Correspondence 0001104659-25-066461 from iDirect Private Credit Fund (CIK 0002042256)
iDirect Private Credit Fund (CIK 0002042256)
Date: July 8, 2025 · CIK: 0002042256 · Accession: 0001104659-25-066461
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-283577, 811-24031
Letter
Division of Investment Management Washington, DC 20549 Re: iDirect Private Credit Fund Registration Statement on Form N-2 File Nos. 333-283577 and 811-24031
Dear Ms. Fettig:
This letter responds to a comment that Ms. Christina DiAngelo Fettig conveyed in telephonic conversation with Monica R. Patel on July 8, 2025, with respect to Pre-Effective Amendment No. 3 to the registration statement filed on Form N-2 (the "Registration Statement") under the Securities Act of 1933, as amended (the "Securities Act"), and the Investment Company Act of 1940, as amended (the "1940 Act"), filed with the U.S. Securities and Exchange Commission (the "SEC") on June 26, 2025 on behalf of iDirect Private Credit Fund (the "Fund"), and the Fund's prior correspondence filing made on July 7, 2025 (the "Prior Correspondence"). The Fund has considered your comment and has authorized us to make the response on its behalf. Capitalized terms have the meanings attributed to such terms in the Registration Statement and/or the Prior Correspondence.
On behalf of the Fund, set forth below is the comment of the SEC staff ("Staff") along with our response to or any supplemental explanations of such comment, as requested.
1. Comment : In connection with the response to comment 5 of the Prior Correspondence, please confirm that the Fund calibrated the value of investments in investment funds to public observable market equivalent data as of 3/31/25.
Response : The Fund so confirms.
* * * * *
Should you have any questions or comments, please contact the undersigned at 202.261.3402.
Sincerely,
/s/ Alexander Karampatsos
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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
ALEXANDER C. KARAMPATSOS
alexander.karampatsos@dechert.com +1 202 261 3402 Direct
July 8, 2025
VIA E-Mail
Ms. Christina DiAngelo Fettig
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: iDirect Private Credit Fund
Registration Statement on Form N-2
File Nos. 333-283577 and 811-24031
Dear Ms. Fettig:
This letter responds to a comment that Ms. Christina
DiAngelo Fettig conveyed in telephonic conversation with Monica R. Patel on July 8, 2025, with respect to Pre-Effective Amendment No.
3 to the registration statement filed on Form N-2 (the "Registration Statement") under the Securities Act of 1933, as amended
(the "Securities Act"), and the Investment Company Act of 1940, as amended (the "1940 Act"), filed with the U.S.
Securities and Exchange Commission (the "SEC") on June 26, 2025 on behalf of iDirect Private Credit Fund (the "Fund"),
and the Fund's prior correspondence filing made on July 7, 2025 (the "Prior Correspondence"). The Fund has considered
your comment and has authorized us to make the response on its behalf. Capitalized terms have the meanings attributed to such terms in
the Registration Statement and/or the Prior Correspondence.
On behalf of the Fund, set forth below is the
comment of the SEC staff ("Staff") along with our response to or any supplemental explanations of such comment, as requested.
1. Comment : In connection with the response to comment 5 of the Prior Correspondence, please
confirm that the Fund calibrated the value of investments in investment funds to public observable market equivalent data as of 3/31/25.
Response :
The Fund so confirms.
* * * * *
Should you have any questions or comments, please
contact the undersigned at 202.261.3402.
Sincerely,
/s/ Alexander Karampatsos
Alexander Karampatsos
2