TRI-CONTINENTAL CORPORATION
225 Franklin Street
Boston, MA 02110
April 29, 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 |
| Pre-Effective Amendment No. 2 |
Dear Mr. | : |
This letter responds to a comment received from the staff of the Securities and Exchange Commission on April 29, 2020 for the above-referenced Pre-Effective Amendment to the Registration Statement on Form N-2 (the "Filing") filed by and on behalf of the Corporation. The comment and response are outlined below.
Disclosure Comment
Comment 1: Please revise the first paragraph under the heading Principal Risks from "An investment in the Fund involves risks, including..." to "An investment in the Fund involves risks. In particular, investors should consider...".
Response: Such revisions will be incorporated into the definitive 497c to be filed on behalf of the Corporation on Friday, May 1, 2020.
If you have any questions, please contact either me at (312) 634-9280 or Kayla Sylvia at (617) 385-9539.
Sincerely,
Megan E. Garcy
Megan E. Garcy
Assistant Secretary
Tri-Continental Corporation