SEC Division of Investment Management staff letter: BlackRock Multi-Sector Income Trust

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WASH INGTON, D .C. www.skadden.com WILMINGTON BEl..) lN G BRUSSELS FRANKFURT June 18, 2013 HONG KONG

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VIENNA
Douglas J. Scheidt, Esq.
Associate Director and Chief Counsel
Division of Investment Management
Securities and Exchange Commission
100 F Street, N .K
Washington, DC 20549
Dear Mr. Scheidt:
We are writing on behalf of BlackRock Multi-Sector Income Trust (the "Trust"), a closed-end management investment company for which BlackRock Advisors, LLC serves as investment adviser. On behalf of the Trust, we seek confirmation that the staff of the Division of Investment Management (the "Staff') will not recommend that the Securities and Exchange Commission (the "Commission") take any enforcement action under Section 8(b )(1) of the Investment Company Act of 1940 (the "1940 Act") if the Trust implements a concentration policy pursuant to which the Trust will invest at least 25% of its total assets in mortgage related securities, including securities of issuers of mortgage-backed securities ("MBS") issued by private entities ("Private MBS") and MBS issued or guaranteed by U.S. federal agencies or government-related guarantors ("Government MBS"). Background In the course of the Staffs review of the Trust's Registration Statement on Form N-2 (the "Registration Statement"), the Staff commented on the Trust's fundamental investment restriction with respect to industry concentration. The Staff requested that the Trust revise its concentration policy to make clear whether the Trust will invest at least 25% of its total assets in Private MBS . In response to this comment, the Trust explained that it believed its policy to concentrate in the group of industries represented by issuers of mortgage related securities, inclusive of both Private MBS and Government MBS, was reasonable. The matter was referred to the Office of Chief Counsel for the Division of Investment Management, and the Trust