Correspondence 0001193125-25-143733 from Carlyle AlpInvest Private Markets Fund (CIK 0001899610)
Carlyle AlpInvest Private Markets Fund (CIK 0001899610)
Date: June 20, 2025 · CIK: 0001899610 · Accession: 0001193125-25-143733
AI Filing Summary & Sentiment
File numbers found in text: 811-23805
Letter
VIA EDGAR Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Carlyle AlpInvest Private Markets Fund (the “Fund”) (File No. 811-23805)
Dear Mr. Fox:
Thank you for your oral comments provided on June 11, 2025, regarding your review of the Fund’s annual report to shareholders for the period ended March 31, 2025, which was filed with the Securities and Exchange Commission on Form N-CSR on June 2, 2025 (as amended on June 9, 2025). Your comments are summarized below, followed by the Fund’s response. Unless otherwise noted expressly, the staff’s comments may be addressed prospectively only.
* * *
1. Comment: Please define the term “Loss Recovery Account” in Note 4 under Related Party Transactions.
Response: The Fund confirms that it will include the requested disclosure in future shareholder reports.
2. Comment: Please indicate, by an appropriate symbol, each issue of securities whose value was determined using significant unobservable inputs. The staff notes there is a footnote regarding fair value, but most securities were valued as a practical expedient.
Response: The Fund confirms that it will make the requested change in future shareholder reports.
* * *
We hope the foregoing responses adequately address the staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (415) 315-6374.
Very truly yours,
/s/ Chelsea M. Childs
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CORRESP 1 filename1.htm Carlyle AlpInvest Private Markets Fund ROPES & GRAY LLP THREE EMBARCADERO CENTER SAN FRANCISCO, CA 94111 WWW.ROPESGRAY.COM Chelsea M. ChildsT +1 415 315 6374 Chelsea.Childs@ropesgray.com June 20, 2025 VIA EDGAR Mr. Jason Fox U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Carlyle AlpInvest Private Markets Fund (the “Fund”) (File No. 811-23805) Dear Mr. Fox: Thank you for your oral comments provided on June 11, 2025, regarding your review of the Fund’s annual report to shareholders for the period ended March 31, 2025, which was filed with the Securities and Exchange Commission on Form N-CSR on June 2, 2025 (as amended on June 9, 2025). Your comments are summarized below, followed by the Fund’s response. Unless otherwise noted expressly, the staff’s comments may be addressed prospectively only. * * * 1. Comment: Please define the term “Loss Recovery Account” in Note 4 under Related Party Transactions. Response: The Fund confirms that it will include the requested disclosure in future shareholder reports. 2. Comment: Please indicate, by an appropriate symbol, each issue of securities whose value was determined using significant unobservable inputs. The staff notes there is a footnote regarding fair value, but most securities were valued as a practical expedient. Response: The Fund confirms that it will make the requested change in future shareholder reports. * * * We hope the foregoing responses adequately address the staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (415) 315-6374. Very truly yours, /s/ Chelsea M. Childs Chelsea M. Childs, Esq. cc: Cameron Fairall, AlpInvest Private Equity Investment Management, LLC Jennifer Juste, Carlyle AlpInvest Private Markets Fund Michael G. Doherty, Ropes & Gray LLP Michelle Huynh, Ropes & Gray LLP -2-