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July 9, 2025

VIA E-mail

Payam Siadatpour
Eversheds Sutherland
700 Sixth Street, NW Suite 700
Washington, DC 20001-3980
payamsiadatpour@eversheds-sutherland.com

 Re: Nuveen Churchill BDC V
 File No. 000-56757

Dear Mr. Siadatpour:

 On June 6, 2025, you filed a registration statement on Form 10 on
behalf of Nuveen
Churchill BDC V (the Company ). We have reviewed the registration
statement and have
provided our comments below. Where a comment is made in one location, it is
applicable to all
similar disclosure appearing elsewhere in the registration statement. All
capitalized terms not
otherwise defined herein have the meaning given to them in the registration
statement.

 Please respond to this letter within ten (10) business days by either
amending the filing,
providing the requested information, or advising us when you will provide the
requested
information. We may have additional comments after reviewing your responses to
the following
comments, or any amendment to the filing.

 We note that the Company is voluntarily registering shares of its
beneficial interests
under section 12(g) of the Securities Exchange Act of 1934 ( Exchange Act
). Please note that a
filing on Form 10 goes effective automatically by lapse of time 60 days after
the original filing
date, pursuant to Exchange Act section 12(g)(1). If our comments are not
satisfactorily
addressed within this 60-day time period, you should consider withdrawing the
Company s Form
10 prior to its effectiveness and re-filing a revised Form 10 that includes
changes responsive to
our comments. If the Company chooses not to withdraw its Form 10 registration
statement, it
will be subject to the reporting requirements of Exchange Act section 13(a).
Additionally, we
will continue to review the filing until all of our comments have been
satisfactorily addressed.
 Payam Siadatpour
Nuveen Churchill BDC V
Page 2

 EXPLANATORY NOTE Page 1

 1. Please add the following bullet points:

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

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

 x The Company s distributions may be funded from unlimited amounts of
offering
 proceeds or borrowings, which may constitute a return of capital and
reduce the amount
 of capital available to us for investment. Any capital returned to
shareholders through
 distributions will be distributed after payment of fees and expenses.

 ITEM 1. BUSINESS
 (a) General Development of Business Page 5

 2. Has the Company granted, or does it expect to grant, preferential
rights or terms to
 certain investors that are not available to other investors, pursuant
to a side letter or
 otherwise? If so, what are such rights or terms, and what are the
criteria by which such
 investors were selected? How does the granting of such rights or terms
impact the fund
 and investors who are not granted them? We may have further comments
based on
 your response.

 (c) Description of Business
 The Company Nuveen Churchill BDC V
 Investment Strategy Page 17

 3. Please define middle market companies as the term is used for
purposes of the
 Company s investment strategy and market opportunity sections.

 4. Please specify what is meant by leading private equity firms, and
clarify whether
 ownership of a portfolio company by such firms is a prerequisite to the
Company s
 investments. If not, please make this clear. If so, then discuss what
criteria, if any, the
 Company will use to determine that the private equity firm has a
sufficient ownership
 interest in the portfolio company.

 Overview of Market Opportunity
 Large, Resilient and Attractive Addressable Market Page 18

 5. We note your statement that if it were a standalone economy, the
U.S. middle market
 would be the third largest economy in the world based on GDP, but
were unable to
 confirm this statistic in the references cited in the registration
statement. Please revise
 the reference, or alternatively, delete the sentence.
 Payam Siadatpour
Nuveen Churchill BDC V
Page 3

Summary of Key Attributes of Investments
Environmental, Social and Governance Policies Pages 25-26

 6. Please briefly identify examples of the ESG factors and risks
considered.

The Private Offering Page 32

 7. Disclosure in the first full paragraph beginning on page 33 relates to
the remedies that
 the Company may pursue against an investor in default of its
obligations under the
 subscription agreement. On a supplemental basis, please explain to us
how the
 contractual remedy for a Defaulting Subscriber, whereby the Defaulting
Subscriber s
 Shares may be offered to other shareholders or third parties, or a
portion of the Shares
 may be transferred to the other shareholders, is consistent with Rule
23c-2 under the
 1940 Act (applicable to BDCs through Section 63), which requires that
redemptions be
 made in a manner as will not discriminate unfairly against any
holder ...

Promoters and Certain Control Persons Page 100

 8. Please disclose whether the initial portfolio held by the investment
adviser is being held
 pursuant to a warehouse facility or agreement and describe in
disclosure the material
 terms of the agreement(s). We may have additional comments based on
your response.

ITEM 15. FINANCIAL STATEMENTS AND EXHIBITS

 9. Please discuss in your response letter the fund s method for
accounting for offering
 costs. Please include appropriate U.S. GAAP citations that support the
accounting
 treatment.

 10. Please provide an analysis under Article 6 11 of Regulation S X and
discuss whether
 the Company will acquire all or substantially all of the portfolio
investments held by
 private funds. If so, please include financial statements and consents
for the private
 funds in the registration statement and ensure that these financial
statements have been
 audited in accordance with U.S. GAAP and Article 12 of Regulation S X
as required by
 Article 6 11 of Regulation S X.

 11. If the acquisition of the initial portfolio does not meet the
requirements in Article 6 11
 of Regulation S X, please include an unaudited special purpose
schedule of investments
 prepared in accordance with Article 12 12 of Regulation S X in the
body of the
 registration statement that includes the initial portfolio of
investments that the fund
 expects to purchase.

 * * * * * *

 We remind you that the Company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments,
action, or absence of
 Payam Siadatpour
Nuveen Churchill BDC V
Page 4

action by the staff. Should you have any questions regarding this letter,
please contact me at
(202) 551-3623 or Jeffrey Long at (202) 551-6983.

 Sincerely,

 /s/ Daniel S. Greenspan

 Senior Counsel

cc: Ryan Sutcliffe, Branch Chief
 Christian Sandoe, Assistant Director
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