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Faegre
Drinker Biddle & Reath LLP

1177
Avenue of the Americas, 41st Floor

New
York, New York 10036

Phone:
(212) 248-3140

Fax:
(212) 248-3141

www.faegredrinker.com

September 19,
2025

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Ken Ellington

 Re: FlowStone
                                            Opportunity Fund (the “Fund” or the “Registrant) (File Nos.: 811-23352;
                                            333-281060)

Dear
Mr. Ellington,

This
letter responds to the Staff’s accounting comments provided via telephone on August 22, 2025, relating to the Fund’s
March 31, 2025 annual shareholder report (the “Annual Report”), filed with the U.S. Securities and Exchange Commission
on Form N-CSR on June 6, 2025. For your convenience, we have repeated each comment below in bold, and our responses follow
your comments. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Fund's Annual Report, unless
otherwise indicated. All disclosure changes will be reflected in the Fund’s future shareholder reports.

 1. Comment:
                                            In the footnote to the Consolidated Schedule of Investments that identifies level 3 investments,
                                            please disclose that the value was determined using significant unobservable inputs, as required
                                            by Article 12-12, Footnote 9, of Regulation S-X.

Response:
The Registrant confirms that it will make the requested change in future financial statements.

 2. Comment:
                                            The cost for each restricted security held by the Fund is currently disclosed in a single
                                            footnote to the Consolidated Schedule of Investments as block text, separated only by commas,
                                            without direct linkage to the individual security to which the cost is related. This presentation
                                            may be confusing for shareholders. Please include the cost amount in a separate column in
                                            the Consolidated Schedule of Investments in the same line as the corresponding investment.
                                            See AICPA Investment Company Expert Panel Minutes dated July 15 through July 16,
                                            2024.

Response:
The Registrant confirms that it will make the requested changes in future financial statements.

 3. Comment:
                                            Please disclose the reasons for the transfers into or out of level 3 of the fair value hierarchy
                                            during the period. See ASC 820-10-50-2(c)(3).

Response:
The Registrant confirms that it will make the requested changes in future financial statements.

 4. Comment:
                                            Please disclose the average dollar amount of borrowings as required by Article 6-07(3) of
                                            Regulation S-X.

Response:
The Registrant confirms that it will make the requested changes in future financial statements.

 5. Comment:
                                            The staff notes that the Fund does not list each unfunded commitment separately by portfolio
                                            company or borrower in either the Consolidated Schedule of Investments or in a schedule included
                                            within the Notes to the Consolidated Financial Statements. Please include these disclosures
                                            in future financial statements. See AICPA Investment Company Expert Panel Minutes dated January 2006.

Response:
The Registrant confirms that it will make the requested changes in future financial statements.

 6. Comment:
                                            Item 4(e)2 of Form N-CSR discloses that all of the services described in paragraphs
                                            (b) through (d) of Item 4 were approved by the Audit Committee. This paragraph
                                            describes situations where the pre-approval requirement was waived, not when approval was
                                            obtained. Please confirm that this disclosure is accurate.

Response:
The Registrant confirms that all of the services described in paragraphs (b) through (d) of Item 4 were pre-approved by the
Audit Committee. Therefore, none of the services described in paragraphs (b) through (d) of Item 4 were approved by the Audit
Committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X during the fiscal year ended March 31, 2025.

The
Registrant further confirms that it will revise the statement included under Item 4(e)2 in its future Form N-CSR to reflect the
percentage of services described in each of paragraphs (b) through (d) of this Item that were approved by the audit committee
pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.

*****

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We
trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned
at (212) 248-3298 or, in my absence, to Joshua Deringer at (215) 988-2959.

    Sincerely,

    /s/ Joshua Lindauer

    Joshua Lindauer

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