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U.S. Securities and Exchange Commission

Securities Exchange Act of 1934 — Rule 14a-8
Delaware Enhanced Global Dividend and Income Fund

May 11, 2018

Mr. Michael D. Mabry, Esq.
Stradley Ronon Stevens & Young, LLP
2005 Market Street, Suite 2600
Philadelphia, PA 19103

Delaware Enhanced Global Dividend and Income Fund
Omission of Shareholder Proposal Submitted by Saba< Capital Management, L.P.

Dear Mr. Mabry:

In a letter dated April 10, 2018, on behalf of the Delaware Enhanced Global Dividend and Income Fund (the“Fund”), you requested confirmation from the staff of the Division of Investment Management (“Division”) that it would not recommend enforcement action to the Securities and Exchange Commission if a shareholder proposal and supporting statement (“Supporting Statement”) (collectively, the “Proposal”) submitted by Saba Capital Management, L.P. (the “Proponent”) is excluded from the proxy materials for the proxy statement and related materials associated with the Fund’s 2018 annual meeting of shareholders (the “Proxy Materials”). The Proposal provides:

BE IT RESOLVED, that the shareholders of Delaware Enhanced Global Dividend and Income Fund (the “Fund”), request that the Board of Trustees (the “Board”) consider authorizing a self-tender offer for all outstanding common shares of the Fund at or close to net asset value (“NAV”). If more than 50% of the Fund's outstanding shares are submitted for tender, the tender offer should be cancelled and the Fund should be liquidated or converted into an open-end mutual fund.

The Fund maintains that the Proposal may be excluded from the Proxy Materials pursuant to Rule 14a-8(i)(3), because the Supporting Statement contains statements that are materially false or misleading, including statements that impugn the integrity of the Fund’s Board.

We are unable to concur in your view that the Fund may exclude the Proposal from the Proxy Materials under Rule 14a-8(i)(3). We do not conclude that you have demonstrated objectively that the proposal is materially false or misleading, including by impugning the integrity of the Board. Accordingly, we cannot assure the Fund that we would not recommend Enforcement action if the Fund excludes the Proposal from its Proxy Materials in reliance on Rule14a-8(i)(3).

Attached is a description of the informal procedures the Division follows in responding to shareholder proposals. You may contact me at (202) 551-6929 if you have any questions.


/s/ Alberto H. Zapata

Alberto H. Zapata
Senior Counsel

Attachment: Informal Procedures Regarding Shareholder Proposals

Incoming Letter

The Incoming Letter is in Acrobat format.


Modified: 5/14/2018