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SEC Company Response from PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) (CIK 0001504619) (PFLA) — Dec 15, 2016

PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) (CIK 0001504619)
Date: Dec. 15, 2016 · CIK: 0001504619 · Accession: 0001193125-16-794458

Offering / Registration Process Regulatory Compliance Capital Structure

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Document Type
Confidence
SEC Posture
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Summary

Reasoning

Date
December 15, 2016
Author
/s/ William J. Tuttle
Form
CORRESP
Company
PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) (CIK 0001504619)

Letter

Re: PennantPark Floating Rate Capital Ltd.

December 15, 2016

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Attn: Ashley Vroman-Lee

Registration Statement on Form N-2

Ladies and Gentlemen:

PennantPark Floating Rate Capital Ltd., a Maryland corporation (the “Company”), has today filed with the Securities and Exchange Commission a Registration Statement on Form N-2, which registers an aggregate $500 million of securities that may be offered by the Company from time to time in reliance on Rule 415 under the Securities Act of 1933, as amended.

If you have any questions, please feel free to contact Thomas J. Friedmann at 617.728.7120 (or by email at thomas.friedmann@dechert.com) or the undersigned by telephone at 202.261.3352 (or by email at william.tuttle@dechert.com). Thank you for your cooperation and attention to this matter.

Sincerely,
/s/ William J. Tuttle

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CORRESP
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CORRESP

 December 15, 2016

 VIA EDGAR

 United
States Securities and Exchange Commission

 Division of Investment Management

100 F Street, N.E.

 Washington, DC 20549

Attn: Ashley Vroman-Lee

Re:
PennantPark Floating Rate Capital Ltd.

Registration Statement on Form N-2

 Ladies and Gentlemen:

PennantPark Floating Rate Capital Ltd., a Maryland corporation (the “Company”), has today filed with the Securities and Exchange Commission a
Registration Statement on Form N-2, which registers an aggregate $500 million of securities that may be offered by the Company from time to time in reliance on Rule 415 under the Securities Act of 1933,
as amended.

 If you have any questions, please feel free to contact Thomas J. Friedmann at 617.728.7120 (or by email at thomas.friedmann@dechert.com) or
the undersigned by telephone at 202.261.3352 (or by email at william.tuttle@dechert.com). Thank you for your cooperation and attention to this matter.

Sincerely,

 /s/ William J. Tuttle

William J. Tuttle

cc:
Arthur H. Penn, PennantPark Floating Rate Capital Ltd.

Aviv Efrat, PennantPark Floating Rate Capital Ltd.

Thomas J. Friedmann, Dechert LLP