SEC Company Response from Portman Ridge Finance Corp (PTMN) (CIK 0001372807) (BCIC) — Oct 4, 2012
Portman Ridge Finance Corp (PTMN) (CIK 0001372807)
Date: Oct. 4, 2012 · CIK: 0001372807 · Accession: 0001144204-12-054671
AI Filing Summary & Sentiment
File numbers found in text: 333-183032
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CORRESP 1 filename1.htm [Letterhead of Stifel, Nicolaus & Company, Incorporated] October 4, 2012 Via Electronic Submission United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: KCAP Financial, Inc. Registration Statement on Form N-2 File No. 333-183032 Ladies and Gentlemen: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Stifel, Nicolaus & Company, Incorporated, as representatives of the several Underwriters, hereby join in the request of KCAP Financial, Inc. that the effective date of the above-captioned Registration Statement be accelerated so that the same will become effective on October 4, 2012 at 3:30pm, New York City time, or as soon as practicable thereafter. The following is supplemental information supplied under Rule 418(a)(7) and Rule 460 under the Securities Act of 1933: (i) Date of preliminary prospectus: October 3, 2012 (ii) Dates of distribution: October 3, 2012-October 4, 2012 (iii) Number of prospective underwriters to whom the preliminary prospectus was furnished: 7 (iv) Number of prospectuses so distributed: approximately 3,250 (v) We have been informed by the participating underwriters that they have complied and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934. Very truly yours, Stifel, Nicolaus & Company, Incorporated By /s/ Allen G. Laufenberg Name: Allen G. Laufenberg Title: Managing Director