Nuveen California AMT-Free Quality Municipal Income Fund (NKX) CORRESPCorrespondence with SEC

April 9, 2021

Ms. Megan Miller

U.S. Securities and Exchange Commission

Division of Investment Management, Disclosure Review & Accounting Office

100 F Street N.E.

Washington DC 20549

Nuveen Closed-End and Open-End Funds – Sarbanes Oxley Review

Dear Ms. Miller,

This letter addresses the comments you provided in a telephone discussion on March 5, 2021, regarding reviews performed by the staff of the U.S. Securities and Exchange Commission (the “SEC Staff”) of certain regulatory filings made by the Nuveen closed-end and open-end registered investment companies listed on Appendix A attached hereto, (each a “Fund” or “Registrant” and collectively, the “Funds” or “Registrants”), and advised by Nuveen Fund Advisors, LLC (the “Adviser”). Each comment is shown below followed by management’s response.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds will disclose the realized gains and losses recognized in connection with 17a-7 transactions. The gain and loss amounts will be added to the Funds’ current disclosure for 17-a transactions, which is within Note 7. Management Fees and Other Transactions with Affiliates, Other Transactions with Affiliates of the notes to financial statements.

Response: The Funds met the requirements of ASC 946-20-50-11 by disclosing the respective components of distributable earnings on a tax basis within Note 6. Income Tax Information of the notes to financial statements. The components of distributable earnings on a tax basis consist of net unrealized appreciation/(depreciation), undistributed net tax-exempt income, undistributed net ordinary income, undistributed net long-term capital gains, and unused capital loss carry forwards, where applicable. These amounts align with the distributable earnings on the statement of assets and liabilities after adjusting for the income distribution that

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was declared on February 3, 2020 and paid on March 2, 2020 as disclosed in the footnote under the tax components of undistributed income table, which read as follows in the February 29, 2020 annual report for the Nuveen California and New York closed-end Funds:

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the following disclosure will be included within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements, and will immediately follow the tables that summarize the fair values of the Funds’ investments as of the end of the reporting period:

The Funds hold liabilities in floating rate obligations and preferred shares, where applicable, which are not reflected in the tables above. The fair values of the Funds’ liabilities for floating rate obligations approximate their liquidation values. Floating rate obligations are generally classified as Level 2 and further described in Note 4. Portfolio Securities and Investments in Derivatives. The fair values of the Funds’ liabilities for preferred shares approximate their liquidation preference. Preferred shares are generally classified as Level 2 and further described in Note 5. Fund Shares.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, a “Commitments and Contingencies” line item will be added to the Funds’ statement of assets and liabilities, where applicable. This line item will also direct the reader to the applicable footnote disclosure within the notes to financial statements, which will generally read as follows, and will be updated as appropriate:

Commitments and Contingencies

In the normal course of business, each Fund enters into a variety of agreements that may expose the Fund to some risk of loss. These could include recourse arrangements for certain TOB Trusts and certain agreements related to preferred shares, which are each described elsewhere in these Notes to Financial Statements. The risk of future loss arising from such agreements, while not quantifiable, is expected to be remote. As of the end of the reporting period, the Funds did not have any unfunded commitments.

From time to time, the Funds may be a party to certain legal proceedings in the ordinary course of business, including proceedings relating to the enforcement of the Funds’ rights under contracts. As of the end of the reporting period, the Funds are not subject to any material legal proceedings.

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Response: Beginning with the Funds’ regulatory filings dated March 31, 2021, the Funds will include a tabular disclosure for each of the long and short futures contracts in their portfolios of investments, where applicable.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, when cash, cash equivalents, foreign currency, and restricted cash are presented in more than one line item on the statement of assets and liabilities, a Fund will include a reconciliation of the total in the statement of cash flows to the related captions on the statement of assets and liabilities. The following is an example of how such disclosure will appear using Nuveen Preferred & Income Opportunities Fund’s (JPC) annual report for the fiscal year ended July 31, 2020:

The following table provides a reconciliation of cash and cash collateral at brokers to the statement of assets and liabilities:

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Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ reverse repurchase agreements presented on the statement of assets and liabilities will include the accrued interest payable associated with those reverse repurchase agreements. The following is an example using Nuveen Preferred & Income Opportunities Fund’s (JPC) annual report for the fiscal year ended July 31, 2020:

Response: Management has determined that the elimination of LIBOR is not a principal risk for Nuveen Multi-Market Income Fund (JMM), however, management is continuously evaluating the potential effect a discontinuation of LIBOR could have on the Funds’ investments. At this time, management is not anticipating any significant impacts to the Funds’ investments, and as such, beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ will enhance their existing disclosure around LIBOR within Note 2. Significant Accounting Policies of the notes to financial statements as follows (new disclosure underlined):

Reference Rate Reform

In March 2020, FASB issued Accounting Standards Update (“ASU”) 2020-04, Reference Rate Reform: Facilitation of the Effects of Reference Rate Reform on Financial Reporting. The main objective of the new guidance is to provide relief to companies that will be impacted by the expected change in benchmark interest rates, when participating banks will no longer be required to submit London Interbank Offered Rate (LIBOR) quotes by the UK Financial Conduct Authority (FCA). The new guidance allows companies to, provided the only change to existing contracts are a change to an approved benchmark interest rate, account for modifications as a continuance of the existing contract without additional analysis. For new and existing contracts, the Funds may elect to apply the amendments as of March 12, 2020 through December 31, 2022. Management has not yet elected to apply the amendments, is continuously evaluating the potential effect a discontinuation of LIBOR could have on the Funds’ investments and has currently determined that it is unlikely the ASU’s adoption will have a significant impact on the Funds’ financial statements and various filings,

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Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Funds’ disclosure relating to reverse repurchase agreements that is included within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements will be enhanced to read as follows:

The Fund may enter into a reverse repurchase agreement with brokers, dealers, banks or other financial institutions that have been determined by the Adviser to be creditworthy. In a reverse repurchase agreement, a Fund sells to the counterparty a security that it holds with a contemporaneous agreement to repurchase the same security at an agreed-upon price and date, reflecting the interest rate effective for the term of the agreement. It may also be viewed as the borrowing of money by the Fund. Cash received in exchange for securities delivered, plus accrued interest payments to be made by the Fund to a counterparty, are reflected as a liability on the Statement of Assets and Liabilities. Interest payments made by the Fund to counterparties are recognized as a component of “Interest expense and amortization of offering costs” on the Statement of Operations.

In a reverse repurchase agreement, the Fund retains the risk of loss associated with the sold security. In order to minimize risk, the Fund pledges and/or segregates securities and cash as collateral with a fair value at least equal to its purchase obligations under these agreements (including accrued interest). Reverse repurchase agreements also involve the risk that the purchaser fails to return the securities as agreed upon, files for bankruptcy or becomes insolvent. Upon a bankruptcy or insolvency of a counterparty, the Fund is considered to be an unsecured creditor with respect to excess collateral and as such the return of excess collateral may be delayed. A Fund will pledge assets determined to be liquid by the Adviser to cover its obligations under reverse repurchase agreements.

Response: Management has determined that the elimination of LIBOR is not a principal risk for the Funds referenced by the SEC Staff. However, the Funds will add the following risk disclosure in their N-CSR filings going forward:

LIBOR Replacement Risk. The use of the LIBOR will begin to be phased out in the near future, which may adversely affect the Fund’s investments whose value is tied to LIBOR. There remains uncertainty regarding the future use of LIBOR and the nature of any replacement reference rate. Actions by regulators have resulted in the establishment of alternative reference rates to LIBOR in most major currencies and markets are slowly

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developing in response to these new rates. The transition process away from LIBOR may involve, among other things, increased volatility or illiquidity in markets for instruments that currently rely on LIBOR. The potential effect of a discontinuation of LIBOR on the Fund’s investments will vary depending on, among other things: (1) existing fallback provisions that provide a replacement reference rate if LIBOR is no longer available; (2) termination provisions in individual contracts; and (3) whether, how, and when industry participants develop and adopt new reference rates and fallbacks for both legacy and new products and instruments held by the Fund. Accordingly, it is difficult to predict the full impact of the transition away from LIBOR until it is clearer how the Fund’s products and instruments will be impacted by this transition.

Response: When a Fund incurs interest expense and such expense is not separately identified on the statement of operations, it is typically included as an “other expense.” Beginning with the Funds’ shareholder reports dated March 31, 2021, if such expense is included within “other expenses,” the notes to financial statements will disclose this interest expense. The following is an example using Nuveen Large Cap Core Fund’s annual report for the fiscal year ended July 31, 2020 (new disclosure underlined):

The credit facility has the following terms: a 0.10% upfront fee, 0.15% per annum on unused commitment amounts and a drawn interest rate equal to the higher of (a) one-month LIBOR (London Inter-Bank Offered Rate) plus 1.25% (1.00% prior to June 24, 2020) per annum or (b) the Fed Funds rate plus 1.25% (1.00% prior to June 24, 2020) per annum on amounts borrowed. Interest expense incurred by the Participating Funds, when applicable, is recognized as a component of “Other expenses” on the Statement of Operations. Participating Funds paid administration, legal and arrangement fees, which are recognized as a component of “Other expenses” on the Statement of Operations, and along with commitment fees, have been allocated among such Participating Funds based upon the relative proportions of the facility’s aggregate capacity reserved for them and other factors deemed relevant by the Adviser and the Board of each Participating Fund.

Response: Nuveen Credit Income Fund’s portfolio turnover as of the Fund’s last annual report was 80%, which is why there was no disclosure indicating that high portfolio turnover is a principal risk of the Fund. However, management agrees to monitor for Funds with consistently high portfolio turnover and will add appropriate risk language, where necessary going forward.

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Response: When a Fund is due compensation from the Adviser for the cost of services obtained from broker-dealers, such amounts are settled on a quarterly basis. Certain Nuveen Funds began to accrue for such services during 2020. Depending on the timing of when those accruals began versus when the first quarterly payment was received from the Adviser, it is possible that the “Receivable due from affiliate” on the Fund’s statement of assets and liabilities will equal the “Payment from affiliate” on the statement of operations.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, the Fund Performance and Expense Ratios section of the Funds’ shareholder reports will be enhanced to include such disclosure. The following is an example using Nuveen Mid Cap Growth Opportunities Fund’s annual report for the fiscal year ended October 31, 2020 (new disclosure underlined):

Expense Ratios

The expense ratios shown are as of the Fund’s most recent prospectus. The expense ratios shown reflect total operating expenses (before fee waivers and/or expense reimbursements, if any). The expense ratios include management fees and other fees and expenses. Refer to the Financial Highlights later in this report for the Fund’s expense ratios as of the end of the reporting period.

Response: Beginning with the Funds’ shareholder reports dated March 31, 2021, income from securities lending will include “net” in its statement of operations line item description.

Response: The S&P 500 Index is not a primary or secondary index for the Fund. In the Fund’s December 31, 2020 annual report, the MDFP stated “For the twelve-month reporting period ended December 31, 2020, BXMX’s shares at NAV outperformed the Chicago Board Options Exchange (Cboe) S&P 500^® BuyWrite Index (BXM^SM), its primary index.” As the S&P 500 Index is no longer being referenced in the MDFP, it will cease to be included within the MDFP chart that discloses performance.

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Response: We agree with the SEC Staff that the securities identified in the Fund’s December 31, 2019 annual report were not U.S. registrants, and therefore, the footnote reference inaccurately referred the reader to www.sec.gov for further information. In re-evaluating Reg S-X §210.12-12, and as the Fund’s exposure to this investment company does not represent a significant percentage of the Fund’s portfolio, management does not believe this footnote disclosure is necessary, and as such, the footnote will be removed beginning with the Fund’s regulatory filings for the period ended March 31, 2021.

Response: The Fund’s valuation policy for registered investment companies traded on a foreign exchange is the same as its valuation policy for foreign equity securities and therefore the following valuation disclosure for the Fund, and other Funds when applicable, will be updated as follows within Note 3. Investment Valuation and Fair Value Measurements of the notes to financial statements (new disclosure in underline):

Foreign equity securities and registered investment companies that trade on a foreign exchange are valued at the last sale price or official closing price reported on the exchange where traded and converted to U.S. dollars at the prevailing rates of exchange on the date of valuation. To the extent these securities are actively traded and that valuation adjustments are not applied, they are generally classified as Level 1. If there is no official close of business, then the latest available sale price is utilized. If no sales are reported, then the mean of the latest available bid and ask prices is utilized and are generally classified as Level 2.

The above disclosure will also be accompanied by the Fund’s current disclosure, which reads as follows:

For events affecting the value of foreign securities between the time when the exchange on which they are traded closes and the time when the Funds’ net assets are calculated, such securities will be valued at fair value in accordance with procedures adopted by the Board. These foreign securities are generally classified as Level 2.

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CC:   Audit Committee of the Funds

Eric Fess, Chapman & Cutler, LLP, Counsel to the Independent members of the Board of Directors/Trustees of the Funds

Gifford R. Zimmerman, Chief Compliance Officer and Vice President of the Funds

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APPENDIX A

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APPENDIX A (continued)

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