SecProbe.io

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 July 1, 2025

Daniel B. Wolfe
Chief Executive Officer
Yukon New Parent, Inc.
c/o 180 Degree Capital Corp.
7 N. Willow Street, Suite 4B
Montclair, NJ 07042

 Re: Yukon New Parent, Inc.
 Amendment No. 2 to the Registration Statement on Form S-4
 Filed June 12, 2025
 File No. 333-286043
Dear Daniel B. Wolfe:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our June 3, 2025
letter.

Amendment No. 2 to the Registration Statement on Form S-4
General

1. We note your response to prior comment 41 and your Rule 425 filing dated
January
 17, 2025, which includes statements suggesting the combination of asset
management
 and insurance businesses is expected to generate returns of "~26%." If
these
 statements continue to reflect your expectations, please revise
Background of the
 Mergers, MD&A, and/or where appropriate to address the underlying
assumptions. If
 this statement no longer reflects your current view, please clarify so
in the Form S-4
 and explain why.
 July 1, 2025
Page 2

About This Preliminary Joint Proxy Statement/Prospectus, page i

2. We note your response to prior comment 40. We further note that on page
i you
 state "neither Mount Logan nor any of its directors or officers assumes
any
 responsibility for the accuracy or completeness of such information
including any of
 180 Degree Capital s financial statements." You also make a similar
statement for 180
 Degree Capital. These statements appear to imply a disclaimer of
responsibility for
 this information in the registration statement by both Mount Logan and
180 Degree
 Capital. Please revise this section and others with similar statements
to remove such
 implication.
The Mergers
Mount Logan's Reasons for the Mergers, page 120

3. We note that, in your response to prior comment 9, you state in the
registration
 statement that the other proposals you considered "never progressed
beyond early
 stages"; however, in your response letter you stated that a proposed
business
 combination with Canaccord Genuity G Ventures Corp. was announced in
August
 2023. Please revise to clarify or advise us why the announced
transaction is not
 deemed progressed beyond early stages.
Opinion of 180 Degree Capital's Financial Advisor
MLC Projections, page 134

4. We note that the financial projections provided to Fenchurch for 2024
includes $21.9
 million in asset management revenue for Mount Logan, whereas the audited
 consolidated Statement of Operations for the year ended December 31,
2024, reflects
 only $15.0 million in actual asset management revenue. Please revise to
further clarify
 the basis for the 2024 projection and why it materially exceeds the
actual audited
 results for the same year.
5. We note your statement that neither "Mount Logan or its management
considers the
 MLC Projections to be predictive of actual future performance or that
the MLC
 Projections should be relied upon in any way in making a decision
regarding the
 proposed Business Combination, any investment in Mount Logan, or any
other
 matter." We further note your statement that "[n]either Mount Logan nor
any other
 person makes any representation regarding the MLC Projections or the
ultimate
 performance of Mount Logan compared to the MLC Projections or any other
 prospective financial information." While you may include qualifying
language with
 respect to such projections, it is inappropriate to disclaim
responsibility for this
 information. Please revise to eliminate these disclaimers.
Regulatory Approvals and Related Matters, page 135

6. We note your response to prior comment 16. Please revise your disclosure
in the
 registration statement to clarify the status of required filings or
notices and the
 expected timing of remaining approvals.
 July 1, 2025
Page 3
Critical Accounting Estimates - Insurance Solutions Segment
Goodwill, page 295

7. We note your response to prior comment 33 and revised critical
accounting estimates
 disclosures regarding goodwill impairment testing. Please further revise
and expand
 your disclosure for the following:
 the percentage by which fair value exceeded carrying value as of the
date of the
 most recent test;
 a description of the key assumptions used and how the key
assumptions were
 determined as described in your response; and
 how much each estimate and/or assumption has changed over a relevant
period,
 and the sensitivity of the reported amount to the methods,
assumptions and
 estimates underlying its calculation.
Management's Discussion and Analysis, page 340

8. We note that you have included interest rate sensitivity disclosure for
Mount Logan
 on pages 270 and 302. However, similar interest rate sensitivity
disclosure does not
 appear to be provided for 180 Degree Capital Corp. In this regard, we
also note your
 disclosure discussing interest rate risk and interest rate sensitivity
as a potential impact
 to earnings for 180 Degree Capital Corp. Please revise to provide
interest rate risk and
 sensitivity information for 180 Degree Capital or tell us why you
believe it is not
 required. Refer to Item 305 of Regulation S-K.
Index to Financial Statements
180 Degree Capital Corp., page F-1

9. In regards to the unaudited interim financial statements for 180 Degree
Capital Corp.,
 we note that reference on page F-2 to the three month periods ended
March 31, 2025
 and 2024 included on page F-183. Please address the following.
 It appears that the page number references for the interim financial
statements
 refer to your annual financial statements. Revise to ensure the
appropriate page
 number references are included.
 It appears that you have only included unaudited interim financial
statements for
 the three months ended March 31, 2025, but not for the three months
ended
 March 31, 2024 as stated on the index. We also note your results of
operations
 discussion on pages 344 through 348 within the MD&A includes a
comparison
 between the three months ended March 31, 2025 and 2024. For the
unaudited
 interim financial statements, revise to provide the corresponding
interim period of
 the preceding year or if you believe it is not applicable or
required, tell us why
 and revise the index to the financial statements to clarify
accordingly.
 Tell us your consideration to disclose a statement in the interim
financial
 statements consistent with the requirements of Rule 3-03(d) of
Regulation S-X.
 July 1, 2025
Page 4

 Please contact Lory Empie at 202-551-3714 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: John Mahon, Esq.
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