FORM 3
        
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

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Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934 or Section 30(h) of the Investment Company Act of 1940
                      

1. Name and Address of Reporting Person *

Sun Life Assurance Co of Canada
2. Date of Event Requiring Statement (MM/DD/YYYY)
11/5/2020 

3. Issuer Name and Ticker or Trading Symbol

BOULDER GROWTH & INCOME FUND [BIF]
(Last)        (First)        (Middle)

ONE YORK STREET, 
4. Relationship of Reporting Person(s) to Issuer (Check all applicable)

_____ Director                          ___X___ 10% Owner
_____ Officer (give title below)        _____ Other (specify below)
(Street)

TORONTO, A6 M5J 0B6      

(City)              (State)              (Zip)
5. If Amendment, Date Original Filed(MM/DD/YYYY)
 

6. Individual or Joint/Group Filing(Check Applicable Line)

___ Form filed by One Reporting Person
_X_ Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1.Title of Security
(Instr. 4)
2. Amount of Securities Beneficially Owned
(Instr. 4)
3. Ownership Form: Direct (D) or Indirect (I)
(Instr. 5)
4. Nature of Indirect Beneficial Ownership
(Instr. 5)
2.62% Series A Senior Notes due November 5, 2030 $18200000 D  
2.72% Series B Senior Notes due November 5, 2032 $13600000 D  
2.62% Series A Senior Notes due November 5, 2030 $20000000 I See Footnote 1 (1)
2.72% Series B Senior Notes due November 5, 2032 $15000000 I See Footnote 1 (1)

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivate Security
(Instr. 4)
2. Date Exercisable and Expiration Date
(MM/DD/YYYY)
3. Title and Amount of Securities Underlying Derivative Security
(Instr. 4)
4. Conversion or Exercise Price of Derivative Security5. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 5)
6. Nature of Indirect Beneficial Ownership
(Instr. 5)
Date ExercisableExpiration DateTitleAmount or Number of Shares

Explanation of Responses:
(1) Sun Life Financial Inc. (a) owns 100% of the outstanding common stock of Sun Life Assurance Company of Canada, the direct owner of $18,200,000 of the 2.62% Series A Senior Notes due November 5, 2030 and $13,600,000 of the 2.72% Series B Senior Notes due November 5, 2032 and (b) indirectly owns 100% of the outstanding shares of the common stock of Sun Life Capital Management (U.S.) LLC, which is deemed to be the beneficial owner of $1,800,000 of the 2.62% Series A Senior Notes due November 5, 2030 and $1,400,000 of the 2.72% Series B Senior Notes due November 5, 2032 on behalf of certain of its investment advisory clients.

Reporting Owners
Reporting Owner Name / Address
Relationships
Director10% OwnerOfficerOther
Sun Life Assurance Co of Canada
ONE YORK STREET
TORONTO, A6 M5J 0B6

X

SUN LIFE FINANCIAL INC
SUN LIFE ASSURANCE CO OF CANADA
ONE YORK STREET
TORONTO, A6 M5J 0B6

X


Signatures
/s/ Randolph B. Brown, authorized signatory on behalf of Sun Life Assurance Company of Canada and Sun Life Financial Inc.11/9/2020
**Signature of Reporting PersonDate

/s/ Brett W. Pacific, authorized signatory on behalf of Sun Life Assurance Company of Canada and Sun Life Financial Inc.11/9/2020
**Signature of Reporting PersonDate

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