SEC Company Response from New Mountain Finance Corp (NMFC, NMFCZ) (CIK 0001496099) (NMFC) — Feb 28, 2013
New Mountain Finance Corp (NMFC, NMFCZ) (CIK 0001496099)
Date: Feb. 28, 2013 · CIK: 0001496099 · Accession: 0001104659-13-016268
AI Filing Summary & Sentiment
File numbers found in text: 333-185954, 333-185955
Letter
VIA EDGAR Division of Investment Management Re: New Mountain Finance Corporation and New Mountain Finance Holdings, L.L.C. Registration Statement on Form N-2 Filed on January 10, 2013 File Nos. 333-185955 and 333-185954
Dear Mr. Ganley:
On behalf of New Mountain Finance Corporation (the “Fund”) and New Mountain Finance Holdings, L.L.C. (the “Operating Company” and together with the Fund, the “NMF Funds”), in connection with the NMF Funds’ joint registration statement on Form N-2 (File Nos. 333-185955 and 333-185954), filed with the Securities and Exchange Commission (the “Commission”) on January 10, 2013 (the “Registration Statement”), the NMF Funds hereby confirm to the staff of the Division of Investment Management of the Commission that:
(i) each of the NMF Funds files annual, quarterly and other reports pursuant to Section 13 under the Securities Exchange Act of 1934, as amended, and all reports due thereunder have been filed;
(ii) for the fiscal year ended December 31, 2012, each of the NMF Funds reasonably and in good faith expects to report income attributable to such NMF Fund, after taxes but before extraordinary items and the cumulative effect of any change in accounting principles; and
(iii) for the fiscal year ended December 31, 2011, each of the NMF Funds reported income attributable to such NMF Fund, after taxes but before extraordinary items and the cumulative effect of any change in accounting principles.
* * *
If you have any questions or additional comments concerning the foregoing, please contact the undersigned at (202) 383-0176 or John J. Mahon at (202) 383-0515.
Sincerely,
/s/ Steven B. Boehm
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CORRESP 1 filename1.htm [Letterhead of Sutherland Asbill & Brennan LLP] February 28, 2013 VIA EDGAR John M. Ganley, Esq. Senior Counsel Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: New Mountain Finance Corporation and New Mountain Finance Holdings, L.L.C. Registration Statement on Form N-2 Filed on January 10, 2013 File Nos. 333-185955 and 333-185954 Dear Mr. Ganley: On behalf of New Mountain Finance Corporation (the “Fund”) and New Mountain Finance Holdings, L.L.C. (the “Operating Company” and together with the Fund, the “NMF Funds”), in connection with the NMF Funds’ joint registration statement on Form N-2 (File Nos. 333-185955 and 333-185954), filed with the Securities and Exchange Commission (the “Commission”) on January 10, 2013 (the “Registration Statement”), the NMF Funds hereby confirm to the staff of the Division of Investment Management of the Commission that: (i) each of the NMF Funds files annual, quarterly and other reports pursuant to Section 13 under the Securities Exchange Act of 1934, as amended, and all reports due thereunder have been filed; (ii) for the fiscal year ended December 31, 2012, each of the NMF Funds reasonably and in good faith expects to report income attributable to such NMF Fund, after taxes but before extraordinary items and the cumulative effect of any change in accounting principles; and (iii) for the fiscal year ended December 31, 2011, each of the NMF Funds reported income attributable to such NMF Fund, after taxes but before extraordinary items and the cumulative effect of any change in accounting principles. * * * If you have any questions or additional comments concerning the foregoing, please contact the undersigned at (202) 383-0176 or John J. Mahon at (202) 383-0515. Sincerely, /s/ Steven B. Boehm Steven B. Boehm cc: David Cordova / New Mountain Finance Corporation John J. Mahon / Sutherland Asbill & Brennan LLP 2