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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

 +1-202-636-5543

 E-mail Address

Rajib.Chanda@stblaw.com

 August 23, 2024

 VIA
EDGAR

 Securities and Exchange Commission

 Division of
Investment Management

 Disclosure Review and Accounting Office

100 F Street, NE

 Washington, DC 20549

Attn: David Manion, CPA, CAIA

Re:
 BC Partners Lending Corporation (File No. 814-01269)

 Form 10-K for the year ended December 31, 2023, filed on
March 12, 2024

 Dear Mr. Manion:

On behalf of BC Partners Lending Corporation (the “Company”), we are providing the following response to the oral comments issued by
the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on July 24, 2024, relating to the Company’s annual report on Form 10-K for the fiscal year
ended December 31, 2023 (the “Annual Report”), filed with the Commission on March 12, 2024.

 The Staff’s comments
are described below and have been summarized to the best of our understanding. We have discussed the Staff’s comments with representatives of the Company. The Company’s response to the Staff’s comments are set out immediately under
the restated comments. Unless otherwise indicated, defined terms used herein have the meanings set out in the Annual Report.

Comments

 Comment 1: In
Part II, Item 7 (“Management’s Discussion and Analysis of Financial Condition and Results of Operations”), on page 64, the disclosure states that during the fiscal year ended December 31, 2023, “reimbursements from the
Adviser totaled, $1.4 million,” but elsewhere in the financial statements, this amount is reported as an expense or repayment to related parties. Please:

A. Confirm which disclosure is correct, and whether the payment was a payment to the Adviser from the Company, or to the Company from the
Adviser.

 Response: The Company confirms that the referenced amount is correctly reflected in
the Consolidated Statements of Operations as an expense support repayment to related parties. The referenced amount reflects a payment made by the Company to the Adviser, reimbursing the Adviser for amounts that the Adviser previously paid to cover
eligible operating expenses of the Company under the Expense Support and Conditional Reimbursement Agreement (the “Support Agreement”) between the Adviser and the Company. The Company will correct the referenced disclosure in future
periodic reports filed with the Commission to indicate that the amount is “to” the Adviser, rather than “from” the Adviser.

B. Discuss the character of the amounts paid, including timeliness (i.e., whether related to the current year’s expenses or recoupment
of expenses for prior years) and the nature of the expenses (e.g., organizational costs, operating costs).

 Response: The
Company directs the attention of the Staff to page F-19 in the Annual Report, which contains a table showing expense reimbursements paid by the Company to the Adviser, for the year ended December 31,
2023, to reimburse the Adviser for amounts that the Adviser previously paid to cover eligible operating expenses of the Company under the Support Agreement. This table illustrates (i) the historical periods when initial payments were received
by the Company from the Adviser; (ii) the amount of the reimbursement payment made to the Adviser in fiscal 2023; (iii) the portion (if any) of these historical initial payments that were not reimbursed; and (iv) the date through which
payments are eligible to be reimbursed to the Adviser, according to the terms of the Support Agreement. As illustrated in this table, the payments reflected in the Consolidated Statements of Operations as an expense support repayment to related
parties for the year ended December 31, 2023 related to the Adviser’s recoupment of expenses for prior years in accordance with the terms of the Support Agreement.

The Company confirms that no payments have been made to the Adviser for any of the Adviser’s historical reimbursements to the Company that
are older than the three-year limit imposed by the Support Agreement.

 By way of example, the Company notes that in the quarter ended
December 31, 2019, the Adviser supported the Company to cover its operating expenses for approximately $2.17 million. Through the quarter ended December 31, 2022, the Company reimbursed the Adviser for approximately $1.45 million
of the $2.17 million of support previously provided by the Adviser. Therefore, approximately $0.72 million of such amount was not reimbursed to the Adviser and was no longer eligible for reimbursement to the Adviser after December 31,
2022. Thus, the Adviser did not, and will not, recover such remaining amount from the Company.

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 The Support Agreement provided that the Adviser would initially reimburse the Company for
any operating expenses in amounts necessary to ensure that no portion of distributions made to the Company’s stockholders would be paid from the Company’s offering proceeds or borrowings (and further, that such amounts would then be paid
back to the Adviser from the Company if certain conditions were met).

 Finally, the Company notes that, as disclosed in the Annual Report,
the Support Agreement expired pursuant to its terms on September 26, 2022, other than with respect to reimbursement payments that the Adviser may be entitled to from the Company pursuant to the Support Agreement, for a period of three years
following the last business day of the calendar quarter in which the Adviser reimbursed the Company. In accordance with the Support Agreement, the last eligible expense was recouped in the quarter ended September 30, 2023, and would have
otherwise ceased to be eligible for recoupment as of March 31, 2024. As a result, the Company no longer has any obligation to make reimbursement payments to the Adviser under the Support Agreement.

C. Discuss whether the Adviser is paying certain expenses on behalf of the Company and then receiving reimbursements (i.e., under the
Statements of Operations caption “expense support repayment paid to related parties”), or recording the expense to the Company.

Response: The Company confirms that it is properly recording its gross expenses in the Company’s Consolidated Statements of
Operations and that no operating expenses are being recorded under the line item for expense support repayments paid to related parties. All of the Company’s expenses are broken out in the Consolidated Statements of Operations, and, as
described in greater detail above, the referenced line item only shows payments to reimburse the Adviser for amounts it has previously paid to the Company to cover the Company’s operating expenses under the Support Agreement.

D. Confirm whether any amounts are recoupable under the Support Agreement, including amounts related to
pre-commencement of operations, as of December 31, 2023. Based on the disclosure, it appears that all amounts subject to repayment to the Adviser have been collected by the Adviser.

Response: As noted above, the Adviser cannot recoup any amounts from the Company that are no longer eligible for recoupment under the
Support Agreement. Amounts related to pre-commencement of operations are no longer eligible to be recouped by the Adviser. As noted above, under the terms of the Support Agreement, the last eligible expense
was recouped in the quarter ended September 30, 2023, and would have otherwise ceased to be eligible for recoupment as of March 31, 2024.

Comment 2: In Part II, Item 7 (“Management’s Discussion and Analysis of Financial Condition and Results of Operations),” on page 64,
disclosure states:

 “All organization and offering costs since inception through December 31, 2023 were funded by the Adviser
and we will have no responsibility for such costs until the Adviser submits such costs, or a portion thereof, for reimbursement, subject to a cap of 1.50% of our total commitments and provided further that the Adviser or its affiliates may not be
reimbursed for payment of excess organization and offering expenses that were incurred more than three years prior to the proposed reimbursement.”

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 Please discuss in correspondence whether the Company has any obligation to repay any organization and
offering costs since 2019. If so, please state the amounts. Additionally, discuss any accounting guidance under ASC 450 that supports the amounts recoverable by the Adviser, as more than three years have elapsed since commencement of operations.

 Response: The Company advises the Staff that it no longer has any obligation to reimburse the Adviser for organization and offering costs
since 2019. All such costs have either been reimbursed within the requisite three year period, or any unreimbursed amounts are otherwise no longer eligible for recoupment as more than three years have elapsed. Given that the Company does not have
any liability in respect of such unreimbursed amounts, and no such amounts paid by the Adviser were eligible for recoupment for a period in excess of three years, the analysis under ASC 450 is not implicated.

Comment 3: In Part II, Item 8 (“Consolidated Financial Statements and Supplementary Data),” on page
F-18, disclosure states:

 “Amounts incurred by the Adviser subsequent to the
Company’s commencement of operations were offset against amounts due from the Adviser in connection with the Expense Support Agreement, as described below. For the years ended December 31, 2023 and 2022, the Adviser paid operating expenses
on behalf of the Company in the amount of $1.4 million and $1.5 million, respectively.”

 A. The Staff notes that no
waiver amount is reflected on the face of the Statements of Operations, nor any amounts related to expenses/recoupments for the $1.4 million and $1.5 million indicated.

Response: The Company notes that the amounts described in the second sentence of the referenced disclosure are not related
to the Support Agreement, but instead reflect the administrative procedure whereby the Adviser pays for the Company’s expenses in the interest of operational convenience, and then seeks reimbursement. The Company notes that the amount of
$1.4 million (which is coincidentally the same amount described above in relation to the amount recouped by the Adviser under the Support Agreement in 2023), represents a different figure, which is comprised of audit fees, legal fees,
professional fees, directors’ fees and other expenses, as itemized in the Consolidated Statements of Operations; the Company will repay the Adviser for such amount, which is reflected in the “Due to affiliate” line item in the
Consolidated Statements of Assets and Liabilities.

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 B. Discuss in correspondence the accounting for these expenses. In addition, please
ensure that disclosure is revised in future reports to ensure understanding by shareholders and include a reconciliation of the amounts paid by the Adviser on behalf of the Company and any amounts remitted by the Company to the Adviser for all
arrangements.

 Response: The Company refers the Staff to its response to Comment 3(A) above. As noted, although the Company has
recorded a liability for the aggregate repayment obligation in the “Due to affiliate” line item in the Consolidated Statements of Assets and Liabilities in respect of amounts paid by the Adviser on the Company’s behalf, the individual
components of such aggregate amount have been properly reflected as itemized operating expenses of the Company in the Consolidated Statements of Operations (comprising audit fees, legal fees, professional fees, directors’ fees and other
expenses). As a result, the Company respectfully advises the Staff that the requested reconciliation is in effect already broken out and reflected in its Statement of Operations. In the interest of further clarity, in future periodic reports, the
Company will delete the first sentence in the referenced disclosure since it relates solely to historical repayments under the Support Agreement and is no longer relevant.

Comment 4: Part II, Item 8 (“Consolidated Financial Statements and Supplementary Data),” on page
F-19 disclosure states:

 “As of December 31, 2023, due to affiliate includes
amounts payable for administrative fee, operating expenses reimbursable and reimbursement payment.”

 Please ensure the amounts related to each
expense are disclosed separately in future financial statements, either in the notes to the financial statements or on the face of the Statements of Operations, as these are related party transactions requiring separate disclosure under US GAAP
and Regulation S-X.

 Response: The Company respectfully directs the Staff to its Consolidated
Statements of Operations, which separately identify the various components of Operating Expenses, including Administrative Fees and the various expenses that were paid by the Adviser on behalf of the Company for operational efficiency and are now
reimbursable to the Adviser, as further described in the Company’s response to Comment 3(A) above.

 Comment 5: Please confirm in
correspondence whether the various tests prescribed under Regulation S-X, Rules 3-09 and 4-08(g) have been performed as of
December 31, 2023 and confirm that additional disclosures under these rules is not necessary.

 Response: The Company advises the Staff
that in every reporting period, the Company first determines whether it had any “controlled” affiliates during such period (based on the presumption of control under the Investment Company Act of 1940, tied to ownership of more than 25% of
voting securities of a portfolio company), and for each such controlled affiliate, performs the

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required significance tests to determine if the financial statement and information requirements of Rules 3-09 and
4-08(g) of Regulation S-X were triggered. As stated on page F-20 of the Annual Report, the Company advises the Staff that
as of December 31, 2023, it did not have any controlled affiliates; accordingly, the Company has concluded that Rules 3-09 and 4-08(g) of Regulation S-X were not applicable.

 Comment 6: In Part II, Item 8 (“Consolidated Financial Statements and
Supplementary Data”) under Note 9 (Financial Highlights), footnotes 6, 7 and 8 appear to be incorrectly tagged to line-items in the table.

Response: The Company acknowledges the typographical error and will ensure that the referenced footnotes are correctly tagged to their respective

line-items in future periodic reports.

 Comment 7: In
Part II, Item 8 ( “Consolidated Financial Statements and Supplementary Data),” under Note. 9 (Financial Highlights), footnote 6 states:

“Ownership of equity investments may occur through a holding company.”

A. Please clarify what footnote 6 refers to and what is meant by holding company. Is it a consolidated wholly owned subsidiary, or is it
indirectly through an unconsolidated entity not wholly owned?

 Response: The referenced footnote refers to BCPL Sub Holdings
LLC, which is a wholly-owned, consolidated, taxable subsidiary formed by the Company in January 2020 that holds certain equity investments of the Company, as disclosed in the Annual Report in Item 7 and Note 1 to the financial statements.

B. Please ensure the footnote is expanded in future financial statements to clarify how these positions are held.

Response: The Company will expand the footnote in future financial statements as requested to clarify that the equity investment is held
through a wholly-owned, consolidated, taxable subsidiary.

 Comment 8: In Part II, Item 8 (“Consolidated Financial Statements and
Supplementary Data),” under the Consolidated Schedule of Investments for December 31, 2023, footnote 16 does not appear to refer to anything in the Schedule of Investments. Please confirm that footnote 16 was erroneously included from last
year after the position it refers to was eliminated. Please ensure the clarity o