy of the filing; and |
| 4. | The Registrant will not assert the staff’s acceleration of effectiveness of the filing as a defense in any proceeding initiated by the Commission or any other person under the federal securities laws. |
| Very Truly Yours, | ||
| Highland Funds I | ||
| By: | /s/ Frank Waterhouse | |
| Name: | Frank Waterhouse | |
| Title: | Principal Executive Officer, Principal Financial Officer, Principal Accounting Officer and Treasurer | |
