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CORRESP
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CORRESP

 Simpson Thacher & Bartlett llp

900 G STREET, NW

WASHINGTON, D.C. 20001

TELEPHONE:
+1-202-636-5500

FACSIMILE:
+1-202-636-5502

 Direct Dial Number

+1-202-636-5592

 E-mail Address

steven.grigoriou@stblaw.com

VIA EDGAR

November 22, 2024

 U.S. Securities and Exchange Commission

Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Apollo Debt Solutions BDC

Registration Statement on Form N-14

Ladies and Gentlemen:

 On November 22,
2024, Apollo Debt Solutions BDC (the “Company”) filed a Registration Statement on Form N-14 (the “Registration Statement”) with the Securities and Exchange Commission (the
“Commission”) in accordance with the Securities Act of 1933, as amended.

 The securities covered by the Registration Statement
will be issued in an exchange offer to be conducted by the Company. Attached is a letter from the Company indicating its reliance on the no-action letters issued to Exxon Capital Holdings Corporation (publicly
available May 13, 1988), Morgan Stanley & Co. Incorporated (publicly available June 5, 1991) and Shearman & Sterling (publicly available July 2, 1993).

Please do not hesitate to call David Blass at (202) 636-5863, Jonathan Pacheco at (202) 636-5876 or me at (202) 636-5592 with any questions you may have regarding this filing.

Very truly yours,

 /s/ Steven Grigoriou

cc:
 David Blass, Simpson Thacher & Bartlett LLP

Jonathan Pacheco, Simpson Thacher & Bartlett LLP

NEW YORK  BEIJING   HONG KONG   HOUSTON   LONDON   LOS ANGELES   PALO
ALTO   SÃO PAULO   TOKYO

 VIA EDGAR

 Securities
and Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

 Re: Apollo Debt Solutions BDC

 In
connection with the offer (the “Exchange Offer”) being made by Apollo Debt Solutions BDC (the “Company”) to issue 6.900% Notes due 2029 (the “6.900% Exchange Notes”) and 6.700% Notes due 2031 (the “6.700% Exchange
Notes” and, together with the 6.900% Exchange Notes, the “Exchange Notes”) in exchange for its outstanding 6.900% Notes due 2029 that were issued in transactions not requiring registration under the Securities Act of 1933, as amended
(the “1933 Act”) on March 21, 2024 and September 19, 2024 (the “6.900% Restricted Notes”) and the 6.700% Notes due 2031 that were issued in a transaction not requiring registration under the 1933 Act on July 29,
2024 (the “6.700% Restricted Notes” and, together with the 6.900% Restricted Notes, the “Restricted Notes”), pursuant to the prospectus contained in the Company’s Registration Statement on Form
N-14 filed with the Securities and Exchange Commission (the “Commission”) on November 22, 2024 and the related letter of transmittal, this letter confirms the following:

(1) The Company is registering the Exchange Offer in reliance upon the position of the Staff of the Commission set forth in the no-action letters issued to: (i) Exxon Capital Holdings Corporation (available May 13, 1988); (ii) Morgan Stanley & Co. Incorporated (available June 5, 1991); and
(iii) Shearman & Sterling (available July 2, 1993) (together, the “No-Action Letters”).

(2) The Company has not entered into any arrangement or understanding with any person to distribute any of the Exchange Notes to be issued
pursuant to the Exchange Offer in exchange for Restricted Notes, and, to the best of the Company’s information and belief, each person participating in the Exchange Offer is acquiring Exchange Notes in the ordinary course of its business, is
not participating in, and has no arrangement or understanding with any person to participate in, the distribution of any Exchange Notes to be received in the Exchange Offer, is not an “affiliate” of the Company within the meaning of Rule
405 under the 1933 Act, and did not purchase any Restricted Notes to be exchanged for Exchange Notes directly from the Company to resell pursuant to Rule 144A under the 1933 Act or another exemption under the 1933 Act. In addition, to the best of
the Company’s information and belief, each person participating in the Exchange Offer who is not a broker-dealer is not engaged in and does not intend to engage in a distribution of any Exchange Notes. In this regard, the Company will make each
person participating in the Exchange Offer aware that if such person is participating in the Exchange Offer with the intention of participating in any manner in a distribution of any Exchange Notes, such person (i) could not rely on the Staff
position set forth in the No-Action Letters or interpretative letters to similar effect and (ii) must be identified as an underwriter in the prospectus and must comply with the registration and prospectus
delivery requirements of the 1933 Act in connection with any secondary resale transaction, unless an exemption from registration is otherwise available. The Company acknowledges that such a secondary resale for the purpose of distributing Exchange
Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 of Regulation S-K.

(3) Neither the Company nor any of its affiliates have entered into any arrangement or understanding with any broker-dealer to distribute the
Exchange Notes.

 (4) The Company will include in the letter of transmittal to be executed by an exchange offeree in order to participate
in the Exchange Offer a provision to the effect that if the exchange offeree is a broker-dealer holding Restricted Notes acquired for its own account as a result of market-making activities or other trading activities, such broker-dealer will
acknowledge that it will deliver a prospectus meeting the requirements of the 1933 Act in connection with any resale of Exchange Notes received in respect of such Restricted Notes pursuant to the Exchange Offer.

Sincerely,

Apollo Debt Solutions BDC

By:

 /s/ Kristin Hester

 Kristin Hester

 Chief Legal Officer and
Secretary