April 18, 2008


Richard T. Prins, Esq.
Skadden, Arps, Slate, Meagher & Flom LLP
Four Times Square
New York, NY  10036


      RE:	The Gabelli Convertible and Income Securities Fund, Inc.
      333-149938; 811-05715

Dear Mr. Prins:

	We have reviewed the registration statement on Form N-2 for
The
Gabelli Convertible and Income Securities Fund, Inc., filed with
the
Securities and Exchange Commission on March 28, 2008.  We have the
following comments:


1. We note that the Fund did not include a cover letter with its
registration statement indicating the purpose of the filing.  In
the
future, we suggest the Fund include written correspondence with
each
filing indicating the name and the telephone number of the person
to
be contacted for information regarding the submission, the purpose
of
the filing, and whether it contains any novel or special issues,
or
disclosure that warrant staff attention.

2. Please explain to the staff whether the Fund will file post-
effective amendments in order to sell securities off the shelf or
whether it proposes to file supplements under Rule 497.  If the
latter, advise the staff how the Fund will update its financial
statements and legal opinion.

PROSPECTUS

Prospectus Summary

3. The registration statement pertains to a shelf offering for
preferred stock and notes but does not disclose the material terms
of
these securities.  Please revise the disclosure to include the
material terms of the subject securities.  In addition, please
explain to us the circumstances and conditions under which notes
will
be offered versus preferred stock.


4. Under the heading, "Dividends and Distributions," please
disclose
whether any dividends for preferred shares constituted return of
capital for the fiscal year ended December 31, 2007.

5. Under the heading, "Dividends and Distributions," the
disclosure
states that "[f]or the fiscal year ended December 31, 2007, the
Fund
made distributions of $0.80 per common share, of which 21%
constituted a return of capital."  In addition, as disclosed in
the
Financial Highlights, distributions to Common Shareholders in four
of
the last five years constituted a return of capital.  Please
explain
to us whether the Board has considered changing the distribution
policy for the Fund.  In addition, pursuant to Item 4 of Form N-2,
please change the line item in the Financial Highlights from
"Paid-in
capital" to "Return of capital."  Also, add a footnote to the
financial highlights explaining the return of capital and the
consequences of a return of capital to shareholders.

6. Please inform us whether the Fund intends to report
distribution
yield/rate.  If the Fund intends to report distribution yield at
any
point prior to finalizing its tax figures, the Fund should
estimate
the portion of the distribution yield that results from return of
capital and exclude this amount from the distribution yield.  In
addition, reports containing distribution yields/rates should be
accompanied by the total return and/or SEC yield with at least
equal
prominence.

7. Many investors may not fully understand a return of capital.
Under the heading, "Dividends and Distributions," in both the
Prospectus Summary and the text of the Prospectus, please clarify
that:

* Shareholders who periodically receive the payment of a dividend
or
other distribution consisting of a return of capital may be under
the
impression that they are receiving net profits when they are not.
* Shareholders should not assume that the source of a distribution
from the Fund is net profits.

8. Under the heading, "Use of Proceeds," please disclose how long
it
will take the Fund to invest the proceeds from the offering.

9. Under the heading, "Risk Factors and Special Considerations,"
the
disclosure states that "[t]he Fund would pay (and the holders of
common shares will bear) all costs and expenses relating to the
issuance and ongoing maintenance of the preferred shares,
including
any additional advisory fees on the incremental assets
attributable
to such shares."  If the advisory fee will be based on assets of
the
Fund including any outstanding debt, please correct the statement
above and include the issuance and ongoing maintenance of the
notes.
(See Comment 11).




Investment Objective and Policies

10. Under the heading, "Leveraging," the disclosure states that
"[t]he Fund currently has authorized the issuance of 2,000,000
shares
of preferred stock."  Please make clear whether or not this
includes
the amount of preferred shares being offered in this registration
statement.

Management of the Fund

11. The disclosure states that "As compensation for its services
and
the related expenses borne by the Investment Adviser, the Fund
pays
the Investment Adviser a fee, computed daily and payable monthly,
equal, on an annual basis, to 1.00% of the Fund`s average weekly
net
assets."  Please disclose whether or not the Fund`s average weekly
net assets include the amount attributable to preferred shares
and/or
debt outstanding.  (See Comment 9).

Regulatory Matters

12. The disclosure states, "In February 2007, the Investment
Adviser
made an offer of settlement to the Staff for communication to the
SEC
for its consideration to resolve this matter.  This offer of
settlement is subject to final agreement regarding the specific
language of the SEC`s administrative order and other settlement
documents.  Since these discussions are ongoing, the Investment
Adviser cannot determine whether they will ultimately result in a
settlement of this matter and, if so, what the terms of the
settlement might be."  Please update the disclosure as applicable
and
provide more specific information concerning the settlement offer.

Automatic Dividend Reinvestment and Voluntary Cash Purchase Plan

13. The disclosure states that "a shareholder whose common shares
are
registered in his or her own name will have all distributions
reinvested automatically by Computershare, which is agent under
the
Plan, unless the shareholder elects to receive cash."  Because the
return of capital distributions have been significant, please
disclose the effect to shareholders of receiving a return of
capital
distribution that is automatically reinvested in the Fund.

STATEMENT OF ADDITIONAL INFORMATION

Secondary Market Trading and Transfer of Auction Rate Preferred
Shares

14. We believe the third paragraph under this heading contains
useful
information for shareholders.  Please include this information in
the
prospectus under the heading, "Description of Capital Stock and
Notes."


FINANCIAL STATEMENTS

Schedule of Investments

15. As of December 31, 2007, the Fund held approximately 44% of
its
net assets in U.S. Government Obligations (U.S. Treasury Bills and
Notes).  Please discuss the Fund`s strategy of investing in U.S.
Government Obligations in the prospectus including the Prospectus
Summary if investment in U.S. Government Obligations is a primary
investment strategy of the Fund.

Financial Highlights

16. Please add a footnote to the financial highlights that
explains
the type of transactions referred to in the line item "Increase in
net asset value from common share transactions."

GENERAL

17. We note that portions of the filing 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
pre-effective amendments.

18. If you intend to omit certain information from the form of
prospectus included with the registration statement that is
declared
effective in reliance on Rule 430A under the Securities Act,
please
identify the omitted information to us supplementally, preferable
before filing the Fund`s final pre-effective amendment.

19. Response to this letter should be in the form of a pre-
effective
amendment filed pursuant to Rule 472 of the Securities Act.  Where
no
change will be made in the filing in response to a comment, please
indicate this fact in a supplemental letter and briefly state the
basis for your position.


TANDY LETTER

   We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

   Notwithstanding our comments, please furnish a letter
acknowledging that
* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* The Fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.

   We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.


			*		*		*		*

If you have any questions about these comments, please call me at
202-551-6957.

								Sincerely,



								Laura E. Hatch
								Staff Accountant