April 27, 2010
Ms. Laura E. Hatch
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re: GAMCO Gold Fund, Inc. (the "Fund")
Post-Effective Amendment No. 20 to the Registration Statement
on Form N-1A (33-79180)
Dear. Ms. Hatch:
This letter responds to your comments communicated by telephone on
April 7, 2010, with respect to the Post-Effective Amendment No. 20 to the
Registration Statement on Form N-1A (the "Registration Statement") of the Fund
that was filed with the Securities and Exchange Commission (the "SEC") on
February 26, 2010 (accession number 0000950123-10-017793).
In addition, in connection with this filing, the Fund hereby states the
following:
1. The Fund acknowledges that in connection with the comments
made by the Staff of the SEC, the Staff has not passed on the
accuracy or adequacy of the disclosure made herein, and the
Fund and its management are solely responsible for the content
of such disclosure;
2. The Fund acknowledges that the Staff's comments, and changes
in disclosure in response to the Staff's comments, do not
foreclose the SEC or other regulatory body from the
opportunity to seek enforcement or take other action with
respect to the disclosure made herein;
3. The Fund represents that neither it nor its management will
assert the Staff's comments or changes in disclosure in
response to the Staff's comments as a defense in any action or
proceeding by the SEC or any person.
The Fund's responses to your comments are reflected below.
Comments that applied to both the Class AAA Shares prospectus and the
Class ABCI Shares prospectus have only been addressed once. The
substance of your comments has been restated for your ease of
reference.
COMMENT #1-COVER PAGE: You requested that the Fund pare down the
information in the top left hand corner to remove duplicative
references.
RESPONSE #1: The Fund has deleted the following parenthetical
language that appears at the end of the disclosure in the top
left hand corner: "(Net Asset Value per share may be obtained
daily by calling 800-GABELLI after 7:00 p.m.)."
COMMENT #2-COVER PAGE: You requested that the Fund add the required
legend disclosure if the Fund intends to utilize a summary prospectus.
RESPONSE #2: The Fund will not be utilizing a summary
prospectus at this time and therefore the legend has not been
added.
COMMENT #3-PERFORMANCE TABLE: The Fund lists three indices in the
performance table. You requested that the Fund determine which index is
the broad-based index and list such index first.
RESPONSE #3: The Fund has listed the S&P 500 Index first.
COMMENT #4-PERFORMANCE TABLE: You requested that the Fund delete the
second sentence of the text after the performance table regarding
"Return After Taxes on Distributions and Sale of Fund Shares" if it is
not applicable for the Fund.
RESPONSE #4: If this disclosure is not applicable for the
Fund, the Fund will remove it.
COMMENT #5-STATEMENT OF ADDITIONAL INFORMATION (THE "SAI"): You
requested that the Fund include the new corporate governance and board
member disclosure.
RESPONSE #5: The Fund will include such disclosure in the SAI.
COMMENT #6-SAI: You noted that because of Rule 35d-1 under the
Investment Company Act of 1940 ("1940 Act") and the Fund's policy of
investing 80% of its net assets in stocks of gold-related industries
(the "80% Policy"), the Fund should have a concentration policy to the
effect that at least 25% of its assets will be invested in gold-related
industries (the "Concentration Policy") and that such policy should be
a fundamental policy. Consequently, you requested that the Fund add
disclosure to the Fund's SAI that the Fund has a non-fundamental
Concentration Policy. Additionally, you requested that the Fund
represent that at the next meeting of shareholders, a proposal be
presented to the shareholders of the Fund seeking shareholder approval
of the Concentration Policy as a fundamental policy of the Fund.
RESPONSE #6: The Fund will set forth in its SAI a description
of the Fund's non-fundamental 25% concentration policy
regarding gold-related issuers, but will also note that such
policy may not be changed without shareholder approval in
accordance with Section 13(a)(3) of the 1940 Act. The SAI will
also state that at the next meeting of shareholders of the
Fund, it will present a proposal to the shareholders of the
Fund seeking shareholder approval of the Concentration Policy
as a fundamental policy of the Fund.
Should you have any questions regarding the foregoing, please do not
hesitate to contact Helen A. Robichaud at PNC Global Investment
Servicing, Inc., the Fund's Sub-Administrator, at 617-338-4595.
Very truly yours,
/s/ Bruce N. Alpert
-------------------
Bruce N. Alpert
President
cc: Helen A. Robichaud Arlene Lonergan
PNC Global Investment PNC Global Investment
Servicing, Inc. Servicing, Inc.
Peter D. Goldstein Christoper Tafone
Gabelli Funds, LLC Paul, Hastings, Janofsky & Walker LLP
Rachael Schwartz
Paul, Hastings, Janofsky & Walker LLP