SEC Division of Investment Management staff letter: DNP Select Income Fund Inc.

71 South Wacker Drive
Chicago, Illinois 60606-4637
Main Tel +1 312 782 0600
Main Fax +1 312 701 7711 October 4, 2018 www.mayerbrown.com Lawrence R. Hamilton Direct Tel +1 312 701 7055 Direct Fax +1 312 706 8333 Mr. Paul G. Cellupica, Esq. lhamilton@mayerbrown.com Deputy Director and Chief Counsel Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: DNP Select Income Fund Inc. Dear Mr. Cellupica:
On behalf of DNP Select Income Fund Inc. (the “Fund”), we seek assurance that the staff of the Division of Investment Management (the “Staff”) will not recommend enforcement action against the Fund to the Securities and Exchange Commission (the “Commission”) under Section 5(b) or Section 6(a) of the Securities Act of 1933, as amended (the “Securities Act”), if the Fund utilizes Rule 486(b) under the Securities Act to file post-effective amendments to its registration statement in satisfaction of the undertakings contained in its registration statement under the circumstances set forth in this letter.
I. Background
The Fund is a closed-end management investment company that is registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). The Fund is organized as a Maryland corporation and is governed by a board of directors (the “Board”). The Fund is authorized to issue shares of common stock. The Commission declared the Fund’s equity shelf registration statement on Form N-2 (File Nos. 333-223945 and 811-04915) effective on June 6, 2018. The Fund’s common stock is registered under Section 12(b) of the Securities Exchange Act of 1934, as amended, and is listed and traded on the New York Stock Exchange. Duff & Phelps Investment Management Co. serves as the investment adviser to the Fund. The Fund has a fiscal year end of October 31. The Fund has filed and had declared effective by the Commission an equity shelf registration statement on Form N-2 pursuant to which it has registered, and may issue, shares of common stock in accordance with the terms of Rule 415(a)(1)(x) under the Securities Act and the positions of the Staff articulated in Pilgrim America Prime Rate Trust, SEC Staff No-Action Letter (May 1, 1998) (“Pilgrim”) and Nuveen Virginia Premium Income Municipal Fund, SEC Staff No-Action Letter (Oct. 6, 2006) (“Nuveen I”). The Board, including a majority of the independent directors (“Independent Board Members”), has concluded that the continued ability to raise capital through the public offering of additional Mayer Brown LLP operates in combination with other Mayer Brown entities, which have offices in North America, Europe and Asia and are associated with Tauil & Chequer Advogados, a Brazilian law partnership.