 | 787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 |
October 25, 2017
Via EDGAR
Ms. Kimberly Browning
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Re: | The New Ireland Fund, Inc. (the “Fund”); |
Registration Statement on Form N-2 Filed on September 12, 2017
Securities Act File No. 333-220436; Investment Company Act File No. 811-05984
Dear Ms. Browning:
This letter responds to a comment on the above-referenced Registration Statement that you provided in a telephone conversation with Elliot Gluck on October 23, 2017. For your convenience, the substance of your comment has been restated below. The Fund’s response to the comment is set out immediately under the restated comment. Defined terms, unless otherwise defined herein, have the meanings given them in the Registration Statement.
GENERAL
PROSPECTUS
Prospectus Summary
Investment Policies
Comment No. 1: We note that the Fund may invest in convertible securities. Please advise, and add disclosure, if the Fund will invest in “contingent convertible securities.”
Response: The Fund does not intend to invest in contingent convertible securities as part of its investment strategies.
* * *
Securities and Exchange Commission
October 25, 2017
Should you have any questions concerning the above, please call the undersigned at (212) 728-8762 or Elliot Gluck at (212) 728-8138.
Very truly yours,
/s/ Patrick T. Quinn
Patrick T. Quinn
cc: Lelia Long, The New Ireland Fund, Inc.
Rose F. DiMartino, Willkie Farr & Gallagher LLP
Elliot J. Gluck, Willkie Farr & Gallagher LLP