Nuveen New Jersey Premium Income Municipal Fund (NNJ) Inactive
Filed: 30 Jul 13, 12:00am
Kathleen M. Long
Direct Phone: +1.202.373.6149
Direct Fax: +1.202.373.6001
kathleen.long@bingham.com
July 30, 2013
Mr. Kieran G. Brown
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | Nuveen New Jersey Premium Income Municipal Fund, Inc., File Numbers: 333-187009; 811-07118 (the “Fund” or “Registrant”) |
Dear Mr. Brown:
This letter responds to the comment we received from the staff via telephone on July 12, 2013 on the Fund’s filing on FormN-2, which was filed with the U.S. Securities and Exchange Commission (“SEC”) on July 11, 2013. The following summarizes your comment and provides our response to that comment. Unless otherwise noted, capitalized terms have the same meaning as given in the Fund’s Prospectus and/or Statement of Additional Information.
PROSPECTUS
| 1. | Comment: Please confirm the Fund will limit its investment in 3(c)(1) or 3(c)(7) funds to no more than 15% of its Managed Assets. |
Response: Registrant confirms that a 10% limit applies only to registered investment companies; however, Registrant notes that its ability to invest in other types of pooled vehicles is not a principal strategy of the Fund, Registrant has not historically invested in such vehicles to any material degree (i.e., more than 15% of its Managed Assets), nor does it currently intend to invest in such vehicles to any material degree. That said, Registrant is not aware of any limitations on the investment in such vehicles under the 1940 Act or otherwise and reserves the right to invest in such companies in the future in a manner consistent with the Fund’s investment objectives. To the extent the Fund does so, the registration statement will be updated to include additional disclosure describing such investments, the associated risks and
July 30, 2013
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any other pertinent disclosures. The updated registration statement will be filed with the SEC as appropriate (e.g., via POS 8C) at which time Registrant will endeavor to engage in a discussion with the staff regarding such changes. Of course, to the extent the Securities and Exchange Commission adopts any rules or regulations, or its staff issues any guidance in this area, Registrant will modify its policies in accordance with such guidance.
* * * * * *
I hereby acknowledge on behalf of the Fund that: (i) the Fund is responsible for the adequacy and accuracy of the disclosure in its registration statement; (ii) SEC staff comments or changes to disclosure in response to staff comments on the registration statement reviewed by the staff do not foreclose the SEC from taking any action with respect to the registration statement; and (iii) the Fund may not assert SEC staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.
If you have any additional questions or comments, please do not hesitate to contact me at 202.373.6149.
Sincerely yours,
/s/ Kathleen M. Long
Kathleen M. Long
| cc: | Kevin McCarthy |
Gifford Zimmerman