SEC Company Response from Portman Ridge Finance Corp (PTMN) (CIK 0001372807) (BCIC) — May 23, 2013

Portman Ridge Finance Corp (PTMN) (CIK 0001372807)
Date: May 23, 2013 · CIK: 0001372807 · Accession: 0001144204-13-031275

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AI Filing Summary & Sentiment

File numbers found in text: 333-187570

Date

May 23, 2013

Author

Not clearly detected

Form

CORRESP

Company

Portman Ridge Finance Corp (PTMN) (CIK 0001372807)

Letter

VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 RE: KCAP Financial, Inc. – Registration Statement on Form N-2 (File No. 333-187570)

Dear Ms. Cole and Ms. Stout:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, KCAP Financial, Inc. hereby respectfully requests that the above-captioned registration statement, including all amendments thereto, be ordered effective on May 23, 2013, at 3:30 p.m., or as soon thereafter as practicable.

KCAP Financial, Inc.

By: /s/ Dayl W. Pearson

Name: Dayl W. Pearson

Title: President and Chief Executive Officer

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CORRESP
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May 23, 2013

VIA EDGAR

Mary A. Cole, Senior Counsel

Sheila Stout, Senior Staff Accountant

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 RE: KCAP Financial, Inc. – Registration Statement on Form N-2 (File No. 333-187570)

Dear Ms. Cole and Ms. Stout:

In accordance with Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, KCAP Financial, Inc. hereby respectfully requests that the
above-captioned registration statement, including all amendments thereto, be ordered effective on May 23, 2013, at 3:30 p.m., or
as soon thereafter as practicable.

    KCAP Financial, Inc.

    By:
    /s/ Dayl W. Pearson

    Name:
    Dayl W. Pearson

    Title:
    President and Chief Executive Officer

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