SEC Company Response from Portman Ridge Finance Corp (PTMN) (CIK 0001372807) (BCIC) — Dec 19, 2012
Portman Ridge Finance Corp (PTMN) (CIK 0001372807)
Date: Dec. 19, 2012 · CIK: 0001372807 · Accession: 0001144204-12-068734
AI Filing Summary & Sentiment
Letter
VIA EDGAR Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: KCAP Financial, Inc. Registration Statement on Form N-2 Filed on December 19, 2012
Dear Ms. Cole:
On behalf of KCAP Financial, Inc. (the “Company”), we hereby respectfully request that the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) afford the Company’s registration statement on Form N-2, filed with the Commission on December 19, 2012 (the “Registration Statement”), a selective review in accordance with Securities Act Release No. 6510 (February 15, 1984).
The disclosure contained in the Registration Statement contains no material changes from the disclosure included in the Company’s registration statement on Form N-2 (File No. 333- 183032), initially filed with the Commission on August 2, 2012, which registration statement related to Company’s offering of its senior notes (the “Notes”), except for (i) the replacement of disclosure describing the Notes and the related offering terms with disclosure describing the Company’s common stock and the related offering terms and (ii) the inclusion of updated unaudited financial statements and information relating thereto.
* * *
Ms. Mary A. Cole
December 19, 2012
Page 2
If you have any questions or additional comments concerning the foregoing, please contact me at (202) 383-0805.
Sincerely,
/s/ Harry S. Pangas
Show Raw Text
CORRESP 1 filename1.htm [Letterhead of Sutherland Asbill & Brennan LLP] December 19, 2012 VIA EDGAR Ms. Mary A. Cole Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: KCAP Financial, Inc. Registration Statement on Form N-2 Filed on December 19, 2012 Dear Ms. Cole: On behalf of KCAP Financial, Inc. (the “Company”), we hereby respectfully request that the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) afford the Company’s registration statement on Form N-2, filed with the Commission on December 19, 2012 (the “Registration Statement”), a selective review in accordance with Securities Act Release No. 6510 (February 15, 1984). The disclosure contained in the Registration Statement contains no material changes from the disclosure included in the Company’s registration statement on Form N-2 (File No. 333- 183032), initially filed with the Commission on August 2, 2012, which registration statement related to Company’s offering of its senior notes (the “Notes”), except for (i) the replacement of disclosure describing the Notes and the related offering terms with disclosure describing the Company’s common stock and the related offering terms and (ii) the inclusion of updated unaudited financial statements and information relating thereto. * * * Ms. Mary A. Cole December 19, 2012 Page 2 If you have any questions or additional comments concerning the foregoing, please contact me at (202) 383-0805. Sincerely, /s/ Harry S. Pangas Harry S. Pangas