Correspondence 0001193125-23-229389 from Apollo Diversified Credit Fund (CIK 0001676197)
Apollo Diversified Credit Fund (CIK 0001676197)
Date: Sept. 6, 2023 · CIK: 0001676197 · Accession: 0001193125-23-229389
AI Filing Summary & Sentiment
File numbers found in text: 811-23159
Letter
VIA EDGAR Securities and Exchange Commission Division of Investment Management New York, NY 10004-2616 Attn: Mindy Rotter, Esq., CPA Re: Apollo Diversified Credit Fund (File No. 811-23159) Response to SEC Comment – Sarbanes-Oxley Review
Dear Ms. Rotter:
On behalf of Apollo Diversified Credit Fund (the “Fund”), we are providing the following response to the oral comment made pursuant to Section 408 of the Sarbanes-Oxley Act of 2002 by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on August 23, 2023, relating to the Fund’s annual report on Form N-CSR for the fiscal year ended December 31, 2022 (the “Annual Report”) originally filed with the Commission on March 8, 2023. The Staff’s comment is described below and has been summarized to the best of our understanding. We have discussed the Staff’s comment with representatives of the Fund. The Fund’s response to the Staff’s comment is set out immediately under the restated comment. Unless otherwise indicated, defined terms used herein have the meanings set out in the Annual Report.
Comment
Comment 1: The most recent version of the Form N-CSR, which was updated in January 2022, can be found on the Commission’s website. The updated Form N-CSR includes Items 4(i) and 4(j) that are required to be addressed whether or not the response is: “Not Applicable”. Please provide responses to Items 4(i) and 4(j) and confirm that, going forward, the current Form N-CSR will be used containing responses to all Items.
Response: The Fund confirms that for future filings it will use the updated Form N-CSR and will provide a response for each Item thereunder. With respect to the Annual Report, the Fund confirms that the responses to Items 4(i) and 4(j) would have been “Not Applicable”.
* * * * *
Please call me (202-636-5806) with any questions you may have regarding this filing or if you wish to discuss the above responses.
Respectfully submitted,
/s/ Ryan P. Brizek
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CORRESP
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CORRESP
Simpson Thacher & Bartlett LLP
900 G STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE:
+1-202-636-5500
FACSIMILE:
+1-202-636-5502
Direct Dial Number
(202) 636-5806
E-mail Address
ryan.brizek@stblaw.com
September 6, 2023
VIA EDGAR
Securities and Exchange Commission
Division of
Investment Management
Disclosure Review and Accounting Office
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Attn: Mindy Rotter, Esq., CPA
Re: Apollo Diversified Credit Fund (File No. 811-23159)
Response to SEC Comment – Sarbanes-Oxley Review
Dear Ms. Rotter:
On behalf of Apollo
Diversified Credit Fund (the “Fund”), we are providing the following response to the oral comment made pursuant to Section 408 of the Sarbanes-Oxley Act of 2002 by the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) on August 23, 2023, relating to the Fund’s annual report on Form N-CSR for the fiscal year ended December 31, 2022 (the “Annual Report”)
originally filed with the Commission on March 8, 2023. The Staff’s comment is described below and has been summarized to the best of our understanding. We have discussed the Staff’s comment with representatives of the Fund. The
Fund’s response to the Staff’s comment is set out immediately under the restated comment. Unless otherwise indicated, defined terms used herein have the meanings set out in the Annual Report.
Comment
Comment 1: The most recent
version of the Form N-CSR, which was updated in January 2022, can be found on the Commission’s website. The updated Form N-CSR includes Items 4(i) and 4(j) that are
required to be addressed whether or not the response is: “Not Applicable”. Please provide responses to Items 4(i) and 4(j) and confirm that, going forward, the current Form N-CSR will be used
containing responses to all Items.
Response: The Fund confirms that for future filings it will use the updated Form N-CSR and will provide a response for each Item thereunder. With respect to the Annual Report, the Fund confirms that the responses to Items 4(i) and 4(j) would have been “Not Applicable”.
* * *
* *
Please call me
(202-636-5806) with any questions you may have regarding this filing or if you wish to discuss the above responses.
Respectfully submitted,
/s/ Ryan P. Brizek
cc:
Kristin Hester, Esq., Apollo Global Management, Inc.
Cody Lipke, Esq., Apollo Global Management, Inc.
Debra E. W. Sutter, Esq.
John G.
Dikmak, Jr., Esq.
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