SEC Company Response from Barings BDC, Inc. (BBDC) (CIK 0001379785) (BBDC) — Jul 2, 2012
Barings BDC, Inc. (BBDC) (CIK 0001379785)
Date: July 2, 2012 · CIK: 0001379785 · Accession: 0001193125-12-291584
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-175160
Letter
VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-4041 Re: Triangle Capital Corporation — Post-Effective Amendment No. 3 to Registration Statement on Form N-2, File No. 333-175160 (the “Registration Statement”)
Dear Mr. Rupert
On behalf of Triangle Capital Corporation (the “Company”), set forth below is the Company’s response to the comment of the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that you provided to us via phone on June 28, 2012 regarding the Registration Statement. The Staff’s comment is set forth below and is followed by the Company’s response.
Comment: In future filings of the prospectus, include on the cover page of the prospectus, language in boldface type regarding the credit quality of the types of investments that the Company makes, including disclosure regarding the fact that such investments may be below investment grade.
Response: In response to the Staff’s comment, the Company undertakes to include language similar to the language below on the cover page of future prospectus filings.
We generally invest in securities that would be rated below investment grade if they were rated. Below investment grade securities, which are often referred to as “high yield” or “junk,” have speculative characteristics with respect to the issuer’s capacity to pay interest and repay principal.
If you have any questions concerning the foregoing, please contact me via phone at (901) 543-5918 or via email at hwbrown@bassberry.com.
Sincerely,
/s/ Helen W. Brown
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CORRESP 1 filename1.htm Response to SEC Comments The Tower at Peabody Place 100 Peabody Place, Suite 900 Memphis, TN 38103-3672 (901) 543-5900 July 2, 2012 CONFIDENTIAL VIA EDGAR Kevin Rupert Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-4041 Re: Triangle Capital Corporation — Post-Effective Amendment No. 3 to Registration Statement on Form N-2, File No. 333-175160 (the “Registration Statement”) Dear Mr. Rupert On behalf of Triangle Capital Corporation (the “Company”), set forth below is the Company’s response to the comment of the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that you provided to us via phone on June 28, 2012 regarding the Registration Statement. The Staff’s comment is set forth below and is followed by the Company’s response. Comment: In future filings of the prospectus, include on the cover page of the prospectus, language in boldface type regarding the credit quality of the types of investments that the Company makes, including disclosure regarding the fact that such investments may be below investment grade. Response: In response to the Staff’s comment, the Company undertakes to include language similar to the language below on the cover page of future prospectus filings. We generally invest in securities that would be rated below investment grade if they were rated. Below investment grade securities, which are often referred to as “high yield” or “junk,” have speculative characteristics with respect to the issuer’s capacity to pay interest and repay principal. If you have any questions concerning the foregoing, please contact me via phone at (901) 543-5918 or via email at hwbrown@bassberry.com. Sincerely, /s/ Helen W. Brown bassberry.com