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SEC Company Response from PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) (CIK 0001504619) (PFLA) — Sep 18, 2013

PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) (CIK 0001504619)
Date: Sept. 18, 2013 · CIK: 0001504619 · Accession: 0001193125-13-370417

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File numbers found in text: 333-190602, 814-00891

Date
September 18, 2013
Author
Aviv Efrat
Form
CORRESP
Company
PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) (CIK 0001504619)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Investment Management Attn: John M. Ganley Re: PennantPark Floating Rate Capital Ltd. Registration Statement on Form N-2 File Numbers 333-190602; 814-00891

Dear Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, PennantPark Floating Rate Capital Ltd. (the “Company”) respectfully requests acceleration of the effective date of Pre-Effective Amendment No. 1 to its Registration Statement on Form N-2 (Registration No. 333-190602) (the “Registration Statement) so that such Registration Statement may be declared effective on Friday, September 20, 2013, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone call to William J. Tuttle of Dechert LLP at (202) 261-3352, and that such effectiveness also be confirmed in writing.

The Company hereby acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (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; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
PennantPark Floating Rate Capital Ltd.

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Request

 PENNANTPARK FLOATING RATE CAPITAL LTD.

590 MADISON AVENUE, 15TH FLOOR

 NEW
YORK, NY 10022

 September 18, 2013

 VIA
EDGAR

 United States Securities and Exchange Commission

Division of Investment Management

 100 F Street, N.E.

Washington, DC 20549

 Attn: John M. Ganley

Re:
PennantPark Floating Rate Capital Ltd.

Registration Statement on Form N-2

File Numbers 333-190602; 814-00891

 Dear Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, PennantPark Floating Rate Capital Ltd. (the “Company”) respectfully requests
acceleration of the effective date of Pre-Effective Amendment No. 1 to its Registration Statement on Form N-2 (Registration No. 333-190602) (the “Registration Statement) so that such Registration Statement may be declared effective on
Friday, September 20, 2013, or as soon as practicable thereafter.

 We request that we be notified of such effectiveness by a telephone call to
William J. Tuttle of Dechert LLP at (202) 261-3352, and that such effectiveness also be confirmed in writing.

 The Company hereby acknowledges that
(i) should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (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; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the
adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,

PennantPark Floating Rate Capital Ltd.

By:

 /s/ Aviv Efrat

Name:

Aviv Efrat

Title:

Chief Financial Officer