[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP]

January 11, 2018

Angela Mokodean

Senior Counsel

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 (File Nos. 333-221873 and 811-21982)

Dear Ms. Mokodean:

The purpose of this letter is to confirm that the Financial Industry Regulatory Authority ("FINRA") has reviewed the terms and arrangements of the offering by Guggenheim Strategic Opportunities Fund (the “Fund”), pursuant to the registration statement on Form N-2 (the “Registration Statement”) filed by the Fund on December 1, 2017, and has issued a conditional no objection letter to the Fund. Should you have any additional comments or concerns, please do not hesitate to contact me at (312) 407-0641.

Sincerely,

/s/ Kevin T. Hardy

Kevin T. Hardy