June 26, 2013 

IM Ref. No. 20134121540 

Credit Suisse High Yield Bond Fund 

and Credit Suisse Asset Management 

RESPONSE OF THE OFFICE OF CHIEF COUNSEL Income Fund, Inc. 

DIVISION OF INVESTMENT MANAGEMENT File No. 811-08777 

Your letter dated June 21,2013 requests our assurance that we would not recommend 

enforcement action to the Securities and Exchange Commission ("Commission") under Section 

5(b) or Section 6(a) of the Securities Act of 1933 (the "Securities Act") against Credit Suisse 

High Yield Bond Fund and Credit Suisse Asset Management Income Fund, Inc. (each a "Fund," 

and collectively, the "Funds"), each of which filed and had declared effective by the 

Commission a shelf registration statement on Form N-2 ("Registration Statement"), if a Fund 

files a post-effective amendment to its Registration Statement pursuant to Rule 486(b) under the 

Securities Act, under the circumstances set forth in your letter. 

Background 

You state that each Fund is a closed-end management investment company registered 

under the Investment Company Act of 1940 (the "Investment Company Act"). Each Fund filed 

and had declared effective by the Commission its Registration Statement pursuant to which it 

may issue common shares of beneficial interest or shares of common stock, as applicable, on a 

delayed basis in accordance with Rule 415(a)(l)(x) under the Securities Act and the positions of 

the Commission staff. 1 Credit Suisse Asset Management, LLC serves as the investment adviser 

to each Fund. Each Fund's common shares of beneficial interest or shares of common stock, as 

applicable, are registered under Section 12(b) of the Securities Exchange Act of 1934 and are 

listed and traded on the NYSE MKT. Credit Suisse High Yield Bond Fund has a fiscal year 

ending on October 31. Credit Suisse Asset Management Income Fund, Inc. has a fiscal year 

ending on December 31. 

You state that each Fund's board oftrustees/directors (the "Board"), including a majority 

ofindependent trustees/directors, has concluded that a continuously effective shelf registration 

statement would be beneficial to each Fund, its shareholders and potential investors. You state 

that each Fund, therefore, needs a continuously effective Registration Statement, and annually 

would have to file post-effective amendments to its Registration Statement pursuant to Section 

8(c) ofthe Securities Act ("Post-Effective Amendments") to bring the Fund's financial 

statements up to date or to make other non-material changes. You further state that each Fund, 

its shareholders and potential investors would benefit if Post-Effective Amendments filed for the 

purpose of bringing the Fund's financial statements up to date or to make any other non-material 

changes were effective immediately, as permitted by Rule 486(b) under the Securities Act 

available to certain registered closed-end investment companies. You state that utilization of 

Rule 486(b) would help ensure that the Funds have the ability to raise capital as the opportunity 

arises, and could reduce expenses incurred by the Funds in the Post-Effective Amendment 

See Nuveen Virginia Premium Income Municipal Fund, SEC Staff No-Action Letter (Oct. 6, 2006); Pilgrim 

America Prime Rate Trust, SEC StaffNo-Action Letter (May 1, 1998) ("Pilgrim Letter"). 
process. You further state that due to the limited purpose for which the Funds would use Rule 

486(b ), no erosion of investor protection would occur and investors could have faster access to 

important information about the Funds, including their updated financial information. 

Discussion 

Rule 486(b) under the Securities Act, in relevant part, states that a post-effective 

amendment to a registration statement filed by a registered closed-end management investment 

company which makes periodic repurchase offers under Rule 23c-3 under the Investment 

Company Act ("Interval Fund") shall become effective on the date on which it is filed with the 

Commission, provided that certain conditions are met. The conditions of Rule 486(b) require, 

among other things, that the post-effective amendment be filed for no purpose other than, among 

other things, bringing the financial statements up to date or making non-material changes, and 

that the registrant make certain representations concerning the purpose for which the amendment 

is filed. 

In adopting Rule 486(b) in 1994, the Commission recognized that Interval Funds may 

have a need to raise capital continuously, and therefore need continuously effective registration 

statements and would benefit if certain filings could become effective automatically. 2 The 

Commission staff in 1998 recognized that registered closed-end management investment 

companies such as the Funds, which are not Interval Funds, also may benefit from the flexibility 

to take advantage of favorable market conditions to raise additional capital through continuous or 

delayed offerings of their securities. 3 You assert that the Funds and their shareholders also 

would benefit if the Funds' Post-Effective Amendments that comply with the conditions of Rule 

486(b) could become effective immediately pursuant to that Rule. 

You represent that each filing made in reliance on the requested relief would be made in 

compliance with the conditions of Rule 486(b), and that each Fund will file a Post-Effective 

Amendment containing a prospectus pursuant to Section 8( c) ofthe Securities Act prior to any 

offering of its common shares of beneficial interest or shares of common stock, as applicable, at 

a price below net asset value. You also represent that in relying on the requested relief to sell 

shares of beneficial interest or shares of common stock, as applicable, each Fund will sell newly 

issued shares at a price no lower than the sum ofthe Fund's net asset value plus the per share 

commission or underwriting discount. 4 

Conclusion 

Based on the facts and representations set forth in your letter, we would not recommend 

that the Commission take any enforcement action under Section 5(b) or Section 6(a) of the 

2 See Post-Effective Amendments to Investment Company Registration Statements, Investment Company 

Act Release No. 20486 (Aug. 17, 1994), n.22 and accompanying text. An Interval Fund operates pursuant to a 

fundamental policy that requires the Interval Fund to make periodic offers to repurchase its common stock in an 

amount not less than five percent of the outstanding shares. See Rule 23c-3 under the Investment Company Act. 

These repurchase offers may create a need for the Interval Fund to replenish its assets by making a continuous or 

intermittent offering of its common stock. See Continuous or Delayed Offerings by Certain Closed-End 

Management Investment Companies; Automatic Effectiveness of Certain Registration Statements and Post-Effective 

Amendments, Investment Company Act Release No. 19391 (Apr. 7, 1993). 

See Pilgrim Letter, supra note 1, at n.l2 and accompanying text. 

4 See Pilgrim Letter, supra note 1, at n.4 and accompanying text. 

2 

Securities Act against the Funds if the Funds file Post-Effective Amendments to their 

Registration Statements pursuant to Rule 486(b) under the Securities Act. This response 

expresses our view on enforcement action only and does not express any legal or interpretive 

conclusion on the issues presented. Because our position is based upon all of the facts and 

representations in your letter, any different facts or representations may require a different 

conclusion.5 We note that each Fund has acknowledged that the staff may withdraw any 

assurance granted in this letter if the staff finds that the Fund is misusing Rule 486(b) or for any 

other reason. 

Ck~~~ 

Adam Glazer 

Senior Counsel 

The Division of Investment Management generally permits third parties to rely on no-action or interpretive 

letters to the extent that the third party's facts and circumstances are substantially similar to those described in the 

underlying request for a no-action or interpretive letter. See Informal Guidance Program for Small Entities, 

Investment Company Act Release No. 22587 (Mar. 27, 1997), n.20. In light ofthe very fact-specific nature of the 

Funds' request, however, the position expressed in this letter applies only to the Funds, and no other entity may rely 

on this position. The staff is willing to consider similar requests from other registered closed-end management 

investment companies. 

3 

June 21,2013 

Mr. Douglas Scheidt, Esq. 

Associate Director and Chief Counsel 

Division of Investment Management 

United States Securities and Exchange Commission 

100 F Street, N.E. 

Washington, DC 20549 

Dear Mr. Scheidt: 

On behalf of Credit Suisse High Yield Bond Fund (the "DHY") and Credit Suisse Asset 

Management Income Fund, Inc. ("CIK" and together with DHY, the "Funds" and each, a 

"Fund"), we seek assurance that the staff ofthe Division oflnvestment Management (the 

"Staff') will not recommend enforcement action against the Funds to the Securities and 

Exchange Commission (the "Commission") under Section 5(b) or Section 6(a) ofthe Securities 

Act of 1933, as amended (the "Securities Act"), if each Fund utilizes Rule 486(b) under the 

Securities Act to file post-effective amendments to its registration statements in satisfaction of 

the undertakings contained in its registration statements under the circumstances set forth in this 

letter. 

I. Background 

Each Fund is a closed-end management investment company that is registered under the 

Investment Company Act of 1940, as amended (the "Investment Company Act"). Each Fund's 

common shares of beneficial interest or shares of common stock, as applicable, are registered 

under Section 12(b) ofthe Securities Exchange Act of 1934, as amended, and are listed and 

traded on the NYSE MKT. Credit Suisse Asset Management, LLC serves as the investment 

adviser to each Fund. DHY has a fiscal year end of October 31 and CIK has a fiscal year end of 

December 31. Each Fund has filed and had declared effective by the Commission a shelf 

registration statement on Form N-2 pursuant to which it has registered, and may issue, common 

shares of beneficial interest or shares of common stock, as applicable, in accordance with the 

terms of Rule 415(a)(l)(x) under the Securities Act and the positions of the Staff articulated in 

Pilgrim America Prime Rate Trust, SEC StaffNo-Action Letter (May 1, 1998) and Nuveen 

Virginia Premium Income Municipal Fund, SEC StaffNo-Action Letter (October 6, 2006) 

("Nuveen 1"). 
7771830.5 

Mr. Douglas Scheidt 

June21,2013 

Page 2 

The Commission initially declared effective DHY's shelf registration statement on Form 

N-2 (File Nos. 333-183901; 811-08777) on October 17, 2012 and CIK's shelf registration 

statement ofForm N-2 (File Nos. 333-184589; 811-05012) on January 22,2013. 

The Board of Trustees/Directors of each Fund (the "Board"), including a majority ofthe 

independent trustees/directors, has concluded that the continued ability to raise capital through 

the public offering of additional securities on a delayed and continuous basis is beneficial to each 

Fund and its shareholders. The Board has also concluded that a continuously effective shelf 

registration statement is beneficial to each Fund, its shareholders and potential investors. As 

discussed below, however, each Fund is subject to the risk of being unable to sell securities 

pursuant to its effective shelf registration statement for significant portions of each year due to 

the post-effective amendment process currently required to bring the Fund's financial statements 

up to date. The post-effective amendment process requires the Commission to review and 

declare effective any post-effective amendments filed to the shelf registration statement in order 

to bring a Fund's financial statements up to date. 

The Board of each Fund believes that the Fund, its shareholders and potential investors 

would benefit if the Fund were allowed to utilize Rule 486(b) under the Securities Act, which is 

available only to a certain category of registered closed-end investment companies, 1 to file postetlective amendments to its shelf registration statements that would become effective 

immediately, primarily for the purposes of updating its financial statements or making nonmaterial changes. Investors would benefit from the Funds' ability to raise capital in continuous 

offerings of their securities at non-dilutive prices, without potentially significant periods of 

disruption to such offering process. In addition, Fund shareholders could benefit from 

considerable cost savings, as expenses incurred in respect of the current post-effective 

amendment process can be significant. Due to the limited purpose for which the Funds propose 

to use Rule 486(b ), no erosion of investor protections would occur. 

II. Discussion 

Section 5(b)(l) ofthe Securities Act makes it unlawful for any person directly or 

indirectly to transmit, through interstate commerce, a prospectus relating to any security with 

respect to which a registration statement has been filed, unless the prospectus meets the 

requirements of Section 10 of the Securities Act. Similarly, Section 5(b )(2) of the Securities Act 

makes it unlawful for any person directly or indirectly to carry or cause to be carried any security 

for the purpose of sale or delivery, unless preceded or accompanied by a prospectus that meets 

the requirements of Section 1 O(a) of the Securities Act. 

Section 1 0( a)( 1) of the Securities Act, in pertinent part, states that a prospectus relating to 

a security other than a security issued by a foreign issuer shall contain the information 

contained in the issuer's registration statement. Section 1 0( a )(3) states that, notwithstanding 

1 The Funds are not organized as interval funds pursuant to Rule 23c-3 under the Investment Company Act, and 

therefore Rule 486(b) is not currently available to the Funds. 
7771830.5 

Mr. Douglas Scheidt 

June 21, 2013 

Page 3 

Section 10( a)( 1), a prospectus that is used more than nine months after the effective date ofthe 

registration statement must have information as of a date not more than sixteen months prior to 

such use, so far as the information is known to the user ofthe prospectus or can be furnished by 

the user ofthe prospectus without unreasonable effort or expense (a "10(a)(3) Prospectus"). 

Open-end management investment companies ("Open-end Funds"), unit investment 

trusts, and face-amount certificate companies are required by Section 24(e) ofthe Investment 

Company Act to use a 10( a)(3) Prospectus that does not vary from the latest prospectus filed as 

part of a post-effective amendment to the fund's registration statement. Open-end Funds satisfy 

this requirement by filing a post-effective amendment pursuant to Rule 485, which provides for 

automatic or immediate effectiveness? Notably, however, Section 24(e) does not apply to 

closed-end management investment companies, and there is no statutory requirement mandating 

that a closed-end fund make such a post-effective filing. 3 Instead, Rule 415(a)(3) requires a 

registrant that is an investment company filing on Form N-2 (the registration statement utilized 

by closed-end funds) to furnish the undertakings required by Item 34.4 of Form N-2. Item 34.4.a 

of Form N-2 requires closed-end funds to undertake "to file, during any period in which offers or 

sales are being made, a post-effective amendment to the registration statement: (1) to include any 

prospectus required by Section 1O(a)(3) of the 1933 Act." 

Each Fund has made this undertaking in its effective registration statement. As a 

consequence, each Fund currently is required to file a post-effective amendment on an annual 

basis to update its shelf registration statement with its audited financial statements in accordance 

with this undertaking, as well as to make any non-material updates. Each Fund currently 

satisfies this undertaking by filing a post-effective amendment with the Commission pursuant to 

Section 8( c) ofthe Securities Act. Section 8( c) does not provide a mechanism for automatic 

effectiveness.4 A post-effective amendment filed pursuant to Section 8(c) must be declared 

effective by the Staff in order to take effect. This process subjects the filings to Staff review and 

comment, including for routine non-material amendments, which in the Funds' experience can 

be a lengthy process. Prior to the post-effective amendment being declared effective by the 

Staff, a Fund cannot issue common shares of beneficial interest pursuant to it, thereby 

potentially preventing the Fund from taking advantage of what may be an attractive market to 

raise assets for the benefit of Fund shareholders. 

Closed-end funds that are operated as interval funds pursuant to Rule 23c-3 under the 

Investment Company Act are not subject to these delays. Rule 486(b) provides that a post2 Rule 485(a) pennits automatic effectiveness after the passage of a specified period oftime. Rule 485(b) provides 

for immediate effectiveness of filings made for certain purposes, including, among other things, updating financial 

statements and making non-material changes. 

3 See Section 24(e) of the Investment Company Act; L. Loss & J. Seligman, Securities Regulation, 566 (3rd ed. 

1998). 

4 But see supra note 2 and accompanying text for a discussion of Rule 485, which provides for automatic and 

immediate effectiveness for Open-end Funds. 
7771830.5 

Mr. Douglas Scheidt 

June 21,2013 

Page 4 

effective amendment to an effective registration statement, or a registration statement for 

additional shares of common stock, filed by a registered closed-end management investment 

company or business development company which makes periodic repurchase offers under Rule 

23c-3 under the Investment Company Act ("Interval Funds") shall become immediately effective 

on the date it is filed, or on a later date designated by the registrant that is no more than 30 days 

after the filing is made, provided that the post-effective amendment or registration statement is 

filed solely : (i) to register additional shares of common stock for which a registration statement 

filed on Form N-2 is effective, (ii) to bring the financial statements up to date under section 

10(a)(3) ofthe Securities Act or rule 3-18 of Regulation S-X, (iii) to designate a new effective 

date for a previously filed post-effective amendment or registration statement for additional 

shares under Rule 486(a), which has not yet become effective, (iv) to disclose or update the 

information required by Item 9c of Form N-2, 5 (v) to make any non-material changes the 

registrant deems appropriate, and (vi) for any other purpose the Commission shall approve. 

In the adopting release for Rule 486, the Commission stated that "[t]he initial proposal of 

rule 486 recognized that closed-end interval funds may need continuously effective re~istration 

statements and would benefit if certain filings could become effective automatically." The 

Funds believe that this line ofreasoning should be extended to them as closed-end funds that are 

conducting offerings pursuant to Rule 415(a)(1)(x). 

Recently, your office has concurred with this approach. In Nuveen Municipal High 

Income Opportunity Fund, SEC StaffNo-Action Letter (Nov. 9, 2010) ("Nuveen II"), Calamos 

Convertible Opportunities and Income Fund, SEC StaffNo-Action Letter (Feb. 14, 2011) and 

Aberdeen Australia Equity Fund, Inc., SEC Staff No-Action Letter (April 12, 2012), the Staff 

granted no-action assurances to three closed-end fund complexes that were engaged in a delayed 

or continuous offering pursuant to Rule 415(a)(l)(x). In the letters, the Staff agreed not to 

recommend enforcement action to the Commission under Sections 5 and 6(a) ofthe Securities 

Act based on the representation that the respective funds' board of directors approved the funds' 

delayed or continuous offerings, the representation that each fund's post-effective amendments 

would comply with the conditions of Rule 486(b ), and the representation that each fund would 

file a post-effective amendment containing a prospectus pursuant to Section 8(c) ofthe Securities 

Act prior to any offering of its common stock at a price below net asset value. 

Your office has stated that, "[i]n light ofthe very fact specific nature" of the requests, this 

relief is limited on its face to the addressees of the no-action letters. Your office has also stated, 

however, that it "is willing to consider similar requests from other registered closed-end 

management investment companies." 

5 We note that Form N-2 does not have, and has never had, an "Item 9c." Based upon a review ofthe administrative 

history of Rule 486, we believe that this should be a reference to Item 9 .I.e. of Form N-2, which relates to 

information regarding individual portfolio managers. Accordingly the Fund plans to treat the reference to "Item 9c" 

as a reference to Item 9.l.c. of Form N-2. 

6 Post-Effective Amendments to Investment Company Registration Statements, SEC Rei. No. 33-7083 (Aug. 17, 

1994). 
7771830.5 

Mr. Douglas Scheidt 

June 21, 2013 

Page 5 

We submit that the facts presented by the Funds in this request are similar to those 

presented in the Nuveen II, Calamos and Aberdeen letters. As was the case with each ofthe 

funds in the Nuveen II, Calamos and Aberdeen letters, each Fund's Board, including a majority 

of its independent trustees, has concluded that the continued ability to raise capital through the 

public offering of additional common shares of beneficial interest on a delayed and continuous 

basis would benefit each Fund and its shareholders. In addition, each Fund's Board has 

concluded that a continuously effective shelf registration statement would be beneficial to the 

Fund, its shareholders and potential investors. In furtherance of these conclusions, each Fund 

has an effective registration statement on file with the Commission pursuant to which the Fund 

may issue common shares of beneficial interest on a delayed and continuous basis in accordance 

with Rule 415(a)(l)(x) under the Securities Act and the positions of the Commission staff in the 

Nuveen I and Pilgrim letters. 

As is the case with Interval Funds, the Funds and their common shareholders would also 

benefit from having continuously effective registration statements. The ability to utilize Rule 

486(b) under the Securities Act would have significant benefits for a Fund and its investors: 

• 	 The Fund would have the ability to raise capital as the opportunity arises; 

• 	 The Fund could reduce the expenses it presently incurs as part ofthe registration 

statement review and comment process, thus benefiting shareholders; and 

• 	 Investors could have faster access to important information about the Fund including 

its updated financial information. 

In addition, because the ability to rely on Rule 486(b) would only permit the Funds to 

update their financial statements, or to make non-material changes to their registration 

statements, the Funds believe that the public policy of protecting investors would be 

safeguarded. Each Fund represents that each filing made in reliance on the requested relief 

would be made in compliance with the conditions of Rule 486(b ), and that each Fund will file a 

post-effective amendment containing a prospectus pursuant to Section S(c) of the Securities Act 

prior to any offering of its common shares of beneficial interest or shares of common stock, as 

applicable, at a price below net asset value. In relying on the requested relief to sell common 

shares of beneficial interest or shares of common stock, as applicable, each Fund will sell newly 

issued shares at a price no lower than the sum of the Fund's net asset value plus the per share 

commission or underwriting discount. 7 

Each Fund would utilize Rule 486(b) to file post-effective amendments only to: (1) bring 

the financial statements ofthe Fund up to date under Section 10(a)(3) ofthe Securities Act or 

7 See Calamos Convertible Opportunities and Income Fund, SEC StaffNo-Action Letter (Feb. 14, 2011). 
7771830.5 

Mr. Douglas Scheidt 

June 21,2013 

Page 6 

rule 3-18 of Regulation S-X; (2) update the information required by Item 9 .l.c of Form N-2; or 

(3) make any non-material changes the registrant deems appropriate. 8 

III. Conclusion 

In light of the forgoing, we seek your assurances that the Staff will deem each Fund to 

have complied with its undertaking provided in response to Item 34.4.a of Form N-2, and will 

not recommend enforcement action against the Funds to the Commission under Section 5(b) or 

Section 6(a) of the Securities Act ifthe Funds utilize Rule 486(b) ofthe Securities Act, under the 

circumstances set forth above. 

Each Fund acknowledges that the Staff may withdraw any assurance granted in response 

to this letter if the Staff finds that the Fund is misusing Rule 486(b ), or for any other reason. 

Please contact the undersigned at (212) 728-8215, with any questions or comments regarding this 

letter. 

Sincerely, 

Rose F. DiMartino, 

8 The Funds would not seek to use a filing made in accordance with Rule 486(b) to register additional securities 

without first obtaining relief from Rule 413 under the Securities Act.