SecProbe.io

May 3, 2017
Mail Stop 4 720

Via E -mail
Curtis L. Buser
Chief Financial Officer
The Carlyle Group L.P.
1001 Pennsylvania Avenue, NW
Washington, D.C. 20004 -2505

Re: The Carlyle Group L.P.
Form 10 -K for the Fis cal Year Ended December 31, 2016
Filed February 16, 2017
Form 8 -K
Filed February 8, 2017
 File No. 001 -35538

Dear Mr. Buser :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe ou r
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2016

Management’s Di scussion and Analysis of Financial Condition and Results of Operations

Recent Transactions, page 88

1. We note your disclosure of transactions with Claren Road, ESG and the DGAM
Restructuring during 2016.  Please address the following:

 Confirm that the Par tnership did not receive anything in exchange for the transfer of
interests in Claren Road and ESG.
 Tell us the economic substance and benefit the Partnership expects to receive as  a
result of these transactions.

Curtis L. Buser
The Carlyle Group L.P.
May 3, 2017
Page 2

 In future filings, clearly disclose how the aggregate impact of these transactions
impact revenues and income from continuing operations .  Refer to Item 303(a)(3)(ii)
of Regulation S -K.

2. We also note that during 2016, you decided to wind down the commodities products that
were offered through  Vermillion.  During your fourth quarter earnings call and on page
220, this was highlighted as an area that was negatively impacted in 2016 with a net
amount of $150 million attributable to losses from certain funds and vehicles associated
with Vermillion  Asset Management.  Please address the following in your future filings:

 Expand to disclose the factors contributing to the losses from those certain funds and
vehicles associated with Vermillion Asset Management to the extent it is related to
your decisi on to wind down the commodities products offered.
 Quantify the remaining exposure the Partnership has associated with the existing
commodities products offered through Vermillion.
 Clearly disclose how the impact of this wind down impact s revenues and incom e
from continuing operations.  Refer to Item 303(a)(3)(ii) of Regulation S -K.

Non-GAAP Financial Measures, page 109

3. We note on page 110  that you present a full non -GAAP income statement s along with
corresponding reconciliation s of income (loss) before pr ovision for income  taxes to
economic income, to fee related earnings, and distributable earnings for each of the years
ended December 31, 2016, 2015 and 2014.  Please tell us how you r presentation and
related reconciliation(s) complies with Questions 104.0 4 and 102.10 of the updated Non -
GAAP Financial Measures Compliance and Disclosure Interpretations issued on May 17,
2016  (the “updated Non -GAAP C&DI”).

Form 8 -K Filed February 8, 2017

Exhibit 99. 2

4. We note your presentation of economic net income per adjusted unit and distributable
earnings per common unit for the fourth quarter and full year 2016 periods .  Please tell us
whether you consider these  to be liquidity measure s and why you believe presenting them
on a per share basis  complies with Question 102.05 of the updated Non -GAAP C&DI .

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the st aff.

Curtis L. Buser
The Carlyle Group L.P.
May 3, 2017
Page 3

 You may contact Robert Klein  at (202) 551 -3847 or me at (202) 551 -3872 if you have any
questions.
Sincerely,

 /s/ Hugh West

Hugh West
Accounting Branch Chief
Office of Financial Services