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SEC Company Response from BARINGS GLOBAL SHORT DURATION HIGH YIELD FUND (BGH) (CIK 0001521404) (BGH) — Oct 25, 2012

BARINGS GLOBAL SHORT DURATION HIGH YIELD FUND (BGH) (CIK 0001521404)
Date: Oct. 25, 2012 · CIK: 0001521404 · Accession: 0001193125-12-434322

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File numbers found in text: 333-174430, 811-22562

Date
October 22, 2012
Author
MERRILL LYNCH, PIERCE, FENNER & SMITH
Form
CORRESP
Company
BARINGS GLOBAL SHORT DURATION HIGH YIELD FUND (BGH) (CIK 0001521404)

Letter

Division of Investment Management Washington, DC 20549 Babson Capital Global Short Duration High Yield Fund Registration Statement on Form N-2 File Nos. 333-174430 and 811-22562

Dear Mr. Minore:

Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended, we, on behalf of the several underwriters, wish to advise you that distribution of the Registration Statement on Form N-2 as filed on May 23, 2011 and the Preliminary Prospectus dated September 24, 2012, began on September 24, 2012 and is expected to conclude at approximately 5:00 p.m., Eastern Time, on October 25, 2012, with anticipated distribution results as follows: a limited number of Registration Statements have or will be sent to underwriters and approximately 44,000 copies of the Preliminary Prospectus have or will be sent to underwriters, dealers and institutions.

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, on behalf of the underwriters of the offering of shares of common stock of the Trust, hereby joins in the request of the Trust for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 10:00 a.m., Eastern Time, on October 25, 2012 or as soon thereafter as practicable.

Sincerely,
MERRILL LYNCH, PIERCE, FENNER & SMITH

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CORRESP
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Babson Capital Global Short Duration High Yield Fund

Global Markets & Investment Banking

 One Bryant Park – 8th Floor

New York, New York 10036

646-855-6780

 October 22, 2012

 Dominic Minore

 U.S. Securities and Exchange Commission

Division of Investment Management

 100 F Street,
NE

 Washington, DC 20549

 Babson Capital Global Short Duration High Yield Fund

 Registration
Statement on Form N-2

 File Nos. 333-174430 and 811-22562

 Dear Mr. Minore:

 Pursuant to Rule 460 of the General Rules and Regulations under
the Securities Act of 1933, as amended, we, on behalf of the several underwriters, wish to advise you that distribution of the Registration Statement on Form N-2 as filed on May 23, 2011 and the Preliminary Prospectus dated September 24, 2012, began
on September 24, 2012 and is expected to conclude at approximately 5:00 p.m., Eastern Time, on October 25, 2012, with anticipated distribution results as follows: a limited number of Registration Statements have or will be sent to underwriters and
approximately 44,000 copies of the Preliminary Prospectus have or will be sent to underwriters, dealers and institutions.

 In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, on behalf of the underwriters of the offering of shares of common stock of the Trust, hereby joins in the request of the
Trust for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 10:00 a.m., Eastern Time, on October 25, 2012 or as soon thereafter as practicable.

 Sincerely,

 MERRILL LYNCH, PIERCE, FENNER & SMITH

INCORPORATED

On behalf of the Several Underwriters

By:

 MERRILL LYNCH, PIERCE, FENNER & SMITH

INCORPORATED

 By:

 /s/ Palma Mazzolla

Name: Palma Mazzolla

Title:   Authorized Signatory