SecProbe.io

September 14, 2017
Via Email
William J. Janetschek
Chief Financial Officer
KKR & Co. L.P.
9 West 57th Street, Suite 4200
New York, NY 10019

Re: KKR & Co. L.P.
Form 10 -Q for the Quarterly Period Ended June 30, 2017
Filed August 4, 2017
File No. 001 -34820

Dear Mr. Janetschek :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -Q for the Quarterly Period Ended June 30, 2017

Note 1. Organization

PAAMCO Prisma, page 12

1. We note o n June 1, 2017, KKR completed its transaction t o combine PAAMCO and
KKR Prisma to create  PAAMCO Prisma , a leading liquid alternatives investment firm,
which operates independently from KKR.  In connection with this transaction, KKR
contributed $114.1 million of net assets in exchange for a 39.9% equity interest in
PAAMCO Prisma and the right to receive certain payments from PAAMCO Prisma.   We
also note that KKR reports its investment in PAAMC O Prisma using the equity method
of accounting.   Please clarify whether PAAMCO Prisma is considered a variable interest
entity or a voting rights entity and address the following:

 Tell us  the purpose and design of PAAMCO Prisma, including who participated  in
the design of the entity .

William J. Janetschek
KKR & Co. L.P.
September 14, 2017
Page 2

  Clarify  KKR’s rights and obligations to PAAMCO Prisma, specifically as it relates to
KKR’s  “right to receive certain payments.”

 Tell us the significant activities that most impact  the economic performance of
PAAMCO Prisma  and how decisions are made over those activities .  As part of your
response, tell us KKR’s rights and involvement over decision making of the entity,
including whether KKR is a general partner, limited partner or other.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Segment Operating and Performance Measures, page 78

2. We note your presentation of a full non -GAAP income statement on page 79 .  Please
revise to remove your full non -GAAP income statement or revise  your presentation in
future filings so that it complies with Question 102.10 and 104.04 (and any other
prominence considerations) of the updated non -GAAP C&DI Financial Measures
Compliance and Disclosure Interpretations issued on May 17, 2016 (the “update d Non -
GAAP C&DI”).

Expenses Allocated to Principal Activities, page 93

3. We note in 2017 that you changed the expense all ocation to your Principal Activities
segment .  In this regard, we note that the allocation percentage for 2017 will not be more
than 25.7% based on cumulative revenues earned since 2009, whereas the 2016 allocation
is based on revenues earned in 2015, 2014, 2013 and 20 12.  Please tell us how you
considered the guidance in ASC 280 -10-50-36 in showing all segment information on a
comparab le basis.  In this regard, tell us why you did not revise the 2016 allocation to
also be based on cumulative revenues since 2009.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwi thstanding any review, comments, action or absence of
action by the staff.

You may contact Robert Klein, Staff Accountant at (202) 551 -3847 or me at (202) 551 -
3872 if you have questions.

Sincerely,

 /s/ Hugh  West

 Hugh West
 Accounting Branch Chief
Office of Financial Services