Correspondence 0001193125-25-165429 from Goldman Sachs Private Middle Market Credit II LLC (CIK 0001772704)
Goldman Sachs Private Middle Market Credit II LLC (CIK 0001772704)
Date: July 25, 2025 · CIK: 0001772704 · Accession: 0001193125-25-165429
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 814-01307
Letter
Re: Goldman Sachs Private Middle Market Credit II LLC Annual Report on Form 10-K for the period ended December 31, 2024 File No. 814-01307 Ladies and Gentlemen: On behalf of Goldman Sachs Private Middle Market Credit II LLC (the “ Company ”), set forth below is the Company’s response to the comments of the staff (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ SEC ”) that you provided by telephone conversation on July 1, 2025, relating to the above-referenced Annual Report on Form 10-K. For the Staff’s convenience, the Staff’s verbal comments are set forth below, followed by the Company’s responses.
July 25, 2025 VIA EDGAR Mindy Rotter U.S. Securities and Exchange Commission Division of Investment Management 100 Pearl Street, Suite 20-100 New York, NY 10004-2616
1. Investment companies are required to disclose if there has been a change in a valuation approach and/or a valuation technique and the reason for making the change for its investments valued using Level 2 and Level 3 inputs. Please discuss in correspondence any changes that have occurred and if the disclosures and notes to the financial statements adequately addressed such changes. Response : The Company’s set of valuation approaches and/or valuation techniques for investments valued using Level 2 and Level 3 inputs was consistent throughout the periods presented in the Form 10-K, and therefore no additional disclosure was required.
2. Please confirm in correspondence that the Company’s investments remain consistent with its diversification for both RIC and tax purposes. Response : The Company confirms that its investments remain consistent with its status as a non-diversified investment company under the Investment Company Act and its status as a RIC for tax purposes.
3. The registrant is required to ensure that all financial data included in its filings is properly tagged using the standardized XBRL taxonomy. Please confirm in correspondence that going forward the standardized XBRL tags will be used. Response : The Company confirms that it will apply standardized XBRL tags to financial data going forward, to the extent applicable.
* * * * * * Should you have further questions, or require further information relating to the foregoing, please contact the undersigned at (212) 859-8689.
Very truly yours,
/s/ Joshua Wechsler
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CORRESP 1 filename1.htm CORRESP July 25, 2025 VIA EDGAR Mindy Rotter U.S. Securities and Exchange Commission Division of Investment Management 100 Pearl Street, Suite 20-100 New York, NY 10004-2616 Re: Goldman Sachs Private Middle Market Credit II LLC Annual Report on Form 10-K for the period ended December 31, 2024 File No. 814-01307 Ladies and Gentlemen: On behalf of Goldman Sachs Private Middle Market Credit II LLC (the “ Company ”), set forth below is the Company’s response to the comments of the staff (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ SEC ”) that you provided by telephone conversation on July 1, 2025, relating to the above-referenced Annual Report on Form 10-K. For the Staff’s convenience, the Staff’s verbal comments are set forth below, followed by the Company’s responses. 1. Investment companies are required to disclose if there has been a change in a valuation approach and/or a valuation technique and the reason for making the change for its investments valued using Level 2 and Level 3 inputs. Please discuss in correspondence any changes that have occurred and if the disclosures and notes to the financial statements adequately addressed such changes. Response : The Company’s set of valuation approaches and/or valuation techniques for investments valued using Level 2 and Level 3 inputs was consistent throughout the periods presented in the Form 10-K, and therefore no additional disclosure was required. 2. Please confirm in correspondence that the Company’s investments remain consistent with its diversification for both RIC and tax purposes. Response : The Company confirms that its investments remain consistent with its status as a non-diversified investment company under the Investment Company Act and its status as a RIC for tax purposes. 3. The registrant is required to ensure that all financial data included in its filings is properly tagged using the standardized XBRL taxonomy. Please confirm in correspondence that going forward the standardized XBRL tags will be used. Response : The Company confirms that it will apply standardized XBRL tags to financial data going forward, to the extent applicable. * * * * * * Should you have further questions, or require further information relating to the foregoing, please contact the undersigned at (212) 859-8689. Very truly yours, /s/ Joshua Wechsler Joshua Wechsler cc: Stanley Matuszewski (Goldman Sachs Private Middle Market Credit II LLC) Caroline Kraus (Goldman Sachs Private Middle Market Credit II LLC) Curtis Tate (Goldman Sachs Private Middle Market Credit II LLC) Thomas J. Friedmann (Dechert LLP) Darius I. Ravangard (Dechert LLP) 2