SecProbe.io

CORRESP
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CORRESP

 Cira Centre

 2929 Arch Street

Philadelphia, PA 19104-2808

 +1 215 994 4000 Main

+1 215 994 2222 Fax

 www.dechert.com

 JAMES A. LEBOVITZ

james.lebovitz@dechert.com

 +1 215 994 2510 Direct

 July 28, 2023

 VIA
EDGAR

 Securities and Exchange Commission

 Division of
Investment Management

 100 F Street, NE

 Washington, DC 20549

Attn:
 Raymond A. Be, Attorney-Adviser

Mindy Rotter

Re:
 KKR FS Income Trust Select

Registration Statement on Form N-2

File No. 811-23880

Dear Mr. Be and Ms. Rotter:

 On behalf
of KKR FS Income Trust Select (the “Company”), this letter responds to the comments issued by the staff of the Division of Investment Management (the “Staff”) of the U.S. Securities and Exchange
Commission (“Commission”) in a letter dated July 13, 2023 relating to the Company’s registration statement on Form N-2 under the Investment Company Act of 1940, as amended
(the “1940 Act”), that was filed with the Commission on June 7, 2023 (the “Registration Statement”).

For your convenience, the Staff’s comments are included in this letter, and each comment is followed by the response of the Company.
Capitalized terms used in this letter and not otherwise defined herein shall have the meanings ascribed to them in Amendment No. 1 to the Registration Statement filed by the Company on the date hereof (referred to herein as the
“Amended Registration Statement”). Unless otherwise indicated, all page references in the Company’s responses below are to page numbers in the Amended Registration Statement.

General

1.
 We note that portions of the filing are incomplete. We may have additional comments on such portions when you
complete them in a pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits added in any amendments.

Response: The Company acknowledges the Staff’s comment.

2.
 Please supplementally explain the status of any exemptive relief or
no-action request submitted, or expected to be submitted, in connection with the registration statement, including with respect to multi-class relief for K-FIT. Clarify
whether the Company will commence with its private placement prior to K-FIT receiving its relief to issue Class I shares, and if so, what will happen to invested funds pending receipt of relief.

 July 28, 2023

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 2

 Response: The Company does not currently intend to submit any requests for no-action or exemptive relief in connection with its operations, and no requests for no-action relief or applications for exemptive relief relating to the Company are
currently pending. In addition, the Company does not intend to rely on any existing order for exemptive relief from the SEC granting exemptions from Sections 18(a)(2), 18(c), 18(i) and 61(a) of the 1940 Act to permit affiliates of the Company
to issue multiple classes of shares, interests or units, as the case may be, with varying sales loads and asset-based service and/or distribution fees.

The Company’s planned private placement is not contingent on any relief that may be issued to K-FIT, and the
Company expects to purchase K-FIT Class I Shares as soon as the Company commences its private placement.

3.
 Please tell us if you have presented any test the waters materials in connection with this offering. We may
have additional comments based on your response.

 Response: The Company respectfully advises the Staff that the Company
has not engaged in any “test the waters” activities, as it is not conducting, nor does it anticipate conducting, a public offering of the Company Shares under the Securities Act of 1933, as amended (the “Securities
Act”); there is no need for the Company to gauge interest in a public offering by using the “test the waters” process. The Company is offering the Company Shares in private placement transactions that do not involve any
“public offering” within the meaning of Section 4(a)(2) of, and/or Regulation D under the Securities Act (the “Company Private Offering”). In connection with the Company Private Offering, the
Company is limiting investments in Company Shares to only individuals or entities meeting the definition of an “accredited investor” in Regulation D under the Securities Act.

4.
 Throughout the document, the Company uses terms such as “we,” “us,” and “our” to
refer to a third party (K-FIT) rather using those terms in their more common context to refer to itself, which makes the use of these terms very confusing. Notwithstanding the Company’s intent to solely
invest in K-FIT, please revise the document throughout so it is clear to whom such terms refer.

Response: The Company has revised the disclosure in the Amended Registration Statement in response to the Staff’s comment.

5.
 The disclosure indicates that the Company intends to only offer securities privately while simultaneously
investing solely in an affiliated privately-offered BDC. Supplementally explain what the business purpose of this structure is.

Response: The business purpose of the Company is to pursue its investment objective of generating current income and, to a lesser extent,
long-term capital appreciation, by investing substantially all of its assets in K-FIT, an affiliated privately-offered BDC. The master-feeder structure will allow the use of a feeder fund to access different
distribution channels with different cost structures while still maintaining a common single underlying portfolio. The Company intends to invest in K-FIT in accordance with the requirements of
Section 12(d)(1)(E) of the 1940 Act.

 We note that this use of a master-feeder structure is well established, and the Commission’s Division of
Investment Management has acknowledged the existence of such a structure and has spoken to its many advantages. In Protecting Investors: A Half Century of Investment Company Regulation, SEC Div. Inv. Mgmt. (May 1992) (the
“Protecting Investors Report”), the Staff stated that:

 July 28, 2023

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 3

 A recent related development is the “hub and spoke” fund structure, under which
funds with different costs share a single investment portfolio. It is similar to a multiclass structure, but uses separate funds instead of classes. Typically, the spoke funds invest solely in the hub fund, which holds the investment portfolio and
bears advisory fees.

 More than 30 years ago, in a report authored by the Division of Investment Management, the Division noted the potential advantages
of the hub and spoke or master-feeder structure, stating that

 [s]poke funds can be sold through various distribution channels to different
targeted markets such as retail investors, brokerage sweep accounts, foreign investors, or bank trust funds. Distribution costs are paid through front-end sales loads, deferred sales charges, rule 12b-1 fees, or a combination of these charges, depending upon the method chosen by the spoke fund’s promoters.

Similarly, administrative and service fees can vary from spoke to spoke depending upon the level of services sought by the fund’s
investors.

 Although traditional “stand alone” funds can also be marketed to a targeted group of investors with different sales
charge and fee structures, they may not attract enough investment dollars for efficient operation. By enabling a spoke fund to pool its assets with other spoke funds, however, the
hub-and-spoke structure may offer certain advantages over more traditional investment companies:

•

 Participating spoke funds may achieve economies of scale by sharing among a greater number of investment dollars
fixed expenses of portfolio management and fund administration.

•

 Participating funds may participate in securities transactions involving larger denominations than would be
available to individual investment companies.1

 The Company agrees with the
Staff’s longstanding views on this structure and its many advantages. In addition, the Staff has issued a number of no-action letters regarding such a master-feeder structure, including a number of no-action letters recommending no enforcement action under Section 12(d)(1) of the 1940 Act in structures in which a feeder fund acquires the securities of a master fund in excess of the limits of Sections
12(d)(1)(A) and 12(d)(1)(B) of the 1940 Act in compliance with the conditions of Section 12(d)(1)(E) of the 1940 Act, in many instances for the same purpose of accessing different distribution channels.2 Finally, the Staff has also declared effective many closed-end funds’ registration statements employing the same master-feeder structure to access
different distribution channels.

6.
 Please discuss whether, and to what extent, the Company’s investible assets in K-FIT will result in K-FIT making new ABF Investments. Will any of the Company’s assets be used to facilitate or support
K-FIT’s share repurchase program or the transferring of existing K-FIT shareholders? If so, please explain in correspondence the nature of any arrangements, and
revise disclosure accordingly.

1
 Letter to Congressman John D. Dingell from Richard C. Breeden, Chairman, SEC (April 15, 1992) (providing report
on hub-and-spoke funds prepared by the Division of Investment Management) (the “Dingell Letter”).

2
 See, e.g., Dechert LLP, SEC No-Action Letter (pub. avail.
March 8, 2017); PIMCO Funds, SEC No-Action Letter (pub. avail. July 9, 2002); Signature Financial Group, Inc., SEC No-Action Letter (pub. avail. Dec. 28,
1999); Neuberger & Berman Income Funds, SEC No-Action Letter (pub. avail. Feb. 27, 1998); The Eaton Vance Group of Investment Companies, SEC No-Action Letter
(pub. avail. July 25, 1997); Principle Preservation Portfolios, Inc., SEC No-Action Letter (pub. avail. Dec. 6, 1995); and Carter Group, Inc., SEC No-Action Letter
(pub. avail. Sept. 12, 1971).

 July 28, 2023

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 4

 Response: The Company respectfully advises the Staff that there are no arrangements to transfer
existing K-FIT shareholders. As disclosed in the Registration Statement, the Company will invest all of its investable assets (except for de minimis investments in cash for cash management purposes), which
will consist of the proceeds from the Company Private Offering, in K-FIT Class I Shares in connection with K-FIT’s private offering, which is being conducted
pursuant to the exemption from registration under Section 4(a)(2) of, and/or Regulation D under, the Securities Act (the “K-FIT Private Offering”).
K-FIT intends to use the proceeds from the K-FIT Private Offering, including the proceeds received from the Company, to (1) make investments in accordance with K-FIT’s investment strategy and policies, (2) reduce borrowings and repay indebtedness incurred under various financing agreements K-FIT may enter into,
(3) fund repurchases under K-FIT’s share repurchase program, and (4) for general corporate purposes, including paying operating expenses and other various fees and expenses such as base
management fees and incentive fees. The Company respectfully refers the Staff to page 42 of the Registration Statement in this regard.

 As disclosed in
the Registration Statement, K-FIT expects to invest up to 30% of its total assets in ABF Investments, subject to compliance with Section 55(a) of the 1940 Act. The Company notes that it currently includes
risk factor disclosure regarding asset-based finance opportunities on page 62 of the Registration Statement. In addition, the Company notes that it discloses the potential for proceeds from the K-FIT Private
Offering (and thus from the Company Private Offering) to be used to fund repurchases under K-FIT’s share repurchase program in multiple locations throughout the Registration Statement.

Prospectus

 Unlisted Closed-End Fund Risks (cover page)

7.
 Please include a risk bullet with the following disclosure: “An investor will pay a sales load of up to
[__]% and offering expenses of up to [__]% on the amounts it invests. If you pay the maximum aggregate [__]% for sales load and offering expenses, you must experience a total return on your net investment of [__]% in order to recover these
expenses.”

 Response: The Company has revised the disclosure in the Amended Registration Statement in response to the
Staff’s comment. Please see the page of the Amended Registration Statement that immediately precedes the table of contents therein.

Hard Asset (page 8)

8.
 The term “Great Financial Crisis” has not been defined. Please define terms when first used. Also,
rather than using defined terms, consider using terms of common usage, such as the financial crisis of 2008 when possible.

Response: The Company has revised the disclosure in the Amended Registration Statement in response to the Staff’s comment. Please see page
8 of the Amended Registration Statement for reference.

 Management and Incentive Fees (page 16)

9.
 Clarify briefly here, as disclosed elsewhere, that the Company will not pay a separate advisory fee to the
Advisor above the fee structure at the K-FIT level.

 July 28, 2023

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 5

 Response: The Company respectfully refers the Staff to the following existing disclosure on
page 16 of the Registration Statement, which the Company believes is responsive to the Staff’s comment: “In light of this, the Company does not incur a separate management fee or incentive fee under the Company Advisory Agreement, but the
Company and its Shareholders are indirectly subject to K-FIT’s Base Management Fee and Incentive Fee.”

Valuations (page 31)

10.
 The disclosure indicates that the Company’s NAV will be “based on the value of its interest in K-FIT.” Consider clarifying, if true, that the Company’s NAV will be the value of its assets (which will include its interest in K-FIT and other assets) less its
liabilities.

 Response: The Company has revised the disclosure in the Amended Registration Statement in response to the
Staff’s comment. Please see page 31 of the Amended Registration Statement for reference.

 Risk Factors (page 53)

11.
 It appears that the Company’s primary purpose is to purchase securities of
K-FIT and sell its own securities. Please supplementally provide us with your analysis of the Company’s status as an underwriter under Rule 140 of the Securities Act. To the extent the Company might be
considered an underwriter, consider discussing any legal implications and risks related to such status.

 Response: The
Company acknowledges that, if the offering of the Company Shares was a registered offering under the Securities Act, an argument could be made under Securities Act Rule 140 (“Rule 140”) that that Company would be an
underwriter of the K-FIT Class I Shares; however, as noted in the Company’s response to Comment #2 above, the Company Private Offering is being conducted in reliance on exemptions from the
registration requirements of the Securities Act provided by Section 4(a)(2) thereof, and/or Regulation D promulgated thereunder.

 The Company
understands that with respect to funds relying on Section 12(d)(1)(E) of the 1940 Act (i.e., so-called master-feeder funds), like the Company, there have been circumstances where the Staff has
requested the master fund sign the feeder fund’s registration statement based on the Commission’s view that the master fund is a co-issuer of the feeder fund’s securities under Rule 140. The
Company respectfully submits that the policy considerations of Rule 140 are not present here. The rationale for the adoption of Rule 140 was to curb abuses in the underwriting of securities by persons whose primary business was
the purchase and sale of securities, where the Commission had concerns that a co-issuer could avoid liability associated with publicly registering an offering of securities through the use of the feeder
issuer’s registered sale of its own securities. The Company respectfully notes that this requirement is premised on the assumption that the securities offering of the master fund would not be registered under the Securities Act, while the
feeder f