TRI-CONTINENTAL CORPORATION
225 Franklin Street
Boston, MA 02110
April 14, 2020
VIA EDGAR
Mr. John 
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549
RE: | Tri-Continental Corporation (the "Corporation") |
| File Nos. 333-236947/811-00266 |
| Registration Statement on Form N-2 |
Dear Mr. | : |
This letter responds to comments received from the staff of the Securities and Exchange Commission on April 2, 2020 for the above-referenced Registration Statement on Form N-2 (the "Filing") filed by and on behalf of the Corporation. The comments and responses are outlined below.
Disclosure Comments
Comment 1: Please consider whether risk disclosure regarding the current COVID-19 pandemic should be added to the Filing.
Response: We have revised Foreign Securities Risk, Issuer Risk and Market Risk, which are included in the Corporation's prospectus and Statement of Additional Information (SAI), to contemplate disease/virus epidemics/outbreaks. We believe that these edits coupled with the COVID-19-specific enhancements to Terrorism, War, Natural Disaster and Epidemic Risk disclosure included in the Corporation's SAI sufficiently cover the risks associated with the current COVID-19 pandemic.
Comment 2: Please consider whether risk disclosure should be arranged in order of importance rather than alphabetically.
Response: We have identified, at the very beginning of the Corporation's Principal Risks discussion, what the Corporation views as its main principal risks, which is consistent with the Risk Guidance and consistent with remarks made (in-person) by Mr. Brent Fields at the ICI's SEC Rules Committee Meeting on June 26, 2019.
If you have any questions, please contact either me at (312) 634-9280 or Kayla Sylvia at (617) 385-9539.
Sincerely,
/s/ Megan E. Garcy
Megan E. Garcy
Assistant Secretary Tri-Continental Corporation