Delaware Ivy High Income Opportunities Fund (IVH)
Filed: 29 May 13, 12:00am
IVY HIGH INCOME OPPORTUNITIES FUND
6300 LAMAR AVENUE
SHAWNEE MISSION, KANSAS 66202-4200
May 29, 2013
Ms. Mary A. Cole
Senior Counsel
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | Ivy High Income Opportunities Fund (Registrant) |
| File Nos. 811-22800 and 333-186489 |
Dear Ms. Cole:
Per the Staff’s request, I am confirming on behalf of the Registrant that Ivy Investment Management Company (the “Adviser”) may not recoup any of the Registrant’s (i) organizational expenses or (ii) offering expenses in excess of $.04 per common share, which the Adviser has agreed to pay in connection with the Registrant’s offering of public shares.
If you should require additional information, please call me at (913) 236-2432.
Very Truly Yours,
/s/ Mara D. Herrington |
| Mara D. Herrington |
| Secretary |