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March 9, 2023
Boris Kogut
Director and Chief Executive Officer
Golden Credit Card Limited Partnership
c/o Golden Credit Card GP Inc.
200 Bay Street, 12th Floor
Royal Bank Plaza, South Tower
Toronto, Ontario M5J 2J5
Re:Golden Credit Card Limited Partnership
Golden Credit Card Trust
Registration Statement on Form SF-3
Filed February 10, 2023
File Nos. 333-269709 and 333-269709-01
Dear Boris Kogut:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form SF-3
General
1.Please file your remaining exhibits, including the underlying transaction agreements, with
your next amendment.  Refer to Item 1100(f) of Regulation AB and Instruction 1 to Item
601 of Regulation S-K.  Note that we may have additional comments on your registration
statement following our review of the transaction agreements.

 FirstName LastNameBoris Kogut
 Comapany NameGolden Credit Card Limited Partnership
 March 9, 2023 Page 2
 FirstName LastName
Boris Kogut
Golden Credit Card Limited Partnership
March 9, 2023
Page 2
2.Please confirm that, if delinquent assets are included in the pool at the time of the
prospectus, the delinquent assets will not constitute 20% or more of the asset pool on the
date of any issuance of notes under this form of prospectus.  Refer to General Instruction
I.B.1(e) of Form SF-3.
Form of Prospectus, page 1
3.We note your disclosure indicates that the notes will evidence debt obligations of the trust
secured by "the Series 202[ ]-[ ] ownership interest," which includes "an undivided co-
ownership interest" in a pool of credit card receivables.  We note also that "Series
Ownership Interests" are listed as newly-registered securities in the filing fee table in
Exhibit 107.1.  Please confirm that any such ownership interest that the trust acquires will
comply with the requirements of Rule 190 under the Securities Act, and make any
necessary revisions to your registration statement.  Refer to Section III.A.6. of the 2004
Regulation AB Adopting Release (Release No. 33-8518) and Rule 190(c) under the
Securities Act.
Enforceability of Civil Liabilities Against Foreign Persons, page 4
4.Please revise your disclosure to more specifically address the required information under
Item 101(g) of Regulation S-K, including whether or not investors may bring actions
under the civil liability provisions of the U.S. federal securities laws against the depositor,
issuing entity or other transaction parties.  Please note that if your disclosure is based on
an opinion of counsel, a consent of counsel must be filed as an exhibit to your registration
statement.  Refer to Item 1100(e) of Regulation AB.
Part I - The Series 202[ ]-[ ] Ownership Interest and the Notes
Credit Card Portfolio
The Accounts, page 53
5.We note your bracketed disclosure indicating that static pool information is not being
included "at this time" because all of the accounts are 60 or more months past the date on
which they were originated.  Please confirm that you do not reasonably expect the asset
pool to include accounts that are less than 60 months past the date on which they were
originated at the time of any offering under this shelf registration statement, or else revise
your form of prospectus to include alternative bracketed disclosure describing the static
pool information that would be provided if any such assets were to be included.  Refer to
Item 1105 of Regulation AB.

 FirstName LastNameBoris Kogut
 Comapany NameGolden Credit Card Limited Partnership
 March 9, 2023 Page 3
 FirstName LastName
Boris Kogut
Golden Credit Card Limited Partnership
March 9, 2023
Page 3
Certain Features of Series 202[ ]-[ ] Ownership Interest and Notes
Swap Agreement
The Swap Counterparty, page 75
6.Please revise your bracketed disclosure to address the expected significance percentage of
the swap agreement and corresponding financial information regarding the swap
counterparty required by Item 1115 of Regulation AB.  Refer to Items 1115(a)(4) and
1115(b) of Regulation AB.
Requirements for SEC Shelf Registration
Asset Representations Review, page 80
7.We note your disclosure on page 82 that an asset representations review may be
considered "incomplete" based on missing or incomplete review materials.  Please revise
your form of prospectus to explain how an incomplete review would be presented in the
asset representations reviewer’s final report, and whether the servicer or the asset
representations reviewer will have any additional responsibilities if a review is determined
to be incomplete.

Part II - The Sponsor, Seller, Administrative Agent and Servicer
Royal Bank of Canada, page 105
8.Please describe the Servicer’s experience in servicing credit card receivables or similar
assets.  Refer to Item 1108(b)(2) of Regulation AB.
Operations of the Trust
The Assignment and Transfer of Account Assets
Addition of Accounts, page 113
9.We note your disclosure that, in certain circumstances, the seller may be required to "add
participations representing undivided interests in or securities backed by a pool of assets
consisting primarily of credit card receivables and collections thereon" to the account
assets.  To the extent such participations or other assets are securities, their inclusion in
the asset pool would trigger the resecuritization requirements discussed in Section III.A.6.
of the 2004 Regulation AB Adopting Release (Release No. 33-8518) and Rule 190 under
the Securities Act.  Please revise to disclose how you intend to meet your registration,
disclosure, and prospectus delivery obligations for participations or other securities that
may be added to the asset pool after the effectiveness of the registration statement.
Additionally, to the extent applicable, please tell us whether participations or other
securities are currently included in the trust or were included in the trust in the past.

 FirstName LastNameBoris Kogut
 Comapany NameGolden Credit Card Limited Partnership
 March 9, 2023 Page 4
 FirstName LastName
Boris Kogut
Golden Credit Card Limited Partnership
March 9, 2023
Page 4
Mandatory Purchase of Account Assets, page 117
10.We note that Royal Bank of Canada ("RBC"), as seller and servicer, has an obligation to
repurchase account assets upon the breach of certain representations and warranties.
Please confirm that you will provide information regarding RBC's financial condition if
there is a material risk that the ability of RBC to comply with the repurchase provisions
could have a material impact on pool performance or performance of the asset-backed
securities.  Refer to Item 1104(f) of Regulation AB.
Signatures, page II-8
11.Please include the signature of the registrant's authorized representative in the United
States.  See Instruction 1 to Signatures in Form SF-3.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Jason Weidberg at 202-551-6892 or Benjamin Meeks at 202-551-
7146 with any questions.
Sincerely,
Division of Corporation Finance
Office of Structured Finance