| | | | |

| | | | Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com |
March 22, 2017 | | | | Brendan R. Hamill Associate +1 202 312 3010 bhamill@vedderprice.com |
VIA EDGAR
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
To the Commission:
On behalf of the Registrant, electronically transmitted herewith is the Registrant’s preliminary Proxy Statement and Schedule 14A pursuant to Section 14(a) of the Securities Exchange Act of 1934 (the “Proxy Statement”). The Proxy Statement is directed to holders of common shares of the Registrant in connection with the Registrant’s annual shareholder meeting (the “Meeting”). At the Meeting, the Registrant’s common shareholders will be asked to consider, among other things, proposals relating to the election of four members to the Board of Trustees and the approval of a new sub-advisory agreement between Nuveen Fund Advisors, LLC, the Registrant’s investment adviser, and INTECH Investment Management LLC, the Registrant’s sub-adviser.
Please call the undersigned at (202) 312-3010 with any questions or comments regarding this filing.
Yours very truly,
/s/ Brendan Hamill
Brendan R. Hamill
Associate
BRH
| | | | | | |
1401 I Street NW, Suite 1100 | | Washington, DC 20005 | | T +1 202 312 3320 | | F +1 202 312 3322 |
Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore. |