SEC Company Response from Portman Ridge Finance Corp (PTMN) (CIK 0001372807) (BCIC) — Jul 20, 2017

Portman Ridge Finance Corp (PTMN) (CIK 0001372807)
Date: July 20, 2017 · CIK: 0001372807 · Accession: 0001144204-17-037500

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AI Filing Summary & Sentiment

File numbers found in text: 333-218596

Date

July 20, 2017

Author

Not clearly detected

Form

CORRESP

Company

Portman Ridge Finance Corp (PTMN) (CIK 0001372807)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Investment Management Washington, D.C. 20549-4041 Re: KCAP Financial, Inc. Pre-Effective Amendment No. 1 to Registration Statement on Form N-2 File No. 333-218596

Dear Mr. O’Connor and Ms. Churko:

On behalf of KCAP Financial, Inc. (the “Registrant”) and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, I hereby request acceleration of the effective date of the Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-2 to 12:00 p.m. Eastern Time on July 21, 2017, or as soon thereafter as is practicable.

Should you have any questions concerning this request, please contact me at (212) 455-8300 or, our counsel, Harry Pangas at Eversheds Sutherland (US) LLP at (202) 383-0805.

Sincerely,
KCAP Financial, Inc.

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CORRESP
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295 Madison Avenue, 6th Floor

New York, NY 10017

July 20, 2017

VIA EDGAR

James E. O’Connor

Kathy Churko

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-4041

    Re:
    KCAP Financial, Inc.

Pre-Effective Amendment No. 1
to Registration Statement on Form N-2

File No. 333-218596

Dear Mr. O’Connor and Ms. Churko:

On behalf of KCAP Financial, Inc. (the “Registrant”)
and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, I hereby request acceleration of the effective
date of the Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-2 to 12:00 p.m. Eastern Time
on July 21, 2017, or as soon thereafter as is practicable.

Should you have any questions concerning
this request, please contact me at (212) 455-8300 or, our counsel, Harry Pangas at Eversheds Sutherland (US) LLP at (202) 383-0805.

    Sincerely,

    KCAP Financial, Inc.

    By: /s/ Dayl W. Pearson

    Name: Dayl W. Pearson

    Title: President and Chief Executive Officer

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