June 30, 2023

VIA E-mail

Richard Jason Alexander Elmhirst
950 Third Avenue
New York, New York 10022

                      Re:     Coller Secondaries Private Equity Fund (the
Fund   )
                              File Nos. 811-23879; 333-272265

Dear Mr. Elmhirst:

        We have reviewed the registration statement on Form N-2 filed May 30,
2023, with the
Commission on behalf of the Fund (the    Registration Statement   ) with
respect to an offering of
common shares. Our comments are set forth below. Please consider a comment made
with
respect to one section applicable to similar disclosure elsewhere in the
Registration Statement.
All capitalized terms not otherwise defined herein have the meaning given to
them in the
Registration Statement.

General

   1. We note that portions of the Registration Statement are incomplete. We
may have
      additional comments on such portions when you complete them in a
pre-effective
      amendment, on disclosures made in response to this letter, on information
supplied
      supplementally, or on exhibits added in any amendments.

   2. We also note you have filed two exemptive applications on behalf of
C-SPEF. The
      applications relate to C-SPEF   s ability to offer multiple classes of
shares and to engage in
      certain co-investments alongside the Adviser   s affiliates. Please let
us know in the
      response letter if C-SPEF intends to request any additional exemptive or
no-action relief.
      In addition, please update us on the status of your exemptive
applications during the
      course of our review.

   3. We note the term Private Equity precedes the word    Fund    in your
name. We believe the
      use of this term as written is misleading because the term Private Equity
Fund connotes a
      specific type of unregistered investment fund, which a registered fund is
not regardless of
      whether it provides access to private equity. Please revise your name to
avoid the
      potential for investor confusion. In addition, the name includes the word
   Secondaries
      which the staff believes suggests a specific type of investment. If the
word
 Richard Jason Alexander Elmhirst
Page 2

            Secondaries    remains in the name, the Fund   s 80% test should be
modified so that it is
         specific to secondaries investments (i.e., it should not include
investments in newly
         formed private funds, Direct Investments or Co-Investments). In
addition, please confirm
         the calculation of the Fund   s 80% test will not include capital
commitments that have not
         yet been called by an underlying fund.

   4. Please tell us if you have presented or will present any    test the
waters    materials to
      potential investors in connection with this offering. If so, we may have
additional
      comments.

   5. Please confirm that the Fund does not intend to issue debt securities or
preferred shares
      within a year from the effective date of the registration statement. If
the Fund plans to
      issue preferred shares within a year from the effectiveness of the
registration statement,
      please include additional disclosure of risks to shareholders in the
event of a preferred
      shares offering.

   6. The registration statement appears to contemplate a transaction with the
Predecessor
      Fund that will occur after your decision to become registered as an
investment company.
      Please tell us how this transaction will be structured to comply with
section 17 of the
      1940 Act, including any no-action relief upon which you intend to rely.


                                            Prospectus

Cover

   7. The Cover prominently discloses that Coller Capital is    First in
Secondaries   . Please
      supplementally provide support for this disclosure and explain why it is
not misleading.

   8. On the Cover, please specify C-SPEF   s principal strategies that are
speculative (e.g., use
      of leverage/derivatives, high yield/distressed debt and emerging markets
investment) and
      include a cross-reference to the disclosure regarding the risks
associated with these
      strategies. See Form N-2, Item 1.1.j. and the Guidelines to Form N-2,
Guide 6.

   9. On page ii, in footnote (1) to the table, the disclosure states    C-SPEF
may, in its sole
      discretion, accept investments below [$1,000,000 with respect to Class I
Shares, and
      $25,000 with respect to Class D Shares and Class I-2 Shares].    Please
explain to us the
      circumstances under which C-SPEF may reduce these stated minimum
investments.
      Also, in the second paragraph on page 13, the disclosure states    The
Board reserves the
      right to accept lesser amounts below these minimums [in certain cases].
 Is the Board   s
      ability to lower minimums in addition to that of C-SPEF? If so, please
also discuss the
      Board   s ability to lower minimums in your explanation to us. If not,
please reconcile the
      inconsistency in the disclosure.

   10. In the second paragraph on page ii, the disclosure states that
simultaneous with C-SPEF   s
       Commencement of Operations, the Predecessor Fund    reorganized with and
transferred
       substantially all its assets into C-SPEF.    Regarding the
reorganization:
 Richard Jason Alexander Elmhirst
Page 3


          a. Please disclose how the private fund holders    shares will be
valued for purposes
             of the reorganization. Will there be any dilution for other
shareholders who
             purchase shares in the initial offering? If so, please provide
appropriate
             disclosure on the Cover and in the Prospectus.

          b. Please explain to us in correspondence what information investors
will have
             available to them about the Predecessor Fund and its portfolio
prior to purchasing
             shares of C-SPEF.

          c. Please explain to us what assets will not be transferred from the
Predecessor Fund
             to C-SPEF, and why these assets will not be transferred.

   11. Please explain to us whether the Predecessor Fund meets the definition
of a "fund" as
       defined in Rule 6-11(a)(2) under the 1940 Act. If the Predecessor Fund
meets the
       definition of a fund, please explain how the requirements of Rule 6-11
of Regulation S-X
       will be met, including the supplemental financial information
requirements. In your
       response, please indicate the fiscal year end of the Predecessor Fund
and what fiscal year-
       ends and interim periods will be included. If the Predecessor Fund does
not meet the
       definition of a    fund,    please discuss with the Staff what
Predecessor Fund financial
       information will be provided, which may include an audited schedule of
investments that
       complies with Article 12 of Regulation S-X and presents the fair value
of investments
       according to FASB ASC 820.

   12. Please note, to the extent that you intend to present the prior
performance of the
       Predecessor Fund within the registration statement, we will have further
comments.

   13. On page ii, in the penultimate bullet, the disclosure states    Shares
may not be
       transferred or resold except as permitted under C-SPEF   s agreement and
declaration of
       trust.    Please define    C-SPEF   s agreement and declaration of trust
   here. Please also
       provide here a cross-reference to the section Transfer Restrictions on
page 63.

   14. The disclosure in the final bullet on page ii states    The amount of
distributions that C-
       SPEF may pay, if any, is uncertain.    With respect to C-SPEF   s
distributions, please
       disclose the following as additional bolded bullets on the Cover, as
appropriate:

               C-SPEF may pay distributions in significant part from sources
that may not be
              available in the future and that are unrelated to the Fund   s
performance, such as
              offering proceeds, borrowings, and amounts from C-SPEF   s
affiliates that are
              subject to repayment by investors.

          x   The Fund   s distributions may be funded from unlimited amounts
of offering
              proceeds or borrowings, which may constitute a return of capital
and reduce the
              amount of capital available to the Fund for investment. Any
capital returned to
              Shareholders through distributions will be distributed after
payment of fees and
              expenses.
 Richard Jason Alexander Elmhirst
Page 4

            x   A return of capital to Shareholders is a return of a portion of
their original
                investment in the Fund, thereby reducing the tax basis of their
investment. As a
                result from such reduction in tax basis, Shareholders may be
subject to tax in
                connection with the sale of Shares, even if such Shares are
sold at a loss relative
                to the Shareholder   s original investment.

Summary of Offering Terms

         Investment Objectives and Strategy (pages 2)

   15. On page 2, the disclosure in the first line of the last paragraph states
   C-SPEF may also
       invest in debt issued by private companies.    Please disclose here the
credit quality of C-
       SPEF   s debt investments. Please also disclose the credit quality of
these investments in
       Private Credit Investments on page 12.

   16. In the second paragraph on page 3, the disclosure states    C-SPEF may
make investments
       directly or indirectly through one or more wholly owned subsidiaries   .
   Regarding C-
       SPEF   s use of Subsidiaries:

            a. Please note, any investment advisory agreement between a
Subsidiary and its
               investment adviser is a material contract that should be
included as an exhibit to
               the registration statement. For purposes of complying with
Section 15(c), the
               reviews of the Fund   s and Subsidiaries    investment advisory
agreements may be
               combined.

            b. Confirm in correspondence that each Subsidiary and its board of
directors will
               agree to inspection by the staff of the Subsidiary   s books and
records, which will
               be maintained in accordance with Section 31 of the 1940 Act and
the rules
               thereunder.

            c. Confirm any wholly-owned Subsidiary   s management fee
(including any
               performance fee), if any, will be included in the line item
Advisory Fee    and the
               wholly-owned Subsidiary   s expenses will be included in
Other Expenses    in C-
               SPEF   s fee table.

   17. In the penultimate line on page 2, the disclosure states    C-SPEF seeks
to hold an amount
       of Liquid Assets and other liquid investments consistent with prudent
liquidity
       management.    Please tell us in correspondence how you reconcile this
disclosure with
       the potential for C-SPEF to    over-commit    as disclosed in the second
full paragraph on
       page 3.

   18. In this section, please briefly disclose C-SPEF   s principal
investments, such as those
       disclosed on pages 24-25 in Private Equity and Special Situations/Other
Private Assets.
       For example, these sections describe C-SPEF   s direct and underlying
investment in
       troubled companies, distressed debt and small/mid-market transactions,
as well as the
       types of securities C-SPEF invests in. Please also disclose the risks
associated with the
       Fund   s principal investments in Principal Risk Factors.
 Richard Jason Alexander Elmhirst
Page 5


         Principal Risk Factors (page 3)

   19. On page 3, in the second sentence of the introductory paragraph of this
section, please
       delete the phrase    which do not purport to be a complete description
of any of the
       particular risks referred to or a complete list of all risks involved in
an investment in C-
       SPEF    as this implies the Fund   s risk disclosure is materially
incomplete.

   20. On page 4, in the first paragraph of Conflicts of Interest, the
disclosure states    For
       example, the Adviser provides services to C-SPEF for which C-SPEF
compensates it. As
       a result, the Adviser has an incentive to enter into arrangements with
C-SPEF, and faces
       conflicts of interests when balancing that incentive against the best
interests of C-SPEF.
       Please clarify the conflict this disclosure is describing (i.e., how
does compensation for
       services create a conflict? What is the Adviser   s incentive that it
needs to balance against
       C-SPEF   s best interests?).

   21. On page 4, in the second paragraph of Conflicts of Interest, the
disclosure references the
       application for an exemptive order to allow the Fund to co-invest
alongside the Adviser   s
       affiliates. Please disclose here there is no guarantee such relief will
be granted. Please
       include similar disclosure wherever C-SPEF   s exemptive applications
are referenced
       throughout the registration statement.

   22. On page 11, in Loans to Private Companies, please briefly describe the
types of loans C-
       SPEF will invest in. In doing so, please describe the type of interest
rates of the loans
       (e.g., floating) and disclose if C-SPEF will invest in covenant lite
loans.

   23. In this section, please disclose the risks associated with foreign
investment, including
       emerging markets, the use of leverage and in general the risks
associated with C-SPEF   s
       principal investments.

         Share Classes; Minimum Investments (pages 12)

   24. In the last sentence of the first paragraph on page 13, immediately
following the phrase
          so long as initial investments    please insert    in C-SPEF   .

         Advisory Fee (page 16)

   25. In the first paragraph of this section, the disclosure states that the
Advisory Fee may be
       based on 1) C-SPEF   s NAV or 2) NAV, less cash, plus    the total of
all commitments
       made by C-SPEF that have not yet been drawn for investment,    whichever
is greater.
       Please disclose any conflicts this calculation of the Advisory Fee
presents. For example,
       would the Adviser have an increased incentive to make investments with
longer term
       unfunded commitments or engage in an over-commitment strategy?
 Richard Jason Alexander Elmhirst
Page 6

         Distribution and Servicing Fee (page 17)

   26. The disclosure in the second paragraph states    Class D Shares and
Class I-2 Shares pay a
       Distribution and Servicing Fee to the Distributor at an annual rate
based on the
       aggregate net assets of C-SPEF attributable to such class [emphasis
added].    Please
       explain in the disclosure what    aggregate net assets    are.

Summary of Fees and Expenses (pages 20)

   27. Do the calculations presented in the fee table assume a certain amount
of leverage? If so,
       disclose this amount in the narrative preceding the fee table.

   28. Consistent with Form N-2, the fee table includes a parenthetical after
Estimated Annual
       Operating Expenses noting that the expenses are shown as    a percentage
of net assets
       attributable to Shares.    Disclosure in footnote 3 explains that the
Advisory Fee may be
       based on either NAV or the amount of NAV less cash and cash equivalents
plus the total
       of all commitments made by C-SPEF that have not yet been drawn for
investment.
       Please explain to us how C-SPEF may account for the latter method of
calculating the
       Advisory Fee (the method including unfunded commitments) without causing
the fee
       table   s presentation of the Advisory Fee to be misleading.

   29. In footnote 6, regarding repayments to the Adviser under the Expense
Limitation
       Agreement, the disclosure states    Any such repayments must be made
within three years
       after the year in which the Adviser incurred the expense [emphasis
added].    Please
       replace    year    with    date    or    month   .

   30. In the fee table, please insert a line item for Dividend Reinvestment
and Cash Purchase
       Plan Fees or explain why the line item has not been provided. Please
refer to Item 3 of
       Form N-2.

Investment Objective and Strategy (page 22)

   31. On page 23, the disclosure references foreign investment, including
companies and funds
       in emerging markets. If C-SPEF will focus its investments in a
particular country or
       region, please disclose so.

         Investment Strategies (page 24)

   32. In the first line of the second paragraph of this section, the
disclosure references an
          appropriately diversified portfolio   . As C-SPEF is characterized as
non-diversifed
       under the 1940 Act, to avoid confusion, please delete or replace the
term    diversified   .
       Please make corresponding changes throughout this section and the
registration statement
       generally.

   33. In the same paragraph, please provide context in the disclosure for the
terms    top quartile
       returns    and    as great as in the past   .
 Richard Jason Alexander Elmhirst
Page 7

         Types of Portfolio Investments (page 25)

   34. On page 25, in Co-Investments and Direct Investments, please disclose in
plain English
       the meaning of    risk-adjusted returns    and    minority investor
as used in the first
       paragraph of this section.

   35. On page 26, the disclosure in the second line of Liquid Assets
references    below
       investment grade fixed-income securities.    Please note here these are
otherwise known
       as junk.

   36. On page 27, in ESG Integration, the disclosure states that the Adviser,
as part of its
       investment process, incorporates    financially material ESG factors
with    the goals of
       managing risk and assessing the attractiveness of the opportunity.
Please elaborate on
       how the assessment of ESG factors is integrated into the Adviser   s
investment process
       and the types of investments ESG analysis is applied to. Please also
briefly disclose the
       material ESG factors considered and the quantitative and qualitative
factors analyzed in
       determining how they may be financially material to these investments.
Your disclosure
       should address any material limits to the ESG analysis, including limits
associated with
       data accuracy, availability and comparability.

Other Investment Risks (page 43)

   37. On page 43, please update the LIBOR risk. We note that the disclosure
refers to a June
       30, 2023 date that has now passed.

   38. On page 49, in Risks Related to Hedging and Derivative Transactions, the
disclosure in
       the first line states    C-SPEF may invest in certain securities, such
as swaps, derivatives,
       hedges or foreign currency forward contracts, among others   .    The
disclosure in this
       section describes the tax risks associated with these investments.
Please disclose C-
       SPEF   s use of derivatives as an investment strategy and the risks
associated with these
       investments, as appropriate within the registration statement.

Conflicts of Interest (page 50)

   39. Please disclose here or at an appropriate place within the registration
statement, the
       Adviser   s conflict in determining the Fund   s use of leverage while
receiving an asset-
       based Advisory Fee. Please also disclose the Adviser   s similar
conflict of receiving an
       asset-based fee while determining the fair valuation of the Fund   s
investments (the
       disclosure on page 57 in Net Asset Valuation states    The Board has
designated the
       Adviser to perform [C-SPEF   s] fair value determinations       in
accordance with its
       procedures and Rule 2a-5).

Investment Advisory Agreement (page 55)

   40. On page 57, at the end of this section, the disclosure states    A
discussion regarding the
       basis for the approval by the Board of the Investment Advisory Agreement
will be
 Richard Jason Alexander Elmhirst
Page 8

         available in C-SPEF   shareholder report for the period ending [ ].
Please specify either
         the Annual or Semi-annual Report. See, Form N-2, Item 9.b.(4).

Repurchase of Shares

   41. On page 64, the disclosure in the last sentence of the third paragraph
states    C-SPEF may
       cause the repurchase of a Shareholder   s Shares if, among other
reasons, C-SPEF
       determines that such repurchase would be in the interest of C-SPEF.
Please explain to
       us what this disclosure means. Please also tell us the circumstances
under which this
       might occur. We may have further comments.

   42. On page 64, in the penultimate sentence of the fifth paragraph in this
section, the
       disclosure states    Any such proceeds that are held back will be paid
no later than five
       business days after the completion of such audit [emphasis added].
Please replace
          five    with    two   .

   43. On page 65, the disclosure in the last sentence of the first full
paragraph states    As such,
       the Repurchase Date for each repurchase offer should occur within 65
calendar days after
       the Expiration Date of such offer [emphasis added].    Please replace
should    in this
       sentence with    will   .

   44. On page 65, in the penultimate paragraph, please delete or revise the
first sentence
       beginning    Following the commencement of an offer to repurchase Shares
  .    C-SPEF
       may terminate the offer only upon the occurrence of conditions specified
at the outset of
       the offer that are objectively verifiable and outside the control of
C-SPEF or its agents or
       affiliates.

   45. In the last paragraph on page 65, the disclosure in the second sentence
states    The second
       and final payment for the balance due will be paid no later than 5
business days after the
       completion of the annual audit of C-SPEF   s financial statements for
the fiscal year in
       which the applicable repurchase is effected   .[emphasis added]    In
this sentence please
       replace    5    with    two   .

   46. Also in the last paragraph on page 65, please delete all the disclosure
beginning with    If,
       based upon       through    by the amount of any underpayment and issue
for no additional
       consideration a number of Shares having an aggregate value equal to such
amount, as
       applicable,   .    Alternatively, please explain to us how this
disclosure complies with the
       disclosure in the first sentence of this paragraph stating that the
portion of the amount due
       to tendering Shareholders that the Fund may hold back,    will not
exceed 5% of the total
       amount due to such Shareholders   . If compliant with this requirement,
and this
       disclosure remains, please disclose plainly that the Fund will hold back
no more than 5%
       of the amount due Shareholders. Further, in the last line of the
paragraph (if this
       disclosure remains), please replace the phrase    as promptly as
practicable    with    within
       two business days.

   47. On page 66, the disclosure in the second paragraph beginning    However,
C-SPEF is
       permitted to allocate to Shareholders       through to the end of the
paragraph, does not
 Richard Jason Alexander Elmhirst
Page 9

         appear consistent with Rule 13e-4(f)(8) under the Securities Exchange
Act of 1934.
         Please review the rule   s requirements and revise accordingly.
Further, the disclosure in
         this paragraph does not comport with earlier disclosure stating that
shares will be
         purchased at NAV.


                                   Statement of Additional Information

   48. On page 3, Fundamental Polices, the disclosure in the first full
paragraph states that C-
       SPEF   s concentration policy will permit investment without limit in
municipal securities,
       securities of foreign governments and issuers domiciled in a single
jurisdiction or
       country. Please note the following and revise as needed:

            a. Regarding municipal securities, please qualify the disclosure to
note that
               municipal securities issued to finance a particular project are
considered for
               purposes of concentration to be in the industry of that project.

            b. Please clarify in the disclosure that investments in the
sovereign debt of any
               single country are considered investments in a single industry
for concentration
               purposes.

            c. Issuers domiciled in a single jurisdiction or country are
subject to C-SPEF   s
               policy on concentration     these investments are not    without
limit.

   49. Much of the risk disclosure presented in the SAI appears to be relevant
to a number of the
       Fund   s principal investments. Please review the registration statement
and determine if
       the risk disclosure included in the SAI should also be included as risk
disclosure in the
       Prospectus and/or the Summary, as appropriate.


                                              Exhibits

   50. Please include the Fund   s governing documents as Exhibits to the
registration statement.
       We may have further comments.

   51. Please provide audited seed financial statements of the Registrant.

       A response to this letter should be in the form of a pre-effective
amendment filed
pursuant to Rule 472 under the Securities Act. The pre-effective amendment
should be
accompanied by a supplemental letter that includes your responses to each of
these comments.
Where no change will be made in the filing in response to a comment, please
indicate this fact in
your supplemental letter and briefly state the basis for your position.

        We remind you that the Fund and its management are responsible for the
accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action, or
absence of
action by the staff.
 Richard Jason Alexander Elmhirst
Page 10

         Should you have any questions regarding this letter, please contact me
at (202) 551-
6779 or Rossottok@sec.gov.

                                                Sincerely,

                                                /s/ Karen Rossotto

                                                Karen Rossotto
                                                Senior Counsel


cc: Rajib Chanda, Esq. and Nathan Somogie, Esq., Simpson Thacher & Bartlett LLP
    Jay Williamson, Branch Chief
    Jeff Long, Staff Accountant