ALPS Distributors, Inc.
1290 Broadway, Suite 1100
Denver, CO 80203
VIA EDGAR
December 20, 2018
Mr. Dominic Minore
U.S. Securities and Exchange Commission
Division of Investment Management
Office of Filings and Information Services
Branch of Registrations and Examinations
Mail Stop 0-25
100 F Street, N.E.
Washington, DC 20549
Re: Axonic Alternative Income Fund
Registration Statement on Form N-2
File Nos. 333-227724; 811-23385
Dear Mr. Minore:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), ALPS Distributors, Inc., in its capacity as distributor of Axonic Alternative Income Fund, a Delaware statutory trust (the “Fund”), hereby joins in the request of the Fund for acceleration of the effective date of Pre-Effective Amendment No. 2 to its Registration Statement on Form N-2 (File Nos. 333-227724; 811-23385) so that such Registration Statement may be declared effective at 10:00 a.m., Eastern Time, on December 21, 2018 or as soon as possible thereafter.
The undersigned, in making this request for acceleration, hereby states that it is aware of its obligations under Rule 461 and the other applicable provisions of the Securities Act.
| | Very truly yours, |
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| | ALPS Distributors, Inc.
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| | By: | /s/ Steven B. Price
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| | Name: | Steven B. Price
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| | Title: | SVP, Director of Distribution Services
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