Correspondence 0001104659-23-071222 from Golub Capital Private Credit Fund (CIK 0001930087)
Golub Capital Private Credit Fund (CIK 0001930087)
Date: June 14, 2023 · CIK: 0001930087 · Accession: 0001104659-23-071222
AI Filing Summary & Sentiment
Letter
Via EDGAR Securities and Exchange Commission Division of Investment Management Attn: Bernard A. Nolan, Senior Counsel Re: Golub Capital Private Credit Fund Draft Registration Statement on Form N-2 CIK No. 0001930087
Dear Mr. Nolan:
On behalf of Golub Capital Private Credit Fund (the “Fund”), we transmit for filing the Fund’s response to a comment received via telephone from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on June 13, 2023, relating to the Fund’s letter responding to prior comments from the Staff, filed with the SEC on May 5, 2023 (the “Prior Response Letter”), in respect of the above-referenced Registration Statement on Form N-2 (the “Registration Statement”). The response and information described below are based upon information provided to us by the Fund.
1. We note your response to Comment 1 in the Prior Response Letter. Your response indicates that you might not immediately commence the offering of the Fund’s common shares registered pursuant to the Registration Statement (the “Common Shares”). Please confirm that, as required by paragraph (a)(1)(ix) of Rule 415 under the Securities Act of 1933, as amended (the “Rule”), you will commence the offering of the Fund’s Common Shares promptly following effectiveness and advise us what period of time might pass prior to you commencing the offering. In this regard, we note that waiting a period of weeks or months as you indicate would not be deemed prompt under the Rule.
Response: Without necessarily agreeing or disagreeing with the Staff’s legal analysis, the Fund confirms that it will commence offering the Fund’s Common Shares promptly following effectiveness of the Registration Statement in accordance with the Rule. In this regard, to the extent permissible by applicable law, including state securities laws, the Fund expects to start offering the Fund’s Common Shares as soon as practicable after effectiveness, which we currently expect to be within a few days after being declared effective.
Securities and Exchange Commission June 14, 2023
_________________
Please call me (202-636-5915) with any questions you may have regarding this filing or if you wish to discuss the above response.
Very
truly yours,
/s/
Nathan Briggs
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filename1.htm
Simpson
Thacher & Bartlett llp
900
G Street NW
Washington,
DC 20001
____________________
telephone:
+1-202-636-5500
facsimile:
+1-202-636-5502
Direct
Dial Number
202-636-5915
E-mail
Address
Nathan.Briggs@stblaw.com
June 14, 2023
Via EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Bernard A. Nolan, Senior Counsel
Re: Golub Capital Private Credit Fund
Draft Registration Statement on Form N-2
CIK No. 0001930087
Dear Mr. Nolan:
On behalf of Golub
Capital Private Credit Fund (the “Fund”), we transmit for filing the Fund’s response to a comment received via
telephone from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on June 13,
2023, relating to the Fund’s letter responding to prior comments from the Staff, filed with the SEC on May 5, 2023 (the
“Prior Response Letter”), in respect of the above-referenced Registration Statement on Form N-2 (the “Registration
Statement”). The response and information described below are based upon information provided to us by the Fund.
1. We note your response to Comment 1 in the Prior Response Letter. Your response indicates
that you might not immediately commence the offering of the Fund’s common shares registered pursuant to the Registration
Statement (the “Common Shares”). Please confirm that, as required by paragraph (a)(1)(ix) of Rule 415 under the
Securities Act of 1933, as amended (the “Rule”), you will commence the offering of the Fund’s Common Shares promptly following
effectiveness and advise us what period of time might pass prior to you commencing the offering. In this regard, we note that
waiting a period of weeks or months as you indicate would not be deemed prompt under the Rule.
Response: Without necessarily agreeing or
disagreeing with the Staff’s legal analysis, the Fund confirms that it will commence offering the Fund’s Common Shares promptly
following effectiveness of the Registration Statement in accordance with the Rule. In this regard, to the extent permissible by applicable
law, including state securities laws, the Fund expects to start offering the Fund’s Common Shares as soon as practicable after effectiveness,
which we currently expect to be within a few days after being declared effective.
Securities
and Exchange Commission
June
14, 2023
_________________
Please call me (202-636-5915) with any questions
you may have regarding this filing or if you wish to discuss the above response.
Very
truly yours,
/s/
Nathan Briggs
Nathan
Briggs
cc:
Keith O’Connell, Branch Chief
Michael J. Spratt, Assistant Director
Disclosure Review and Accounting Office
Joshua Levinson, Golub Capital Private Credit Fund
Daniel Colaizzi, Golub Capital Private Credit Fund
Rajib Chanda, Simpson Thacher & Bartlett LLP
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