[ING LOGO]
March 22, 2007
ING Asia Pacific High Dividend Equity Income Fund
7337 East Doubletree Ranch Road
Scottsdale, AZ 85258
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attention: Brion R. Thompson, Esq.
Re: | ING Asia Pacific High Dividend Equity Income Fund |
Registration Statement on Form N-2
(File Nos. 333-139981 and 811-22004)
Dear Mr. Thompson:
In accordance with Rule 461 under the Securities Act of 1933, as amended, ING Asia Pacific High Dividend Equity Income Fund (the “Fund”) hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it may become effective by 10:00 a.m., New York City time, on March 27, 2007, or as soon thereafter as practicable.
Also, in accordance with Section 12 of the Securities Exchange Act of 1934, as amended, and the General Instructions to Form 8-A, the Fund respectfully requests that the above-referenced Form 8-A become effective upon the effectiveness of the Registration Statement.
Sincerely, | ||
ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND | ||
By: | /s/ Huey P. Falgout, Jr. | |
Huey P. Falgout, Jr. | ||
Secretary |
7337 East Doubletree Ranch Road | Scottsdale, AZ 85258-2034 | Toll Free: 800.745.4746 |
[CITIGROUP LETTERHEAD]
March 22, 2007
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4720
Attention: Brion R. Thompson
Re: | ING Asia Pacific High Dividend Equity Income Fund |
Common Shares of Beneficial Interest
Registration Nos. 333-139981
811-22004
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned, as the representative of the prospective Underwriters of the above captioned securities, hereby joins in the request of the ING Asia Pacific High Dividend Equity Income Fund that the effectiveness of the Registration Statement relating to such securities be accelerated so that the Registration Statement will become effective by 10:00 a.m., Eastern Time, on March 27, 2007, or as soon thereafter as practicable.
Very truly yours, | ||
CITIGROUP GLOBAL MARKETS INC. | ||
By: | /s/ Robert F. Bush, Jr. | |
Robert F. Bush, Jr. | ||
Managing Director |