SecProbe.io

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[Letterhead of Sutherland Asbill & Brennan LLP]

August 13, 2015

VIA EDGAR

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Newtek Business Services Corp.

Registration Statement on Form
N-2

File Nos.: 814-01035: 333-204915

Dear Ms. Cole and Ms. Stout:

On behalf of Newtek
Business Services Corp. (the “Company”), set forth below are the Company’s responses to the comments
provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) to the Company in a letter dated July 10, 2015 with respect to the Company’s
shelf registration statement on Form N-2 (File No. 333-204915), filed with the Commission on June 12, 2015, as amended (the “Registration
Statement”), and the prospectus included therein (the “Prospectus”). The Staff’s
comments are set forth below and are followed by the Company’s responses. Where revisions to the Prospectus are indicated
in the Company’s responses, such revisions are set forth in the Prospectus included in Amendment No. 1 to the Registration
Statement, filed concurrently herewith.

General

 1. Whenever a comment is made with respect to disclosure in one location of the filing, it applies
to similar disclosure found elsewhere.

Response: The Company acknowledges the
Staff’s comment.

 2. Certain items of disclosure were omitted from the registration statement. We may have comments
on such items when they are included in a pre-effective amendment to the registration statement.

Response: The Company acknowledges the
Staff’s comment.

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

August 13, 2015

Page 2

Prospectus

 3. Common shareholders should have some basis to determine and understand the maximum dilution that
might be imposed upon their shares as a result of the Company’s future issuances of securities. Please add appropriate risk
disclosure and provide an example (i.e., a table that provides dilution amounts for a common stock offering at different
prices below NAV). Further, in places where you disclose that the Company may issue shares at a price below NAV with shareholder
approval, add disclosure that makes it clear that shareholders have provided such approval.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment. The Company advises the Staff on a supplemental
basis that under Section 63(2)(A) of the 1940 Act, the Company’s approval to sell below NAV expired on June 24, 2015, the
date of Company’s last annual shareholder meeting. The Company respectfully refers the Staff to the table providing dilution
amounts for common stock at different prices below NAV in the “Sales of Common Stock Below Net Asset Value” section
within the Prospectus.

 4. Page 33 states, “Typically, the debt in which we invest is not initially rated by any rating
agency; however, we believe that if such investments were rated, they would be below investment grade.” Please add disclosure
that below investment grade securities are often referred to as Junk.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment.

 5. Page 54 states, “We target our debt investments, which are principally made through our small
business finance platform under the SBA 7(a) program, to produce a coupon rate of prime plus 2.75% which enables us to generate
rapid sales of loans in the secondary market, producing gains with a yield on investment in excess of 30%.” If true, please
disclose that the “yield on investment” is determined before, and therefore do not take into account, the payment of
all of the company’s expenses.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment.

 6. In your response letter, please describe the types of debt that the Company contemplates offering
through this registration statement. Additionally, undertake to advise us in advance of any proposed debt offering pursuant to
this registration statement and to provide for staff review the preliminary prospectus supplement relating to any debt offering
by the Company. Further undertake to clear all staff comments prior to the commencement of any such debt offering whenever the
preliminary prospectus supplement materially differs from the form of prospectus supplement included in this registration statement
at the time of effectiveness. In this regard, please note that the prospectus supplement should, as applicable:

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

August 13, 2015

Page 3

(1) Disclose that none of the
Company's indebtedness is currently subordinated to the debt securities. It should also disclose whether there is a current intention
to issue indebtedness that expressly provides that it is subordinated to the debt securities.

(2) Disclose that the debt securities
are "structurally subordinated" and are “effectively subordinated” to all existing and future indebtedness
of the Company and other obligations of its subsidiaries, financing vehicles and similar facilities. The significance of the debt
securities being structural subordinated and effectively subordinated should be explained in plain English, specifically highlighting
how such subordination affects the rights and priorities of the holders of the debt securities. Also, disclose the approximate
total dollar amount of all liabilities and obligations to which the debt securities being offered are structurally subordinated
and effectively subordinated.

(3) Refrain from using the word
"senior" in the title of any debt securities issued by the Company, or when describing/identifying their ranking, if
the debt securities are not contractually senior in right of repayment to the other outstanding obligations of the Company. Even
where the Company’s debt securities are contractually senior in right of repayment to the other outstanding obligations of
the Company, consider the appropriateness of referring to the debt securities as “senior” when they are also structurally
subordinated to the obligations of the Company’s subsidiaries, financing vehicles and similar facilities.

(4) Disclose that the debt securities
will not be subject to any sinking fund and explain the significance thereof; for example, state that no amounts will be set aside
for the express purpose of repayment of principal and any unpaid interest on the debt securities, and that repayment of the debt
securities will depend upon the financial condition of the Company and its subsidiaries as they exist as of the maturity date of
the debt securities.

Response: The Company
respectfully refers the Staff to the “Description of Our Debt Securities” section of the Prospectus for a description
of the types of debt securities that the Company may offer, issue, and sell pursuant to the Registration Statement. In addition,
the Company has filed forms of prospectus supplements as exhibits to the Registration Statement for the Staff’s review. The
Company further undertakes to inform the Staff, and clear all Staff comments prior to the commencement of any such debt offering,
whenever the preliminary prospectus supplement materially differs from the form of prospectus supplement for debt offerings included
in the Registration Statement at the time of effectiveness.

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

August 13, 2015

Page 4

 7. Please add an undertaking that the Company will file, during any period in which offers or sales
are being made, a post-effective amendment if it determines to conduct one or more offerings of the Company’s common shares
at a price below its net asset value per common share at the date the offering is begun and such offering or offerings will result
in greater than a 15% dilution to the Company’s net asset value per common share.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment.

 8. Please add that
the Company undertakes in the event that the securities being registered are to be offered to existing stockholders pursuant to
warrants or rights, and any securities not taken by shareholders are to be reoffered to the public, to supplement the prospectus,
after the expiration of the subscription period, to set forth the results of the subscription offer, the transactions by the underwriters
during the subscription period, the amount of unsubscribed securities to be purchased by underwriters and the terms of any subsequent
underwriting thereof. Registrant further undertakes that if any public offering by the underwriters of the securities being registered
is to be made on terms differing from those set forth on the cover page of the prospectus, the Registrant shall file a post-effective
amendment to set forth the terms of such offering.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment.

 9. Please add an undertaking to file a post-effective amendment to the registration statement, and
to suspend any offers or sales pursuant the registration statement until such post-effective amendment has been declared effective
under the 1933 Act, in the event the shares of Registrant are trading below its net asset value and either (i) Registrant receives,
or has been advised by its independent registered accounting firm that it will receive, an audit report reflecting substantial
doubt regarding the Registrant’s ability to continue as a going concern or (ii) Registrant has concluded that a material
adverse change has occurred in its financial position or results of operations that has caused the financial statements and other
disclosures on the basis of which the offering would be made to be materially misleading.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment.

 10. We note that you have not yet filed prospectus supplements. We may have additional comments when
they are submitted as exhibits to the registration statement.

Response: The Company
acknowledges the Staff’s comment.

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

August 13, 2015

Page 5

Exhibits

 11. Please file as an exhibit the legality opinion in respect
of each category of security being registered, and related consent of counsel, with your next pre-effective amendment. In this
regard, it appears that the terms of the actual offerings from this registration statement have not yet been authorized by the
Company’s Board of Directors. Therefore, in your response letter, provide an undertaking on behalf of the Company to file,
in a post-effective amendment with each takedown from this shelf registration statement, an unqualified legality opinion and related
consent of counsel that will be consistent with the views set forth in Staff Legal Bulletin No. 19 (CF).

Response: The Company
acknowledges the Staff’s comment and has filed the legality opinion in respect of each category of security being registered,
and related consent of counsel with Amendment No. 1 to the Registration Statement. The Company undertakes to file, in a post-effective
amendment with each takedown from this shelf registration statement, an unqualified legality opinion and related consent of counsel
that will be consistent with the views set forth in Staff Legal Bulletin No. 19 (CF).

Accounting Comments

 12. Please file an updated consent from McGladrey LLP with
the amended N-2 filing.

Response: The Company
has filed an updated consent from McGladrey LLP with Amendment No. 1 to the Registration Statement.

 13. Please file an updated audit report for the Senior Securities table.

Response: The Company
respectfully refers the Staff to Exhibit n.4 of the Registration Statement filed on June 12, 2015 and incorporated by reference
to Amendment No. 1 to the Registration Statement for an updated audit report for the Senior Securities table.

 14. In your response, confirm that the financial statements of all wholly owned and all substantially
owned subsidiaries are consolidated with the financial statements of the Company.

Response: The Company
confirms that the financial statements of all wholly owned and all substantially owned subsidiaries that are “investment
companies” within the meaning of the 1940 Act are consolidated with the financial statements of the Company.

 15. Confirm that the Company performs a quarterly analysis
as to whether the disclosure requirements of Rules 3-09 or 4-08(g) of Regulation S-X should be applied for any unconsolidated
subsidiaries.

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

August 13, 2015

Page 6

 o The Staff believes that Rules 3-09 and 4-08(g) of Regulation S-X apply to BDCs and RICs. Rule 3-09
of Regulation S-X is applicable for a majority owned subsidiary (greater than 50% ownership) that is not consolidated by the Registrant.
Rule 4-08(g) of Regulation S-X is applicable for subsidiaries (generally, 25% or more ownership) not consolidated.

 o See definition of subsidiary in 1-02 (x) of Regulation S-X and definition of affiliate
in Section 602(a) of Regulation S-X.

Response: The Company confirms that
it performs a quarterly analysis as to whether the disclosure requirements of Rules 3-09 or 4-08(g) of Regulation S-X should be
applied for any unconsolidated subsidiaries.

 16. In the Fees and Expenses table on page 18, if the Company has included proceeds from the offering
in the calculation of the annual expenses, include in a footnote the assumptions used.

Response:
The Company has not included proceeds from the offering in this calculation. The annual expenses were based on the company’s
annualized expenses and NAV as of June 30, 2015.

 17. In the table on page 51, Price Range of Common Stock and Distributions, consider disclosing the
date that the Company became an investment company.

Response: The Company
has revised the above-referenced disclosure in response to the Staff’s comment.

 18. In the Accompanying Notes to the Consolidated Financial Statements, include a discussion of the
nature of the “servicing income” fees received by the Company similar to the discussion of the “interest income”
and “other income.” Please include a detailed discussion on “other income” and “servicing income”
in the Accompanying Notes to the Financial Statements so that shareholders may assess the nature of the income and whether it is
recurring or non-recurring income. Refer to the issue discussed at the September 16, 2014, AICPA Expert Panel Meeting:

(c) The SEC staff discussed it may be important for BDC shareholders
to understand the amount of income generated by BDCs that is non-recurring. The SEC staff noted that BDCs may receive certain non-recurring
fees from their borrowers, including up-front fees (e.g., financing fees or structuring fees) and back-end fees (e.g., prepayment
fees or unamortized original issue discount (OID)). However, BDCs generally have not disclosed the impact of these non-recurring
fees on earnings and/or yield (e.g., in either the financial statements or in Management’s Discussion and Analysis). The
SEC staff believes disclosure of the impact of non-recurring fees on earnings and/or yield could be important to the users of financial
statements to help investors analyze the BDC’s potential future cash flows and dividend sustainability.

Ms. Mary A. Cole, Esq.

Ms. Sheila Stout

August 13, 2015

Page 7

Response: The Company
confirms to the Staff that it included in its Quarterly Report on Form 10-Q for the period ended June 30, 2015, a discussion on
“other income” and “servicing income,” in the Investment Income section of Note 2, and that going forward
it will disclose the amount of other income generated that is non-recurring and will describe the impact of non-recurring fees
on earnings and/or yield in future “Management’s Discussion and Analysis of Financial Condition and Results of Operations”
sections