Correspondence 0001104659-25-010985 from Antares Private Credit Fund (CIK 0001976336)
Antares Private Credit Fund (CIK 0001976336)
Date: Feb. 10, 2025 · CIK: 0001976336 · Accession: 0001104659-25-010985
AI Filing Summary & Sentiment
File numbers found in text: 333-283111
Letter
100 F Street NE Washington, D.C. 20549-0504 Re: Antares Private Credit Fund File No: 333-283111
Dear Mr. Ellington:
We are writing in response to comments provided on February 10, 2025 with respect to the registration statement on Form N-2 filed with the Securities and Exchange Commission (the “SEC”) on February 5, 2025 (the “Registration Statement”) on behalf of Antares Private Credit Fund (the “Fund”), a closed-end management investment company that has elected to be treated as a business development company (“BDC”). The Fund has considered your comments and has authorized us, on its behalf, to make the responses discussed below. Capitalized terms have the meanings attributed to such terms in the Registration Statement.
On behalf of the Fund, set forth below are the SEC Staff’s comments along with our responses to or any supplemental explanations of such comments, as requested.
General
Comment 1. If the Registration Statement is not declared effective until after February 12, 2025, please update it to include unaudited financial statements as of a date within 135 days before the filing is expected to become effective. See Article 3-12 of Regulation S-X.
Response 1. The Fund has filed acceleration requests concurrently with this response letter to have the Registration Statement declared effective February 12, 2025. Pursuant to Article 3-12(b) of Regulation S-X, where the anticipated effective date of a registration statement is within 45 days of the registrant’s fiscal year end, the registrant need not include financial statements more current than as of the end of the third fiscal quarter of the most recently completed fiscal year, unless the audited financial statements for such fiscal year are available. As the audited financial statements for the fiscal year ended December 31, 2024 are not yet available for the Fund, the Fund respectfully submits that the September 30, 2024 audited financial statements included with the Registration Statement will not be stale until after February 14, 2025. In the event the Registration Statement is not declared effective until after February 14, 2025, the Registration Statement will be updated to include updated financial statements in accordance with the SEC Staff’s comment.
* * *
If you would like to discuss any of these responses in further detail or if you have any questions, please feel free to contact me at (202) 261-3386 or Nadeea Zakaria at (212) 641-5671.
Sincerely,
/s/ William J. Bielefeld
Show Raw Text
CORRESP
1
filename1.htm
1900 K Street, N.W.
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
WILLIAM J. BIELEFELD
william.bielefeld@dechert.com
+1 202 261 3386 Direct
+1 202 261 3333 Fax
February 10, 2025
Kenneth Ellington
U.S. Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549-0504
Re: Antares Private Credit Fund
File No: 333-283111
Dear Mr. Ellington:
We are writing in response
to comments provided on February 10, 2025 with respect to the registration statement on Form N-2 filed with the Securities and
Exchange Commission (the “SEC”) on February 5, 2025 (the “Registration Statement”) on behalf of Antares Private
Credit Fund (the “Fund”), a closed-end management investment company that has elected to be treated as a business development
company (“BDC”). The Fund has considered your comments and has authorized us, on its behalf, to make the responses discussed
below. Capitalized terms have the meanings attributed to such terms in the Registration Statement.
On behalf of the Fund, set
forth below are the SEC Staff’s comments along with our responses to or any supplemental explanations of such comments, as requested.
General
Comment
1. If the Registration Statement is not declared effective
until after February 12, 2025, please update it to include unaudited financial statements as of a date within 135 days before the
filing is expected to become effective. See Article 3-12 of Regulation S-X.
Response
1. The Fund has filed acceleration requests concurrently with
this response letter to have the Registration Statement declared effective February 12, 2025. Pursuant to Article 3-12(b) of
Regulation S-X, where the anticipated effective date of a registration statement is within 45 days of the registrant’s fiscal year
end, the registrant need not include financial statements more current than as of the end of the third fiscal quarter of the most recently
completed fiscal year, unless the audited financial statements for such fiscal year are available. As the audited financial statements
for the fiscal year ended December 31, 2024 are not yet available for the Fund, the Fund respectfully submits that the September 30,
2024 audited financial statements included with the Registration Statement will not be stale until after February 14, 2025. In the
event the Registration Statement is not declared effective until after February 14, 2025, the Registration Statement will be updated
to include updated financial statements in accordance with the SEC Staff’s comment.
* * *
If you would like to discuss any of these responses
in further detail or if you have any questions, please feel free to contact me at (202) 261-3386 or Nadeea Zakaria at (212) 641-5671.
Sincerely,
/s/ William J. Bielefeld
William J. Bielefeld
2