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CORRESP
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    April 24, 2024

Kimberly A. Browning

Thankam Varghese

Michael Spratt

Kenneth Ellington

Office of Finance

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

      Re: Kayne
                                            Anderson BDC, Inc.

                                            Registration Statement on Form N-2

                                            CIK No. 0001747172

                                            File No. 333-278414

Dear Kimberly A. Browning, Thankam Varghese, Michael
Spratt and Kenneth Ellington:

On behalf of Kayne Anderson
BDC, Inc., a Delaware corporation (the “Company”), we submit to the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) this letter setting forth the Company’s responses to the
oral comments given on April 16, 2024 and April 23, 2024 by Kimberly A. Browning, regarding the above-referenced Registration Statement
on Form N-2 submitted to the Commission on April 1, 2024.

For
the Staff’s convenience, we have repeated below each of the Staff’s comments in italics, and have followed such comment with
the Company’s response. We have restated the substance of those comments to the best of our understanding. Concurrently with the
transmission of this letter, we are filing the Company’s first amendment to the Registration Statement on Form N-2 with the Commission
through EDGAR (the “Amendment No. 1”), which reflects the Company’s responses to the comments received by the Staff
and certain other updated information. For your convenience, we will send to you a marked copy of Amendment No. 1 showing changes made.
Unless otherwise specified, page references in the text of this response letter correspond to the page numbers in Amendment No. 1. All
capitalized terms not otherwise defined herein shall have the meaning set forth in Amendment No. 1. The Registrant acknowledges the Staff’s
standard disclaimer that the Registrant remains responsible for its disclosure in Amendment No. 1.

Registration Statement on Form N-2 submitted
on April 1, 2024

General Comments

 1. In connection with the Company and/or its Advisor entering into side
letters with Company investors, please disclose the following in the Registration Statement:

“The
Company and/or its Advisor (on behalf of the Company and itself) have entered, or may enter, into agreements, known as “side letters,”
with Company shareholders. As a result of such letters, certain Company shareholders may be provided with certain terms that other Company
shareholders will not receive. None of these side letters have, or will have, the effect of creating different investment terms in the
Company and primarily, or will primarily, address administrative, tax and other operational matters. The Company represents that neither
the Company and/or the Advisor have entered, or will enter, into side letters with Company shareholders related to their investment in
the Company that contravene applicable law, including the Investment Company Act of 1940 and the Investment Advisors Act of 1940.”

Response:
The Company acknowledges the Staff’s comment and has included the requested disclosure on page 90 of Amendment No. 1.

April 24, 2024

Page 2

 2. Please confirm supplementally to the Staff whether the Company has
received a no objections letter from FINRA and disclose the date of such letter.

Response:
The Company confirms to the Staff it received the FINRA no objections letter which is dated April 3, 2024.

 3. With respect to dilution, will any existing shareholders receive
some accretion in NAV as a result of the public offering? Please address this in the context of the no action letter issued in response
to an inquiry from Big Apple Capital Corporation that is publicly available May 6, 1982. Confirm that the price at which shares were issued
prior to the public offering was consistent with Section 23(a)(1) of the 1940 Act.

Response:
The Company respectfully acknowledges the Staff’s comment.

The
Company respectfully notes that the scenario addressed in Big Apple Capital Corp., SEC Staff No-Action Letter (May 6, 1982), is distinguishable
from the Company’s present situation. As noted in Big Apple Capital Corp., the Commission took the position in Investment Company
Act Release No. 40-3187 (Feb. 8, 1961) (the “Release”) that Section 23(a)(1) of the 1940 Act prohibits promoters of an investment
company from purchasing common stock of their company at one price per share at the company’s organization in contemplation of the
investment company’s making a public offering of common stock at an increased price per share, and in Big Apple Capital Corp. the
Staff confirmed that that same principle applied to a business development company.

In
contrast to Big Apple Capital Corp., the existing investors in the Company (namely, private institutional investors) have been in place
for a period of years, allowing the Company to engage in substantial investment operations. The investors in the Company’s initial
public offering are not investing in an entity with no assets or nominal assets, but rather in an existing business with substantial investment
operations and a net asset value. In this regard, the Company’s situation is more akin to that described in Enervest, Inc., SEC
Staff No-Action Letter (January 19, 1981). In Enervest, the Staff stated that it would not recommend an enforcement action if a closed-end
investment company offered its shares to the public at a price in excess of its net asset value. In Enervest, the initial investors had
invested over a period of three years. By the time it sought to raise money in a public offering at a price in excess of net asset value,
Enervest had a substantial operating history. As noted in Enervest, it is the intent of the Release “to stem attempts to obtain
promoters’ profits in situations involving newly formed companies. The Release is not intended to cover companies with substantial
operating histories.” The Company has already engaged in substantial investment operations.

Further,
the Company’s prior private placement of its shares of common stock was not for services as prohibited by Section 23(a)(1). Those
investors all purchased shares for cash. In addition, all prior issuances of shares were done at a price of then-current NAV per share,
and the Company intends to follow a similar methodology in determining the per-share for the issuance of shares in this offering. The
Company does not believe that any existing shareholders will receive accretion in NAV as a result of the public offering (as the Company
will be required the bear the expenses of the offering and sales load payable to the underwriters).

April 24, 2024

Page 3

 4. Please confirm supplementally to the Staff that the underwriters
can only purchase additional shares at the initial public offering price (less sales load) from the Company (i.e., no such shares are
being offered by legacy shareholders).

Response:
The Company acknowledges the Staff’s comment and confirms to the Staff that the underwriters can only purchase additional shares
at the initial public offering price (less sales load) from the Company and no such shares are being offered to the underwriters by legacy
shareholders.

 5. Please confirm to the Staff whether the description in the paragraph
immediately after the price to public table refers to the underwriters’ overallotment option described elsewhere in the Registration
Statement and if so, harmonize the terminology throughout with respect to the overallotment option.

Response:
The Company acknowledges the Staff’s comment and confirms to the Staff that the underwriters’ option to purchase additional
shares of common stock refers to the underwriters’ “overallotment option.” The Company has harmonized the disclosure
on the cover page and on pages 5, 14, 54, 65, 66, 152 and 154 of Amendment No. 1 to include references to the underwriters’
overallotment option.

 6. Please confirm supplementally to the Staff that terms such as “Joint
Lead Book Running Managers” and similar terms refer to the underwriters.

Response:
The Company respectfully acknowledges the Staff’s comment and supplementally confirms to the Staff that the terms “joint lead
book running managers,” “joint book running managers” and “co-managers” disclosed on the cover page refer
to the underwriters. As previously noted in the Company’s response letter dated February 2, 2024, each underwriter listed on the
cover page is either a joint lead book running manager, a book running manager or a co-manager. The term “joint lead book running
manager” refers to the lead managing underwriters, “joint book running managers” refers to managing underwriters and
“co-managers” refers to the co-underwriters.

 7. With respect to prior comment 3, please update the disclosure with
respect to the private offerings to indicate the date on which the final closing occurred. Please also update the heading of “private
offerings” to singular. Please supplementally confirm to the Staff that private offering is not conditioned on the public offering.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on pages 4, 11, 68, 73 and 90 of Amendment
No. 1 to indicate the private offering closed (and no subscription obligations on the part of existing stockholders) on April 2, 2024
and to update the disclosure regarding the completion of the Company’s pre-initial public offering capital raise private placement.
The Company has updated the heading to “private offering” on pages 3, 11 and 89 of Amendment No. 1 in accordance with
the Staff’s comment. The Company confirms supplementally to the Staff that the private offering is separate from and not conditioned
on the offering to which the Registration Statement relates.

 8. With respect to prior comment 3 and prior comment 8 from the Company’s
response letter dated April 5, 2024, please address the prior comment regarding the satisfaction of Rule 152(b).

Response:
The Company respectfully acknowledges the Staff’s comment. For purposes of the safe harbor of Rule 152(b)(1), the Company notes
that for purposes of Rule 152(a)(1) to which that paragraph refers, that none of the investors in the private offering invested on the
basis of any general solicitation. These investors were solicited either based on existing investor relationships of the Advisor to the
Company or were management personnel of the Advisor and its affiliates. Further, by using Rule 152(d)(1) as a guideline, the termination
of that private offering occurred upon obtaining binding subscription agreements from those private investors, the last of which was executed
on December 5, 2023, which was well before even the public filing of the Registration Statement on Form N-2 (and more than 30 days) was
made and any public offering would be commenced. Accordingly, the Company believes it complied with the safe harbor requirements of Rule
152(b)(1).

April 24, 2024

Page 4

 9. Please confirm supplementally to the Staff that nothing has materially
changed since the Company responded to the Staff’s comments in connection with its DRS filings with respect to the Company’s
use of wholly owned subsidiaries.

Response:
The Company acknowledges the Staff’s comment and confirms that nothing has materially changed since the Company responded to the
Staff’s comments in connection with its DRS filings with respect to the Company’s use of wholly owned subsidiaries.

Prospectus Summary —Investment
Advisory Agreement (page 5)

 10. Please enhance the disclosure regarding the base management fee and
income incentive fee in the last paragraph under this heading to make it more prominent for investors (e.g., by bolding or underscoring
the text).

Response:
The Company acknowledges the Staff’s comment and has bolded the disclosure regarding the base management fee and income incentive
fee on page 6 of Amendment No. 1 to make it more prominent for investors.

 11. With respect to the statement that “the Advisor has implemented
a waiver of the base management fee,” please revise the text to reflect that the Advisor has entered into an agreement for a contractual
waiver and harmonize disclosure throughout to refer to the contractual nature of such waiver.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on pages 6, 17 and 119 of Amendment No. 1 to state
that the Advisor has entered into an agreement for the contractual waiver of the base management fee and to harmonize the disclosure accordingly.

Prospectus Summary—Recent Developments—Declared
Dividends (page 10)

 12. Please revise the disclosure for clarity and accuracy to reflect
that the dividends were paid in respect of common shares.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure under “Declared Dividends” to clarify that
such distributions paid were in respect of common shares.

 13. Please clarify the timing of the dividend referenced in the second
paragraph under this heading. Please also clarify whether investors in this offering will be entitled to receive the dividend. Please
also clarify each distribution’s source of payment (e.g., will the Company use offering proceeds, post-offering earnings including
interest and capital gains generated by the investment portfolio). Please also address the fact that there is no assurance that the Company
will have any earnings post-offering.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure under this heading to clarify that the Company paid
a dividend on April 17, 2024 to stockholders of record on March 29, 2024, which represents the Company’s regular quarterly distribution.
In addition, the Company intends to pay an additional dividend on July 15, 2024 to stockholders of record on June 28, 2024 and special
dividends to stockholders of record (i) 195 days following the consummation of the offering, (ii) 285 days following the consummation
of the offering and (iii) 380 days following the consummation of the offering; provided that such special dividends shall only
be payable if this offering has been consummated on or before May 13, 2024.

April 24, 2024

Page 5

Investors
in this offering are intended to be entitled to receive the additional dividend payable on July 15, 2024 and the special dividends. To
the extent the public offering is not consummated on or before May 13, 2024, the Company expects that the Board would declare a similar
set of special dividends with updated dates. With respect to the source of payment, such additional dividends will be paid out of net
investment income earned during the quarter that the initial public offering is consummated and thereafter and will not constitute a return
of capital (which may include some net investment income earned during the quarter prior to the consummation of this offering). The Company
has also added a statement under this heading and on page 63 of Amendment No. 1 regarding the fact that there can be no assurance that
the Company will have any earnings post-offering in accordance with the Staff’s comment.

 14. Please explain in a supplemental response to the Staff whether either
distribution mentioned is contingent on the consummation of the initial public offering. If so, please explain whether either constitutes
a return of capital and if so, why the term dividend is being used (i.e., does either constitute the purchase of a dividend).

Response:
The Company acknowledges the Staff’s comment and confirms that the special dividends shall only be payable if the initial public
offering has been consummated on or before May 13, 2024. However, as noted in the response to Comment 13, to the extent the public offering
is not consummated on or before May 13, 2024, the Company expects that the Board would declare a similar set of special dividends w