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SEC Company Response from Barings BDC, Inc. (BBDC) (CIK 0001379785) (BBDC) — Feb 13, 2007

Barings BDC, Inc. (BBDC) (CIK 0001379785)
Date: Feb. 13, 2007 · CIK: 0001379785 · Accession: 0000950144-07-001160

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File numbers found in text: 333-138418

Date
February 13, 2007
Author
By
Form
CORRESP
Company
Barings BDC, Inc. (BBDC) (CIK 0001379785)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Investment Management Re: Triangle Capital Corporation Registration Statement on Form N-2 File No. 333-138418

Dear Mr. Di Stefano:

On behalf of Triangle Capital Corporation (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 Registration Statement, to 3:00 p.m., Eastern Standard Time, on Tuesday February 13, 2007, or as soon thereafter as is practicable.

The disclosure in the referenced filing is the responsibility of the Registrant. The Registrant represents to the U.S. Securities and Exchange Commission (the “Commission”) that should the Commission, or the staff acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing, and the Registrant represents that it will not assert staff comments or the action of the staff to declare the filing effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Registrant further acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing.

Should you have any questions concerning this request, please contact me at (919) 719-4770 or, our counsel, Robert C. Humphreys at Bass, Berry & Sims PLC at (901) 543-5910.

Sincerely,
TRIANGLE CAPITAL CORPORATION

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CORRESP
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filename1.htm

Triangle Capital Corporation

Triangle Capital Corporation

3600 Glenwood Avenue, Suite 104

Raleigh, North Carolina 27612

February 13, 2007

VIA EDGAR

Mr. Vincent J. Di Stefano, Senior Counsel

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

         Re:

    Triangle Capital Corporation

Registration Statement on Form N-2

File No. 333-138418

Dear Mr. Di Stefano:

     On behalf of Triangle Capital Corporation (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 Registration Statement, to 3:00 p.m., Eastern
Standard Time, on Tuesday
February 13, 2007, or as soon thereafter as is practicable.

     The disclosure in the referenced filing is the responsibility of the Registrant. The
Registrant represents to the U.S. Securities and Exchange Commission (the “Commission”) that should
the Commission, or the staff acting pursuant to delegated authority, declare the filing effective,
it does not foreclose the Commission from taking any action with respect to the filing, and the
Registrant represents that it will not assert staff comments or the action of the staff to declare
the filing effective as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

     The Registrant further acknowledges that the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the filing effective does not relieve the Registrant
from its full responsibility for the adequacy and accuracy of the disclosures in the filing.

     Should you have any questions concerning this request, please contact me at (919) 719-4770 or,
our counsel, Robert C. Humphreys at Bass, Berry & Sims PLC at (901) 543-5910.

    Sincerely,

TRIANGLE CAPITAL CORPORATION

    By:
    /s/ Garland S. Tucker, III

    Name:
    Garland S. Tucker, III

    Title:
    President and Chief Executive Officer