September 30, 2020


Thomas R. Westle, Esq.
Blank Rome
1271 Avenue of the Americas
New York, NY 10020

       Re:    High Income Securities Fund
              Registration Statement on Form N-2
              Filing Nos. 333-248590

Dear Mr. Westle:

        The staff has reviewed the above-referenced initial registration
statement, which the
Commission received on August 31, 2020. Based on our review, we have the
following
comments on the registration statement. Capitalized terms have the same meaning
as defined in
the registration statement. Where a comment requests a change to disclosure,
please make
corresponding changes wherever similar disclosure appears in the registration
statement.

General Comments

1.     Please either confirm that the rights offering will not involve any
arrangements among
       the Fund, any underwriters, and/or any broker dealers or that FINRA has
reviewed any
       proposed underwriting terms and other arrangements for the transaction
described in the
       registration statement and has no objections.

                                    Accounting Comments

2.     Please update financial information and include an auditor   s consent.

Summary of Fund Expenses, page 10

3. Please explain the 0.92% in the line item of    Other Expenses    since the
expense ratio from
   the financial statements on page 21 is 1.89%

4. Please confirm the Acquired Fund Fees and Expenses which, given the Fund   s
portfolio of
   closed-end funds and BDC   s, appears low.
 Thomas R. Westle, Esq.
September 30, 2020
Page 2

                                       Legal Comments

Registration Statement Facing Sheet

5.    Please revise the facing sheet of the registration statement to reflect
the new Form N-2
      effective August 1, 2020. See Securities Offering Reform for Closed-End
Companies
      (Release No. IC-33866).

Cover Page

6.    The last sentence of the first paragraph, as well as multiple other
places in the registration
      statement, state that if there are not enough unsubscribed Shares to
honor all additional
      subscription requests, the Fund may, in its sole discretion, issue
additional Shares up to
      100% of the Shares available in the Offering to honor additional
subscription requests.
      The Fund is registering an equal number of Shares and Rights, and
footnote 1 to the
      registration fee table states that the amount of securities being
registered includes Shares
      subject to the Additional Subscription Privilege. Please supplementally
confirm that the
      Fund will have enough registered, issued and outstanding Shares to honor
all additional
      subscription requests, including Over Subscriptions, and revise the
disclosure
      accordingly.

7.    Please add disclosure stating that the rights offering: (a) will
substantially dilute the net
      asset value of shares owned by Shareholders who do not fully exercise
their rights and
      purchase additional Shares; (b) will substantially dilute the voting
power of shareholders
      who do not fully exercise their rights since they will own a smaller
proportionate interest
      in the Fund upon completion of the offering; and (c) may increase the
discount if the
      subscription price per Share is set at a time when Shares are trading at
a discount.

8.    In the second paragraph, please consider highlighting (e.g., bold) the
last sentence which
      discusses the risk that the discount will increase as a result of the
Offering. Alternatively,
      please add bullet points to highlight this risk and risks discussed in
comment 7 above.

9.    Please clarify how long after the Expiration Date (a) a Shareholder who
exercises the
      right to purchase a Basic Subscription will receive subscribed Shares and
(b) a
      Shareholder who exercises the Additional Subscription Privilege will
receive additional
      Shares, or add a cross-reference to where such information is presented
in the prospectus.

10.   If the Fund   s distribution policy includes a return of capital, please
disclose this on the
      cover page and include a cross-reference to the discussion of return of
capital in the
      prospectus.

11.   In the table, please revise the recent market price to a more recent date
in your next filing.

12.   In footnote 2 to the table, please define    Over Subscription Shares
for context or add    as
      defined below.
 Thomas R. Westle, Esq.
September 30, 2020
Page 3


13.   Please combine footnotes 2 and 3 which relate to the same column of the
table and repeat
      information.

14.   In the second paragraph on page 4, third sentence, please clarify those
jurisdictions where
         the offer or sale    of the securities being registered is not
permitted.

Summary, pages 6-9

The Fund, page 6

15.   Please discuss the Fund   s history in greater detail. We note, for
example, that after the
      proxy contest, the Fund   s Board moved substantially all of the Fund   s
assets into cash
      and cash equivalents so the Fund could conduct a self-tender offer and
convert from a
      closed-end fund to an operating company. After failing to find suitable
investments, in
      April 2019, the Board decided it would be in the best interests of the
shareholders to
      resume investing in securities.

The Offering, page 6

16.   The second sentence of the third paragraph states that    [t]he Fund
intends to expand the
      types of investments in which the Fund   s assets (including proceeds of
the Offering) are
      invested.    Please clarify whether the Fund intends to change its
objectives and policies,
      and briefly describe the types of investments in which the Fund intends
to    expand    into
      and how the Fund   s current asset size prevents such expansion.

17.   The penultimate sentence of the first paragraph states that Shareholders
who exercise all
      of their rights may purchase Shares that were not otherwise subscribed by
others in the
      Basic Subscription. Please add a cross-reference to the discussion of the
Additional
      Subscription Privilege.

18.   Please clarify that because the rights are non-transferable, a
Shareholder cannot trade the
      rights on the secondary market if he or she chooses not to exercise them.

Purpose of the Offering, page 6

19.   Please clarify whether offering proceeds will be used to support the Fund
  s distribution
      policy, and if so, disclose that this will be a return of capital.

20.   In the fifth paragraph, please clarify that Shareholders who choose not
to exercise their
      full rights to purchase additional Shares will permit Shareholders who
exercise the
      Additional Subscription Privilege to purchase additional Shares at a
discount without
      furnishing additional rights or providing any compensation to the
non-participating
      Shareholders for the dilution of their ownership percentage or voting
rights.
 Thomas R. Westle, Esq.
September 30, 2020
Page 4

21.    Please provide an example showing the extent of the dilutive effect when
the subscription
       price is below the NAV on the pricing date.

Investment Strategies, page 7

22.    Please clarify whether the Fund invests in affiliated or unaffiliated
funds or BDCs.

Transitional Investment Committee, page 8

23.    The name    Transitional Investment Committee    seems to imply that
this committee will
       only be managing the Fund temporarily, for a transitional period. The
disclosure states
       that the Board may engage an investment advisory firm in the future.
Please reconcile.

Distribution Policy, page 8

24.    The Fund   s Semi-Annual Report states that in August 2019, the Fund
resumed monthly
       distributions and that the goal of the Fund in 2020 is to distribute 10%
of the Fund   s
       NAV. Please disclose whether the Fund   s distributions during 2020 have
included a
       return of capital. In addition, please define    return of capital
and explain the
       consequences of a return of capital distribution including the impact on
a Shareholder   s
       tax basis.

Summary of Fund Expenses, page 10

25.    Footnote 2 to the Fee table states that the Fund does not pay a
management fee.
       Supplementally, please discuss the amount of director   s fees paid to
the three directors
       serving on the Transitional Investment Committee and provide an analysis
as to why
       these amounts should not be considered a management fee.

26.    Footnote 3 to the fee table states the Fund has a fundamental policy
prohibiting short
       sales; however, the SAI does not identify a prohibition on short sales
as a fundamental
       policy. Please reconcile

The Offering, pages 11-19

Purpose of the Offering, page 12

27.    You include the purchase of mutual funds as a potential use of the
proceeds of the
       Offering but the discussion of principal strategy does not include
mutual funds as a
       principal investment. Please clarify whether mutual funds will be a
principal investment
       of the Fund; we note the SAI states the Fund has a non-fundamental
policy limiting its
       investment in open-end investment companies.
 Thomas R. Westle, Esq.
September 30, 2020
Page 5

Payment for Shares, page 15

28.   In the third paragraph, please highlight the information and break up the
paragraph using
      bullet points or other formatting techniques.

Use of Proceeds, page 21

29.   As required by Item 7 of Form N-2, please identify how the Fund intends
to use the net
      proceeds of the offering and clarify the approximate amount to be used
for each purpose.
      For example, please revise the third sentence to clarify the amount of
proceeds that may
      be considered a    substantial portion.

30.   If the Fund needs the proceeds of the offering to meet monthly
distributions, please revise
      this section to emphasize this intended use of proceeds.

Investment Objectives and Policies, pages 22-26

Investment Objectives, page 22

31.   Please revise the first sentence to note that    high yield securities
are also known as
         junk bonds.

32.   Please confirm the Fund   s investment objective which currently states
that it will invest
      in    a portfolio of lower-grade or non-rated convertible securities and
non-convertible,
      high-yield securities.

Investment Strategies, page 22

33.   The Fund has an 80% policy to invest in fixed income securities,
including debt
      instruments, convertible and preferred stock. The Fund   s latest
Semi-Annual Report
      disclosed that as of February 29, 2020, 70% of the Fund   s portfolio was
invested in other
      investment companies, 15% in money market funds, and 14% in special
purpose
      acquisition companies. The Fund   s benchmark index for measuring its
performance is a
      6-month Treasury Bill index. Supplementally, please discuss whether the
Fund   s name is
      consistent with rule 35d-1 given its current portfolio and whether the
Fund   s investments
      are consistent with its stated 80% policy, particularly with respect to
its investment in
      common stocks and SPACs, and its investment objectives.

34.   Please clarify whether the Fund may hold fixed income securities with any
maturity or
      duration.
 Thomas R. Westle, Esq.
September 30, 2020
Page 6

Portfolio Investments, Other Closed End Investment Companies, page 23

35.   Please describe the holdings of the underlying closed-end investment
companies in greater
      detail. Please confirm that the Fund looks through to the underlying
funds to determine
      compliance with its 80% test and revise disclosure accordingly. Please
also revise
      disclosure, as necessary, to account for the investments and risks of the
underlying funds
      that are principal to the Fund.

Corporate Bonds, Government Debt Securities and Other Debt Securities, page 23

36.    Please describe the kinds of securities that may pay variable rates of
interests in greater
       detail. If the Fund may invest in bank loans or other floating rate
loans, please describe
       these loans in greater detail, and discuss any risks related to an
investment in variable rate
       securities in the discussion of principal risks (e.g., settlement risk
for bank loans or any
       risks posed by the discontinuation of LIBOR).

37.    Please review the second paragraph and consider moving the last three
sentences to the
       discussion of principal risks since they discuss risks that are likely
to affect the Fund   s
       net asset value, yield and total return.

Illiquid Securities, page 25

38.    Please clarify whether the Fund   s principal investments, particularly
in SPACs, are
       consistent with this disclosure in this section that states that the
Fund will limit
       investments in illiquid securities to 10% of its net assets.

Risk Factors, pages 26-36

39.    Common stock risk and small and medium company risk are identified as
principal risks
       of investing in the Fund even though the Fund has an 80% policy focused
on fixed
       income securities. Please confirm that investments in common stock,
including in small
       and medium companies, is a principal investment strategy of the Fund.
Please move any
       risks related to non-principal investments of the Fund to the SAI.

40.    Investments in exchange traded funds and short sales are not identified
as a principal
       investment strategy of the Fund and the prospectus states in a number of
places that the
       Fund will not engage in short sales; however, ETF risk and short sale
risk are identified
       as principal risks of investing in the Fund. Please reconcile.

41.    Leverage risk is discussed on page 30. The fee table suggests that the
fund itself does not
       borrow for investment purposes and the principal investment strategy
does not suggest
       the Fund invests in derivatives. Please clarify here how the fund is
subject to leverage
       risk (e.g., through underlying funds, if accurate).

42.    On page 35, you identify principal risks related to options and futures,
securities lending
       and    Other Risks,    yet none of these investment types is identified
as a principal
 Thomas R. Westle, Esq.
September 30, 2020
Page 7

       investment strategy of the Fund. Please reconcile so that principal risk
section discusses
       only those risks associated with the Fund   s objectives, policies,
capital structure and
       trading. See, ADI 2019-08     Improving Principal Risks Disclosure. With
regard to
          Other Risks,    it is unclear whether the types of securities
included in discussion are
       principal investments of the Fund, and what the risks related to these
investments entail.

Non-Principal Risks, page 36

43.    Given the fund   s 80% policy, please confirm that interest rate risk
and debt security risk
       are non-principal risks of the Fund.

Management, pages 37-39

Portfolio Management, page 37

44.    Because the Fund invests in foreign securities, please provide a basis
to assess the
       expertise and experience of the Transitional Investment Committee. See,
Guide 9 to
       Form N-2.

Exhibits

45.    Rule 411 under the Securities Act and rule 0-4 under the Investment
Company Act
       require the hyperlinking to any exhibits filed with the registration and
to any other
       information incorporated by reference in a registration statement if
publicly available on
       EDGAR. Please add appropriate hyperlinks to your next filing with the
Commission.

Undertakings

46.    The registration statement filed on August 31, 2020 failed to include
the undertaking
       required by Item 34.1 of Form N-2. Please include the undertaking in
your next filing
       with the Commission.

                                   **********************


        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
filing 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.
 Thomas R. Westle, Esq.
September 30, 2020
Page 8

        We remind you that the company 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. Should you have any questions regarding this letter,
please contact me at
(202) 551-6870 or hahnja@sec.gov.
                                                   Sincerely,

                                                   /s/ Jaea Hahn

                                                   Jaea F. Hahn
                                                   Senior Counsel


cc:    Andrea Ottomanelli Magovern, Assistant Director
       Sumeera Younis, Branch Chief
       Jeffrey Long, Staff Accountant