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: 0001193125-12-434323
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-174430, 811-22562
Letter
United States Securities and Exchange Commission Washington, DC 20549 Attention: Mr. Kevin Rupert Re: Babson Capital Global Short Duration High Yield Fund (the “Fund”) Registration Statement on Form N-2 (File Nos. 811-22562 and 333-174430)
Dear Mr. Minore:
Pursuant to Rule 461(a) under the Securities Act of 1933, as amended (the “Securities Act”), the Fund respectfully requests that the effectiveness of the above-referenced registration statement on Form N-2 be accelerated to 10:00 a.m. on Thursday, October 25, 2012, or as soon thereafter as practicable.
The Fund acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or its staff (the “staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any actions 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 Fund from its full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) the Fund 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.
The Fund also brings to your attention that pursuant to Rule 430A under the Securities Act, the form of prospectus (including the statement of additional information) filed as part of the Fund’s registration statement on Form N-2 omits certain information, including information with respect to the public offering price, discounts or commissions to dealers, amount of proceeds and other items dependent upon the offering price, delivery dates, and terms of the securities dependent upon the offering date.
Very truly yours,
BABSON CAPITAL GLOBAL HIGH YIELD FUND
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CORRESP 1 filename1.htm Babson Capital Global Short Duration High Yield Fund BABSON CAPITAL GLOBAL SHORT DURATION HIGH YIELD FUND 550 South Tryon Street, Suite 3300 Charlotte, North Carolina 28202 October 24, 2012 Dominic Minore United States Securities and Exchange Commission 100 F Street N.E. Washington, DC 20549 Attention: Mr. Kevin Rupert Re: Babson Capital Global Short Duration High Yield Fund (the “Fund”) Registration Statement on Form N-2 (File Nos. 811-22562 and 333-174430) Dear Mr. Minore: Pursuant to Rule 461(a) under the Securities Act of 1933, as amended (the “Securities Act”), the Fund respectfully requests that the effectiveness of the above-referenced registration statement on Form N-2 be accelerated to 10:00 a.m. on Thursday, October 25, 2012, or as soon thereafter as practicable. The Fund acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or its staff (the “staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any actions 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 Fund from its full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) the Fund 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. The Fund also brings to your attention that pursuant to Rule 430A under the Securities Act, the form of prospectus (including the statement of additional information) filed as part of the Fund’s registration statement on Form N-2 omits certain information, including information with respect to the public offering price, discounts or commissions to dealers, amount of proceeds and other items dependent upon the offering price, delivery dates, and terms of the securities dependent upon the offering date. Very truly yours, BABSON CAPITAL GLOBAL HIGH YIELD FUND By: /s/ Russell D. Morrison Name: Russell D. Morrison Title: President and Principal Executive Officer