SecProbe.io

CORRESP
1
filename1.htm

              1900 K Street, NW

                Washington, DC  20006-1110

              +1  202  261  3300  Main

              +1  202  261  3333  Fax

              www.dechert.com

                HARRY S. PANGAS

                harry.pangas@dechert.com

                +1 202 261 3466 Direct

                +1 202 261 3333 Fax

      January 23, 2024

      Via EDGAR

      Megan F. Miller, Staff Accountant

      Division of Investment Management

      Office of Disclosure and Review

      U.S. Securities and Exchange Commission

      100 F Street N.E.

      Washington, D.C. 20549

              RE:
              Barings Capital Investment Corporation (File No. 814-01348)

      Dear Ms. Miller:

      On behalf of Barings Capital Investment Corporation (the “Company”), set forth below are the Company’s responses to the follow-up comments provided
        verbally by the Staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to the Company’s legal counsel on December 13, 2023 with respect to the Staff’s review of the Company’s
        Annual Report on Form 10-K for the year ended December 31, 2022 (File No. 814-01348), filed with the SEC on February 23, 2023 (the “Form 10-K”). The Staff’s follow-up comments are set forth below and are followed by the Company’s responses.

            1.

              Comment: The Company supplementally advised the Staff in its response letter dated December 8, 2023 that it had disclosed its net realized and unrealized gains (losses) on investments in forward foreign currency contracts separately from any net realized and unrealized gains (losses) on investments in foreign currency transactions in

                the Company’s Consolidated Statements of Operations included in its Quarterly Report on Form 10-Q for the quarter ended September  30, 2023 (File No. 814-01348), filed with the SEC on November 9,
                2023 (the “Third Quarter Form 10-Q”), and will continue to do so in future SEC filings. Please provide an Accounting Standards Codification 250 analysis indicating if this was a change in accounting
                  principle or policy or an error and include a Staff Accounting Bulletin No. 99 materiality analysis.

      Response: The Company respectfully advises the Staff that the above-described financial statement presentation change constituted a financial
        statement reclassification and not a change in an accounting principle or an error for purposes of Accounting Standards Codification 250. In addition, the Company had previously disclosed its net realized and unrealized gains (losses) on
        investments in forward foreign currency contracts separately from its net realized and unrealized gains (losses) on investments in foreign currency transactions in the notes to its financial statements included in periodic reports filed prior to
        the Third Quarter Form 10-Q.  See “Note 6. Derivative Instruments” of the Company’s Notes to Consolidated Financial Statements in its Form 10-Q for the quarter ended June 30, 2023 (File No. 814-01348), filed with the SEC on August 9, 2023 and prior
        quarterly reports on Form 10-Q and the Form 10-K and prior annual reports on Form 10-K. The Company updated its Consolidated Statements of Operations in the Third Quarter 10-Q to comply with the requirements of Regulation S-X, 6-07.7(a), as the
        previously described presentation in the Form 10-K was not technically in alignment therewith. The Company will continue to disclose its net realized and unrealized gains (losses) on investments in forward foreign currency contracts separately from
        its net realized and unrealized gains (losses) on investments in foreign currency transactions in its Consolidated Statements of Operations in future SEC filings in accordance with Regulation S-X, 6-07.7(a).

                  Barings-Corporate

                  January 23, 2024

                    Page 2

            2.

              Comment: Please explain how the presentation of the Company’s Schedule of Investments is in accordance with Rule 12-12 of Regulation S-X or in correspondence state
                that the presentation does not align with Rule 12-12 of Regulation S-X.

      Response: The Company respectfully advises the Staff that it will include the industry composition and portfolio composition tables that are currently
        included in the Company’s Notes to Consolidated Financial Statements in the Form 10-K under the headings “Note 3. Investments—Portfolio Composition” (the “Portfolio Composition Table”) and “—Industry Composition” (the “Industry Composition Table”),
        respectively, in the footnotes to its Schedule of Investments in future SEC filings. The Company will also include a summary of the Company’s investment portfolio by industry composition as a percentage of net assets in the Industry Composition
        Table in future SEC filings.

      The Company respectfully advises the Staff that it believes including the Portfolio Composition Table and Industry Composition Table in the footnotes to the Schedule of Investments in future SEC
        filings will satisfy the regulatory intent behind the disclosure requirements contained in footnotes 2 and 5 of Rule 12-12 of Regulation S-X.

      *          *          *

      If you have any questions, please feel free to contact the undersigned by telephone at 202.261.3466 (or by email at harry.pangas@dechert.com) or Clay Douglas by telephone at
        202.261.3326 (or by email at clay.douglas@dechert.com).

              Sincerely,

                /s/ Harry S. Pangas

              Harry S. Pangas

            cc:
            Bryan High, Barings Capital Investment Corporation

              Matthew Freund, Barings Capital Investment Corporation

              Elizabeth Murray, Barings Capital Investment Corporation

              Ashlee Steinnerd, Barings Capital Investment Corporation

              Clay Douglas, Dechert LLP

                  Barings-Corporate