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U.S. Securities and Exchange Commission

Securities and Exchange Act of 1934 - Rules 14a-8(c ) and 14a-8(j)(1)
The Ibero-America Fund, Inc.

September 9, 2010

By Facsimile and U.S. Mail

Kathleen K. Clarke, Esquire
Seward & Kissel LLP
1200 G Street, N.W.
Washington, D.C. 20005

Re: The Ibero-America Fund, Inc.
Omission of Shareholder Proposal Pursuant to Rule 14a-8

Dear Ms. Clarke:

In a letter dated August 12, 2010, on behalf of The Ibero-American Fund, Inc. (the "Fund"), you requested confirmation from the staff of the Division of Investment Management that it would not recommend enforcement action to the Securities and Exchange Commission if a shareholder proposal (the "Proposal") submitted by Banco Bilbao Vizcaya Argentaria, S.A., is omitted from the proxy materials for the next annual shareholder meeting of the Fund scheduled for November 8, 2010.

The Proposal states:

Resolved, that shareholders of The Ibero-America Fund, Inc. (the "Fund") hereby request that the Board of Directors take the steps necessary to implement a plan of liquidation and dissolution of the Fund.

You request our assurance that we would not recommend enforcement action if the Fund omits the Proposal from the proxy materials for the next scheduled shareholder meeting of the Fund pursuant to Rules 14a-8(e) and 14a-8(f) under the Securities Exchange Act of 1934. These rules provide that a registrant may exclude a proposal if the proposal is submitted after the registrant's properly determined deadline for such submission.

There appears to be some basis for your view that the Fund may exclude the Proposal under Rules 14a-8(e) and 14a-8(f) because the Fund received it after the deadline for submitting proposals. See, e.g., The College Retirement Equities Fund, SEC Staff No-Action Letter (May 19, 2008). Accordingly, we would not recommend enforcement action to the Commission if the Fund omits the Proposal from its proxy materials in reliance on Rules 14a-8(e) and 14a-8(f).

We note that the Fund did not file its statement of objections to including the Proposal in its proxy materials at least 80 calendar days before the date it intends to file its definitive proxy as required by Rule 14a-8(j)(1). Noting the circumstances of the delay, we grant the Fund's request that the 80-day requirement be waived.

Attached is a description of the Division's informal procedures regarding shareholder proposals. If you have any questions or comments concerning this matter, please call me at (202) 551-6941.

Linda B. Stirling
Senior Counsel

Incoming Letter

The Incoming Letter is in Acrobat format.


Modified: 09/10/2010