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CORRESP
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CORRESP

 September 18, 2025

Lisa N. Larkin

 Senior Counsel

U.S. Securities and Exchange Commission

 Division of Investment
Management

 100 F Street, N.E.

 Washington,
DC 20549

Re:
 TCW Steel City Perpetual Levered Fund LP (File
No. 000-56771)

 Dear Ms. Larkin:

This letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) to our client, TCW Steel City Perpetual Levered Fund LP (the “Company” or the “Fund,” as applicable) with respect to the Company’s
registration statement on Form 10 (“Registration Statement”) in connection with the registration of the Company’s shares under Section 12(g) of the Securities Exchange Act of 1934, as amended (the “Exchange
Act”). Below, we provide the Staff’s comments and the Fund’s responses. Capitalized terms shall have the same meaning as in the Registration Statement, unless otherwise indicated.

Page 1 – Explanatory Note

1.
 Staff Comment: Please add the following bullet points:

a.
 The Company’s common stock is not currently listed on an exchange, and it is uncertain whether a
secondary market will develop.

b.
 Repurchases of common stock by the Company, if any, are expected to be very limited.

c.
 An investment in the Company may not be suitable for investors who may need the money they invest in a
specified time frame.

d.
 Investment in the Company is suitable only for sophisticated investors and requires the financial ability
and willingness to accept the high risks and lack of liquidity inherent in an investment in the Company.

e.
 The Company intends to invest primarily in privately-held companies for which very little public information
exists. Such companies are also generally more vulnerable to economic downturns and may experience substantial variations in operating results.

f.
 The privately-held companies and below-investment-grade securities in which the Company will invest will be
difficult to value and are illiquid.

 Response: Comments accepted and
the requested changes have been made in the amended Registration Statement.

2.
 Staff Comment: In the third paragraph, disclosure states, “Once this Registration
Statement has been deemed effective . . . .” Please change “has been deemed” to “is.”

 Response: Comment accepted and the
requested change has been made in the amended Registration Statement.

 Page 2 – Forward-Looking Statements

3.
 Staff Comment: In the eleventh bullet point, disclosure refers to PNCCM. Please define
that term, or cross-reference to the location where it is defined.

 Response:
Comment accepted and the requested change has been made in the amended Registration Statement.

 Page 7 – General Development
of Business

4.
 Staff Comment: In the first paragraph, disclosure refers to the Company’s intent
to convert to a Delaware statutory trust prior to commencement of operations and to change the Company’s name to “TCW Steel City Senior Lending BDC.”

a.
 Please explain supplementally the details of the conversion, including whether shareholder approval is
required.

 Response to (a): The Company commenced investment activities as a
private fund in May 2025. Furthermore, on September 8, 2025, the Company made its election to be regulated as a business development company under the 1940 Act. The Fund intends to convert its entity form by operation of law from a Delaware
limited partnership to a Delaware statutory trust approximately on or shortly after the date the Registration Statement is declared effective. Limited Partners of the private fund approved the conversion.

b.
 Please tell us when the Company will change its name.

Response to (b): The Company will file the certificate of name change approximately at the same time as
its conversion to a Delaware statutory trust.

c.
 The Company’s new name includes “senior lending,” which refers to a type of investment.
Please adopt an 80% policy with regard to the Company’s investments consistent with the requirements of rule 35d-1 under the 1940 Act. Please disclose this policy in the Registration Statement, and state
in the disclosure that this policy cannot be changed without 60 days’ prior written notice to shareholders (or alternatively, that the policy is fundamental).

Response to (c): Comment accepted and the requested changes have been made in the amended
Registration Statement.

d.
 Please add “PNC” prior to “Steel City” in order to avoid confusion with reference to
the term “Steel City.”

 Response to (d): The Company respectfully
submits that in the name of the platform, the term “Steel City” indicates PNC’s involvement, as PNC is a Pittsburgh-based organization. Further, “PNC” has intentionally been omitted from the defined term to avoid
potential confusion with PNC’s broader banking business. Therefore, the Company believes that no revision is necessary.

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5.
 Staff Comment: In the third paragraph, disclosure states that the Company will make
direct investments in senior secured loans to middle market companies or other issuers. Please explain what a middle market company is. Please also explain who the other issuers are.

Response: The Company has added the following definition in the amended Registration Statement:
“Middle market companies are generally defined as companies with annual earnings before interest, taxes, depreciation and amortization, or EBITDA, of $10 million to $75 million at the time of investment.” The Company
respectfully submits that other issuers refers to issuers that do not meet the definition of middle market companies, as set out above.

6.
 Staff Comment: In the fourth paragraph, disclosure states that the Company may
“invest indirectly in investments through intermediate entities established by us.”

a.
 If such entities include a subsidiary, please:

i.
 Disclose that “Subsidiary” includes entities that engage in investment activities in securities
or other assets that are primarily controlled by the Company. “Primarily controlled” means (1) the Company controls the unregistered entity within the meaning of section 2(a)(9) of the 1940 Act, and (2) the Company’s
control of the unregistered entity is greater than that of any other person;

 Response to
(a)(i): Comment accepted and the requested changes have been made in the amended Registration Statement.

ii.
 Disclose that the Company complies with the provisions of the 1940 Act governing capital structure and
leverage (Section 18) on an aggregate basis with the Subsidiary so that the Company treats the Subsidiary’s debt as its own for purposes of Section 18.

Response to (a)(ii): The Company confirms that it will comply with the provisions of the 1940 Act
governing capital structure and leverage (Section 61) on an aggregate basis with any subsidiary entity. The Company respectfully submits that no disclosure revision is necessary in response to this comment.

iii.
 Disclose that any investment adviser to the Subsidiary complies with provisions of the 1940 Act relating to
investment advisory contracts (section 15) as if it were an investment adviser to the Company under section 2(a)(20) of the 1940 Act. Any investment advisory agreement between the Subsidiary and its investment adviser is a material contract that
should be included as an exhibit to the registration statement. If the same person is the adviser to both the Company and the Subsidiary, then, for purposes of complying with section 15(c), the reviews of the Company’s and the
Subsidiary’s investment advisory agreements may be combined.

 Response to
(a)(iii): The Company acknowledges the Staff’s comments and notes that it does not expect that any subsidiary entity will be party to an investment advisory contract. As a result, the Company respectfully submits that no
disclosure revision is necessary in response to this comment.

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iv.
 Disclose that each Subsidiary complies with provisions relating to affiliated transactions and custody
(Sections 17 and 57). Identify the custodian of the Subsidiary, if any.

 Response to
(a)(iv): The Company respectfully submits that any subsidiary entity would not be a registered investment company under the 1940 Act and therefore would not be required to comply with the requirements of the 1940 Act applicable to
registered investment companies, including Section 57. However, the Company will apply the provisions relating to affiliated transactions and custody set forth in Section 57 of the 1940 Act and/or the rules thereunder to any subsidiary
entity, as if they were registered investment companies. The Company respectfully submits that no disclosure revision is necessary in response to this comment.

v.
 Disclose any of the Subsidiary’s principal investment strategies or principal risks that constitute
principal investment strategies or risks of the Company. The principal investment strategies and principal risk disclosures of a fund that invests in a Subsidiary should reflect aggregate operations of the fund and the Subsidiary.

 Response to (a)(v): The principal investment strategies and principal risks
already disclosed in the Registration Statement would appropriately reflect the aggregate operations of the Company and any subsidiary entity. The Company respectfully submits that no disclosure revision is necessary in response to this comment.

b.
 Please explain in correspondence whether the financial statements of the Subsidiary will be consolidated
with those of the Company. If not, please explain why not.

 Response to (b): The
Company respectfully confirms that the financial statements of any subsidiary entity will be consolidated with those of the Company.

c.
 Please confirm in correspondence that the Subsidiary and its board of directors will agree to inspection by
the staff of the Subsidiary’s books and records, which will be maintained in accordance with section 31 of the 1940 Act and the rules thereunder.

Response to (c): The Company respectfully confirms that any subsidiary entity and its board of directors
(if applicable) will agree to inspection by the Staff of the subsidiary entity’s books and records, which will be maintained in accordance with Section 31 of the 1940 Act (as it applies through Section 64).

d.
 If the Company will have a foreign subsidiary, please confirm that the Subsidiary and its board of directors
will agree to designate an agent for service of process in the United States.

 Response to
(d): The Company respectfully confirms in the case of any subsidiary entity that is a foreign corporation, the subsidiary and its board of directors will agree to designate an agent for service of process in the United States.

e.
 If the Company will have only a wholly-owned subsidiary, please confirm that the wholly-owned
subsidiary’s management fee (including any performance fee), if any, will be included in “Management Fees,” and the wholly-owned subsidiary’s expenses will be included in “Other Expenses” in the Company’s
fee table.

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 Response to (e): The Company acknowledges the
Staff’s comment and confirms that any wholly-owned subsidiary that charges a management fee (including any performance fee) has been included in “Management Fees”. The Company respectfully notes that Form 10 does not require Fee
Table disclosure and such disclosure has not been included in the Form 10 registration statements of many other private BDCs. As a result, the Company respectfully submits that no further disclosure is necessary.

Page 9 – The Advisor and the Sub-Advisor

7.
 Staff Comment: In the second paragraph, disclosure refers to “TCW’s Private
Credit Group.” Please add disclosure that explains the relevance of the group.

Response: The Company respectfully submits that the following disclosure is already included in the
Registration Statement and no further disclosure is needed: “The investment activities of the Advisor will be managed by the investment professionals from the Private Credit Group.”

Page 15 – Incentive Fee

8.
 Staff Comment: Please ensure that the Company adds a graphic to this section that
demonstrates the operation of the incentive fee.

 Response: Comment accepted and
the requested change has been made in the amended Registration Statement.

9.
 Staff Comment: Please consider disclosing a fee table that conforms to the requirements
of Item 3.1 of Form N-2 adjacent to this section. Please also consider disclosing an expense example that conforms to the requirements of Instruction 11 to Item 3.1 of Form
N-2.

 Response: The Company respectfully
acknowledges the comment but notes that Form 10 does not require such disclosure and such disclosure has not been included in the Form 10 registration statements of many other private BDCs. As a result, the Company respectfully submits that no
further disclosure is necessary.

 Page 24 – The Private Offering

10.
 Staff Comment: In the first paragraph, disclosure states that the Company reserves the
right to enter into Subscription Agreements that contain terms and conditions not found in the Subscription Agreements entered into with other investors, subject to applicable law.

Please explain:

a.
 How having subscription agreements with different terms would comply with sections 18 and 61 under the 1940
Act (e.g., could it result in an investor having priority over any other investor as to distribution of assets or payment of dividends);

Response to (a): The Company respectfully submits that it has not entered and does not intend to enter
into any subscription agreement that would be in contravention of section 18 and 61 under the 1940 Act.

b.
 Whether different terms in any subscription agreements could have a material, negative effect on other
Company investors;

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 Response to (b): The Company respectfully submits that
it has not entered and does not intend to enter into any subscription agreement with differing terms that would have a material, negative effect on other Company investors.

c.
 Whether the terms of different subscription agreements will be disclosed to all Company investors, and how
they will be disclosed including the timing of such disclosure;

 Response to (c):
The Company respectfully submits, because any differing terms found in any subscription agreement would not have a material, negative effect on other Company investors, no disclosure beyond the disclosure already included in the Registration
Statement is necessary.

d.
 Whether the terms of these subscription agreements include preferential redemption or withdrawal rights, or
about portfolio holdings or exposures; and

 Response to (d): The Company
respectfully submits that it has not entered and does not intend to enter into any subscription agreement that includes terms that provide for preferential redemption or withdrawal rights, or preferential information about portfolio holdings or
exposures.

e.
 Whether the terms of these subscription agreements have a direct or indirect effect on the management fee
attributable to the applicable shareholders with whom such agreements are made.

 Response to
(e): The Company respectfully submits that it has not entered and does not intend to enter into any subscription agreement that contains terms that have a direct or indirect effect on the management fee attributable to the applicable
shareholders with whom such agreements are made.

 Page 26 – Regulation as a Business Development Company

11.
 Staff Comment: In the sixth paragraph, disclosure states that the Advisors have each
filed an application for exemptive relief regarding certain co-investments. Please tell us the status of the application.

Response: The Company respectfully informs the Staff that each exemptive relief application is currently pending
before the SEC. A public notice has been issued for each application, awaiting issuance of final order.

 Page 57 – Reliance upon Consultants

12.
 Staff Comment: Disclosure states that the Advisor may rely upon independ