SecProbe.io

CORRESP
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    Troutman Pepper Locke LLP

    305 Church at N. Hills Street, Suite 1200

    Raleigh, NC 27609

    troutman.com

James L. Severs

james.severs@troutman.com

February 13, 2025

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn: Karen Rossotto, Senior Counsel

Re:           ArrowMark
Financial Corp. (the “Company”)

Registration Statement on Form N-2

1940 Act File No. 811-22853

1933 Act File No. 333-281004

Mses. Fettig and Rossotto:

This letter responds to the supplemental comments
of the staff of the Commission (the “Staff”) to Pre-Effective Amendment No. 2 to the Company’s Registration Statement
on Form N-2 (the “Pre-Effective Amendment”) provided on February 11, 2025 by Karen L. Rossotto. The Pre-Effective
Amendment was filed on February 7, 2025 under the Securities Act of 1933, as amended (the “1933 Act”), and under the
Investment Company Act of 1940, as amended (the “1940 Act”). The Registration Statement relates to the registration, under
the 1933 Act, of the proposed offerings from time to time by the Company of up to an aggregate of $150,000,000 of the Company’s
common stock, preferred stock, debt securities, or subscription rights to purchase shares of common stock.

We appreciate the opportunity to address the
Staff’s comments regarding certain disclosure in the Registration Statement. We have organized this letter by setting forth the
Staff’s comments in italics followed by the Company’s response to the Staff’s comments.

Supplemental Comments

 1. Please confirm that all types of instruments in which the
                                            Company may invest as part of its principal investment strategy are disclosed in the Prospectus
                                            Summary.

Response: The Company so confirms.

    Karen Rossotto

February 13, 2025
 Page 2

 2. Please refer to “below investment grade securities”
                                            consistently as such rather than as non-investment grade securities.

Response: The Company has revised all references
to non-investment grade securities to refer to such securities as “below investment grade securities.”

 3. Please confirm that the statistics related to the community
                                            banking sector included under “Banking Sector Focus” are the most recent such
                                            statistics available to the Company.

Response: The Company so confirms.

 4. The staff notes that the disclosure appears to disclose
                                            in some instances that the Company will invest in convertible securities while, in instances,
                                            referring to contingent convertible securities. Please revise the disclosure to clarify whether
                                            the Company may invest in contingent convertible securities, convertible securities, or both
                                            as part of its principal investment strategy.

Response: The Company has revised the disclosure
to clarify that it may invest in convertible securities, including contingent convertible securities. The Company notes that the risk
disclosure with respect to convertible securities addresses the risks of both convertible securities generally and contingent convertible
securities specifically.

 5. Please revise the disclosure included in the last sentence
                                            under “Market Opportunity” to clarify the meaning of “other regulated banking
                                            institutions.”

Response: The Company has revised the disclosure
to clarify that, along with community banks, it may invest in larger U.S. banks and global money center banks.

    Karen Rossotto

February 13, 2025
 Page 3

 6. The Staff notes that the disclosure appearing under “Additional
                                            Risks Related to Investments in CLOs” stats that the Company is subject to risks associated
                                            with the bankruptcy or insolvency of an issuer or borrower of a loan that it holds. Please
                                            confirm whether the Company intends to invest in loans as part of its principal investment
                                            strategy and, if so, include appropriate disclosure in the Prospectus Summary and Risk Factors
                                            sections.

Response: The reference to loans in the above
referenced risk disclosure related to loans underlying CLOs in which the Company may invest. The Company has revised this disclosure
to clarify that it is subject to risks associated with the bankruptcy or insolvency of an issuer or borrower of a loan underlying
a Structured Product that it holds.

*         *         *

Please direct any questions
concerning this letter to my attention at 919.835.4142, or in my absence to John P. Falco of this office at 215.981.4659.

    Very truly yours,

    /s/ James L. Severs

    James L. Severs

    cc:
    Sanjai Bhonsle, Chairman and Chief
    Executive Officer

    Patrick Farrell, Chief Financial Officer

    Rick Grove, Chief Compliance Officer

    John P. Falco, Esq.

    Theodore D. Edwards, Esq.