CORRESP 15 filename15.htm

corresp_distribrequest.htm

BlackRock Investments, LLC

55 East 52nd Street

New York, NY 10055

October 9, 2014

VIA EDGAR AND ELECTRONIC MAIL

John M. Ganley

Senior Counsel

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

RE:     BlackRock Debt Strategies Fund, Inc. (File Nos. 333-196682 & 811-08603)

Dear Mr. Ganley:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, BlackRock Investments, LLC (the "Distributor") hereby requests that the effec­tiveness of the above-referenced Registra­tion Statement on Form N-2 be accelerated so that it may become effective by 4:00 p.m., Washington, D.C. time, on Friday, October 10, 2014, or as soon thereafter as reasonably practicable.

In connection with this request, the Distributor acknowledges that:

(a) should the Securities and Exchange Commission (the "Commission") or its staff, acting pursuant to delegated authority, declare the above-referenced Registration Statement effective, it does not foreclose the Commission from taking any action with respect to such Registration Statement;

(b) the action of the Commission or its staff, acting pursuant to delegated authority in declaring the above-referenced Registration Statement effective, does not relieve the Distributor from its full responsibility for the adequacy and accuracy of the disclosure contained in such Registration Statement; and

(c) the Distributor may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

	Very truly yours,
	BLACKROCK INVESTMENTS, LLC
	By:	/s/ Jonathan Diorio
		Name:  Jonathan Diorio
		Title:    Director