Correspondence 0001213900-23-019598 from Pender Real Estate Credit Fund (CIK 0001929777)
Pender Real Estate Credit Fund (CIK 0001929777)
Date: March 13, 2023 · CIK: 0001929777 · Accession: 0001213900-23-019598
AI Filing Summary & Sentiment
File numbers found in text: 333-265070, 811-23806
Letter
Via EDGAR Transmission Securities and Exchange Commission Washington, D.C. 20549 Attention: Karen Rossotto Re: Pender Real Estate Credit Fund (the “Fund” or “Registrant”) File Nos.: 333-265070; 811-23806
Dear Ms. Rossotto:
The following responds to the additional comment provided via telephone on March 13, 2023, in connection with the SEC staff’s review of a registration statement (the “Registration Statement”) filed by the Registrant on Form N-2 under the Investment Company Act of 1940, as amended and Securities Act of 1933.
For your convenience, we have repeated the comment below, and the Fund’s response follows your comment. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Registration Statement, unless otherwise indicated.
1. Comment: What does "interest paid on commitment" mean in the Consolidated Schedule of Investments of the Predecessor Fund?
Response: The Fund respectfully notes that “interest paid on commitment” is not prepaid interest; it is the monthly interest due under the loan documents.
*****
We trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned at (215) 988-2959.
Sincerely,
/s/
Joshua B. Deringer
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CORRESP
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filename1.htm
Faegre
Drinker Biddle & Reath LLP
One
Logan Square, Suite 2000
Philadelphia,
Pennsylvania 19103
www.faegredrinker.com
March
13, 2023
Via
EDGAR Transmission
Securities
and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
Attention:
Karen Rossotto
Re: Pender Real
Estate Credit Fund (the “Fund” or “Registrant”)
File
Nos.: 333-265070; 811-23806
Dear
Ms. Rossotto:
The
following responds to the additional comment provided via telephone on March 13, 2023, in connection with the SEC staff’s review
of a registration statement (the “Registration Statement”) filed by the Registrant on Form N-2 under the Investment Company
Act of 1940, as amended and Securities Act of 1933.
For
your convenience, we have repeated the comment below, and the Fund’s response follows your comment. Capitalized terms not otherwise
defined herein shall have the meaning ascribed to them in the Registration Statement, unless otherwise indicated.
1. Comment:
What does "interest paid on commitment" mean in the Consolidated Schedule of
Investments of the Predecessor Fund?
Response:
The Fund respectfully notes that “interest paid on commitment” is not prepaid interest; it is the monthly interest due under
the loan documents.
*****
We
trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned
at (215) 988-2959.
Sincerely,
/s/
Joshua B. Deringer
Joshua
B. Deringer