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 VIA edgar
 December 4, 2025
 Securities and Exchange Commission
 Division of Investment Management
 Disclosure Review and Accounting Office
 100 F Street, N.E.
 Washington, D.C. 20549
 Attn: Lauren Hamilton
 Re:      Blackstone Secured Lending Fund (File No. 814 -01299 ) Annual Report on Form 10 -K for the year ended December 31, 2023
 Dear Ms. Hamilton:
 On behalf of Blackstone Secured Lending Fund (the “Fund”), we herewith transmit the Fund’s responses to the telephonic comments provided by you on behalf of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on October 1, 2024 and November 7, 2024, the supplemental comments provided on January 10, 2025 (the “January Supplemental Comments”), the supplemental comments provided on April 16, 2025 (the “April Supplemental Comments”) and the supplemental comment provided on August 5, 2025 regarding the Fund’s Annual Report on Form 10 -K for the year ended December 31, 2023, filed with the Commission on February 28, 2024 (the “Annual Report”). The Staff’s comments are described below and have been summarized to the best of our understanding. We have discussed the Staff’s comments with representatives of the Fund. The Fund’s responses to the Staff’s comments are set out immediately under the restated comments. Unless otherwise indicated, defined terms used herein have the meanings set out in the Annual Report.
 1.        The Staff notes that the Fund filed an automatic shelf registration statement on July 11, 2024, which included information from the Fund’s Annual Report. Please supplementally explain why the information contained in the Quarterly Report on Form 10 -Q for the quarter ended March 31, 2024, filed with the Commission on May 8, 2024, was not included in the automatic shelf registration statement filed on July 11, 2024.
 Response : The Fund respectfully notes that it did not file an automatic shelf registration statement on July 11, 2024. Rather, it filed its annual report to shareholders as an “ARS” submission in connection with its proxy statement related to its annual meeting of shareholders, which was also filed on July 11, 2024. Pursuant to Rule 14a -3 under the Securities Exchange Act of 1934, as amended, the Fund was required to deliver its annual report to shareholders in connection with the aforementioned proxy statement, and to furnish such report on EDGAR (which furnishing is also required by Rule 101 of Regulation S -T ). Submission of the Annual Report satisfied the annual report requirements of Rule 14a -3 , which does not require inclusion of the Fund’s most recent quarterly report. Separately, the Fund filed an automatic shelf registration statement on Form N -2ASR on July 26, 2022, and such registration statement forward incorporates by reference future filings by the Fund (including annual reports on Form 10 -K and quarterly reports on Form 10 -Q ).

 Ms. Lauren Hamilton

 December 4, 2025

 Item 7
 2.        The disclosure under “Net Realized Gain (Loss)” on page 124 of the Annual Report states that “[f]or the year ended December 31, 2023, we generated realized losses on investments of $23.9 million partially offset by realized gains on investments of $17.7 million, primarily from full or partial sales or restructures of our debt investments.” Please supplementally confirm the amount of such restructures and whether such disclosure is referring to debt extinguishment or debt restructuring.
 Response : The Fund supplementally confirms that the disclosure appropriately refers to debt restructuring and that approximately $6.7 million of realized losses were a result of the restructure of debt investments.
 Schedule of Investments
 3.        In the Schedule of Investments, please include all disclosures required for restricted securities in compliance with Rule 12 -12 of Regulation  S -X .
 Response : The Fund hereby confirms that it will make the requested change in future filings.
 4.        In the Schedule of Investments, the Staff notes various positions where fair value equals par. Please supplementally explain how this is in line with the Fund’s valuation policy and procedures.
 Response : The Fund employs a robust process to estimate the fair value of its investments at the end of each financial quarter. Please refer to the following excerpt from Part II, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations — Critical Accounting Estimates:
 Fair value is based on observable market prices or parameters or derived from such prices or parameters when such quotations are readily available. In accordance with Rule 2a -5 under the 1940 Act, a market quotation is “readily available” only when it is a quoted price (unadjusted) in active markets for identical instruments that a fund can access at the measurement date, provided that such a quotation is not considered to be readily available if it is not reliable. The Company utilizes mid -market pricing (i.e., mid -point of average bid and ask prices) to value these investments. These market quotations are obtained from independent pricing services, if available; otherwise generally from at least two principal market makers or primary market dealers. To assess the continuing appropriateness of pricing sources and methodologies, the Adviser regularly performs price verification procedures and issues challenges, as necessary, to independent pricing services or brokers, and any differences are reviewed in accordance with the valuation procedures. The Adviser does not adjust the prices unless it has a reason to believe market quotations are not reflective of the fair value of an investment. Examples of events that would cause market quotations to not reflect fair value could include cases when a security trades infrequently or not at all, causing a quoted purchase or sale price to become stale, or in the event of a “fire sale” by a distressed seller. All price overrides require approval from the Board.…Where prices or inputs are not available or, in the judgment of the Board are not reliable, valuation techniques based on the facts and circumstances of the particular investment will be utilized. Securities that are not publicly traded or for which market prices are not readily available are valued at fair value as determined in good faith by the Board, based on, among other things, the input of the Adviser, the Audit Committee of the Board (the “Audit Committee”) and independent valuation firms engaged on the recommendation of the Adviser and at the direction of the Board.
 The Fund notes that in following its valuation policies and procedures, as outlined above, 100% of par may be the best estimate of the fair value of a specific investment.

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 Ms. Lauren Hamilton

 December 4, 2025

 Notes to Consolidated Financial Statements
 5.        The Staff notes the inclusion of “Option pricing model” and “Expected volatility” under the columns labeled “Valuation Technique” and “Unobservable Input”, respectively, in the tables on page 193 under “Note 5. Fair Value Measurements”. The Staff further notes that the narrative description below such tables does not reference these items. The Staff notes that the narrative description of the uncertainty of the fair value measurement that would result from using unobservable inputs shall include the unobservable inputs disclosed when complying with the Accounting Standards Codification Topic 820, “Fair Value Measurement,” paragraph 820 -10-50-2 and its subsection (bbb) issued by the Financial Accounting Standards Board. Please revise accordingly.
 Response : The Fund hereby confirms that it will make the requested change in future filings.
 6.        Disclosure in “Note 3 — Agreements and Related Party Transactions — Administration Agreement” on pages 187 – 188 states, “The Administrator has elected to forgo any reimbursement for rent and other occupancy costs for the years ended December 31, 2023, 2022 and 2021.” Disclosure in “Item 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations — Key Components of Our Results of Operations — Expenses” on page 119 states, “However, the Administrator may seek reimbursement for such costs in future periods.” Please supplementally confirm if the referenced costs are included in the Statement of Operations and, if so, which line item they are included in, the amount of such costs and if there is any carry forward recoupment and the related amounts of such recoupment.
 Response : The Fund supplementally confirms that the referenced costs are not included in the Statement of Operations. While rent and other occupancy costs are expenses that are chargeable to the Fund pursuant to the Administration Agreement, the Administrator has historically elected not to charge rent and other occupancy costs to the Fund. Additionally, because the Administrator has simply chosen not to charge these costs to the Fund in the past, it has not undertaken to calculate the amount of rent and other occupancy costs allocable to the Fund. Therefore, there is no basis for seeking recoupment of these historical costs, and the Administrator will not seek recoupment of these historical costs. The Fund supplementally clarifies that the statement, “[T]he Administrator may seek reimbursement for such costs in future periods,” reflects only that the Administrator may in the future determine to establish an allocation methodology for rent and other occupancy costs and charge the Fund its allocable share in future periods.
 7.        Please disclose the average borrowing and interest rates for each financing agreement or arrangement discussed under “Note 6. Borrowings” in accordance with Rule 6 -04 .13 of Regulation  S -X .
 Response : Rule 6 -04 .13(a) requires that an issuer separately state certain amounts payable to certain categories of lenders within one year and after one year. Rule 6 -04 .13(b) requires, in relevant part, that an issuer provide in a note to the financial statements: (i) for unused lines of credit or short -term financings, the amount and terms (if significant) and the weighted average interest rate on borrowings outstanding, and (ii) for unused commitments for long -term financing arrangements, the amount and terms (if significant). The Fund respectfully notes that it believes that its existing disclosure in its notes to its financial statements, including, without limitation, the disclosure on page 200 of the Annual Report, complies with the requirements of Rule 6 -04 .13.
 8.        In future filings, in “Note 11. Financial Highlights and Senior Securities,” please ensure that the market value per share is presented in addition to the per share asset value in accordance with Form N -2 Item 4.1(f).
 Response : The Fund hereby confirms that it will make the requested change in future filings.

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 Ms. Lauren Hamilton

 December 4 , 2025

 January Supplemental Comments
 9.        With respect to comment 6 and your draft response thereto:
 a.        Please clarify the time period for which the Administrator can seek reimbursement. Can the Administrator seek reimbursement in the future for prior period costs or is it only for costs incurred in future periods?
 Response : The Fund respectfully notes that it and the Administrator interpret the Administration Agreement to provide that, if the Administrator wishes to be reimbursed for expenses incurred in a given fiscal period, then it must seek such reimbursement by indicating to the Fund that it intends to seek reimbursement before the Fund’s financial statements are issued for the preceding fiscal period and invoicing the Fund in a timely manner. If the Administrator has not indicated an intention to seek reimbursement for a particular expense incurred during a fiscal period before the Fund’s financial statements are issued for that fiscal period, then the Fund and the Administrator take the view that the Administrator has waived its right to be reimbursed for those expenses pursuant to the last paragraph of Section 4 of the Administration Agreement.
 b.        The draft response seems to indicate that the disclosure is meant to convey something different from what is stated: stating that the Administrator may seek reimbursement implies costs previously incurred. Does the Administration Agreement define reimbursement or recoupment to only include costs in the future? Please confirm whether the disclosure is accurate and, if not, please provide the planned updated disclosure to clarify what is meant.
 Response : Please see the response to comment 9.a above. Furthermore, the Administrator cannot seek reimbursement for expenses for which the Administrator has previously waived the right to be reimbursed. The Administrator also cannot seek reimbursement for expenses that were incurred by the Administrator in a prior fiscal period, because, as noted in the response to comment 9.a above, the Administrator is deemed to have waived its right to be reimbursed for those expenses if it has not indicated to the Fund that it intends to seek reimbursement before the Fund’s financial statements are issued for that fiscal period.
 The Fund will revise its disclosure in subsequent periodic reports to clarify what is meant as follows:
 From time to time, the Adviser or the Administrator may defer or waive fees and/or rights to be reimbursed for expenses. The . Pursuant to the Administration Agreement, the Fund’s allocable portion of the Administrator’s rent and other occupancy costs are expenses of the Fund. However, the Administrator has elected to forgo not historically, and does not currently, calculate the amount of rent and other occupancy costs allocable to the Fund and has not indicated an intention to seek reimbursement from the Fund for such costs. Thus, the Fund and the Administrator treat any such right to any reimbursement for rent and other occupancy costs for prior periods as having been waived pursuant to the terms of the Administration Agreement, including for the years ended December 31, 202X, 202X and 202X.  Additionally, since the Fund and the Administrator treat any such right to reimbursement for rent and occupancy costs as having been waived pursuant to the terms of the Administration Agreement, the Administrator cannot recoup any such expenses. However , in future periods , the Administrator may choose to establish an allocation methodology to calculate these costs and seek reimbursement from the Fund, in which case the Fund will accrue and reimburse the Administrator for such costs for that period s .
 c.        It appears the basis for not recording these expenses is rooted in the fact that the Administrator has not historically elected to charge the Fund. However, please confirm to the Staff whether, if elected, the Administrator would be legally allowed based on the Administration Agreement to charge these costs to the Fund, including costs incurred in arrears.
 Response : As noted in response to comment 9.b above, the Fund and the Administrator interpret the Administration Agreement to preclude the Administrator from recouping any expenses that the Administrator has previously waived.

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 Ms. Lauren Hamilton

 December 4 , 2025

 i.         Is there something about the Administration Agreement that would indicate that past behavior (i.e., not charging historically) would limit the Administrator’s rights to pursue reimbursement under the Administration Agreement?
 Response : As noted in response to comment 9.a above, the Fund and the Administrator interpret the Administration Agreement to limit the Administrator’s ability to seek reimbursement to expenses incurred by the Administrator for which it has not previously waived reimbursement. If the Administrator has not indicated to the Fund that it intends to seek reimbursement from the Fund for a particular expense incurred during a fiscal period before the Fund’s financial

CORRESP
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CORRESP

 November 30, 2018

VIA EDGAR AND EMAIL

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Mailstop 4720, Washington, D.C. 20549

 Attn.: Jay Williamson

Re:
 Blackstone / GSO Secured Lending Fund

 Amended Registration Statement on Form 10, File
No. 000-55974

 Ladies and Gentlemen:

On behalf of Blackstone / GSO Secured Lending Fund (the “Fund”), we are providing the following responses to comments
received by telephone from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on October 23, 2018 and October 24, 2018, relating to (1) the above-referenced
registration statement of the Fund (the “Amended Registration Statement”) filed with the Commission on October 1, 2018, pursuant to the Securities Exchange Act of 1934, as amended, through the Commission’s electronic data
gathering, analysis and retrieval system and (2) the Fund’s response letter dated October 1, 2018 (the “First Response Letter”), which responded to comments made by the Staff in a letter dated August 31, 2018 in
connection with the registration statement of the Fund on Form 10 filed with Commission on August 2, 2018.

 For convenience of
reference, the Staff’s comments have been reproduced herein. All capitalized terms used but not defined in this letter have the meanings given to them in the Amended Registration Statement.

Warehouse Transactions

 1. For each Warehouse
Transaction referenced in your response to comment 2 of the First Response Letter, please provide a timeline of the following dates:

•

 The date on which the Fund was incorporated;

March 26, 2018.

•

 The date on which negotiations began;

Approximately the first week of August 2018 for the Syndicated Warehouse; approximately the end of May 2018 for the Middle Market Warehouse.

•

 The date on which the Warehouse Transaction was signed and agreed to;

August 21, 2018 for the Syndicated Warehouse; September 10, 2018 for the Middle Market Warehouse.

•

 The date on which the Fund registered as a BDC under the Investment Company Act of 1940 Act, as amended (the
“1940 Act”); and

 October 26, 2018.

•

 The date on which the Fund is required or has the option to make purchases under the Warehouse
Transaction.

 For the Middle Market Warehouse, the Fund has the option to purchase assets from the warehouse when it
chooses (so long as before September 10, 2019) and, subject to a fundraising contingency, all qualifying assets must be purchased by September 10, 2019 (as may be extended if agreed by the warehouse provider or accelerated in the case of
an event of default).

 For the Syndicated Warehouse, the Fund or its affiliate has a conditional obligation to execute a takeout within
four months of the date on which the Fund raises equity capital of at least $200,000,000 (which has to be within six months of August 21, 2018).

In addition, please tell us who negotiated and approved the Warehouse Transactions on behalf of the Fund and what their relationship was or is to the Fund.
Please confirm whether the Warehouse Transactions were approved by a 1940 Act-compliant board and/or process.

The Warehouse Transactions were negotiated by the Fund’s Adviser on behalf of the Fund. The Warehouse Transactions were unanimously
approved by the Fund’s board of directors, which include (and included at the time of approval) a majority of directors that are not interested persons as would be required by Section 56(a) of the 1940 Act.

2. We note that portions of your response to comment 2 of the First Response Letter hinge upon whether the fundraising contingency is met. Under certain
circumstances, you may need to evaluate your disclosure obligation based on the probability of the occurrence and not simply whether the event has occurred. Please acknowledge and, if warranted, revise your existing and future disclosures.

The Fund acknowledges the comment and will update future disclosures as warranted.

3. With respect to the Forward Purchase Agreement with Warehouse Investment Limited filed as Exhibit 10.6 to the Amended Registration Statement, please:

•

 Advise whether every asset purchased by Warehouse Investment Limited that the Fund agrees is a qualifying
asset must be presented by Warehouse Investment Limited to the Fund for purchase;

 2

 Confirmed. The Fund must be presented with, and in fact has the obligation, subject to a
fundraising contingency, to purchase (prior to September 10, 2019 under the Forward Purchase Agreement), all qualifying assets held by Warehouse Investment Limited.

•

 Tell us who the “Facility Provider” referenced in Section 2.1 is and any
obligation you owe to them under the agreement or otherwise; and

 The Facility Provider is Warehousing Investment
Limited, the same entity that is the Seller under the Forward Purchase Agreement.

•

 Tell us more about the “broken deal” expenses referenced in Section 3.4,
including how and when they would be reflected in NAV.

 Section 3.4 provides that the Fund may, at its option,
request the Seller under the Forward Purchase Agreement to sell a qualifying asset (i.e., an asset the Fund is obligated, subject to a fundraising contingency, to purchase under the Forward Purchase Agreement) to parties other than the Fund. If the
Fund gives such a direction, the Fund agrees to pay the difference between the price the Fund would have had to pay to purchase such asset from the Seller under the Forward Purchase Agreement and the price the Seller actually obtains in the sale to
another party, which under Section 3.4 is referred to as a “broken deal” expense. Any broken deal expense would be reflected as a reduction in the Fund’s NAV when such expense is paid to the extent the expense was greater than
the liability, if any, for any difference in the market value of the applicable asset and the forward purchase price already reflected in the Fund’s NAV.

4. With respect to the Purchase and Sale Agreement with Sente Master Fund, L.P. filed as Exhibit 10.7 to the Amended Registration Statement, please:

•

 Explain how your characterization of the agreement in your response to comment 2 of the First Response Letter
is accurate when Section 1(a) of the agreement requires the Fund to execute a “GSO Takeout” or arrange for another entity to do so; and,

The previous characterization of the Purchase and Sale Agreement in response to comment 2 of the First Response Letter is consistent with
Section 1(a) of the agreement, which conditionally requires the Fund to execute or arrange the execution of a GSO Takeout in the form of a purchase of the equity interests of the warehouse entity from a third party. Section 1(a) defines
“GSO Takeout” by reference to the “Credit Agreement,” which defines “GSO Takeout” to include, in addition to such purchase of equity interests, a sale of all of the portfolio assets by the warehouse adviser, a
refinancing or a refinancing through a CLO transaction. Importantly, a GSO takeout event does not require the Fund to be the entity that effects a GSO Takeout. Rather the entity effecting a GSO Takeout can be the Fund or another GSO entity.

 3

•

 With respect to the Fund’s assumption of Sente Master Fund, L.P.’s obligations under each of the
“Credit Agreement” and the “Preference Share Subscription Agreement,” briefly explain what these obligations are and how they would be reflected in disclosure, when applicable.

Sente Master Fund, L.P. (“Sente”) has entered into a credit agreement, the salient terms of which are described on page 20 of
the Amended Registration Statement. If the Fund were to acquire the Sente warehouse vehicle and such credit facility were to remain outstanding, it would become an obligation of the Fund’s subsidiary and would be consolidated into the
Fund’s financial statements (along with the assets of the warehouse vehicle).

 Sente is the preferred investor. The preferred investor
has the obligation to subscribe for the preference shares of the warehouse vehicle (Macomb Park) by making capital contributions. Such capital contributions can be used for the warehouse vehicle to acquire assets, pay down the warehouse lenders or
cure certain overcollateralization breaches.

 5. Please disclose additional accounting information relating to the Warehouse Transactions. Will these
be accounted for as derivatives pursuant to FASB Accounting Standards Codification Topic 815, particularly for the Syndicated Warehouse, where you note on page 20 of the Amended Registration Statement there are 64 loans currently held? Will this
asset be accounted for as an equity interest in a CLO or will your financial statements reflect the underlying loans as assets?

 The
Fund’s right under the Syndicated Warehouse would meet the definition of a derivative under ASC 815. Upon the exercise of the right to acquire the equity interest, which the Fund currently intends to exercise prior to December 31,
2018, the Fund will consolidate the Syndicated Warehouse and include the underlying loans as assets in its consolidated financial statements.

With respect to the Middle Market Warehouse, the Fund has a forward purchase obligation on the underlying securities. However, since the
Forward Purchase Agreement requires physical settlement and the underlying securities are not readily convertible to cash, the forward purchase obligation does not meet the definition of a derivative under ASC 815. The Fund will record the forward
purchase obligation at fair value as the difference between (1) the current purchase price the Fund would be obligated to pay to purchase each asset under the Forward Purchase Agreement and (2) the current market value of each such asset
within assets or liabilities on the Fund’s Statement of Net Assets, depending on the mark-to-market position on any given measurement date.

 4

 6. Will the Warehouse Transaction vehicles be consolidated?

If the equity of the Syndicated Loan Warehouse vehicle is acquired by the Fund it will be consolidated. The Fund will not acquire the Middle
Market Warehouse vehicle, but will acquire the assets from that vehicle, which assets will be included in the Fund’s financial statements.

 7. Is
the Fund subject to recourse from the credit facility used by the Syndicated Warehouse?

 No. The credit facility is only recourse to
the Syndicated Warehouse vehicle.

 Item 1 Business (page 2)

8. We note your response to comment 5 of the First Response Letter and request additional clarification. As you know, one of the policy concerns expressed
in the 1940 Act relates to the potential to use one fund’s assets to prop up the assets or positions of another fund. This concern is expressed in Sections 1, 17 and 57 of the 1940 Act, as well as our standard
co-investment orders. Please provide further clarification of how the types of transactions proposed in your response are consistent with these items.

The Fund acknowledges the Staff’s concern, but respectfully submits that the transactions described in comment 5 of the First Response
Letter would be consistent with the requirements of the 1940 Act. The Fund understands that principal and joint transactions involving an investment company or business development company and its affiliates are generally prohibited, with limited
exceptions. In the scenario contemplated in the referenced disclosure, two separate transactions are being conducted (a repayment transaction and a new loan transaction), both transactions are conducted with a third party and neither transaction
results in a joint or principal transaction between the Fund and any of its affiliates. In other circumstances, such as where an affiliate of the Fund controls the third party, transactions of this sort may involve a joint or principal transaction,
in which case the Fund and/or its affiliates would not be permitted to participate in the transaction, which is why the relevant disclosure is qualified by “[s]ubject to the limitations of the 1940 Act.”

9. We note your response to comment 11 of the First Response Letter and request further information. With respect to your response, it appears you only use
quarter-end valuations unless there is information suggesting the valuation of an asset has changed due to a material event. It appears to us that portfolio NAV is a composite and a number of small valuation
changes in individual investments may be material to NAV as a whole, even when no individual material event has occurred at an investment. Please clarify how your valuation policy addresses this or otherwise explain.

 5

 The Fund acknowledges the Staff’s concern. As noted in the Fund’s disclosure
(e.g., “As required by the 1940 Act, a significant portion of our investment portfolio is and will be recorded at fair value as determined in good faith by our Board of Trustees and, as a result, there is and will be uncertainty as to
the value of our portfolio investments”), the fair valuation of illiquid securities is subject to significant uncertainties. The Fund’s policy with respect to illiquid assets is to update a quarterly valuation for any material events and
the Fund would do so even if the material event had a relatively small impact on the valuation of the applicable investment. In the absence of a material market event or material information about the issuer of the security, the Fund will not have
any basis on which to update the valuation of the security. Access to new immaterial information about the investment would not provide a clear basis on which to update a fair valuation. However, the Fund recognizes that significant macroeconomic or
industry-wide market events since the prior quarter could have an impact on the value of many of the Fund’s securities, which could result in material change in the Fund’s NAV (even if the valuation of individual securities does not change
materially). The Fund confirms that it will consider such events when determining the Fund’s NAV.

 10. We note your response to comment 16 of the
First Response Letter. Your disclosure references “any or all” of your assets while your response appears to be limited to assets pledged as collateral. Please clarify, as appropriate.

The Fund confirms that the analysis described in its response to comment 16 of the First Response Letter applies equally to unsecured
borrowings and that the reference to ‘pledged’ assets was incidental. Unsecured borrowers can also seek judgments to enforce their rights by means that include compelling the liquidation of the defaulting borrower’s assets.

Please call Benjamin Wells (212-455-2516) or me (202-636-5543) with any questions you may have regarding this filing or if you wish to discuss the above responses.

Very truly yours,

/s/ Rajib Chanda

 6

August 31, 2018
   Marisa J. Beeney Chief Legal Officer Blackstone/GSO Secured Lending Fund 345 Park Avenue, 31
st Floor
New York, NY 10154
Re: Blackstone/GSO Secured Lending Fund
Registration Statement on Form 10 Filed August 2, 2018
  File Nos. 000-55974 and 812-14835

Dear Ms. Beeney:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

1. Your Form 10 filing indicates yo ur intention “to file an electio n to be regulated as a business
development company …”  Based on your EDGAR filing hist ory you have no t filed a Form
N-6F or a Form N-54A.  Briefly explain your in tentions with respect to the filing of these
forms.

Marisa J. Beeney Blackstone/GSO Secured Lending Fund August 31, 2018 Page 2

Item 1Business, page 2

2. On page three you discuss the possibility that  you may acquire invest ments, including from
an affiliate, “at cost to  the warehousing party plus carrying charges, notwithst anding that the
fair market value of such investments may ha ve declined below or increased above such
cost at the time of transfer.”  You further stat e that “[a]ny such agre ement would be made at
or prior to the warehousing part y’s acquisition, such that the parties would not know at the
time of the agreement whether the investment  will appreciate or depreciate prior to the
Fund’s acquisition …”  With a view  to disclosure, please explain:
 How the types of warehousing  transactions you will us e work and are structured,
including who selects the inve stments that end up in the portfolio, what is included
in “carrying charges,” and other ma terial terms of the arrangement;
 How your obligation to purchase investments,  including potential losses thereon, is
accounted for and otherwise re flected in NAV. In addition , please explain how these
obligations are treated for purposes of comp lying with Section 61 of the Investment
Company Act of 1940 (1940 Act);
 Whether you will treat your  warehouse agreements as  an off-balance sheet
obligation for disclosure purposes pursuant to Item 303(a)(4) of Regulation S-K;
and,
 With respect to purchases involving affili ates, please explain how the transactions
are structured to comply with  Section 57 of the 1940 Act.
In addition, please add disclosure  addressing the potential for i nvestor dilution if you engage
in warehousing transactio ns under these terms.

3. Starting on page three you use footnotes as part of your disclo sure.  In some instances the
footnotes impede the disclosure.  Where possib le, please remove these footnotes and include
necessary context in th e relevant paragraph.

4. On page three you state you will employ “a defensive investment approach … generally
lending on a basis of 3.5 times to 5.5 times the borrower’s ear nings before interest, taxes,
depreciation and amortization and at loan to value ratios of 50%-65% …” Please revise your
disclosure to clarify what lending on a ba sis of 3.5 times to 5. 5 times borrower EBITDA
means.  In addition, please clarify how EBIDTA  is calculated – for example, is it based on
historical or projected numbers, does it includ e add-backs, etc.  Al so, please clarify how
“value” is determined for purposes of calculating your loan  to value ratios.

5. The disclosure on page four states that, “[s]ubj ect to the limitations of  the 1940 Ac t, we may
invest in loans of other securities, the procee ds of which may refinance or otherwise repay
debt or securities of companies whose debt is owned by othe r GSO funds.”  Please explain
to us what sorts of investments are contempl ated by this statement and how they can be
made consistent with the limitatio ns contained in the 1940 Act.

6. On page 15 under Viable Exit St rategy, you disclosure that, “[ i]n addition to payments of
principal and interest, we expect the primary me thods for the strategy to realize returns on

Marisa J. Beeney Blackstone/GSO Secured Lending Fund August 31, 2018 Page 3

our investment include refinancings, sales of po rtfolio companies, and in some cases initial
public offering and secondary o ffering.  Please clarify whether the loans you will typically
make will be amortizing or not ; if not, please consider the need for additio nal disclosure
about the assumptions and risks.  It is uncle ar for example, how ch anges in the credit
markets, economy, and ot her factors impact the viability of your exit st rategies, particularly
for investments at the lower end of your invest ment range.  Please revise or advise as
appropriate.

7. Supplementally tell us what sorts of inform ation is typically provided under “flash
reporting” and how it impacts your NAV calculations.

8. Please clarify the meaning of th e statement on page 18 that, “[w]hen, in order to maximize
our recovery, GS O is forced to take positio ns inconsistent with th e company’s sh areholders,
GSO expects to act quickly to enforce its rights.”

9. Please clarify what you me an by “fulcrum security ” as used on page 19.

10. On page 22 you disclose that  you “intend to conduct repurch ase offers … on a quarterly
basis at a price per share expected to reflect ne t asset value per share.”  Please clarify what
date will be used to calculat e the NAV investors w ill be receive  in a repurchase offer.

11. The disclosure on page 23 discussing the offe ring price following th e initial dr awdown date
includes a parenthetical “taking into account any investment valuation adjustments from the
last quarterly valuation date in accordance with the Fund’s valuatio n policy, subject to
certain adjustments.”  Please confirm your unde rstanding of Section 23 (b) of the 1940 Act
and explain how the NAV used at the time of sale will comply  with Section 23(b).
 Item 1A Risk Factors, page 35

12. You currently present over 25 pages of risk factor disclosure. Some of the risk factors are
lengthy, detailed, and complex.  Others are gene ric and would apply to any issuer.  We
are concerned that the length a nd complexity of the risk disc losure may distract investors
from other essential information contained in  your prospectus.  Please review the risk
factors to ensure it is clear a nd concise and revise as necessary.

13. The disclosure on page 36 indicates the A dvisory Agreement “has been approved,” and
“will have termination provisions that allow the parties to terminate the agreement.”
Disclosure later in your docume nt suggests the Advisory Agre ement has not been approved.
See, e.g., page 72 (“We expect to enter into …”).   Please revise as necessary.

14. The disclosure on page 45 sugg ests you may create a CLO vehicl e.  Please clarify who will
manage the CLO vehicle and an y compensation they may rece ive for structuring and/or
managing the vehicle.

Marisa J. Beeney Blackstone/GSO Secured Lending Fund August 31, 2018 Page 4

15. The disclosure on page 56 and elsewhere desc ribing your co-investm ent relief includes a
statement that “[n]either the adviser nor its affilia tes will be obligated to  offer us the right to
participate in any transactions originated by th em.”  Please reconcile this statement to the
conditions contained within your exemp tive application.

16. On page 58 you state that, in the event you de fault under a credit facili ty, “the agent for the
lenders under such borrowing fac ility could assume control of th e disposition of any or all of
our assets, including the selectio n of such assets to be disp osed and the timing of such
disposition …”  Please explain to us the circ umstances covered by this statement and how
permitting the lending  agent this level of cont rol would be consistent with Section 15 of the
1940 Act and the board and ad viser’s fiduciary duties.

17. We note the page 58 referenc e to “limitations on how borrowed funds may be used”
including restrictions based on  geography, industry, loan size , payment freque ncy, and the
like.  Please confirm that any material restrictions in your  credit agreements impacting
investment flexibility w ill be described in disclosure once known.
 Item 2 Financial Info rmation, page 64

18. The disclosure here and elsewhere indicate s that certain costs and expenses of the
administrator and adviser will be allocated to you.  In  an appropriate locat ion, please explain
the allocation methodologies th at will be used to allocate these co sts and expenses.
 Item 11 Description of th e Registrant’s Securities to  be Registered, page 96

19. Please confirm the disclosure on page 97 unde r Amendment of the Decl aration of Trust; No
Approval by Shareholders is not designed to limit shareholder voting rights under the 1940
Act, including  Section 58.
 Item 15 Financial Statements and Exhibits

20. We note that you have not filed required exhibits.  Please note th at we review and frequently
comment upon these exhibits  and plan accordingly.

Marisa J. Beeney Blackstone/GSO Secured Lending Fund August 31, 2018 Page 5

Closing
  We remind you that the fund  and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding an y review, comments action or absence of action by
the staff.
                                      *  *  *  *  *  If you have any questions prior to filing an  amendment, please call me at (202) 551-3393.

Sincerely,

Jay Williamson Senior Counsel

    cc: Simpson Thacher & Bartlett LLP   Rajib Chanda   Christopher Martini   Ben Wells   GSO Capital Partners LP   Steve Flantsbaum