April 27, 2018
Ms. Kathy Cherko
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
| RE: | Tri-Continental Corporation (the “Fund”) |
FileNo. 333-104669/811-00266
Post-Effective Amendment to a Registration Statement on FormN-2
Dear Ms. Cherko:
This letter responds to comments received by telephone on April 26, 2018 for the above-referenced Post-Effective Amendment (“Filing”). Comments and responses are outlined below:
| Comment 1: | Please confirm that an auditor’s consent will be filed as an exhibit in the next POS 8C submission of the registration statement. |
| Response: | So confirmed. |
| Comment 2: | Please revise the heading of the “Annual Expenses” table to read: “Annual Expenses (as a percentage of net assets attributable to common shares)”. |
| Response: | The heading has been so revised. |
| Comment 3: | Please confirm that the expense example figures are accurate. |
| Response: | The expense example has been revised as follows: |
Although your actual costs may be higher or lower, based on the assumptions listed above, your costs would be:
| 1 year | 3 years | 5 years | 10 years | |||||||||||||
Tri-Continental Corporation Common Stock | $ | 7 | $ | 21 | $ | 37 | $ | 83 | ||||||||
If dividends on the Fund’s $2.50 cumulative preferred stock (Preferred Stock) were not included, the total expenses incurred for 1, 3, 5 and 10 years would be $6, $18, $31 and $69, respectively.
If you have any questions, please contact either me at (312)634-9280 or Joseph D’Alessandro at (212)850-1703.
| Sincerely, |
| /s/ Megan E. Garcy |
| Megan Garcy |
| Counsel |
| Ameriprise Financial, Inc. |
