SecProbe.io

July 26, 2013

Via E -mail
Laurence A. Tosi
Chief Financial Officer
The Blackstone Group L.P.
345 Park Avenue
New York, NY 10154

Re: The Blackstone Group L.P.
 Form 10 -K for Fiscal Year  Ended December 31, 2012
Filed March 1, 2013
File No. 001 -33551

Dear Mr. Tosi:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and  circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2012

Item 1A.  Risk Factors, page 18

We have engaged in large -sized investments, which involve certain…, page 39

1. We note the recent media articles regarding the size of your investments in rental
properties in the United States.  In future filings, please expand your risk factor disclosure
to discuss and quantify  these investments, or tell us why you believe that additional
disclosure is unnecessary.

Laurence A. Tosi
The Blackstone  Group L.P.
July 26, 2013
Page 2

 Item 8 – Financial Statements and Supplementary Data

Cons olidated Statement of Cash Flows, page 142

2. We note the supplemental non -cash investing and financing line items titled Conversion
of Blackstone Holdings Units to Common Units and Acquisition of Ownership Interests
from Non -Controlling Interest Holders.  Please respond to the following.

 Please tell us whether, and if so how, these line items relate to each other.

 To the extent the line item Acquisition of Ownership Interests from Non -
Controlling Interest Holders relates to the tax receivable agreements discussed on
page 191, please tell us how, and provide us with an illustrative example of how
the deferred tax asset amount is calculated.

 Please consider expanding your disclosures to discuss in more detail what these
line items represent given the signi ficance of the amounts.

Level III Valuation Techniques, page 150

Private Equity Investments, page 150

3. We note your disclosure that private equity investments may also be valued at cost for a
period of time after an acquisition as the best indicator of f air value.   Please respond to
the following.

 Tell us the longest period of time that you would value the private equity
investment based on cost instead of based on your typical valuation techniques.

 Tell us whether you calibrate the methodology/models u sed on Day 2 for the
valuation of these investments with the cost paid at acquisition.

 Tell us how illiquidity discounts are applied to these investments over time along
with the factors that drive the size of the illiquidity discounts applied over time.

 Tell us the methodology or procedure used to estimate the illiquidity discounts.

Funds of Hedge Funds, page 150

4. We note your disclosure that in situations where the Partnership determines, based on its
own due diligence and investment procedures, that NAV per share does not represent fair
value, you will estimate the fair value in good faith and in a manner that it reasonably
chooses, in accordance with its valuation policies.   Please respond to the fol lowing.

Laurence A. Tosi
The Blackstone  Group L.P.
July 26, 2013
Page 3

  Tell us the number and dollar value of fund s where you have determined that
NAV per share does not represent fair value at both December 31, 2012 and 2011.

 Tell us the primary drivers considered in reaching the conclusion that NAV per
share does not represent fair value for these funds.

 In future  filings, please provide additional disclosure to address the items in the
previous bullets.

Level 3 Valuation Process, page 151

5. In your disclosures you mention the use of exit multiples as inputs in fair value estimates.
Please respond to the following .

 Where exit multiples are mentioned in the Level III assumptions table on pages
174-175, please clearly define the type of exit multiple utilized, such as an
EBITDA exit multiple, P/E exit multiple, or other.

 Please discuss how the exit multiple input is  being used in the fair value estimate.

Note 4 – Acquisitions, Goodwill and Intangible Assets, page 161

6. We note the pro forma disclosure on page 161 showing what would have been the effect
on your results of operations if Harbourmaster was acquired on Ja nuary 1, 2011.  Based
on your disclosures, it appears that the effect on 2011 annual results would have been to
increase revenues by $726 thousand  and to increase the net loss attributable to The
Blacksto ne Group L.P. by $102 million.  However, based on si milar disclosures
contained in your Form 10 -Q for the quarterly period ended September 30, 2011, it
appears the effect on your results of operations for the nine months ended
September 2011 would have been to increase revenues by $19.0 million and to decr ease
the net loss attributable to The Blackston e Group L.P. by $16.3 million.  Thus, please tell
us the events occurring in Harbourmaster’s fourth quarter of 2011 operations that drove
such a significant change in their results of operations.  Additionally , please provide more
information about the nature of the contractual rights intangible assets acquired, and
whether their value was affected by any of the factors driving the substantial loss in
Harbourmaster’s fourth quarter of 2011 results of operations .

Note 7 - Fair Value Option, page 170

7. We note that you elected the fair value option to account for your consolidated CLOs.
Please revise your future filings to include information required by
ASC 825 -10-50-30(c) and 30(d).

Laurence A. Tosi
The Blackstone  Group L.P.
July 26, 2013
Page 4

 Compensation Elements for  Named Executive Officers, page 215

Participation in Performance Fees, page 216

8. In future filings, please clarify the following:

 whether the carry or incentive fee pools are funded by a fixed percentage of the total
amount of carried interest or incentive fees that you earn, or otherwise;

 whether a realization event is the only condition precedent  for carried interest
distributions, or whether there are any other preconditions, such as a positive return
on investment; and

 how the cash payments in respect of carried interest or incentive fee allocation are
determined for each named executive officer, including what may cause the
participation interest for a named executive officer to vary from year to year.

Determination of Incentive Compensatio n, page 218

9. We note your disclosure regarding the “key factors” that Mr. Schwarzman  and Mr. James
considered in determining incentive compensation for named executive officers and that
you do not discuss performance or contributions made by named executive officers on an
individual basis.  Please expand your disclosure in future filings to explain what elements
of each named executive officer’s individual performance contributed to the officer’s
annual cash payment award.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain  that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for t he accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing ;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Laurence A. Tosi
The Blackstone  Group L.P.
July 26, 2013
Page 5

 You may contact me at (202) 551 -3512  if you have questions regarding comments on the
financial statements and related matters.  Please contact Celia Soehner at (202) 551 -3463  or
Laura Crotty at (202) 551 -3563 with any other questions.

Sincerely,

 /s/ Stephanie J. Ciboroski

Stephanie J. Ciboroski
Senior Assistant Chief Accountant