SEC Company Response from Portman Ridge Finance Corp (PTMN) (CIK 0001372807) (BCIC) — Aug 18, 2006
Portman Ridge Finance Corp (PTMN) (CIK 0001372807)
Date: Aug. 18, 2006 · CIK: 0001372807 · Accession: 0001193125-06-175889
AI Filing Summary & Sentiment
Letter
Letter to the SEC
ROPES
&GRAY
ROPES & GRAY LLP
ONE INTERNATIONAL PLACE BOSTON, MA 02110-2624 617-951-7000 F 617-951-7050
BOSTON NEWYORK SAN FRANCISCO WASHINGTON, DC
August 18, 2006
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Kohlberg Capital, LLC
Ladies and Gentlemen:
We are filing today via EDGAR the following documents on behalf of Kohlberg Capital, LLC, a Delaware limited liability company (the “Company”):
(i) a notice of intent to be subject to sections 55 through 65 of the Investment Company Act of 1940, as amended, on Form N-6F; and
(ii) an initial registration statement on Form N-2 pursuant to the Securities Act of 1933, as amended (the “Securities Act”).
Pursuant to Section 6 of the Securities Act, we have calculated the registration fee (based on a rate of $107.00 per $1 million offered) and have transmitted such fee in the amount of $24,075.00 to the designated lockbox at Mellon Bank in Pittsburgh, Pennsylvania.
As described in the registration statement, the Company will enter into a series of restructuring transactions which will result in its conversion into a Delaware corporation to be named Kohlberg Capital Corporation prior to the completion of the offering.
Please direct any questions or comments regarding this filing to me at (617) 951-7760 or, in my absence, to Craig Marcus of this office at (617) 951-7802. Thank you for your attention in this matter.
Very truly yours,
/s/ Diane Fernandes
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CORRESP 1 filename1.htm Letter to the SEC ROPES &GRAY ROPES & GRAY LLP ONE INTERNATIONAL PLACE BOSTON, MA 02110-2624 617-951-7000 F 617-951-7050 BOSTON NEWYORK SAN FRANCISCO WASHINGTON, DC August 18, 2006 Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Kohlberg Capital, LLC Ladies and Gentlemen: We are filing today via EDGAR the following documents on behalf of Kohlberg Capital, LLC, a Delaware limited liability company (the “Company”): (i) a notice of intent to be subject to sections 55 through 65 of the Investment Company Act of 1940, as amended, on Form N-6F; and (ii) an initial registration statement on Form N-2 pursuant to the Securities Act of 1933, as amended (the “Securities Act”). Pursuant to Section 6 of the Securities Act, we have calculated the registration fee (based on a rate of $107.00 per $1 million offered) and have transmitted such fee in the amount of $24,075.00 to the designated lockbox at Mellon Bank in Pittsburgh, Pennsylvania. As described in the registration statement, the Company will enter into a series of restructuring transactions which will result in its conversion into a Delaware corporation to be named Kohlberg Capital Corporation prior to the completion of the offering. Please direct any questions or comments regarding this filing to me at (617) 951-7760 or, in my absence, to Craig Marcus of this office at (617) 951-7802. Thank you for your attention in this matter. Very truly yours, /s/ Diane Fernandes Diane Fernandes cc: Dayl W. Pearson Christopher Lacovara Craig Marcus, Esq. Michael Doherty, Esq.