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                                                                  July 27, 2021
By Email

Thomas R. Westle, Esq.
Blank Rome
1271 Avenue of the Americas
New York, NY 10020

           Re:      High Income Securities Fund
                    Registration Statement on Form N-2
                    Filing Nos. 333-257397

Dear Mr. Westle:

        The staff has reviewed the above-referenced initial registration
statement, which the
Commission received on June 25, 2021. Based on our review, we have the
following comments
on the registration statement. Capitalized terms have the same meaning as
defined in the
registration statement.1 Where a comment requests a change to disclosure,
please make
corresponding changes wherever similar disclosure appears in the registration
statement.

General Comments

1.         Please either confirm that the rights offering will not involve any
arrangements among
           the Fund, any underwriters, and/or any broker dealers or that FINRA
has reviewed any
           proposed underwriting terms and other arrangements for the
transaction described in the
           registration statement and has no objections.

2.         Supplementally, please discuss why the Fund is proposing to conduct
another rights
           offering less than a year from the conclusion of the last rights
offering and why the Fund
           is choosing to raise additional capital from existing shareholders
rather than through other
           means.

                                              Accounting Comments

3.         Please fill in all blanks, including in the fee table and financials
in your amendment, and
           update information as necessary. Please also file the auditor   s
consent as an exhibit.




1
    Page references are to the blacklined copy of the registration statement
provided by Jennifer Patt on June 30, 2021.
 Thomas R. Westle, Esq.
July 27, 2021
Page 2

                                       Legal Comments

Cover page

4.     Please add disclosure stating whether shareholders who subscribe have
the right to
       withdraw prior to the Expiration Date.

Summary, Distribution Policy, page 4

5.     In the second sentence, please clarify that the payments representing a
reduction in
       Shareholder   s principal investment is a    return of capital.

Financial Highlights, page 17

6.     Please confirm that Tait Weller remains the Company   s auditor.

Portfolio Investments, page 20

7.     We note the Fund currently invests a significant portion of its
portfolio in money market
       funds. Please add these to the description of Portfolio Investments, or
supplementally
       address why they are not principal investments of the Fund.

Fund Expenses, page 32

8.     In the fourth paragraph, please update the Fund's annual operating
expenses to a more
       recent date than August 31, 2020.

Distribution Policy, page 33-34

9.     Please disclose what percentage of the Fund   s distributions in 2020
were a return of
       capital.

Part C, Other Information

       Item 27 Exhibits

10.    Rule 411 under the Securities Act and rule 0-4 under the Investment
Company Act
       require the hyperlinking to any exhibits filed with the registration and
to any other
       information incorporated by reference in a registration statement,
including previously
       filed exhibits, if publicly available on EDGAR. Please add appropriate
hyperlinks to
       your next filing with the Commission.



                                  **********************
 Thomas R. Westle, Esq.
July 27, 2021
Page 3

       We note that portions of the filing are incomplete. We may have
additional comments on
those portions when you complete them in a pre-effective amendment, on
disclosures made in
response to this letter, or on exhibits added in any pre-effective amendments.
        A response to this letter should be in the form of a pre-effective
amendment filed
pursuant to Rule 472 under the Securities Act. The pre-effective amendment
filing should be
accompanied by a supplemental letter that includes your responses to each of
these
comments. Where no change will be made in the filing in response to a comment,
please
indicate this fact in your supplemental letter and briefly state the basis for
your position.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments,
action, or absence of
action by the staff. Should you have any questions regarding this letter,
please contact me at
(202) 551-6870 or hahnja@sec.gov.
                                                    Sincerely,

                                                    /s/ Jaea Hahn

                                                    Jaea F. Hahn
                                                    Senior Counsel


cc:    Andrea Ottomanelli Magovern, Assistant Director
       Sumeera Younis, Branch Chief
       Jeffrey Long, Staff Accountant
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