<Page> Fiduciary/Claymore MLP Opportunity Fund 2455 Corporate West Drive Lisle, Illinois 60532 December 20, 2004 Mr. Brion R. Thompson Securities and Exchange Commission Division of Investment Management 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Fiduciary/Claymore MLP Opportunity Fund Registration Statement on Form N-2 (File Nos. 333-119674 and 811-21652) ---------------------------------------------------------- Dear Mr. Thompson: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Fiduciary/Claymore MLP Opportunity Fund hereby requests acceleration of the effective date of the above-captioned Registration Statement so that it may become effective at 10:00 a.m., Eastern time, on December 22, 2004 or as soon as practical thereafter. Sincerely, FIDUCIARY/CLAYMORE MLP OPPORTUNITY FUND By: /s/ Nicholas Dalmaso ---------------------------------- Nicholas Dalmaso Chief Legal and Executive Officer <Page> A.G. Edwards & Sons 1 North Jefferson Saint Louis, MO 63103 December 20, 2004 Securities & Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Brion R. Thompson Re: Fiduciary/Claymore MLP Opportunity Fund Common Shares Registration No. 333-119674 (the "Registration Statement") 811-21652 (1940 Act) Dear Mr. Thompson: The undersigned, as the representative of the prospective Underwriters of the above-captioned securities, hereby joins in the request of the Fiduciary/Claymore MLP Opportunity Fund that the effectiveness of the Registration Statement relating to such securities be accelerated so that the Registration Statement will become effective at 10:00 a.m. on December 22, 2004, or as soon thereafter as practicable. In connection with the request for acceleration of the effectiveness of the Registration Statement, please be advised that the Preliminary Prospectus has been distributed as follows: approximately 56,441 copies of the Preliminary Prospectus dated November 22, 2004 have been sent to underwriters and selected dealers who it is anticipated will be invited to participate in the offering. Very truly yours, A.G. EDWARDS & SONS, INC. By: /s/ Brian N. Hansen Director - Investment Banking Authorized Signatory