SEC Company Response from Portman Ridge Finance Corp (PTMN) (CIK 0001372807) (BCIC) — May 21, 2014

Portman Ridge Finance Corp (PTMN) (CIK 0001372807)
Date: May 21, 2014 · CIK: 0001372807 · Accession: 0001144204-14-032844

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AI Filing Summary & Sentiment

File numbers found in text: 333-187570

Date

May 21, 2014

Author

Not clearly detected

Form

CORRESP

Company

Portman Ridge Finance Corp (PTMN) (CIK 0001372807)

Letter

VIA EDGAR Division of Investment Management 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 22, 2014, at 11:00 a.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 21, 2014

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 22, 2014, at 11:00 a.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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