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Babson Capital Global Floating Rate & Income Fund

 August 17, 2011

 Mr. Kevin C. Rupert

 Securities and Exchange Commission

100 F Street, NE

 Washington, DC 20549-4720

Re:
Babson Capital Global Floating Rate & Income Fund (the “Registrant”)

File Nos. 333-174430; 811-22562

 Dear Mr. Rupert:

 We are writing to respond to the comments of the staff (the
“Staff”) of the Securities and Exchange Commission (the “SEC”) set forth in your letter addressed to Colleen B. Meyer of this firm dated June 20, 2011 in connection with the Registrant’s registration
statement on Form N-2 (the “Registration Statement”) filed with the SEC on May 23, 2011. The Staff’s comments are set forth below, and each is followed by our response.

General

1.
Comment. We note that material portions of the filing are incomplete. We may have additional comments on such portions when you complete them in a pre-effective
amendment, on disclosures made in response to this letter, on information supplied to the staff, or on exhibits added in any pre-effective amendments.

 Response. The Registrant intends to include all required information and exhibits to the Registration Statement in one or more pre-effective amendments.

Cover Page

2.
Comment. In light of the Fund’s name, please revise the 80% policy in the “Principal Investments” section to apply to floating rate obligations.
This comment also applies to the disclosure on page 1 in the “Portfolio Management Strategies” section.

Response. The term “floating rate” in the Registrant’s name refers to a particular type of investments -
instruments that pay interest at a rate that resets periodically, or “floats.” The term “income” in the Registrant’s name is intended to refer to other (non-floating rate) income-producing investments - instruments a
principal feature of which is the production of income (such as secured loans and secured bonds). To clarify the intended meaning of the Registrant’s name, the Registrant’s 80% investment policy has been revised as follows:

 Under normal market conditions, the Fund will invest at least 80% of its managed assets in
floating rate instruments and secured loans, secured bonds or other income-producing instruments, including floating rate instruments secured and unsecured loans and
bonds.

 The Registrant believes that this investment policy is consistent with the Staff’s “Frequently Asked Questions about
Rule 35d-1 (Investment Company Names)” (available at http://www.sec.gov/divisions/investment/guidance/rule35d-1faq.htm#P103_15038), in which the Staff stated that “Rule 35d-1 would not apply to the use of the term ‘income’
where that term suggests an investment objective or strategy rather than a type of investment.” (Emphasis added.) The Staff also stated that, “[w]hen used by itself, the term ‘income’ in a fund’s name generally
suggests that the fund emphasizes the achievement of current income and does not suggest a type of investment.” (Emphasis added.) By using the term “generally,” the Staff recognized that the term “income,” used by itself,
could, in some circumstances, suggest a type of investment. When a fund’s 80% investment policy makes clear the intended import of the term “income” in the fund’s name, as in the case of the Registrant, the Registrant does not
believe that name is materially deceptive or misleading for purposes of Section 35(d) of the 1940 Act.

3.
Comment. Note (2) to the pricing table states “[t]he Manager (and not the Fund) has agreed to pay from its own assets a [•] fee to [•]….
That fee is not reflected in the table above.” Please disclose whether this payment is made to all underwriters or only certain qualifying underwriters. Please inform the staff whether FINRA has specifically approved the terms of the
underwriting arrangement (including the discounting methodology discussed on page 47 of the prospectus), and whether it has taken a position as to whether this fee should be included in the disclosed underwriting fees. Please disclose the aggregate
dollar amount of the contracts and the value as a percentage of the offering price.

 Response. The
Registrant’s underwriting arrangements have not yet been finalized or submitted for FINRA approval; however, the Registrant intends to include all required information regarding such underwriting arrangements in the Registration Statement in
one or more pre-effective amendments.

4.
Comment. Footnote (3) to the pricing table generally states that the Manager will pay some unknown portion of the Fund’s organizational cost and
offering costs (other than the sales load). Please include in the footnote an estimate of the offering and organizational costs expected to be paid by the Adviser, both in dollars and per share amounts.

Response. The Registrant’s organizational and offering costs are not yet known or susceptible of reasonable
estimation; however, the Registrant intends to include all required information regarding such costs in the Registration Statement in one or more pre-effective amendments.

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5.
Comment. The last two sentences of the section captioned “Portfolio Contents” states that the Fund is not limited in the types of derivatives it may
use and that its “derivatives use will consist primarily of credit default swaps and foreign currency forward contracts and futures.” Pages 10 and 20 of the prospectus have some derivatives disclosure, and pages 18-30 of the Fund’s
Statement of Additional Information (“SAI”) provides additional disclosure about derivatives, and also identifies other derivatives. The Division of Investment Management has recently made a number of observations about derivative related
disclosure by investment companies in a letter from Barry D. Miller, Associate Director, Office of Legal and Disclosure, to Karrie McMillan, General Counsel, Investment Company Institute dated July 30, 2010. [Footnote omitted.] Please review
the observations set forth in that letter and revise your disclosure of use and risks of derivatives accordingly.

Response. The requested change has been made. The Registrant has revised its prospectus disclosure to focus on the
investments that its portfolio managers currently anticipate using in managing the Registrant’s investment portfolio. The Registrant believes that its prospectus disclosure, as revised, is consistent with the letter from Barry D. Miller,
Associate Director, Office of Legal and Disclosure, to Karrie McMillan, General Counsel, Investment Company Institute dated July 30, 2010.

6.
Comment. In light of the Fund’s apparent extensive use of derivatives, disclose in the SAI that the Fund will at all times appropriately segregate assets
for such derivative exposure in accordance with the principles contained in Investment Company Act Release No. 10666 (April 18, 1979), related SEC staff positions, and applicable SEC no-action letters.

Response. The Registrant notes that the following disclosure, which the Registrant believes is responsive to the
Staff’s comment, is currently included in the section of the prospectus captioned “Leverage”:

 Derivative
instruments and financial contracts used by the Fund will not constitute senior securities (and will not be subject to the Fund’s limitations on borrowings) to the extent that the Fund segregates liquid assets at least equal in amount to its
obligations under the instruments, or enters into offsetting transactions or owns positions covering its obligations.

7.
Comment. The Fund should comply with Item 2.1 of Form N-2 regarding the trading information. Please keep the staff current on the status of the Fund’s
exchange listing on the NYSE.

 Response. The Registrant intends to include the trading information
required by Item 2.1 of Form N-2 in the Registration Statement in one or more pre-effective amendments once it receives authorization from the NYSE to list its shares for trading.

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8.
Comment. The section captioned “Portfolio Management Strategies” discusses “inefficiencies between geographies”. Please explain in the
prospectus specifically what is meant by this phrase and how it ties to the Fund’s investment objective. In addition, since the Fund uses the term “Global” in its name, the prospectus must also disclose a policy that states the Fund
will have at least 40% of its assets invested globally (i.e., outside of the United States).

Response. With respect to “inefficiencies between geographies,” the requested change has been made. The following
disclosure has been added to the referenced section:

 For example, the Fund will seek to take advantage of differences in
pricing between loans of an issuer denominated in U.S. dollars and substantially similar loans of the same issuer denominated in Euros, potentially allowing the Fund to achieve a higher relative return for the same credit risk exposure.

In January 1991, the Staff expressed its position that “[a] registrant which includes the terms “international” or
“global” in its name should have an investment policy which requires that, under normal market conditions, at least 65 percent of the value of its total assets be invested in a way that reflects an international (multi-national) or global
(worldwide) character of the portfolio.”1 However, in
adopting Rule 35d-1 in January 2001, the SEC specifically declined to codify the Staff’s position regarding the use of the term “global” in investment company names.2 The SEC explained its declination as follows:

 The term “foreign” indicates investments that are tied economically to countries outside the United States, and an investment company that uses this term would be subject to the 80% requirement.
The terms “international” and “global,” however, connote diversification among investments in a number of different countries throughout the world, and “international” and “global” funds will not be
subject to the rule. We would expect, however, that investment companies using these terms in their names will invest their assets in investments that are tied economically to a number of countries throughout the world.3

 Consistent with the position of the SEC, the Registrant anticipates that its assets will at all times be invested in investments that are tied economically to multiple countries throughout the world;
however, the Registrant believes that a requirement that it at all times invest at least 40% of its assets outside the United States would be both arbitrary and potentially detrimental to its shareholders. In this regard, the registrant notes that,
if one were to combine the Credit Suisse Leveraged Loan Index and the Credit Suisse Western European Leveraged Loan Index, which

1.
Generic Comment Letter, SEC No-Action Letter, 1991 SEC No-Act. LEXIS 1451 at II.A.2 (Jan. 3, 1991). (Hereinafter, the “1991 Letter.”)

2.
See id. at II.C.1.

3.
 Id. at II.C.1 n. 42.

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together represent the investible universe of secured loans, the Credit Suisse Leveraged Loan Index, which measures U.S. secured loans, would represent approximately 70% of the total, while the
Credit Suisse Western European Leveraged Loan Index, which measures European secured loans, would represent only approximately 30% of the total. Thus, with respect to investments in secured loans (which are expected to comprise a substantial portion
of the Registrant’s investment portfolio), compliance with the Staff’s request would require at least a 10% overweight in European secured loans at all times.

 Accordingly, the Registrant believes that its portfolio management strategy disclosure is sufficient as currently written.

9.
Comment. The last paragraph on this page discusses credit default swaps (CDS). This discussion only identifies the Fund as a buyer of protection or insurance
with respect to CDS, and describes the Fund’s obligation only in terms of a series of periodic payments. We note that page 20 of the prospectus identifies the Fund as the seller or writer of a CDS. We also note that the first full paragraph on
page 28 of the SAI states, “[t]he Fund may have exposure to credit default swaps through investments in credit-linked trust certificates. In connection with such investments, the Fund would be in the position of a seller of a credit default
swap contract because the trust that issues the certificates would be selling one or more credit default swap contracts. The seller of a credit default swap contract is required to pay the par (or other agreed-upon) value of a referenced debt
obligation to the counterparty in the event of a default or similar triggering event by a third party, such as a U.S. or foreign corporate issuer, on the debt obligation.” There is further disclosure on page 29 in the SAI that the Fund would be
a seller or writer of conventional CDS protection or insurance, and as such the Fund would effectively add leverage to its portfolio because the Fund would be subject to investment exposure on the notional amount of the swap.

 Thus, the prospectus is ambiguous as to what the Fund’s position and risk exposure will be with respect to
selling/writing CDS protection or insurance. Please clarify the prospectus disclosure in this regard. We note that the Fund’s use of credit-linked trust certificates may require prospectus disclosure and explanation as it appears these may pose
additional risks. If the Fund will write or sell CDS protection or insurance or obtain similar exposure through credit-linked trust certificates, please disclose that the Fund will segregate liquid assets based on the notional amount.

Response. References to credit-linked trust certificates have been removed from the Registrant’s prospectus. The
Registrant does not intend to write protection using credit default swaps, and will use credit default swaps only to hedge credit exposure to particular issuers. The Registrant has revised its prospectus disclosure accordingly.

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10.
 Comment. Please explain to the staff the first sentence of the second paragraph. Are there companies with strong management teams and solid
business positions in stable

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industries that have junk bond ratings (e.g., speculative characteristic with respect to capacity to pay interest and to repay principal)?

Response. Certain of the securities in which the Registrant will invest often will be rated below investment grade based
primarily on the position of such securities within the capital structure of the issuers, rather than the quality of such issuers’ management teams or such issuers’ positions in their industries. Many companies that issue high yield debt
securities are leaders in their industries and have highly regarded management, and certain securities of such companies were rated investment grade prior to such companies being taken private by private equity firms. Many such companies would be
able to issue investment grade debt if they reduced the debt taken on in connection with their privatization. While company ratings are certainly affected by the size and scale of the company’s business, they also are heavily influenced by the
company’s capital structure.

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11.
Comment. Since the Fund’s primary investment objective is to seek as high a level of current income as the “Manager determines is consistent with
capital preservation”, why would the Fund purchase non-performing securities (e.g., default securities)? This practice appears to cause the Fund to prioritize capital appreciation over income in seeking its investment objective.

 Response. The Registrant anticipates that, at the time of any purchase of defaulted securities,
its aggregate investments in defaulted securities will not exceed 10% of its total assets. Accordingly, the Registrant believes that its investments in defaulted securities, when considered as one component of the Registrant’s overall
investment portfolio, will be consistent with its investment objective.

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12.
Comment. Disclose the fee paid by the Manager to Babson Capital U.K. (the “Su