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 VIA edgar
 December 4, 2025
 Securities and Exchange Commission
 Division of Investment Management
 Disclosure Review and Accounting Office
 100 F Street, N.E.
 Washington, D.C. 20549
 Attn: Lauren Hamilton
 Re:      Blackstone Secured Lending Fund (File No. 814 -01299 ) Annual Report on Form 10 -K for the year ended December 31, 2023
 Dear Ms. Hamilton:
 On behalf of Blackstone Secured Lending Fund (the “Fund”), we herewith transmit the Fund’s responses to the telephonic comments provided by you on behalf of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on October 1, 2024 and November 7, 2024, the supplemental comments provided on January 10, 2025 (the “January Supplemental Comments”), the supplemental comments provided on April 16, 2025 (the “April Supplemental Comments”) and the supplemental comment provided on August 5, 2025 regarding the Fund’s Annual Report on Form 10 -K for the year ended December 31, 2023, filed with the Commission on February 28, 2024 (the “Annual Report”). 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 Fund. The Fund’s responses 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.
 1.        The Staff notes that the Fund filed an automatic shelf registration statement on July 11, 2024, which included information from the Fund’s Annual Report. Please supplementally explain why the information contained in the Quarterly Report on Form 10 -Q for the quarter ended March 31, 2024, filed with the Commission on May 8, 2024, was not included in the automatic shelf registration statement filed on July 11, 2024.
 Response : The Fund respectfully notes that it did not file an automatic shelf registration statement on July 11, 2024. Rather, it filed its annual report to shareholders as an “ARS” submission in connection with its proxy statement related to its annual meeting of shareholders, which was also filed on July 11, 2024. Pursuant to Rule 14a -3 under the Securities Exchange Act of 1934, as amended, the Fund was required to deliver its annual report to shareholders in connection with the aforementioned proxy statement, and to furnish such report on EDGAR (which furnishing is also required by Rule 101 of Regulation S -T ). Submission of the Annual Report satisfied the annual report requirements of Rule 14a -3 , which does not require inclusion of the Fund’s most recent quarterly report. Separately, the Fund filed an automatic shelf registration statement on Form N -2ASR on July 26, 2022, and such registration statement forward incorporates by reference future filings by the Fund (including annual reports on Form 10 -K and quarterly reports on Form 10 -Q ).

 Ms. Lauren Hamilton

 December 4, 2025

 Item 7
 2.        The disclosure under “Net Realized Gain (Loss)” on page 124 of the Annual Report states that “[f]or the year ended December 31, 2023, we generated realized losses on investments of $23.9 million partially offset by realized gains on investments of $17.7 million, primarily from full or partial sales or restructures of our debt investments.” Please supplementally confirm the amount of such restructures and whether such disclosure is referring to debt extinguishment or debt restructuring.
 Response : The Fund supplementally confirms that the disclosure appropriately refers to debt restructuring and that approximately $6.7 million of realized losses were a result of the restructure of debt investments.
 Schedule of Investments
 3.        In the Schedule of Investments, please include all disclosures required for restricted securities in compliance with Rule 12 -12 of Regulation  S -X .
 Response : The Fund hereby confirms that it will make the requested change in future filings.
 4.        In the Schedule of Investments, the Staff notes various positions where fair value equals par. Please supplementally explain how this is in line with the Fund’s valuation policy and procedures.
 Response : The Fund employs a robust process to estimate the fair value of its investments at the end of each financial quarter. Please refer to the following excerpt from Part II, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations — Critical Accounting Estimates:
 Fair value is based on observable market prices or parameters or derived from such prices or parameters when such quotations are readily available. In accordance with Rule 2a -5 under the 1940 Act, a market quotation is “readily available” only when it is a quoted price (unadjusted) in active markets for identical instruments that a fund can access at the measurement date, provided that such a quotation is not considered to be readily available if it is not reliable. The Company utilizes mid -market pricing (i.e., mid -point of average bid and ask prices) to value these investments. These market quotations are obtained from independent pricing services, if available; otherwise generally from at least two principal market makers or primary market dealers. To assess the continuing appropriateness of pricing sources and methodologies, the Adviser regularly performs price verification procedures and issues challenges, as necessary, to independent pricing services or brokers, and any differences are reviewed in accordance with the valuation procedures. The Adviser does not adjust the prices unless it has a reason to believe market quotations are not reflective of the fair value of an investment. Examples of events that would cause market quotations to not reflect fair value could include cases when a security trades infrequently or not at all, causing a quoted purchase or sale price to become stale, or in the event of a “fire sale” by a distressed seller. All price overrides require approval from the Board.…Where prices or inputs are not available or, in the judgment of the Board are not reliable, valuation techniques based on the facts and circumstances of the particular investment will be utilized. Securities that are not publicly traded or for which market prices are not readily available are valued at fair value as determined in good faith by the Board, based on, among other things, the input of the Adviser, the Audit Committee of the Board (the “Audit Committee”) and independent valuation firms engaged on the recommendation of the Adviser and at the direction of the Board.
 The Fund notes that in following its valuation policies and procedures, as outlined above, 100% of par may be the best estimate of the fair value of a specific investment.

 2

 Ms. Lauren Hamilton

 December 4, 2025

 Notes to Consolidated Financial Statements
 5.        The Staff notes the inclusion of “Option pricing model” and “Expected volatility” under the columns labeled “Valuation Technique” and “Unobservable Input”, respectively, in the tables on page 193 under “Note 5. Fair Value Measurements”. The Staff further notes that the narrative description below such tables does not reference these items. The Staff notes that the narrative description of the uncertainty of the fair value measurement that would result from using unobservable inputs shall include the unobservable inputs disclosed when complying with the Accounting Standards Codification Topic 820, “Fair Value Measurement,” paragraph 820 -10-50-2 and its subsection (bbb) issued by the Financial Accounting Standards Board. Please revise accordingly.
 Response : The Fund hereby confirms that it will make the requested change in future filings.
 6.        Disclosure in “Note 3 — Agreements and Related Party Transactions — Administration Agreement” on pages 187 – 188 states, “The Administrator has elected to forgo any reimbursement for rent and other occupancy costs for the years ended December 31, 2023, 2022 and 2021.” Disclosure in “Item 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations — Key Components of Our Results of Operations — Expenses” on page 119 states, “However, the Administrator may seek reimbursement for such costs in future periods.” Please supplementally confirm if the referenced costs are included in the Statement of Operations and, if so, which line item they are included in, the amount of such costs and if there is any carry forward recoupment and the related amounts of such recoupment.
 Response : The Fund supplementally confirms that the referenced costs are not included in the Statement of Operations. While rent and other occupancy costs are expenses that are chargeable to the Fund pursuant to the Administration Agreement, the Administrator has historically elected not to charge rent and other occupancy costs to the Fund. Additionally, because the Administrator has simply chosen not to charge these costs to the Fund in the past, it has not undertaken to calculate the amount of rent and other occupancy costs allocable to the Fund. Therefore, there is no basis for seeking recoupment of these historical costs, and the Administrator will not seek recoupment of these historical costs. The Fund supplementally clarifies that the statement, “[T]he Administrator may seek reimbursement for such costs in future periods,” reflects only that the Administrator may in the future determine to establish an allocation methodology for rent and other occupancy costs and charge the Fund its allocable share in future periods.
 7.        Please disclose the average borrowing and interest rates for each financing agreement or arrangement discussed under “Note 6. Borrowings” in accordance with Rule 6 -04 .13 of Regulation  S -X .
 Response : Rule 6 -04 .13(a) requires that an issuer separately state certain amounts payable to certain categories of lenders within one year and after one year. Rule 6 -04 .13(b) requires, in relevant part, that an issuer provide in a note to the financial statements: (i) for unused lines of credit or short -term financings, the amount and terms (if significant) and the weighted average interest rate on borrowings outstanding, and (ii) for unused commitments for long -term financing arrangements, the amount and terms (if significant). The Fund respectfully notes that it believes that its existing disclosure in its notes to its financial statements, including, without limitation, the disclosure on page 200 of the Annual Report, complies with the requirements of Rule 6 -04 .13.
 8.        In future filings, in “Note 11. Financial Highlights and Senior Securities,” please ensure that the market value per share is presented in addition to the per share asset value in accordance with Form N -2 Item 4.1(f).
 Response : The Fund hereby confirms that it will make the requested change in future filings.

 3

 Ms. Lauren Hamilton

 December 4 , 2025

 January Supplemental Comments
 9.        With respect to comment 6 and your draft response thereto:
 a.        Please clarify the time period for which the Administrator can seek reimbursement. Can the Administrator seek reimbursement in the future for prior period costs or is it only for costs incurred in future periods?
 Response : The Fund respectfully notes that it and the Administrator interpret the Administration Agreement to provide that, if the Administrator wishes to be reimbursed for expenses incurred in a given fiscal period, then it must seek such reimbursement by indicating to the Fund that it intends to seek reimbursement before the Fund’s financial statements are issued for the preceding fiscal period and invoicing the Fund in a timely manner. If the Administrator has not indicated an intention to seek reimbursement for a particular expense incurred during a fiscal period before the Fund’s financial statements are issued for that fiscal period, then the Fund and the Administrator take the view that the Administrator has waived its right to be reimbursed for those expenses pursuant to the last paragraph of Section 4 of the Administration Agreement.
 b.        The draft response seems to indicate that the disclosure is meant to convey something different from what is stated: stating that the Administrator may seek reimbursement implies costs previously incurred. Does the Administration Agreement define reimbursement or recoupment to only include costs in the future? Please confirm whether the disclosure is accurate and, if not, please provide the planned updated disclosure to clarify what is meant.
 Response : Please see the response to comment 9.a above. Furthermore, the Administrator cannot seek reimbursement for expenses for which the Administrator has previously waived the right to be reimbursed. The Administrator also cannot seek reimbursement for expenses that were incurred by the Administrator in a prior fiscal period, because, as noted in the response to comment 9.a above, the Administrator is deemed to have waived its right to be reimbursed for those expenses if it has not indicated to the Fund that it intends to seek reimbursement before the Fund’s financial statements are issued for that fiscal period.
 The Fund will revise its disclosure in subsequent periodic reports to clarify what is meant as follows:
 From time to time, the Adviser or the Administrator may defer or waive fees and/or rights to be reimbursed for expenses. The . Pursuant to the Administration Agreement, the Fund’s allocable portion of the Administrator’s rent and other occupancy costs are expenses of the Fund. However, the Administrator has elected to forgo not historically, and does not currently, calculate the amount of rent and other occupancy costs allocable to the Fund and has not indicated an intention to seek reimbursement from the Fund for such costs. Thus, the Fund and the Administrator treat any such right to any reimbursement for rent and other occupancy costs for prior periods as having been waived pursuant to the terms of the Administration Agreement, including for the years ended December 31, 202X, 202X and 202X.  Additionally, since the Fund and the Administrator treat any such right to reimbursement for rent and occupancy costs as having been waived pursuant to the terms of the Administration Agreement, the Administrator cannot recoup any such expenses. However , in future periods , the Administrator may choose to establish an allocation methodology to calculate these costs and seek reimbursement from the Fund, in which case the Fund will accrue and reimburse the Administrator for such costs for that period s .
 c.        It appears the basis for not recording these expenses is rooted in the fact that the Administrator has not historically elected to charge the Fund. However, please confirm to the Staff whether, if elected, the Administrator would be legally allowed based on the Administration Agreement to charge these costs to the Fund, including costs incurred in arrears.
 Response : As noted in response to comment 9.b above, the Fund and the Administrator interpret the Administration Agreement to preclude the Administrator from recouping any expenses that the Administrator has previously waived.

 4

 Ms. Lauren Hamilton

 December 4 , 2025

 i.         Is there something about the Administration Agreement that would indicate that past behavior (i.e., not charging historically) would limit the Administrator’s rights to pursue reimbursement under the Administration Agreement?
 Response : As noted in response to comment 9.a above, the Fund and the Administrator interpret the Administration Agreement to limit the Administrator’s ability to seek reimbursement to expenses incurred by the Administrator for which it has not previously waived reimbursement. If the Administrator has not indicated to the Fund that it intends to seek reimbursement from the Fund for a particular expense incurred during a fiscal period before the Fund’s financial