GOF / Guggenheim Strategic Opportunities Fund - Depositi SEC, Relazione annuale, dichiarazione di delega

Guggenheim Strategic Opportunities Fund
US ˙ NYSE ˙ US40167F1012

Statistiche di base
LEI 549300ZOXRKM68J8NB63
CIK 1380936
SEC Filings
All companies that sell securities in the United States must register with the Securities and Exchange Commission (SEC) and file reports on a regular basis. These reports include company annual reports (10K, 10Q), news updates (8K), investor presentations (found in 8Ks), insider trades (form 4), ownership reports (13D, and 13G), and reports related to the specific securities sold, such as registration statements and prospectus. This page shows recent SEC filings related to Guggenheim Strategic Opportunities Fund
SEC Filings (Chronological Order)
Questa pagina fornisce un elenco completo e cronologico dei depositi SEC, esclusi i documenti di proprietà che forniamo altrove.
February 28, 2025 DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ☒ Definitive

August 20, 2024 NPORT-EX

Protection Premium

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2023 Shares Value COMMON STOCKS† - 7.

May 9, 2024 EX-99

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.01 PER SHARE) FOURTH AMENDMENT CONTROLLED EQUITY OFFERING℠ SALES AGREEMENT May 3, 2024

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.01 PER SHARE) FOURTH AMENDMENT TO CONTROLLED EQUITY OFFERING℠ SALES AGREEMENT May 3, 2024 THIS FOURTH AMENDMENT (this “Amendment”) to the Sales Agreement (defined below) is entered into on and as of May 3, 2024, by and among Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the State of Delawar

May 9, 2024 8-K

Entry into a Material Definitive Agreement, Financial Statements and Exhibits, Other Events

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of report (Date of earliest event reported): May 9, 2024 (May 3, 2024) Guggenheim Strategic Opportunities Fund (Exact name of Registrant as Specified in Its Charter) Delaware 811-21982 20-5997403 (State or other jurisdiction (Co

May 6, 2024 EX-99

AMENDMENT AGREEMENT

AMENDMENT AGREEMENT THIS AMENDMENT AGREEMENT (“Amendment”) dated as of May 12, 2023 to the Committed Facility Agreement by and between GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (“Customer”), on the one hand, and BNP PARIBAS PRIME BROKERAGE INTERNATIONAL, LTD.

May 6, 2024 EX-99

AMENDMENT AGREEMENT

AMENDMENT AGREEMENT THIS AMENDMENT AGREEMENT (“Amendment”) dated as of November 18, 2021 (the “Effective Date”) to the Amended and Restated Committed Facility Agreement dated as of March 6, 2019 by and between GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (“Customer”), on the one hand, and BNP PARIBAS PRIME BROKERAGE INTERNATIONAL, LIMITED (“BNPP PB”), on the other.

May 6, 2024 EX-99

Guggenheim Entities & Revisions

Guggenheim Funds, Guggenheim Partners Investment Management LLC, Security Investors, LLC, Guggenheim Funds Distributors, LLC, Guggenheim Funds Investment Advisors, LLC, Guggenheim Investment Advisors, LLC, Guggenheim Investor Services, LLC, Guggenheim Corporate Funds, LLC, GS Gamma Advisors, LLC, and Guggenheim Partners Advisors, LLC Code of Ethics Sponsor Head of GI Compliance Owner Chief Complia

May 6, 2024 424B5

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $850,000,000

Filed Pursuant to Rule 424(b)(5) Securities Act File No. 333-279126 Investment Company Act File No. 811-21982 PROSPECTUS SUPPLEMENT (to Prospectus dated May 3, 2024) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $850,000,000 Guggenheim Strategic Opportunities Fund (the “Fund”) is a diversified, closed-end managemen

May 6, 2024 EX-FILING FEES

Calculation of Filing Fee Tables Form N-2 (Form Type) Guggenheim Strategic Opportunities Fund (Exact Name of Registrant as Specified in its Charter) Table 1: Newly Registered and Carry Forward Securities

EX-FILING FEES Calculation of Filing Fee Tables Form N-2 (Form Type) Guggenheim Strategic Opportunities Fund (Exact Name of Registrant as Specified in its Charter) Table 1: Newly Registered and Carry Forward Securities Security Type Security Class Title Fee Calculation or Carry Forward Rule Amount Registered Proposed Maximum Offering Price Per Unit Maximum Aggregate Offering Price Fee Rate Amount of Registration Fee Carry Forward Form Type Carry Forward File Number Carry Forward Initial effective date Filing Fee Previously Paid In Connection with Unsold Securities to be Carried Forward Newly Registered Securities Fees to Be Paid Equity Common shares of beneficial interest, $0.

May 6, 2024 EX-99

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.01 PER SHARE) SECOND AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT September 16, 2021

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.01 PER SHARE) SECOND AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT September 16, 2021 THIS SECOND AMENDMENT (this “Amendment”) to the Sales Agreement (defined below) is entered into on and as of September 16, 2021, by and among Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the S

May 6, 2024 EX-99

2

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.

May 6, 2024 EX-99

AMENDMENT AGREEMENT

AMENDMENT AGREEMENT THIS AMENDMENT AGREEMENT (“Amendment”) dated as of December 31, 2021 (the “Effective Date”) to the Amended and Restated Committed Facility Agreement dated as of March 6, 2019 by and between GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (“Customer”), on the one hand, and BNP PARIBAS PRIME BROKERAGE INTERNATIONAL, LIMITED (“BNPP PB”), on the other.

May 6, 2024 EX-99

Guggenheim Strategic Opportunities Fund Fourth Amended and Restated Agreement and Declaration of Trust Dated as of February 29, 2024 TABLE OF CONTENTS

Guggenheim Strategic Opportunities Fund Fourth Amended and Restated Agreement and Declaration of Trust Dated as of February 29, 2024 TABLE OF CONTENTS ARTICLE I The Trust 1.

May 6, 2024 424B3

Supplement Dated May 6, 2024 to the currently effective Prospectus, as may be supplemented from time to time, for Guggenheim Strategic Opportunities Fund (the “Fund”)

Filed Pursuant to Rule 424(b)(3) Securities Act File No. 333-279126 Investment Company Act File No. 811-21982 PROSPECTUS SUPPLEMENT (to Prospectus dated May 3, 2024) Supplement Dated May 6, 2024 to the currently effective Prospectus, as may be supplemented from time to time, for Guggenheim Strategic Opportunities Fund (the “Fund”) This supplement provides updated information beyond that contained

May 6, 2024 EX-99

POWER OF ATTORNEY

POWER OF ATTORNEY BY THESE PRESENTS, that each of the undersigned constitutes and appoints Amy J.

May 6, 2024 EX-99

AMENDED AND RESTATED CLOSED-END FUND ACCOUNTING AND ADMINISTRATION AGREEMENT

AMENDED AND RESTATED CLOSED-END FUND ACCOUNTING AND ADMINISTRATION AGREEMENT This AMENDED AND RESTATED FUND ACCOUNTING AND ADMINISTRATION AGREEMENT (the “Agreement”) is made as of this 24th day of October, 2022 by and between MUFG Investor Services (US), LLC (“MUIS”) and each closed-end registered investment company listed on Schedule A hereto (as amended from time to time), (each individually referred to below as a “Trust”) (each a “Trust” and collectively, the “Trusts”).

May 6, 2024 N-2ASR

As filed with the Securities and Exchange Commission on May 3, 2024 Securities Act File No. 333-________ Investment Company Act File No. 811-21982 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-2 Registration Statement

As filed with the Securities and Exchange Commission on May 3, 2024 Securities Act File No.

May 6, 2024 EX-99

AMENDMENT AGREEMENT

AMENDMENT AGREEMENT THIS AMENDMENT AGREEMENT (“Amendment”) dated as of September 1, 2022 to the Amended and Restated Committed Facility Agreement by and between GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (“Customer”), on the one hand, and BNP PARIBAS PRIME BROKERAGE INTERNATIONAL, LTD.

May 6, 2024 EX-99

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Financial Statements” in the Statement of Additional Information, each dated May 3, 2023, and each included in this Post-Effective Amendment No 34 to the Registration Statement (Form N-2) (File No.

March 4, 2024 DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ☒ Definitive Proxy State

March 1, 2024 DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ☒ Definitive Proxy State

April 11, 2023 8-K

  UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549    FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of report (Date of earliest event reported): April 11, 2023 (March 27, 20

Guggenheim Strategic Opportunities Fund   UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

April 11, 2023 EX-99.1

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.01 PER SHARE) THIRD AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT March 27, 2023

Third Amendment to Controlled Equity Offering Sales Agreement GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.

March 28, 2023 424B5

  GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $330,024,727

Filed Pursuant to Rule 424(b)(5) Securities Act File No. 333-259592 Investment Company Act File No. 811-21982    PROSPECTUS SUPPLEMENT (to Prospectus dated September 20, 2021)   GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $330,024,727 Guggenheim Strategic Opportunities Fund (the “Fund”) is a diversified, closed-e

March 17, 2023 CORRESP

March 17, 2023

March 17, 2023 VIA EDGAR Ms. Andrea Ottomanelli Magovern, Esq. Assistant Director, Disclosure Review Office Division of Investment Management U.S. Securities and Exchange Commission 100 F Street N.E. Washington, D.C., 20549 Re: Guggenheim Strategic Opportunities Fund (File No. 811-21982) Dear Ms. Magovern: This letter is being filed on behalf of Guggenheim Strategic Opportunities Fund (the "Fund")

March 3, 2023 DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ☒ Definitive Proxy State

January 11, 2023 424B3

Supplement Dated January 11, 2023 to the currently effective Prospectus and Statement of Additional Information, as may be supplemented from time to time, for Guggenheim Strategic Opportunities Fund (the “Fund”)

Filed Pursuant to Rule 424(b)(3) Securities Act File No. 333-259592 Investment Company Act File No. 811-21982 PROSPECTUS SUPPLEMENT (to Prospectus dated September 20, 2021) Supplement Dated January 11, 2023 to the currently effective Prospectus and Statement of Additional Information, as may be supplemented from time to time, for Guggenheim Strategic Opportunities Fund (the “Fund”) This supplement

October 27, 2022 NPORT-EX

Investments in Securities (Liabilities)

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 Shares Value COMMON STOCKS† - 13.

April 29, 2022 8-K

Other Events

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of report (Date of earliest event reported): April 29, 2022 Guggenheim Strategic Opportunities Fund (Exact name of Registrant as Specified in Its Charter) Delaware 811-21982 20-5997403 (State or other jurisdiction (Commission Fi

April 28, 2022 NPORT-EX

COMMON STOCKS

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2022 Shares Value COMMON STOCKS† - 29.

March 4, 2022 DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ? Filed by a Party other than the Registrant ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ? Definitive Proxy State

February 25, 2022 424B5

Supplement Dated February 25, 2022 to the currently effective Prospectus (the “Prospectus”) and Statement of Additional Information (the “SAI”), as may be supplemented from time to time, for Guggenheim Strategic Opportunities Fund (the “Fund”)

Filed Pursuant to Rule 424(b)(5) Securities Act File No. 333-259592 Investment Company Act File No. 811-21982 PROSPECTUS SUPPLEMENT (to Prospectus dated September 20, 2021) Supplement Dated February 25, 2022 to the currently effective Prospectus (the ?Prospectus?) and Statement of Additional Information (the ?SAI?), as may be supplemented from time to time, for Guggenheim Strategic Opportunities F

October 27, 2021 NPORT-EX

Ending Balance at August 31, 2021

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2021 Shares Value COMMON STOCKS† - 5.

October 25, 2021 EX-99.9.01

NAV/Share ($)

Guggenheim Investments Announces Completion of the Mergers of GPM, GGM and GOF NEW YORK, NY, October 25, 2021 ? Guggenheim Investments announced today that the mergers (each, a ?Merger? and together, the ?Mergers?) of Guggenheim Enhanced Equity Income Fund (NYSE: GPM) and Guggenheim Credit Allocation Fund (NYSE: GGM) with and into Guggenheim Strategic Opportunities Fund (NYSE: GOF), each a closed-end fund (each, a ?Fund? and together, the ?Funds?), were completed prior to the open of the New York Stock Exchange on October 25, 2021.

October 25, 2021 EX-99.(12)(A)

Tax Opinion of Dechert LLP with respect to GPM and GOF*

Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.

October 25, 2021 EX-99.(4)(B)

Agreement and Plan of Merger with respect to GGM and GOF*

AGREEMENT AND PLAN OF MERGER October 21, 2021 In order to consummate the Merger (as defined in Section 3(a) herein) and in consideration of the promises and the covenants and agreements hereinafter set forth, and intending to be legally bound, Guggenheim Credit Allocation Fund, a Delaware statutory trust and a registered diversified closed-end investment company, File No.

October 25, 2021 EX-99.(4)(A)

Agreement and Plan of Merger with respect to GPM and GOF*

AGREEMENT AND PLAN OF MERGER October 21, 2021 In order to consummate the Merger (as defined in Section 3(a) herein) and in consideration of the promises and the covenants and agreements hereinafter set forth, and intending to be legally bound, Guggenheim Enhanced Equity Income Fund, a Delaware statutory trust and a registered diversified closed-end investment company, File No.

October 25, 2021 EX-99.(12)(B)

Tax Opinion of Dechert LLP with respect to GGM and GOF*

Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.

October 25, 2021 POS EX

As filed with the U.S. Securities and Exchange October 25, 2021

As filed with the U.S. Securities and Exchange October 25, 2021 Registration No. 333-255687 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N?14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. ? Post-Effective Amendment No. 2 ? (Check appropriate box or boxes) Guggenheim Strategic Opportunities Fund (Exact Name of Registrant as Specified in C

October 25, 2021 8-K

Financial Statements and Exhibits, Other Events

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of report (Date of earliest event reported): October 25, 2021 Guggenheim Strategic Opportunities Fund (Exact name of Registrant as Specified in Its Charter) Delaware 811-21982 20-5997403 (State or other jurisdiction (Commission

September 20, 2021 424B5

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $374,537,331

Filed Pursuant to Rule 424(b)(5) Securities Act File No. 333-259592 Investment Company Act File No. 811-21982 PROSPECTUS SUPPLEMENT (to Prospectus dated September 20, 2021) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $374,537,331 Guggenheim Strategic Opportunities Fund (the ?Fund?) is a diversified, closed-end ma

September 20, 2021 EX-99.L

Opinion and Consent of Dechert LLP

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.

September 20, 2021 N-2 POSASR

As filed with the Securities and Exchange Commission on September 20, 2021

As filed with the Securities and Exchange Commission on September 20, 2021 Securities Act File No.

September 20, 2021 EX-99.N

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions ?Financial Highlights?, ?Senior Securities and Other Financial Leverage? and ?Independent Registered Public Accounting Firm? in the Prospectus and ?Independent Registered Public Accounting Firm? and ?Financial Statements? in the Statement of Additional Information and to the incorporation by reference in this Registration Statement (Form N-2) (Post-effective Amendment No.

September 17, 2021 424B5

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $374,537,331

Filed Pursuant to Rule 424(b)(5) Securities Act File No. 333-259592 Investment Company Act File No. 811-21982 PROSPECTUS SUPPLEMENT (to Prospectus dated September 17, 2021) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $374,537,331 Guggenheim Strategic Opportunities Fund (the ?Fund?) is a diversified, closed-end ma

August 31, 2021 DEFA14A

UNITED STATES

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant Filed by a Party other than the Registrant Check the appropriate box: Preliminary Proxy Statement Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) Definitive Proxy Statement Defin

August 25, 2021 DEFA14A

GPM

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant Filed by a Party other than the Registrant Check the appropriate box: Preliminary Proxy Statement Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) Definitive Proxy Statement Defin

August 19, 2021 DEFA14A

UNITED STATES

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant Filed by a Party other than the Registrant Check the appropriate box: Preliminary Proxy Statement Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) Definitive Proxy Statement Defin

July 1, 2021 EX-99.(17)(C)

Form of Proxy Card for Guggenheim Credit Allocation Fund*

PROXY CARD SIGN, DATE AND VOTE ON THE REVERSE SIDE PROXY VOTING OPTIONS 1. MAIL your signed and voted proxy back in the postage paid envelope provided 2. ONLINE at vote.proxyonline.com using your proxy control number found below 3. By PHONE when you dial toll-free 1-888-227-9349 to reach an automated touchtone voting line CONTROL NUMBER 12345678910 YOUR VOTE IS IMPORTANT NO MATTER HOW MANY SHARES

July 1, 2021 EX-99.(17)(A)

Form of Proxy Card for Registrant*

PROXY CARD SIGN, DATE AND VOTE ON THE REVERSE SIDE PROXY VOTING OPTIONS 1. MAIL your signed and voted proxy back in the postage paid envelope provided 2. ONLINE at vote.proxyonline.com using your proxy control number found below 3. By PHONE when you dial toll-free 1-888-227-9349 to reach an automated touchtone voting line CONTROL NUMBER 12345678910 YOUR VOTE IS IMPORTANT NO MATTER HOW MANY SHARES

July 1, 2021 POS EX

As filed with the U.S. Securities and Exchange Commission on July 1, 2021

As filed with the U.S. Securities and Exchange Commission on July 1, 2021 Registration No. 333-255687 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N?14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. ? Post-Effective Amendment No. 1 ? (Check appropriate box or boxes) Guggenheim Strategic Opportunities Fund (Exact Name of Registrant as Spec

July 1, 2021 EX-99.(17)(B)

Form of Proxy Card for Guggenheim Enhanced Equity Income Fund*

PROXY CARD SIGN, DATE AND VOTE ON THE REVERSE SIDE PROXY VOTING OPTIONS 1. MAIL your signed and voted proxy back in the postage paid envelope provided 2. ONLINE at vote.proxyonline.com using your proxy control number found below 3. By PHONE when you dial toll-free 1-888-227-9349 to reach an automated touchtone voting line CONTROL NUMBER 12345678910 YOUR VOTE IS IMPORTANT NO MATTER HOW MANY SHARES

June 29, 2021 424B5

GUGGENHEIM ENHANCED EQUITY INCOME FUND GUGGENHEIM CREDIT ALLOCATION FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND 227 West Monroe Street Chicago, Illinois 60606 (312) 827-0100

GUGGENHEIM ENHANCED EQUITY INCOME FUND GUGGENHEIM CREDIT ALLOCATION FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND 227 West Monroe Street Chicago, Illinois 60606 (312) 827-0100 June 28, 2021 Dear Shareholder: You are cordially invited to attend a joint special meeting of shareholders (the ?Special Meeting?) of Guggenheim Enhanced Equity Income Fund (?GPM?), Guggenheim Credit Allocation Fund (?GGM?) and Guggenheim Strategic Opportunities Fund (?GOF? and, together with GPM and GGM, the ?Funds,? and each, a ?Fund?), scheduled to be held on August 24, 2021, at 10:00 a.

June 23, 2021 CORRESP

1 Year

June 23, 2021 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: David Manion DeCarlo McLaren Re: Guggenheim Strategic Opportunities Fund (File No. 333-255687) (the ?Registrant?) Dear Messrs. Manion and McLaren: On behalf of the Registrant, we wish to respond by this letter to a comment of the U.S. Securities and Exchange

June 21, 2021 CORRESP

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June 21, 2021 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: David Manion DeCarlo McLaren Re: Guggenheim Strategic Opportunities Fund (File No. 333-255687) (the ?Registrant?) Dear Messrs. Manion and McLaren: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange

June 21, 2021 EX-99.(14)

Consent of the Independent Registered Public Accounting Firm(7)

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Other Service Providers,” “Exhibit A Financial Highlights”, and “Representations and Warranties of the Acquiring Fund” and “Representations and Warranties of the Target Fund” in Exhibit B Form of Agreement and Plan of Merger in the Combined Proxy Statement/Prospectus of Guggenheim

June 21, 2021 EX-99.(12)

Form of Tax Opinion of Dechert LLP*

Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.

June 21, 2021 EX-99.(11)

Opinion of Dechert LLP Regarding Legality of the Securities Being Registered(7)

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.

June 21, 2021 N-14 8C/A

As filed with the U.S. Securities and Exchange Commission on June 21, 2021

As filed with the U.S. Securities and Exchange Commission on June 21, 2021 Registration No. 333-255687 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N?14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 1 ? Post-Effective Amendment No. ? (Check appropriate box or boxes) Guggenheim Strategic Opportunities Fund (Exact Name of Registrant as Spe

June 21, 2021 COVER

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June 21, 2021 VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, N.

April 30, 2021 EX-99.17(A)

Form of Proxy Card for Registrant

PROXY CARD SIGN, DATE AND VOTE ON THE REVERSE SIDE YOUR VOTE IS IMPORTANT NO PROXY VOTING OPTIONS MATTER HOW MANY SHARES 1.

April 30, 2021 EX-99.16

Power of Attorney(6)

EX-99.16 4 ex9916.htm POWERS OF ATTORNEY POWER OF ATTORNEY Each of the undersigned, in his or her capacity listed below and not individually, constitutes and appoints Amy J. Lee, Mark E. Mathiasen and Michael P. Megaris (acting alone and without the other) to act as attorney-in-fact and agent with authority of substitution and resubstitution of him or her in his or her name, place and stead, to do

April 30, 2021 EX-99.17(C)

Form of Proxy Card for Guggenheim Credit Allocation Fund

PROXY CARD SIGN, DATE AND VOTE ON THE REVERSE SIDE YOUR VOTE IS IMPORTANT NO PROXY VOTING OPTIONS MATTER HOW MANY SHARES 1.

April 30, 2021 N-14 8C

As filed with the U.S. Securities and Exchange Commission on April 30, 2021

As filed with the U.S. Securities and Exchange Commission on April 30, 2021 Registration No. [ ] U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N?14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. ? Post-Effective Amendment No. ? (Check appropriate box or boxes) Guggenheim Strategic Opportunities Fund (Exact Name of Registrant as Specified i

April 30, 2021 COVER

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April 30, 2021 VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, N.

April 30, 2021 EX-99.17(B)

Form of Proxy Card for Guggenheim Enhanced Equity Income Fund

PROXY CARD SIGN, DATE AND VOTE ON THE REVERSE SIDE YOUR VOTE IS IMPORTANT NO PROXY VOTING OPTIONS MATTER HOW MANY SHARES 1.

April 30, 2021 EX-99.(14)

Consent of the Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions ?Other Service Providers,? ?Exhibit A Financial Highlights?, and ?Representations and Warranties of the Acquiring Fund? and ?Representations and Warranties of the Target Fund? in Exhibit B Form of Agreement and Plan of Merger in the Combined Proxy Statement/Prospectus of Guggenheim

April 28, 2021 NPORT-EX

- GUGGENHEIM STRATEGIC OPPORTUNITIES FUND NQ

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2021 Shares Value COMMON STOCKS† - 6.

March 5, 2021 DEF 14A

- GBAB GGM GPM GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ? Filed by a Party other than the Registrant ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ? Definitive Proxy State

March 3, 2021 DEF 14A

- GBAB GGM GPM GOF

GUGGENHEIM TAXABLE MUNICIPAL BOND & INVESTMENT GRADE DEBT TRUST (NYSE: GBAB) GUGGENHEIM CREDIT ALLOCATION FUND (NYSE: GGM) GUGGENHEIM ENHANCED EQUITY INCOME FUND (NYSE: GPM) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (NYSE: GOF) 227 West Monroe Street, 7th Floor Chicago, Illinois 60606 NOTICE OF ANNUAL MEETING OF SHAREHOLDERS To be held on April 8, 2021 Notice is hereby given to the holders of common shares of beneficial interest, par value $0.

February 2, 2021 424B5

Guggenheim Strategic Opportunities Fund Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $159,724,117

PROSPECTUS SUPPLEMENT (to Prospectus dated October 2, 2020) Guggenheim Strategic Opportunities Fund Common Shares of Beneficial Interests Having an Aggregate Initial Offering Price of Up to $159,724,117 Guggenheim Strategic Opportunities Fund (the “Fund”) is a diversified, closed-end management investment company.

February 2, 2021 EX-99.(H)(II)

Amendment to Controlled Equity OfferingSM Sales Agreement among the Registrant, the Investment Adviser and Cantor Fitzgerald & Co. (*)

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES (PAR VALUE $0.01 PER SHARE) FIRST AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT February 1, 2021 THIS FIRST AMENDMENT (this “Amendment”) to the Sales Agreement (defined below) is entered into on and as of February 1, 2021, by and among Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the State o

February 2, 2021 POS EX

- GOF

As filed with the Securities and Exchange Commission on February 1, 2021 Securities Act File No.

October 27, 2020 NPORT-EX

- GUGGENHEIM STRATEGIC OPPORTUNITIES FUND NQ

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2020 Shares Value COMMON STOCKS† - 3.

October 2, 2020 424B5

Guggenheim Strategic Opportunities Fund Up to 11,250,000 Common Shares

PROSPECTUS SUPPLEMENT (to Prospectus dated October 2, 2020) Guggenheim Strategic Opportunities Fund Up to 11,250,000 Common Shares Guggenheim Strategic Opportunities Fund (the “Fund”) is a diversified, closed-end management investment company.

October 1, 2020 EX-99.(K)(II)(3)

Amendment to Fund Accounting Agreement(5)

AMENDMENT TO FUND ACCOUNTING AGREEMENTS This AMENDMENT (this “Amendment”) is made and entered into, as of this 27th day of August, 2020, by and between MUFG Investor Services (US), LLC (“MUIS”) and each of Fiduciary/Claymore Energy Infrastructure Fund (formerly, Fiduciary/Claymore MLP Opportunity Fund) (“FMO”); Guggenheim Taxable Municipal Managed Duration Trust (formerly, Guggenheim Build America Bonds Managed Duration Trust) (“GBAB”); Guggenheim Energy & Income Fund (“XGEIX”); Guggenheim Credit Allocation Fund (“GGM”); Guggenheim Strategic Opportunities Fund (“GOF”); and Guggenheim Enhanced Equity Income Fund (“GPM”) (each a “Trust” and collectively, the “Trusts”).

October 1, 2020 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Financial Statements” in the Statement of Additional Information and to the incorporation by reference in this Registration Statement (Form N-2) (Post-Effective Amendment No.

October 1, 2020 EX-99.(A)

Third Amended and Restated Declaration of Trust of Registrant dated August 27, 2020(5)

Guggenheim Strategic Opportunities Fund Third Amended and Restated Agreement and Declaration of Trust Dated as of August 27, 2020 TABLE OF CONTENTS ARTICLE I The Trust 1.

October 1, 2020 POS 8C

- GOF

As filed with the Securities and Exchange Commission on September 30, 2020 Securities Act File No.

October 1, 2020 EX-99.(B)

Eighth Amended and Restated By-Laws of the Registrant dated August 27, 2020(5)

EIGHTH AMENDED AND RESTATED BY-LAWS OF GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND EIGHTH AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws (the “By-Laws”), dated as of August 27, 2020, are made and adopted pursuant to Section 3.

October 1, 2020 EX-99.(K)(III)(3)

Amendment to Administration Agreement(5)

AMENDMENT TO FUND ADMINISTRATION AGREEMENT This AMENDMENT (this “Amendment”) is made and entered into, as of this 27th day of August, 2020, by and between MUFG Investor Services (US), LLC (“MUIS”) and each of Fiduciary/Claymore Energy Infrastructure Fund (formerly, Fiduciary/Claymore MLP Opportunity Fund) (“FMO”); Guggenheim Taxable Municipal Managed Duration Trust (formerly, Guggenheim Build America Bonds Managed Duration Trust) (“GBAB”); Guggenheim Energy & Income Fund (“XGEIX”); Guggenheim Credit Allocation Fund (“GGM”); Guggenheim Strategic Opportunities Fund (“GOF”); and Guggenheim Enhanced Equity Income Fund (“GPM”) (each a “Trust” and collectively, the “Trusts”).

October 1, 2020 EX-99.(L)

Opinion and Consent of Dechert LLP

EX-99.(L) 7 ex99l.htm OPINION AND CONSENT OF DECHERT LLP 1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com September 30, 2020 Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 Re: Guggenheim Strategic Opportunities Fund File Nos. 333-230474 and 811-21982 Dear Ladies and Gentlemen: We have acted as counsel for G

September 30, 2020 CORRESP

-

September 30, 2020 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: DeCarlo McLaren Re: Guggenheim Strategic Opportunities Fund (File Nos. 333-230474 and 811-21982) (the “Registrant”) Dear Mr. McLaren: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Guggenhe

September 29, 2020 CORRESP

-

September 29, 2020 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: DeCarlo McLaren Re: Guggenheim Strategic Opportunities Fund (File Nos. 333-230474 and 811-21982) (the “Registrant”) Dear Mr. McLaren: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commissi

July 31, 2020 EX-99.(B)

(b) Amended and Restated By-Laws of Registrant

SEVENTH AMENDED AND RESTATED BY-LAWS OF GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND SEVENTH AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws (the “By-Laws”), dated as of May 18, 2020, are made and adopted pursuant to Section 3.

July 31, 2020 POS 8C

- GOF

As filed with the Securities and Exchange Commission on July 31, 2020 Securities Act File No.

July 31, 2020 EX-99.(S)

Power of Attorney

POWER OF ATTORNEY BY THESE PRESENTS, that each of the undersigned constitutes and appoints Amy J.

July 31, 2020 COVER

-

July 31, 2020 VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, N.

February 26, 2020 DEFR14A

- CEF PROXY

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant ? Filed by a Party other than the Registrant ? Check appropriate box: ? Preliminary Proxy Statement ? Confidential, For Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ? Definitive Proxy Statement

February 25, 2020 DEF 14A

FMO / Fiduciary/Claymore MLP Opportunity Fund DEF 14A - - CEF PROXY

FIDUCIARY/CLAYMORE ENERGY INFRASTRUCTURE FUND (NYSE: FMO) GUGGENHEIM TAXABLE MUNICIPAL MANAGED DURATION TRUST (NYSE: GBAB) GUGGENHEIM CREDIT ALLOCATION FUND (NYSE: GGM) GUGGENHEIM ENHANCED EQUITY INCOME FUND (NYSE: GPM) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (NYSE: GOF) 227 West Monroe Street, 7th Floor Chicago, Illinois 60606 NOTICE OF ANNUAL MEETING OF SHAREHOLDERS To be held on April 2, 2020 Notice is hereby given to the holders of common shares of beneficial interest, par value $0.

January 31, 2020 CORRESP

* * *

January 31, 2020 VIA EDGAR Mr. David Manion U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Guggenheim Strategic Opportunities Fund (File Nos. 811-21982; 333-230474) Guggenheim Taxable Municipal Managed Duration Trust (File Nos. 811-22437; 333-233605) Guggenheim Enhanced Equity Income Fund (File No. 811-21681) (collectively, the

October 29, 2019 NPORT-EX

GOF / Guggenheim Strategic Opportunities Fund NPORT-EX - - GUGGENHEIM STRATEGIC OPPORTUNITIES NQ

Guggenheim Strategic Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2019 Shares Value COMMON STOCKS† - 0.

September 27, 2019 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Financial Statements” in the Statement of Additional Information and to the incorporation by reference in this Registration Statement (Form N-2) (Post-Effective Amendment No.

September 27, 2019 486BPOS

GOF / Guggenheim Strategic Opportunities Fund 486BPOS - - GOF

As filed with the Securities and Exchange Commission on September 27, 2019 Securities Act File No.

July 1, 2019 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Financial Statements” in the Statement of Additional Information and to the incorporation by reference in this Registration Statement (Form N-2) (Post-Effective Amendment No.

July 1, 2019 EX-99.(L)(II)

July 1, 2019

July 1, 2019 Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Guggenheim Strategic Opportunities Fund, a statutory trust (the “Trust”) created under the Delaware Statutory Trust Act (the “DSTA”), in connection with the issuance and sale by the Trust of up to 11,250,000 shares (the “Securities”) of the Trust’s common shares of beneficial interest, par value $0.

July 1, 2019 POS EX

GOF / Guggenheim Strategic Opportunities Fund POS EX - - GOF

As filed with the Securities and Exchange Commission on July 1, 2019 Securities Act File No.

July 1, 2019 EX-99.(H)

Controlled Equity OfferingSM Sale Agreement among the Registrant, the Investment Adviser and Cantor Fitzgerald & Co.(8)

Guggenheim Strategic Opportunities Fund Common Shares (par value $0.01 per share) Controlled Equity OfferingSM Sales Agreement July 1, 2019 Cantor Fitzgerald & Co. 499 Park Avenue New York, NY 10022 Ladies and Gentlemen: Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the State of Delaware (the “Fund”), and Guggenheim Funds Investment Advisors, LLC, a Delawar

June 27, 2019 CORRESP

GOF / Guggenheim Strategic Opportunities Fund CORRESP - -

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] June 27, 2019 Sonny Oh Christina Fettig Securities and Exchange Commission Division of Investment Management 100 F Street, N.

June 7, 2019 CORRESP

GOF / Guggenheim Strategic Opportunities Fund CORRESP - -

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] June 7, 2019 Sunny Oh Christina Fettig Securities and Exchange Commission Division of Investment Management 100 F Street, N.

April 29, 2019 EX-99.CERT

Brian E. Binder

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Brian E. Binder, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statement

April 29, 2019 N-Q

GOF / Guggenheim Strategic Opportunities Fund N-Q (Quarterly Schedule of Portfolio Holdings) GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

February 22, 2019 DEF 14A

FMO / Fiduciary/Claymore MLP Opportunity Fund CEF PROXY

FIDUCIARY/CLAYMORE ENERGY INFRASTRUCTURE FUND (NYSE: FMO) GUGGENHEIM TAXABLE MUNICIPAL MANAGED DURATION TRUST (NYSE: GBAB) GUGGENHEIM CREDIT ALLOCATION FUND (NYSE: GGM) GUGGENHEIM ENHANCED EQUITY INCOME FUND (NYSE: GPM) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (NYSE: GOF) 227 West Monroe Street, 7th Floor Chicago, Illinois 60606 NOTICE OF ANNUAL MEETING OF SHAREHOLDERS To be held on April 4, 2019 Notice is hereby given to the holders of common shares of beneficial interest, par value $0.

October 26, 2018 EX-99.CERT

Brian E. Binder

CERTIFICATIONS I, Brian E. Binder, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect

October 26, 2018 N-Q

GOF / Guggenheim Strategic Opportunities Fund GOF (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

September 7, 2018 486BPOS

GOF / Guggenheim Strategic Opportunities Fund GOF

As filed with the Securities and Exchange Commission on September 10, 2018 Securities Act File No.

September 7, 2018 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Financial Statements” in the Statement of Additional Information and to the incorporation by reference in this Registration Statement (Form N-2) (Post-Effective Amendment No.

September 7, 2018 EX-99.(L)

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] September 10, 2018

EX-99.(L) 4 ex99l.htm OPINION AND CONSENT OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP [Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] September 10, 2018 Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Guggenheim Str

September 7, 2018 EX-99.(R)(II)

Code of Ethics of the Sub-Adviser(6)

Sponsor Guggenheim Partners Investment Management, LLC Chief Compliance Officer Owner GPIM Director of Policies & Procedures Contact Arik.

September 7, 2018 EX-99.(H)(II)

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES ($0.01 PAR VALUE) FIRST AMENDMENT CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT September 10, 2018

EX-99.(H)(II) 3 ex99hii.htm FIRST AMENDMENT TO CONTROLLED EQUITY OFFERING SALE AGREEMENT GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES ($0.01 PAR VALUE) FIRST AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT September 10, 2018 THIS FIRST AMENDMENT (this “Amendment”) to the Sales Agreement (defined below) is entered into on and as of September 10, 2018, by and among Guggenheim Stra

September 7, 2018 EX-99.(R)(I)

Code of Ethics of the Registrant and the Investment Adviser(6)

Policy Number: IC24.0 Code of Ethics Procedure Creation Date: Adopted April 23, 2014 (by the Security Investors, LLC and Guggenheim Funds Investment Advisers, LLC) Procedure Reviewed As Of: April 23, 2014, March 20, 2015, May 9, 2016, April 2017, February 2018, August 2018 Procedure Revised As Of: October 1, 2014 March 20, 2015 May 9, 2016 November 2016 April 2017 February 2018 August 2018 Regulat

April 30, 2018 N-Q

GOF / Guggenheim Strategic Opportunities Fund GOF (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

April 30, 2018 EX-99.CERT

CERTIFICATIONS

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Brian E. Binder, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statement

March 26, 2018 DEF 14A

FMO / Fiduciary/Claymore MLP Opportunity Fund CEF PROXY

FIDUCIARY/CLAYMORE MLP OPPORTUNITY FUND (NYSE: FMO) GUGGENHEIM TAXABLE MUNICIPAL MANAGED DURATION TRUST (NYSE: GBAB) GUGGENHEIM CREDIT ALLOCATION FUND (NYSE: GGM) GUGGENHEIM ENHANCED EQUITY INCOME FUND (NYSE: GPM) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (NYSE: GOF) 227 West Monroe Street, 7th Floor Chicago, Illinois 60606 NOTICE OF ANNUAL MEETING OF SHAREHOLDERS To be held on April 26, 2018 Notice is hereby given to the holders of common shares of beneficial interest, par value $0.

January 16, 2018 EX-99.N

Consent of Independent Registered Public Accounting Firm

EX-99.N 4 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Financ

January 16, 2018 EX-99.(L)(I)

January 16, 2018

EX-99.(L)(I) 3 ex99li.htm OPINION AND CONSENT January 16, 2018 Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Guggenheim Strategic Opportunities Fund, a statutory trust (the "Trust") created under the Delaware Statutory Tru

January 16, 2018 POS EX

GOF / Guggenheim Strategic Opportunities Fund GOF

As filed with the Securities and Exchange Commission on January 16, 2018 Securities Act File No.

January 16, 2018 EX-99.(H)(I)

CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT January 16, 2018

EX-99.(H)(I) 2 ex99hi.htm CONTROLLED EQUITY OFFERING SALES AGREEMENT CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT January 16, 2018 CANTOR FITZGERALD & CO. 499 Park Avenue, 5th Floor New York, New York 10022 Ladies and Gentlemen: Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the State of Delaware (the "Fund"), and Guggenheim Funds Investment Advisors, LLC, a

January 11, 2018 CORRESP

GOF / Guggenheim Strategic Opportunities Fund CORRESP

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] January 11, 2018 Angela Mokodean Senior Counsel Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 (File Nos.

January 10, 2018 CORRESP

GOF / Guggenheim Strategic Opportunities Fund CORRESP

Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 January 10, 2018 Angela Mokodean Senior Counsel Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 (File Nos.

January 10, 2018 CORRESP

GOF / Guggenheim Strategic Opportunities Fund CORRESP

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] January 10, 2018 Angela Mokodean Senior Counsel Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Guggenheim Strategic Opportunities Fund Registration Statement on Form N-2 (File Nos.

October 30, 2017 EX-99.CERT

Vice President

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Amy J. Lee, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements wer

October 30, 2017 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

September 11, 2017 EX-99.(H)(II)

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES ($0.01 PAR VALUE) FIRST AMENDMENT CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT September 11, 2017

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND COMMON SHARES ($0.01 PAR VALUE) FIRST AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT September 11, 2017 THIS FIRST AMENDMENT (this ?Amendment?) to the Sales Agreement (defined below) is entered into on and as of September 11, 2017, by and among Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the State of Dela

September 11, 2017 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 5 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Fina

September 11, 2017 EX-99.(L)(II)

Skadden, Arps, Slate, Meagher & Flom llp 155 NORTH WACKER DRIVE CHICAGO, ILLINOIS 60606-1720 ________ TEL: (312) 407-0700 FAX: (312) 407-0411 www.skadden.com FIRM/AFFILIATE OFFICES ----------- BOSTON HOUSTON LOS ANGELES NEW YORK PALO ALTO WASHINGTON,

Skadden, Arps, Slate, Meagher & Flom llp 155 NORTH WACKER DRIVE CHICAGO, ILLINOIS 60606-1720 TEL: (312) 407-0700 FAX: (312) 407-0411 www.

September 11, 2017 486BPOS

- GOF

As filed with the Securities and Exchange Commission on September 11, 2017 Securities Act File No.

May 1, 2017 EX-99.CERT

Donald C. Cacciapaglia

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such st

May 1, 2017 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

March 31, 2017 DEF 14A

Fiduciary FMO GBAB GGM GPM GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Co-Registrants ? Filed by a Party other than the Co-Registrants ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule

December 7, 2016 EX-99.(L)

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] December 7, 2016

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] December 7, 2016 Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 RE: Guggenheim Strategic Opportunities Fund? Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Guggenheim Strategic Opportunities Fund, a statutory trust (the ?Trust?) created under the Delaware Statutory Trust Act (the ?DSTA?), in connection with the public offering by the Trust of up to 3,900,000 shares (the ?Securities?) of the Trust?s common shares of beneficial interest, par value $0.

December 7, 2016 EX-99.(H)

CONTROLLED EQUITY OFFERING SM SALES AGREEMENT December 7, 2016

CONTROLLED EQUITY OFFERING SM SALES AGREEMENT December 7, 2016 CANTOR FITZGERALD & CO.

December 7, 2016 EX-99.(N)(I)

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions ?Financial Highlights?, ?Senior Securities and Other Financial Leverage? and ?Independent Registered Public Accounting Firm? in the Prospectus and ?Independent Registered Public Accounting Firm? and ?Financial Statements? in the Statement of Additional Information and to the incorporation by reference in this Registration Statement (Form N-2) (Post-Effective Amendment No.

December 7, 2016 POS EX

Guggenheim Strategic Opportunities Fund GOF

As filed with the Securities and Exchange Commission on December 7, 2016 Securities Act File No.

November 10, 2016 CORRESP

Guggenheim Strategic Opportunities Fund ESP

Guggenheim Strategic Opportunities Fund 227 West Monroe Street Chicago, Illinois 60606 November 10, 2016 Asen Parachkevov Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Strategic Opportunities Fund ? Registration Statement on Form N-2 (File Nos.

October 31, 2016 N-Q

Guggenheim Strategic Opportunities Fund GOF (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

October 31, 2016 EX-99.CERT

Donald C. Cacciapaglia

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

October 14, 2016 CORRESP

Guggenheim Strategic Opportunities Fund ESP

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] October 14, 2016 Asen Parachkevov Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Guggenheim Strategic Opportunities Fund (File Nos.

July 29, 2016 EX-99.77O RULE 10F-3

GPIM AFFILIATED UNDERWRITER TRANSACTION FORM 1. Name of Issuer: Albertsons Companies 2. Security Description (Ticker, Cusip/ISIN/Sedol, coupon, etc.): Senior Notes 2024

GPIM AFFILIATED UNDERWRITER TRANSACTION FORM 1. Name of Issuer: Albertsons Companies 2. Security Description (Ticker, Cusip/ISIN/Sedol, coupon, etc.): Senior Notes 2024 3. Underwriting Syndicate: Bank of America Merrill Lynch, Credit Suisse, Citigroup, Morgan Stanley, Goldman, Sachs & Co., Deutsche Bank Securities, Barclays, Guggenheim Securities, RBC Capital Markets, Wells Fargo Securities, Drexe

July 29, 2016 EX-99.77Q1 OTHR EXHB

SIXTH AMENDED AND RESTATED GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND SIXTH AMENDED AND RESTATED BY-LAWS

SIXTH AMENDED AND RESTATED BY-LAWS OF GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND SIXTH AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws (the ?By-Laws?), dated as of February 24, 2016, are made and adopted pursuant to Section 3.

April 29, 2016 N-Q

Guggenheim Strategic Opportunities Fund GOF (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

April 29, 2016 EX-99.CERT

Donald C. Cacciapaglia

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

March 4, 2016 DEF 14A

Guggenheim Strategic Opportunities Fund DEFINITIVE PROXY STATEMENT

gug64158-def14a.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.) Filed by the Co-Registrants x Filed by a Party other than the Co-Registrants o Check the appropriate box: o Preliminary Proxy Statement o Confidential, for Use of the Commission Only (as

March 1, 2016 EX-3.1

SIXTH AMENDED AND RESTATED GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND SIXTH AMENDED AND RESTATED BY-LAWS

Unassociated Document SIXTH AMENDED AND RESTATED BY-LAWS OF GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND SIXTH AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws (the ?By-Laws?), dated as of February 24, 2016, are made and adopted pursuant to Section 3.

March 1, 2016 8-K

Regulation FD Disclosure, Financial Statements and Exhibits

guggof-8k.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of Report (Date of earliest event reported): February 24, 2016 (March 1, 2016) Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in its charter) Delaware 811-21982 20-5997403 (State or

October 30, 2015 EX-99.CERT

Donald C. Cacciapaglia

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

October 30, 2015 N-Q

Guggenheim Strategic Opportunities Fund GOF (Quarterly Schedule of Portfolio Holdings)

gug62789-nq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (

September 30, 2015 486BPOS

- GOF

gug62940gof-486pos.htm As filed with the Securities and Exchange Commission on September 30, 2015 Securities Act File No. 333-190872 Investment Company Act File No. 811-21982 United States Securities and Exchange Commission Washington, D.C. 20549 FORM N-2 x Registration Statement under the Securities Act of 1933 o Pre-Effective Amendment No. x Post-Effective Amendment No. 3 and/or x Registration S

September 30, 2015 EX-99.(R)(I)

Covered Entities:

Code of Ethics Procedure Creation Date: Adopted April 23, 2014 (by the Security Investors, LLC and Guggenheim Funds Investment Advisers, LLC) Procedure Reviewed As Of: April 23, 2014 Procedure Revised As Of: October 1, 2014 March 20, 2015 Regulatory Rules: Rule 17j-1 under the Investment Company Act of 1940 and Rule 204A-1 under the Investment Advisers Act of 1940 Business Unit: Compliance Departm

September 30, 2015 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 4 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights”, “Senior Securities and Other Financial Leverage” and “Independent Registered Public Accounting Firm” in the Prospectus and “Independent Registered Public Accounting Firm” and “Fina

September 30, 2015 EX-99.(R)(I)(I)

Guggenheim Partners Investment Management, LLC Code of Ethics August 2015 FOR INTERNAL USE ONLY

EX-99.(R)(I)(I) 6 ex99rii.htm CODE OF ETHICS OF THE SUB-ADVISER Guggenheim Partners Investment Management, LLC Code of Ethics August 2015 FOR INTERNAL USE ONLY 1 TABLE OF CONTENTS TABLE OF CONTENTS 2 I. OBJECTIVES OF THE CODE OF ETHICS 3 II. WHO IS SUBJECT TO THE CODE? 3 III. WHO ADMINISTERS THE CODE? 4 A. Chief Compliance Officer 4 B. Code of Ethics Compliance Platform 5 IV. FIDUCIARY DUTY TO CLI

September 30, 2015 EX-99.(K)(V)(2)

AMENDMENT No. 1 U.S. PB AGREEMENT

AMENDMENT No. 1 TO U.S. PB AGREEMENT AMENDMENT AGREEMENT (the ?Amendment?), dated as of March 13, 2015 to the U.S. PB Agreement, dated as of November 20, 2008, as may be amended from time to time (the ?Agreement?) between BNP Paribas Prime Brokerage, Inc. (?BNPP PB, Inc.?) and Guggenheim Strategic Opportunities Fund (formerly Claymore/Guggenheim Strategic Opportunities Fund) (the ?Customer?). WHER

April 29, 2015 N-Q

Guggenheim Strategic Opportunities Fund GOF (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

April 29, 2015 EX-99.CERT

Donald C. Cacciapaglia

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

March 27, 2015 DEF 14A

Fiduciary FMO GBAB GGM GPM GGE GEQ GOF

gug61670-def14a.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Co-Registrants x Filed by a Party other than the Co-Registrants o Check the appropriate box: o Preliminary Proxy Statement o Confidential, for Use of the Commission Only (a

October 30, 2014 N-Q

Guggenheim Strategic Opportunities Fund - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

October 30, 2014 EX-99.CERT

Donald C. Cacciapaglia

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such st

October 3, 2014 EX-99.(S)

Guggenheim Partners Investment Management, LLC Code of Ethics & Insider Trading Policy May 2014 FOR INTERNAL USE ONLY

EX-99.(S) 5 ex99s.htm CODE OF ETHICS OF THE SUB-ADVISER Exhibit (s) Guggenheim Partners Investment Management, LLC Code of Ethics & Insider Trading Policy May 2014 FOR INTERNAL USE ONLY i TABLE OF CONTENTS TABLE OF CONTENTS II I. OBJECTIVES OF THE CODE OF ETHICS & INSIDER TRADING POLICY 1 II. WHO IS SUBJECT TO THE CODE? 1 III. WHO ADMINISTERS THE CODE? 2 A Chief Compliance Officer 2 B Financial Tr

October 3, 2014 EX-99.(T)

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND POWER OF ATTORNEY

EX-99.(T) 6 ex99t.htm POWER OF ATTORNEY Exhibit (t) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND POWER OF ATTORNEY That each of the undersigned officers and trustees of Guggenheim Strategic Opportunities Fund, a statutory trust formed under the laws of the State of Delaware (the “Trust”), do constitute and appoint Amy J. Lee, Mark E. Mathiasen and Michael P. Megaris as true and lawful attorneys and age

October 3, 2014 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 3 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Exhibit (n) Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Financial Highlights” and “Independent Registered Public Accounting Firm” in the Prospectus, “Independent Registered Public Accounting Firm” in the Prospectus Supplement, and “Independent Reg

October 3, 2014 EX-99.(R)

Code of Ethics

Exhibit (r) Code of Ethics Procedure Creation Date: Adopted December 11, 1998 (by RDF, RSF, RVT, RGA, RFS, and RDI) Adopted on April 23, 2003 (by Rydex ETF Trust) Adopted by the Security Investors, LLC, February 1, 2005 Adopted by the Board, February 11, 2005 Ratified by the Board, February 17, 2007 Ratified by the Board, February 29, 2008 Ratified by the Boards, November 10, 2009 and November 18,

October 3, 2014 486BPOS

GOF / Guggenheim Strategic Opportunities Fund 486BPOS - - GOF

As filed with the Securities and Exchange Commission on October 3, 2014 Securities Act File No.

September 16, 2014 CORRESP

MZF / Managed Duration Investment Grade Municipal Fund CORRESP - -

[Letterhead of Guggenheim] September 16, 2014 Chad D. Eskildsen Division of Investment Management, Disclosure Review and Accounting Securities and Exchange Commission 100 F Street NE Washington, DC 20549 RE: Fiduciary/Claymore MLP Opportunity Fund (File No. 811-21652) Guggenheim Build America Bonds Managed Duration Trust (File No. 811-22437) Guggenheim Enhanced Equity Income Fund (File No. 811-216

July 29, 2014 EX-99.77Q2 ITEM 405

Based upon the Fund’s review of the copies of such forms effecting the Section 16 filings received by it, the Fund believes that for its most recently completed fiscal year, all filings applicable to such persons were completed and filed in a timely

Based upon the Fund’s review of the copies of such forms effecting the Section 16 filings received by it, the Fund believes that for its most recently completed fiscal year, all filings applicable to such persons were completed and filed in a timely manner, except as follows: a Form 3 (no securities owned) for James W.

July 29, 2014 EX-99.77B ACCT LTTR

Report of Independent Registered Public Accounting Firm

Report of Independent Registered Public Accounting Firm To the Shareholders and Board of Trustees of the Guggenheim Strategic Opportunities Fund In planning and performing our audit of the financial statements of Guggenheim Strategic Opportunities Fund (the Fund) as of and for the year ended May 31, 2014, in accordance with the standards of the Public Company Accounting Oversight Board (United Sta

April 29, 2014 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

April 29, 2014 EX-99.CERT

Donald C. Cacciapaglia

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

April 29, 2014 N-Q/A

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 227 West Monroe Street, Chicago, IL 60606 (Address of principal executive offices) (Zip code) Amy J.

April 29, 2014 EX-99.CERT

Donald C. Cacciapaglia

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such st

March 3, 2014 DEF 14A

- FMO GBAB GGM GPM GGE GEQ GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Co-Registrants x Filed by a Party other than the Co-Registrants o Check the appropriate box: o Preliminary Proxy Statement o Confidential, for Use of the Commission Only (as permitted by Rule

February 28, 2014 CORRESP

-

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] February 28, 2014 Valerie Lithotomos Securities and Exchange Commission Office of Investment Management 100 F Street, NE Washington, DC 20549 RE: Guggenheim Closed-End Funds Preliminary Proxy Statement Dear Ms.

February 7, 2014 PRE 14A

- FMO GBAB GGM GPM GGE GEQ GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Co-Registrants x Filed by a Party other than the Co-Registrants o Check the appropriate box: x Preliminary Proxy Statement o Confidential, for Use of the Commission Only (as permitted by Rule

November 1, 2013 EX-99.(H)(II)

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares ($0.01 par value) FIRST AMENDMENT CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND Common Shares ($0.01 par value) FIRST AMENDMENT TO CONTROLLED EQUITY OFFERINGSM SALES AGREEMENT November 1, 2013 THIS FIRST AMENDMENT (this “Amendment ”) to the Sales Agreement (defined below) is entered into on and as of November 1, 2013, by and among Guggenheim Strategic Opportunities Fund, a statutory trust organized under the laws of the State of Delawar

November 1, 2013 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 5 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the captions “Financial Highlights” and “Independent Registered Public Accounting Firm” in the Prospectus and “General Information – Counsel and Independent Registered Public Accounting Firm” and “Financial Statements

November 1, 2013 POS EX

- GOF

As filed with the Securities and Exchange Commission on November 1, 2013 Securities Act File No.

November 1, 2013 EX-99.(L)

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP]

EX-99.(L) 4 ex99l.htm OPINION AND CONSENT OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP [Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] November 1, 2013 Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 RE: Guggenheim Strategic Opportunities Fund— Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Guggenheim Str

October 30, 2013 EX-99.CERT

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to s

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such st

October 30, 2013 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Amy J.

October 22, 2013 CORRESP

-

Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 October 22, 2013 Valerie J.

October 17, 2013 CORRESP

-

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] October 17, 2013 Christian Sandoe Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Guggenheim Strategic Opportunities Fund File Nos.

July 30, 2013 EX-99.77B ACCT LTTR

Report of Independent Registered Public Accounting Firm

EX-99.77B ACCT LTTR 2 ex9977b.htm REPORT OF INDEPENDENT PUBLIC ACCOUNTING FIRM Report of Independent Registered Public Accounting Firm To the Shareholders and Board of Trustees of Guggenheim Strategic Opportunities Fund In planning and performing our audit of the financial statements of Guggenheim Strategic Opportunities Fund (the Fund) as of and for the period ended May 31, 2013, in accordance wi

April 29, 2013 EX-99.CERT

Donald C. Cacciapaglia

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

April 29, 2013 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Amy J.

March 8, 2013 DEF 14A

- FMO GBAB GOF GEQ GGE GPM

FIDUCIARY/CLAYMORE MLP OPPORTUNITY FUND (NYSE: FMO) GUGGENHEIM BUILD AMERICA BONDS MANAGED DURATION TRUST (NYSE: GBAB) GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (NYSE: GOF) GUGGENHEIM EQUAL WEIGHT ENHANCED EQUITY INCOME FUND (NYSE: GEQ) GUGGENHEIM ENHANCED EQUITY STRATEGY FUND (NYSE: GGE) GUGGENHEIM ENHANCED EQUITY INCOME FUND (NYSE: GPM) 2455 Corporate West Drive Lisle, Illinois 60532 NOTICE OF ANNUAL MEETING OF SHAREHOLDERS To be held on April 3, 2013 Notice is hereby given to the holders of common shares of beneficial interest, par value $0.

October 30, 2012 EX-99.CERT

/s/John Sullivan

CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

October 30, 2012 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Kevin M.

September 28, 2012 COVER

-

Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 September 28, 2012 Kimberly A.

September 28, 2012 CORRESP

-

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] September 28, 2012 Kimberly A.

September 18, 2012 CORRESP

-

The information in this Prospectus is not complete and may be changed. We may not sell these securities until the Registration Statement filed with the Securities and Exchange Commission is effective. This Prospectus is not an offer to sell these securities and is not soliciting an offer to buy these securities in any state where the offer or sale is not permitted. Subject to Completion, dated Aug

September 18, 2012 COVER

-

Skadden, Arps, Slate, Meagher & Flom llp 155 NORTH WACKER DRIVE CHICAGO, ILLINOIS 60606-1720 TEL: (312) 407-0700 FAX: (312) 407-0411 www.

August 31, 2012 EX-99.(K)(IV)(4)

AMENDMENT No. 3 COMMITTED FACILITY AGREEMENT

EX-99.(K)(IV)(4) 4 ex99kiv4.htm AMENDMENT NO. 3 TO THE COMMITTED FACILITY AGREEMENT AMENDMENT No. 3 TO COMMITTED FACILITY AGREEMENT AMENDMENT AGREEMENT (the “Amendment”), dated as of August 27, 2012 to the Committed Facility Agreement, dated as of November 20, 2008, as amended from time to time (the “Agreement”) between BNP Paribas Prime Brokerage, Inc. (“BNPP PB, Inc.”) and Guggenheim Strategic O

August 31, 2012 EX-99.(K)(IV)(3)

AMENDMENT No. 2 COMMITTED FACILITY AGREEMENT

EX-99.(K)(IV)(3) 3 ex99kiv3.htm AMENDMENT NO. 2 TO THE COMMITTED FACILITY AGREEMENT AMENDMENT No. 2 TO COMMITTED FACILITY AGREEMENT AMENDMENT AGREEMENT (the “Amendment”), dated as of February 15, 2012 to the Committed Facility Agreement, dated as of November 20, 2008, as amended on August 5, 2009 (and as may be further amended, supplemented or otherwise modified from time to time, the “Agreement”)

August 31, 2012 COVER

-

COVER 7 filename7.htm [Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] August 31, 2012 Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Strategic Opportunities Fund POS 8C Filing Ladies and Gentlemen: On behalf of Guggenheim Strategic Opportunities Fund (the "Fund"), we are enclosing herewith for filing pursuant to the Securities Act of 1933, as amend

August 31, 2012 POS 8C

- GOF

As filed with the Securities and Exchange Commission on August 31, 2012 Securities Act File No.

August 31, 2012 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 5 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the captions “Financial Highlights” and “Independent Registered Public Accounting Firm” in the Prospectus and “General Information - Independent Registered Public Accounting Firm” and “Financial Statements” in the Stat

July 27, 2012 EX-99.77C VOTES

Results of Shareholder Votes

Exhibit C Results of Shareholder Votes The Annual Meeting of Shareholders of the Fund was held on April 14, 2012.

July 27, 2012 EX-99.77B ACCT LTTR

Report of Independent Registered Public Accounting Firm

EX-99.77B ACCT LTTR 2 ex77b.htm REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Report of Independent Registered Public Accounting Firm To the Shareholders and Board of Trustees of Guggenheim Strategic Opportunities Fund In planning and performing our audit of the financial statements of Guggenheim Strategic Opportunities Fund (the Fund) as of and for the year ended May 31, 2012, in accord

April 27, 2012 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Kevin M.

April 27, 2012 EX-99.CERT

Kevin M. Robinson

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Kevin M. Robinson, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such stateme

March 7, 2012 DEF 14A

- PROXY STATEMENT

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Co-Registrants x Filed by a Party other than the Co-Registrants o Check the appropriate box: o Preliminary Proxy Statement o Confidential, for Use of the Commission Only (as permitted by Rule

February 17, 2012 CORRESP

-

February 17, 2012 Stephen B. Sadoski Cindy Rose Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Guggenheim Funds Third Party Valuation Responses Dear Sir and Madam: Thank you for providing us with your questions following our telephone call on January 19, 2012. We have considered your questions and our responses to those questions are set forth below. While we understa

January 26, 2012 EX-99.(H)(II)

GUGGENHEIM STRATEGIC OPPORTUNITIES FUND 1,500,000 Common Shares of Beneficial Interest ($0.01 par value) UNDERWRITING AGREEMENT

EX-99.(H)(II) 3 ex99hii.htm UNDERWRITING AGREEMENT AMONG REGISTRANT, THE INVESTMENT ADVISER, THE SUB-ADVISER AND THE UNDERWRITERS GUGGENHEIM STRATEGIC OPPORTUNITIES FUND 1,500,000 Common Shares of Beneficial Interest ($0.01 par value) UNDERWRITING AGREEMENT New York, New York January 26, 2012 Citigroup Global Markets Inc. Morgan Stanley & Co. LLC RBC Capital Markets, LLC As Representatives of the

January 26, 2012 EX-99.(L)(III)

[Letterhead of Skadden, Arps, Slate, Meagher & Flom, LLP]

EX-99.(L)(III) 4 ex99liii.htm OPINION AND CONSENT OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP [Letterhead of Skadden, Arps, Slate, Meagher & Flom, LLP] January 26, 2012 Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 RE: Guggenheim Strategic Opportunities Fund — Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Gugg

January 26, 2012 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 5 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the captions “Financial Highlights” and “Independent Registered Public Accounting Firm” in the Prospectus and “General Information - Independent Registered Public Accounting Firm” in the Statement of Additional Informa

January 26, 2012 POS EX

- GOF

As filed with the Securities and Exchange Commission on January 26, 2012 Securities Act File No.

December 30, 2011 CORRESP

-

Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 December 30, 2011 Richard Pfordte Kimberly A.

December 19, 2011 POS EX

- GOF

As filed with the Securities and Exchange Commission on December 16, 2011 Securities Act File No.

December 19, 2011 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

EX-99.(N) 5 ex99n.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the captions “Financial Highlights” and “Independent Registered Public Accounting Firm” in the Prospectus, “General Information - Independent Registered Public Accounting Firm” in the Statement of Additional Informatio

December 19, 2011 EX-99.(L)(II)

[Letterhead of Skadden, Arps, Slate, Meagher & Flom, LLP]

[Letterhead of Skadden, Arps, Slate, Meagher & Flom, LLP] December 16, 2011 Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 RE: Guggenheim Strategic Opportunities Fund? Registration Statement on Form N-2 Ladies and Gentlemen: We have acted as special counsel to Guggenheim Strategic Opportunities Fund, a statutory trust (the ?Trust?) created under the Delaware Statutory Trust Act, in connection with the offering by the Trust of up to 4,875,670 common shares (the ?Offered Common Shares?) of the Trust?s common shares of beneficial interest, par value $0.

December 19, 2011 EX-99.(H)(I)

Execution Version CONTROLLED EQUITY OFFERING SM SALES AGREEMENT December 16, 2011

Execution Version CONTROLLED EQUITY OFFERING SM SALES AGREEMENT December 16, 2011 CANTOR FITZGERALD & CO.

December 2, 2011 EX-3.1

FIFTH AMENDED AND RESTATED GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND FIFTH AMENDED AND RESTATED BY-LAWS

FIFTH AMENDED AND RESTATED BY-LAWS OF GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND FIFTH AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws (the ?By-Laws?), dated as of November 30, 2011, are made and adopted pursuant to Section 3.

December 2, 2011 EX-99.(N)

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the captions “Financial Highlights” and “Independent Registered Public Accounting Firm” in the Prospectus and “General Information - Independent Registered Public Accounting Firm” in the Statement of Additional Information, and to the use of our report dated July 27, 2011 on the May 31, 2011 financial statements of the Guggenheim Strategic Opportunities Fund included in the Registration Statement (Form N-2 Registration No.

December 2, 2011 EX-99.(B)

FIFTH AMENDED AND RESTATED GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND FIFTH AMENDED AND RESTATED BY-LAWS

EX-99.(B) 3 ex99b.htm AMENDED AND RESTATED BY-LAWS FIFTH AMENDED AND RESTATED BY-LAWS OF GUGGENHEIM STRATEGIC OPPORTUNITIES FUND GUGGENHEIM STRATEGIC OPPORTUNITIES FUND FIFTH AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws (the “By-Laws”), dated as of November 30, 2011, are made and adopted pursuant to Section 3.9 of the Second Amended and Restated Agreement and Declaration of Trus

December 2, 2011 EX-99.(R)(I)

Guggenheim Funds Distributors, Inc. Guggenheim Funds Investment Advisors, LLC Guggenheim Funds Advised Closed-End Funds Guggenheim Funds Unit Investment Trusts Guggenheim Funds Advised Exchange Traded Funds CODE OF ETHICS TABLE OF CONTENTS

Guggenheim Funds Distributors, Inc. Guggenheim Funds Investment Advisors, LLC AND Guggenheim Funds Advised Closed-End Funds Guggenheim Funds Unit Investment Trusts Guggenheim Funds Advised Exchange Traded Funds CODE OF ETHICS 1 TABLE OF CONTENTS Page I. INTRODUCTION 1 II. GENERAL STANDARDS 1 III. DEFINITIONS 2 IV. APPLICATION OF THE CODE 4 V. RESTRICTIONS 4 VI. PRE-CLEARANCE AND REPORTING PROCEDUR

December 2, 2011 8-K

Regulation FD Disclosure, Financial Statements and Exhibits

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of Report (Date of earliest event reported): December 2, 2011 (November 30, 2011) Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in its charter) Delaware 811-21982 20-5997403 (State or other juris

December 2, 2011 COVER

-

COVER 11 filename11.htm [Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] December 2, 2011 Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Strategic Opportunities Fund N-2 Filing Ladies and Gentlemen: On behalf of Guggenheim Strategic Opportunities Fund (the "Fund"), we are enclosing herewith for filing pursuant to the Securities Act of 1933, as amend

December 2, 2011 POS 8C

- GOF

As filed with the Securities and Exchange Commission on December 2, 2011 Securities Act File No.

December 2, 2011 EX-99.(R)(II)

Code of Ethics & Insider Trading Policy Guggenheim Partners Asset Management, LLC Guggenheim Investment Management, LLC July 2011

EX-99.(R)(II) 6 ex99rii.htm CODE OF ETHICS OF THE SUB-ADVISER CONFIDENTIAL Code of Ethics & Insider Trading Policy Guggenheim Partners Asset Management, LLC and Guggenheim Investment Management, LLC July 2011 I. OBJECTIVES OF THE CODE OF ETHICS & INSIDER TRADING POLICY 1 A. Regulatory Requirement and Compliance with Applicable Law 1 B. Confidential Information 1 C. Avoiding Conflicts of Interest 1

October 26, 2011 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Kevin M.

October 26, 2011 EX-99.CERT

Date: October 26, 2011 /s/ Kevin M. Robinson Kevin M. Robinson Chief Executive Officer and Chief Legal Officer

CERTIFICATIONS I, Kevin M. Robinson, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respec

July 27, 2011 EX-99.77C VOTES

Result of Shareholder Votes

EX-99.77C VOTES 3 ex77c.htm RESULT OF SHAREHOLDER VOTES Exhibit 77C Result of Shareholder Votes The Annual Meeting of Shareholders of the Fund was held on March 7, 2011. Common shareholders voted on the election of Trustees. With regards to the election of the following Trustees by common shareholders of the Fund: # of Shares in Favor # of Shares Withheld Roman Friedrich III 8,004,288 175,242 Robe

July 27, 2011 EX-99.77B ACCT LTTR

Report of Independent Registered Public Accounting Firm

EX-99.77B ACCT LTTR 2 ex77b.htm NSAR ITEM 77B Report of Independent Registered Public Accounting Firm To the Shareholders and Board of Trustees of Guggenheim Strategic Opportunities Fund In planning and performing our audit of the financial statements of Guggenheim Strategic Opportunities Fund (the Fund) as of and for the year ended May 31, 2011, in accordance with the standards of the Public Comp

April 29, 2011 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Kevin M.

April 29, 2011 EX-99.CERT

Kevin M. Robinson

CERTIFICATIONS I, Kevin M. Robinson, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respec

April 6, 2011 CORRESP

-

Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 April 6, 2011 Richard Pfordte Kimberly A.

April 6, 2011 CORRESP

-

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] April 6, 2011 Richard Pfordte Kimberly A.

March 16, 2011 CORRESP

-

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] March 16, 2011 Richard Pfordte Kimberly A.

February 3, 2011 DEF 14A

- GOF

CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND 2455 Corporate West Drive Lisle, Illinois 60532 NOTICE OF ANNUAL MEETING OF SHAREHOLDERS To be held on March 7, 2011 Notice is hereby given to the holders of common shares of beneficial interest, par value $0.

December 3, 2010 EX-3.1

THIRD AMENDED AND RESTATED BY-LAWS CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND THIRD AMENDED AND RESTATED BY-LAWS

EX-3.1 2 ex31.htm BY-LAWS THIRD AMENDED AND RESTATED BY-LAWS OF CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND THIRD AMENDED AND RESTATED BY-LAWS These Amended and Restated By-Laws are made and adopted pursuant to Section 3.9 of the Agreement and Declaration of Trust establishing Claymore/Guggenheim Strategic Opportunities Fund dated as of Novembe

December 3, 2010 8-K

Regulation FD Disclosure, Financial Statements and Exhibits

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-K CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of Report (Date of earliest event reported): December 3, 2010 (December 1, 2010) Claymore/Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in its charter) Delaware 811-21982 20-5997403 (State or oth

November 24, 2010 CORRESP

-

[Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] November 24, 2010 Kimberly A.

October 26, 2010 EX-99.CERT

Kevin M. Robinson

EX-99.CERT 2 ex99cert.htm CERTIFICATIONS CERTIFICATIONS I, Kevin M. Robinson, certify that: 1. I have reviewed this report on Form N-Q of Claymore/Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which suc

October 26, 2010 N-Q

Quarterly Schedule of Portfolio Holdings - GOF

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Claymore/Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip code) Kevin M.

September 19, 2008 DEF 14A

- DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a Party other than the Registrant o Check the appropriate box: o Preliminary Proxy Statement o Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) x Defin

November 28, 2007 SC 13G/A

Passive Investment -

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G Under the Securities Exchange Act of 1934 (Amendment No. 1) CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (Name of Issuer) COMMON SHARES, PAR VALUE $0.01 PER SHARE (Title of Class of Securities) 18385X104 (CUSIP Number) NOVEMBER 20, 2007 (Date of event which requires filing of this statement) Check the appropri

October 29, 2007 EX-99.CERT

/s/ Nicholas Dalmaso

Certifications CERTIFICATIONS I, Nicholas Dalmaso, certify that: 1. I have reviewed this report on Form N-Q of Claymore/Guggenheim Strategic Opportunities Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not

October 29, 2007 N-Q

Quarterly Schedule of Portfolio Holdings - CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-21982 Claymore/Guggenheim Strategic Opportunities Fund (Exact name of registrant as specified in charter) 2455 Corporate West Drive Lisle, IL 60532 (Address of principal executive offices) (Zip cod

August 9, 2007 SC 13G

Passive Investment -

SC 13G 1 gofsc13g.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G Under the Securities Exchange Act of 1934 CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (Name of Issuer) COMMON SHARES, PAR VALUE $0.01 PER SHARE (Title of Class of Securities) 18385X104 (CUSIP Number) JULY 27, 2007 (Date of event which requires filing of this statement) Check the appropri

July 25, 2007 CORRESP

-

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 333 WEST WACKER DRIVE CHICAGO, ILLINOIS 60606-1285 TEL: (312) 407-0700 FAX: (312) 407-0411 www.

July 24, 2007 CORRESP

-

Claymore/Guggenheim Strategic Opportunities Fund 2455 Corporate West Drive Lisle, Illinois 60532 July 24, 2007 Mr.

July 3, 2007 CORRESP

-

[LETTERHEAD OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP] July 3, 2007 Mr. Christian T. Sandoe Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Claymore/Guggenheim Strategic Opportunities Fund (File Nos. 333-138686 and 811-21982) Dear Mr. Sandoe: Claymore/Guggenheim Strategic Opportunities Fund (formerly, Claymore Strategic Opportunities Fund), a newly organized, diversi

June 27, 2007 8-A12B

-

SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND (Exact Name of Registrant as Specified in its Charter) Delaware (State of Incorporation or Organization) 20-5997403 (IRS Employer Identification Number) 2455 Co

May 31, 2007 CORRESP

-

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 333 WEST WACKER DRIVE CHICAGO, ILLINOIS 60606-1285 TEL: (312) 407-0700 FAX: (312) 407-0411 www.

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