SecProbe.io

September 6, 2016
Mail Stop 4720

Via E -mail
Antony P. Ressler
Chairman a nd Chief Executive Officer
Ares Management, L.P.
2000 Avenue of the Stars, 12th Floor
Los Angeles, CA  90067

Re: Ares Management, L.P.
 Form 10-K for the Fiscal Year Ended December 31, 2015
 Filed February 29, 2016
 Form 10 -Q for the Quarterly Period Ended June 30, 2016
Filed August 9, 2016
File No. 00 1-36429

Dear Mr. Ressler :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After r eviewing your response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2015

Notes to the Consolidated Financial Statements, page F -8

Note 5.   Investments, page F -31

Equity Method Investments, page F-32

1. We note your disclosure of summarized financial information for Ares Energy Investors
Fund V. L.P.  and others, which you have determined to be significant based on the
change in fair value of the fund compared to the total net income available to com mon
unit holders.  Please enhance your disclos ure to provide all of the summarized financial
information required by Rule 4 -08(g)(2) and defined by Rule 1 -02(bb) of Regulation S -
X.

Antony P. Ressler
Ares Management, L.P.
 September 6, 2016
 Page 2

 Note 13.   Commitments and Contingencies, page F -62

Guarantees, page F -63

2. We note  that your contingent consideration liability related to Ares Energy Investors
Fund V, L.P.  (“AEIF”)  decreased by $21.1 million in 2015 as a result of subsequent
remeasurement of future fee payments.  We also note that you have elected the fair value
option for your investment in AEIF on page F -32.  Please address the following:

 Explain in your MD&A on page 107 the underlying reasons and factors occurring
during 2015 for the changes in your estimate of  fair value of the contingent
consideration.  Refer to Item 303 of Regulation S -K and SEC Release 33 -8350;

 In your fair value footnote, provide the disclosures outlined in ASC 820 -10-50-1 to
50-2 for your recurring fair value measurement of contingent con sideration , including
your significant unobservable inputs (e.g. future fee payments), as of the acquisition
date and the reporting date; and

 Tell us what, if any, impact the remeasurement of future fee  payments had on your
valuation assumptions in your determination of fair value for the related investment in
AEIF.  To the extent that the fair value of the investment increased or did not change
as a result of the remeasurement, tell us why.

Form 10 -Q for the Quarterly Period  Ended June 30, 2016

Manag ement’s Discussion and Analysis of Financial Condition and Results of Operations, page
48

Trends Affecting Our Business, page 49

3. We note your commitment to provide $275 million of cash consideration and waive up to
$100 million in ARCC Part I Fees for te n calendar quarters to support the ARCC -ACAS
Transaction discussed on page 27.  We also note your comments during the second
quarter 2016 earnings call stating that “the expected accretion from the ACAS transaction
will paralyze earnings growth for the nex t year and into subsequent periods”.  In future
filings, please expand your MD&A to include a discussion of this information as a known
trend or uncertainty that you reasonably expect will have a material favorable or
unfavorable impact on net revenues or income from continuing operations.  Refer to Item
303(a)(3)(ii) of Regulation S -K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securitie s Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are

Antony P. Ressler
Ares Management, L.P.
 September 6, 2016
 Page 3

 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have m ade.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws o f the United States.

You may contact Michelle Miller at 202 -551-3368 or Robert Klein at 202 -551-3847 with
any questions.

Sincerely,

 /s/ Hugh West

 Hugh West
Accounting Branch Chief
Office of Financial Services