SEC Company Response from Partners Group Lending Fund, LLC (CIK 0001938649) — Dec 19, 2025
Partners Group Lending Fund, LLC (CIK 0001938649)
Date: Dec. 19, 2025 · CIK: 0001938649 · Accession: 0001398344-25-022749
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File numbers found in text: 000-56792
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CORRESP
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1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
Darius I. Ravangard
darius.ravangard@dechert.com
+1 202 261 3345 Direct
December 19, 2025
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-0504
Attn: Jeffrey W. Long
Re: Partners Group Lending Fund, LLC
Registration Statement on Form 10 (File No. 000-56792)
Dear Mr. Long:
On behalf of Partners Group Lending
Fund, LLC, a Delaware limited liability company (the “Fund”), we hereby respond to the accounting comments you provided
to me and Jessica Warshaw of Dechert LLP during a telephonic discussion on December 10, 2025 with respect to your review of the Fund’s
registration statement of Form 10 (the “Registration Statement”), filed with the U.S. Securities and Exchange Commission
(the “SEC”) on October 21, 2025. The Fund has considered your comments and has authorized us, on its behalf, to make
the responses discussed below.
Set forth below are the comments
of the SEC staff (the “Staff”) along with our responses thereto. To the extent not otherwise defined herein, capitalized
terms have the meanings attributed to such terms in the Registration Statement.
1. Comment: In the “Incentive Fee” section
on page 19 of the Registration Statement, please consider revising the disclosure to discuss only the Fund’s current investment
advisory agreement (the Amended and Restated Investment Advisory Agreement).
Response: The Fund advises
the Staff that it has revised such disclosure in the Fund’s amended Registration Statement filed herewith.
December 19, 2025
Page 2
2. Comment: The Staff notes that the Registration Statement
includes financial statements for the period ended June 30, 2025. Please update the Registration Statement to include more recent financial
statements.
Response: The Fund advises
the Staff that it has revised such disclosure in the Fund’s amended Registration Statement filed herewith.
* * *
Should you have any questions
regarding this letter, please contact me at (202) 261-3345 or Darius.Ravangard@dechert.com.
Sincerely,
/s/ Darius I. Ravangard
Darius I. Ravangard
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