August 21, 2024

VIA E-MAIL

Richard Horowitz, Esq.
Dechert LLP
1095 Avenue of the Americas
New York, NY 10036

Re:      Lord Abbett Municipal Opportunities Fund
         Registration Statement on Form N-2
         Filing Nos.: 333-280949; 811-23987

Dear Mr. Horowitz:

        The staff has reviewed the above-referenced initial registration
statement (   Registration
Statement   ), which the Commission received on July 22, 2024. Based on our
review, we have
the following comments. Capitalized terms have the same meaning as defined in
the
Registration Statement.

1. General Comments

      a. Please confirm whether the Fund intends to issue preferred or debt
securities within a
         year from the effective date of the Registration Statement.

      b. 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, please
provide us with copies
         of such materials.

      c. We note that portions of the Registration Statement are incomplete. A
full financial
         review (e.g., seed financial statements, auditor's report, consent)
must be performed prior
         to declaring the registration statement effective. 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 amendment.

2. Cover Page     Investment Strategy

      a. The disclosure states that the Fund will invest at least 80% of its
net assets, plus the
         amount of any borrowings for investment purposes, in municipal bonds
and other
         securities that pay interest exempt from federal income tax. Please
clarify what
    categories and/or types of investments would be considered    other
securities that pay
   interest exempt from federal tax    for rule 35d-1 purposes. Please disclose
with
   specificity the types of principal investments that the Fund will be making
and include
   corresponding risk disclosure.

b. Given the Fund   s name, the Fund   s policy to invest at least 80% of its
net assets, plus the
   amount of any borrowings for investment purposes, in municipal bonds and
other
   securities that pay interest exempt from federal income tax must be
fundamental. Please
   make appropriate changes to the SAI and provide disclosure in the prospectus
explaining
   this fundamental policy and the procedures for the Fund to change this 80%
policy. See
   rule 35d-1(a)(3) of the Investment Company Act. Also, provide disclosure in
the
   prospectus addressing the status of income from the Fund   s investments
with regard to
   state income taxes.

c. The disclosure states that municipal bonds and other securities in which the
Fund may
   invest may pay interest that is subject to the federal alternative minimum
tax (   AMT   )
   for certain taxpayers. For clarity, please consider moving this statement to
the fourth
   paragraph in the sub-section that discusses    AMT paper.    Please ensure
all material risks
   related to the application of AMT are adequately disclosed, including with
respect to the
   expiration of AMT exemption amounts.

d. The Fund may invest in municipal bonds    with a particular emphasis    on
lower rated
   municipal bonds (   junk bonds   ). Please provide a range or estimate of
what portion of
   the Fund   s portfolio will be invested in junk bonds.

e. The Fund states that it may invest without limitation in unrated municipal
bonds. Please
   add disclosure clarifying the relationship between this strategy to invest
without
   limitation in unrated municipal bonds and the strategy to invest at least
75% of the
   Fund   s net assets in, among other things, unrated bonds deemed by Lord
Abbett to be of
   comparable quality to municipal bonds rated BBB+/Baa1 or lower.

f. The Fund may invest in defaulted and distressed debt holdings and the
disclosure states
   that such investment strategies are    generally higher risk relative to
strategies employed
   by funds that invest primarily in investment grade municipal bonds.
Please delete the
   word    generally    from the statement.

g. The Fund may invest without limitation in securities of issuers located in a
single state,
   territory, municipality, or region. If the Fund expects to have material
exposure through
   its investments to any particular state, territory, municipality, or region,
please disclose
   this fact in the principal strategies and risks portions of the prospectus.

h. The Fund states that it may invest in other types of derivatives, such as
futures, for non-
   hedging, hedging, or duration management purposes. Please redraft the
disclosure
   regarding any principal investment related to derivatives so that it is
tailored specifically
   to how the Fund expects to be managed and address those derivative
strategies that the
   Fund expects to be the most important for achieving its objectives and that
it anticipates
   will have a significant effect on its performance. See, Letter from Barry
Miller to the ICI,
   July 30, 2010.



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    i. The Fund states that it may invest in individual securities of any
maturity or duration.
      Please provide further disclosure providing context for this sentence.
What types of
      securities are being referenced in this statement? Does this statement
apply to all of the
      Fund   s investments, including municipal bonds?

3. Cover Page     Interval Fund/Repurchase Offers

   a. Please disclose the intervals between deadlines for repurchase requests,
including the
      anticipated timing of initial repurchase offer.

   b. Include a cross-reference to the prospectus sections that discuss the
Fund   s repurchase
      policies and attendant risks. See Guide 10 to Form N-2.

4. Cover Page     Bullets

      Please add the following, as applicable:

         The Fund 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 from
         offering proceeds, borrowings, and amounts from the Fund's affiliates
that are subject
         to repayment by investors.

5. Prospectus Summary

   a. Please provide cross-references to the relevant disclosures elsewhere in
the prospectus or
      SAI of key features of the offering that are summarized in the Prospectus
Summary. See
      Instruction to Item 3.2 of Form N-2.

   b. Leverage. The Fund may use derivatives including credit default swaps.
Please disclose
      if the Fund may write credit default swaps and include appropriate risk
disclosures.

   c. Investment Strategies. The disclosure states that the Fund   s investment
team may also
      consider ESG factors in its investment decisions. Please provide examples
of such ESG
      factors. Also, state whether ESG factors are considered for all
investments and, if not,
      explain how ESG factors are applied and to which investments. In
addition, explain
      whether an investment could be made in a security that rates poorly with
regard to ESG
      criteria if it rates strongly on other non-ESG factors.

6. Investment Objectives, Strategies, and Principal Risks

   a. The Fund    may invest up to 100% of its net assets    in inverse
floaters. Please consider
      revising the disclosure here and throughout the Registration Statement to
clarify (a)
      whether the Fund expects to invest a substantial portion of its net
assets in inverse
      floaters, and (b) how inverse floaters are treated for the purposes of
the Fund   s 80% test
      under rule 35d-1 (e.g., are inverse floaters the    other securities
referred to in the Fund   s
      80% test).

   b. Portfolio Composition. In the appropriate sections of the Registration
Statement,
      including the Prospectus Summary, please also summarize briefly the basic
elements of


          Page 3 of 5
        tender option bond (TOB) transactions, the Fund   s use of TOB trusts,
the types of
       interests issued by the TOB trust, how the Fund obtains exposure to the
underlying
       markets, and what gives rise to leverage. Please ensure risks associated
with TOB trusts
       inverse floaters are adequately discussed. For example, consider adding
disclosure that
       explains the risks related to early termination of a TOB trust and any
potentially negative
       ramifications for the Fund and its shareholders.

7. Summary of Fund Expenses

       Please confirm that the fee waiver contained in the operating expense
limitation
       agreement between the adviser and the funds will be in place for at
least one year from
       the effective date of the Registration Statement. Please disclose if the
adviser is entitled
       to recoup waived fees.

8. Portfolio Composition

   a. Illiquid and Restricted Securities (p. 20) The disclosure states:    to
the extent consistent
      with the liquidity requirements applicable to interval funds under rule
23c-3 under the
      1940 Act, the Fund may invest without limit in illiquid securities.
Please explain
      supplementally the reference to    liquidity requirements    under rule
23c-3.

   b. Options (p. 21) The Fund may purchase call and put options and write call
and put
      options contracts. If these are principal strategies of the Fund, please
summarize in the
      prospectus summary and confirm related risks are disclosed.

9. Reinvestment Privilege

       (p. 42) The Fund describes in this subsection a privilege to reinvest
proceeds if an
       investor should    redeem Class A Shares of a Lord Abbett Fund.
Please redraft this
       disclosure to clarify that investors cannot not redeem Shares at will;
proceeds for Shares
       are obtained as part of repurchase offers.

Statement of Additional Information

10. Investment Restrictions (p. 3-1)

       The staff notes that the Fund has an investment restriction related to
concentration of
       investments. Please note that the Fund should look through a private
activity municipal
       debt security whose principal and interest payments are derived
principally from the
       assets and revenues of a nongovernmental entity in order to determine
the industry to
       which the investments should be allocated when determining the Fund   s
compliance with
       its concentration policies. Please add disclosure to this effect in the
SAI. Please also
       reconcile the statement in the prospectus that the Fund may invest up to
100% of its net
       assets in private activity bonds with this concentration fundamental
policy.





           Page 4 of 5
        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.

        Responses to these comments should be made in a letter addressed to me
and filed
through the EDGAR system and in amendments to the Registration Statement. If
you believe
that you do not need to make changes to the Registration Statement in response
to a comment,
please indicate that in the letter and explain the basis for your position.

       Although we have completed our initial review of the Registration
Statement, the
Registration Statement will be subject to further review after our preliminary
comments are
resolved. Therefore, please be advised that we may make additional comments on
the
Registration Statement and any additional amendments to it.

        If you have any questions, please call me at (202) 551-6929.
Additionally, copies of
documents or letters filed on EDGAR may be emailed to me at zapataa@sec.gov.
Any mail or
deliveries should include a reference to zip code 20549-8629.

                                                      Sincerely,

                                                      /s/

                                                      Alberto H. Zapata
                                                      Senior Counsel
                                                      Disclosure Review and
Accounting Office




cc:    Andrea Ottomanelli Magovern, Assistant Director
       Asen Parachkevov, Branch Chief





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