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AMG Pantheon Credit Solutions Fund

 Faegre Drinker Biddle & Reath LLP

320 South Canal Street, Suite 3300

Chicago, IL 60606

www.faegredrinker.com

December 12, 2023

 Via EDGAR
Transmission

 Securities and Exchange Commission

 100 F
Street, N.E.

 Washington, D.C. 20549

 Attention: Eileen
Smiley

Re:
 AMG Pantheon Credit Solutions Fund (the “Fund”)

Initial Registration Statement on Form N-2

File Nos. 333-274875 and 811-23904

Dear Ms. Smiley,

 The following responds to
the comments provided via email on November 1, 2023, in connection with the Securities and Exchange Commission (“SEC”) staff’s review of a registration statement (the “Registration Statement”) filed by the Fund on Form N-2 under the Investment Company Act of 1940, as amended (the “1940 Act”) and Securities Act of 1933. The changes to the Fund’s disclosure discussed below are reflected in Pre-Effective Amendment No. 1 to the Fund’s Registration Statement (the “Revised Registration Statement”).

For your convenience, we have repeated each comment below, and the Fund’s responses follow your comments. Capitalized terms not otherwise
defined herein shall have the meaning ascribed to them in the Registration Statement, unless otherwise indicated.

 PROSPECTUS

Cover Page, pages 1 & 2

1.
 Comment: You list three shares of classes and on Page 2 of the prospectus, you state that you
will apply for exemptive relief for a multi-class Fund. Explain supplementally to the staff whether the Fund has applied for exemptive relief for the multiple class structure, and if the Fund has applied, please explain the status of the exemptive
application.

 Response: The Fund confirms that it intends to file an application for multi-class exemptive
relief but that the application has not yet been filed.

2.
 Comment: The ticker symbols are not complete. Please complete all blank or tentative fields in
the entire registration statement.

 Response: The Fund confirms that any remaining blank or tentative
fields will be completed in a pre-effective amendment to the Registration Statement.

3.
 Comment: On the Cover Page, you list the sales price of the Fund shares to be Current Net Asset
Value and the Proceeds to the Fund to be Current Net Asset Value. You have a line item for the sales charge that is not listed at zero. Please supplementally explain to the staff whether you intend to charge a sales charge or not. Please amend the
table to either reflect a zero sales charge or, if a sales charge is contemplated, amend the description of the proceeds to the Fund.

Response: The table and related disclosures throughout the Revised Registration Statement have been updated to reflect a zero
sales charge on Class S Shares and Class I Shares and a 3.50% sales charge on Class B Shares.

4.
 Comment: Item 1.g of Form N-2 requires a table listing
certain information. Please explain supplementally to the staff why footnote 3 is relevant to this table. Unless it will impact the proceeds to the Fund, please delete and address this in the fee table required later in the prospectus to show how
the information in footnote 3 will impact the fees that the Fund will pay once the Fund is operational.

Response: Footnote 3 has been deleted from the above-referenced table in the Revised Registration Statement. The Fund notes that
the information previously contained in footnote 3 is disclosed elsewhere where appropriate in the Revised Registration Statement.

5.
 Comment: Item 1.b requires identification of the type of fund and a brief statement of the
Fund’s investment objectives, not investment policies. If you keep a brief statement of the principal investment policies of the Fund, please:

a) rephrase the 80% policy to refer to debt securities, not credit securities, and then briefly define how the Fund interprets debt securities
(i.e., public or private credit investments).

 b) The prospectus later states that the Fund can invest in preferred securities. If
preferred securities are to be part of the 80% policy, please include those in the definition.

 c) See Comments 9-10 later and make conforming changes. The disclosure of the Fund’s investment policies should be shorter in the cover page and synopsis with cross references to the section of the prospectus detailing the
disclosure required by Item 8.2.

 Response:

a) Rule 35d-1 under the 1940 Act requires a fund to adopt a policy to invest, under normal
circumstances, at least 80% of the value of its assets in investments in accordance with the investment focus that the fund’s name suggests. The Fund respectfully believes that its 80% policy should refer to the term “credit” rather
than “debt” to align with the terminology used in the Fund’s name. The following disclosure has been added to the Revised Registration Statement to define how the Fund interprets credit securities for purposes of its 80% policy:

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 “For purposes of the Fund’s above-referenced policy to invest at least 80% of its
assets directly or indirectly in credit securities, the Fund considers credit securities to include private and public credit investments, including corporate loan investments, investments in private credit investment funds (private funds that are
excluded from the definition of “investment company” pursuant to Sections 3(c)(1) or 3(c)(7) of the Investment Company Act (“Private Funds”)), U.S. or global high yield securities, bank loans, notes, loan participations and
assignments, non-performing loans, convertible securities, preferred securities, private and public business development companies (“BDCs”), mutual funds or exchange traded funds (“ETFs”)
that invest in credit securities, collateralized loan obligations (“CLOs”), collateralized debt obligations (“CDOs”), mezzanine debt and distressed securities.”

b) The Fund confirms that preferred securities will be a part of the 80% policy, and the related disclosures have been revised accordingly in
the Revised Registration Statement.

 c) The Fund confirms that it has shortened the synopsis of the Fund’s investment policies on the
cover page of the Prospectus and has added a cross-reference to the more detailed strategy disclosure in the Prospectus.

6.
 Comment: The second paragraph on Page 2 of the Prospectus in the section entitled Offering of
Shares, states the minimum purchase requirements for the three classes of shares, and further states that the Fund, “in its sole discretion” may accept investments below the stated minimums. Given that the Fund will invest more than
15% of its net assets in private funds excluded from the investment company definition pursuant to sections 3(c)(1) and 3(c)(7), please supplementally confirm to the staff that the Fund will not accept minimum initial investments below $25,000 for
any class of shares.

 Response: The Fund confirms that it generally will not accept minimum initial
investments below $25,000 for any class of shares, subject to certain exceptions as noted in the Revised Registration Statement. The following disclosure has been added to the Revised Registration Statement:

“However, the Fund reserves the right, in its sole discretion, to waive the minimum initial and additional investment amounts for
investments by current or retired officers and Trustees of the Fund and other funds managed by the Adviser or the Administrator, as well as their family members; current or retired officers, directors, and employees of the Adviser or the
Administrator and certain participating affiliated companies of the Adviser or the Administrator; the immediate family members of any such officer, Trustee, or employee (including parents, spouses, children, fathers/mothers-in-law, daughters/sons-in-law, and domestic partners); and a trust or plan established primarily for the benefit
of any of the foregoing persons. In addition,

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the minimums may be reduced (in the case of minimum initial investments, to an amount no lower than $25,000) by the Fund in the discretion of the Adviser or the Administrator based on
consideration of various factors, including the investor’s overall relationship with the Adviser or the Administrator, the investor’s holdings in other funds affiliated with the Adviser or the Administrator, and such other matters as the
Adviser or the Administrator may consider relevant at the time. The Fund, in the sole discretion of the Adviser or the Administrator, may also aggregate the accounts of clients of registered investment advisers and other financial intermediaries
whose clients invest in the Fund for purposes of determining satisfaction of minimum investment amounts.”

7.
 Comment: Please supplementally explain the percentage of assets which the Fund anticipates
investing in private funds excluded from the investment company definition pursuant to sections 3(c)(1) and 3(c)(7).

Response: The Fund confirms that it anticipates investing between 55%-80% of the
Fund’s assets in private funds excluded from the investment company definition pursuant to sections 3(c)(1) and 3(c)(7) of the Investment Company Act.

8.
 Comment: On Page 3 of the prospectus, you state that the shares will not be publicly traded.
Please disclose the special risks associated with non-traded closed end funds relevant to the Fund on the cover page. Examples of such disclosure, include:

•

 The amount of distributions that the Fund may pay, if any, is uncertain.

•

 The Fund may pay distributions in significant part from sources that may not be available in the future and that
are unrelated to the Fund’s performance, such as from offering proceeds, borrowings, and amounts from the Fund’s affiliates that are subject to repayment by investors.

•

 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 bolded risk disclosures on the cover page of the Prospectus have been updated as follows in the Revised
Registration Statement:

 “SHARES ARE SPECULATIVE AND ILLIQUID INVESTMENTS INVOLVING SUBSTANTIAL RISKS OF LOSS.

•

 The Fund has no operating history and the Shares have no history of public trading.

•

 The Fund does not intend to list the Shares on any securities exchange and the Fund does not anticipate a
secondary market for the Shares to develop.

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•

 You should generally not expect to be able to sell your Shares (other than through the limited repurchase
process) regardless of how the Fund performs.

•

 Although the Fund is required to implement a Share repurchase program, only a limited number of Shares will be
eligible for repurchase by the Fund.

•

 You should consider that you may not have access to the money you invest for an indefinite period of time.

•

 An investment in the Shares is not suitable for you if you have a foreseeable need to access the money you
invest.

•

 Because you will be unable to sell your Shares or have them repurchased immediately, you will find it
difficult to reduce your exposure on a timely basis during a market downturn.

•

 The amount of distributions that the Fund may pay, if any, is uncertain.

•

 The Fund may pay distributions in significant part from sources that may not be available in the future and
that are unrelated to the Fund’s performance, such as from offering proceeds, borrowings, and amounts from the Fund’s affiliates that are subject to repayment by shareholders.

•

 All or a portion of a distribution may consist of a return of capital (i.e., from your original investment)
(and not a return of net investment income).

•

 An investor will pay a sales load of up to 3.50% for Class B Shares and offering expenses of up to [_ ]%
on the amounts it invests. If you pay the maximum aggregate [    ]% for sales load and offering expenses for Class B Shares and [    ]% in offering expenses for Class S Shares and Class I
Shares, you must experience a total return on your net investment of [    ]% for Class B Shares and [    ]% for Class S Shares and Class I Shares in order to recover these expenses.”

 PROSPECTUS

SUMMARY OF TERMS, pages 6-13

9.
 Comment: Beginning on page 6, the prospectus contains a “Summary of the Terms”
of the offering, or a synopsis. The synopsis should contain a brief description of the key features and principal strategies of the Fund with cross references to the more detailed disclosure in Item 8 and elsewhere in the prospectus. Please
revise to disclose the key features of the Fund. See Instruction to Item 3.2. of Form N-2 (stating that the synopsis should provide a “clear and concise [emphasis added]” description of
the key features of the offering and the Fund, with cross-references to relevant disclosure elsewhere in the Prospectus or Statement of Additional Information). See also Item 8.2.b.(1) of Form N-2; Item
8.4. of Form N-2 and Instruction a. thereto.

 Response: The Fund
has revised the “Investment Objective and Strategies” section of the “Summary of Terms” to include a briefer synopsis of the principal investment strategy. The Fund respectfully believes that the “Summary of Terms”
section, as included in the Revised Registration Statement, otherwise includes a summary of the key terms of the Fund and the offering and appropriate cross references.

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10.
 Comment: See comment 9 above. There are discrepancies between disclosure in the synopsis
and in the more detailed disclosure later in the prospectus that makes identifying the principal strategies hard to understand. For example:

(a) You immediately disclose what the Fund’s private credit investments will be right after the description of the Fund’s 80%
policy. In the last full paragraph on page 7 you state that the Fund also invests in private credit investments and to a lesser extent public credit instruments. If you intend private and public credit securities to be part of the 80% policy,
consider adding a sentence that the Fund will invest in both private and public credit securities to make this clear. Clearly define what will be in the 80% policy generally before disclosing additional policies.

(b) On page 20 of the prospectus, you state that the Fund will primarily invest in North America-domiciled investments and may also make
European-domiciled investments. On Page 9, you state that the Fund could invest in foreign-domiciled debt and equity securities, including emerging markets. If investments in North America-domiciled investments and European-domiciled investments are
the primary investments, consider adding this in the synopsis and Item 1 with additional, non-primary investments described clearly in subsequent disclosure.

(c) Cross reference to other sections of the prospectus that discuss investment policies in more detail.

Response:

 (a) As
noted in response to Comment 5 above, the Fund has revised the above-referenced disclosure to make clear that both private and public credit investments may be included in the Fund’s 80% investment policy. The Fund has also defined what is
included in the 80% policy before disclosing additional policies in the Revised Registration Statement.

 (b) The Fund confirms that
investments in North America-domiciled investments and European-domiciled investments will be the primary focus. Accordingly, related disclosure has been added in the synopsis and Item 1 disclosure. Disclosure regarding the Fund’s ability to
invest in other foreign-domiciled debt and equity securities, including emerging markets, has been moved to the Item 8 disclosure in the Revised Registration Statement.

(c) A cross reference to the Item 8 strategy disclosure has been added to the Revised Registration Statement.

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11.
 Comment: On Page 7 you state that a portion of the Fund’s assets will be invested in cash in
certain circumstances or market environments. Please add disclosure briefly discussing these “ce