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 Document Yukon New Parent, Inc. c/o 180 Degree Capital Corp. 7 N. Willow Street, Suite 4B Montclair, New Jersey 07042 July 11, 2025 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C.  20549-3628 Attention: Robert Arzonetti Re:    Yukon New Parent, Inc. Registration Statement on Form S-4, as amended (File No. 333-286043) Acceleration Request:     Requested Date: July 11, 2025     Requested Time: 4:00 p.m. Eastern Time Ladies and Gentlemen:     Pursuant to Rule 461 of the Securities Act of 1933, as amended, Yukon New Parent, Inc. (the “ Company ”) hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-4 (File No. 333-286043), as amended (the “ Registration Statement ”), so that the Registration Statement may become effective at the “Requested Date” and “Requested Time” set forth above, or as soon thereafter as practicable.     Please contact John Mahon of Proskauer Rose LLP, counsel to the Company, at (202) 416-6828 or via email at jmahon@proskauer.com, with any questions you may have regarding this request. In addition, please notify Mr. Mahon by telephone when this request for acceleration has been granted. Very truly yours, /s/ Daniel B. Wolfe                 Daniel B. Wolfe President, Chief Financial Officer and Director cc: Proskauer Rose     John Mahon     Joshua Apfelroth     Michael Ellis Dechert LLP     Kenneth Young     Stephen Pratt

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 July 10, 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. 3 to the Registration Statement on Form S-4
 Filed July 9, 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 July 8, 2025
letter.

Amendment No. 3 to the Registration Statement on Form F-1
General

1. We note your revised disclosure and response to prior comment 2. Please
advise us
 why you believe the joint investor presentation after the announcement
of the merger,
 including the slide relating solely to Mount Logan's illustrative ROE,
does not relate
 to the disclosure on pages 21 and 124 and the Background of the Merger.
Please
 revise pages 21 and 124 to further clarify how the Mount Logan board
considered "the
 implied breakeven return on equity to shareholders of Mount Logan" in
making its
 recommendation to approve the transaction. For example, clarify the
quantification
 and assumptions underlying the phrase "implied breakeven," and explain
whether this
 was one of the material factors that "favored the conclusion" of the
board or whether it
 July 10, 2025
Page 2

 was a negative factor. For example, it is unclear if the "limited"
opportunity for the
 ROE to be accretive was considered by the board as a possible risk or
negative factor.
 With respect to the joint investor presentation, it is unclear if the
merger is expected to
 facilitate Mount Logan raising the illustrative $10 million equity
contribution, which
 appears to be a key assumption underlying the 26% ROE. Provide
corresponding
 disclosure in the Background of the Merger section to the extent
expected ROE
 opportunities were material to the discussions.
Control Persons and Principal Shareholders of Mount Logan, page 372

2. Please revise to identify the natural persons who have or
 share voting and/or dispositive powers over the shares held by the
entities in the table.
 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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 SEC Response Letter July 10 2025

 Proskauer Rose LLP 1001 Pennsylvania Avenue, NW Suite 600 South Washington, DC 20004-2533 July 10, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, NE Washington, DC 20549 Attention : Robert Arzonetti Re:    Yukon New Parent, Inc. Amendment No. 3 Registration Statement on Form S-4 Dear Mr. Arzonetti: On behalf of Yukon New Parent, Inc. (the “Company” ), set forth below are the Company’s responses to the comments provided by the staff of the Division of Corporation Finance (the “Staff” ) of the Securities and Exchange Commission (the “Commission” ) to the Company in its letter dated July 10, 2025 with respect to the Company’s amended registration statement on Form S-4 (the “Registration Statement” ) and the Company's response letter addressing the Staff's prior comments with respect to the Registration Statement filed on July 9, 2025. The Staff’s comments are set forth below in italics and are followed by the Company’s responses. Capitalized terms used below but not otherwise defined herein shall have the meanings ascribed to them in the Registration Statement. Where revisions to the Registration Statement are referenced in the below response, such revisions included in the changed pages attached as an exhibit hereto and will be included in the definitive proxy statement/prospectus filed pursuant to Rule 424 following the effectiveness of the Registration Statement. Amendment No. 3 to the Registration Statement on Form S-4 General 1. Comment : We note your revised disclosure and response to prior comment 2. Please advise us why you believe the joint investor presentation after the announcement of the merger, including the slide relating solely to Mount Logan's illustrative ROE, does not relate to the disclosure on pages 21 and 124 and the Background of the Merger. Please revise pages 21 and 124 to further clarify how the Mount Logan board considered "the implied breakeven return on equity to shareholders of Mount Logan" in making its recommendation to approve the transaction. For example, clarify the quantification and assumptions underlying the phrase "implied breakeven," and explain whether this was one of the material factors that "favored the conclusion" of the board or whether it was a negative factor. For example, it is unclear if the "limited" opportunity for the ROE to be accretive was considered by the board as a possible risk or negative factor. With respect to the joint investor presentation, it is unclear if the merger is expected to facilitate Mount Logan raising the illustrative $10 million equity contribution, which appears to be a key assumption underlying the 26% ROE. Provide corresponding disclosure in the Background of the Merger section to the extent expected ROE opportunities were material to the discussions." Beijing | Boca Raton | Boston | Chicago | Hong Kong | London | Los Angeles | New Orleans | New York | Paris | São Paulo | Washington, DC Response : The Company has revised the disclosure in the "Mount Logan's Reasons for the Mergers and Recommendation of the Mount Logan Board" section of the Registration Statement in response to the Staff’s comment. Control Persons and Principal Shareholders of Mount Logan, page 372 2. Comment : Please revise to identify the natural persons who have or share voting and/or dispositive powers over the shares held by the entities in the table. Response : The Company has revised the disclosure in the "CONTROL PERSONS AND PRINCIPAL SHAREHOLDERS OF MOUNT LOGAN" section of the Registration Statement in response to the Staff’s comment. * * * 2 If you have any questions or additional comments concerning the foregoing, please contact the undersigned by phone at 202.416.6828 or by email at jmahon@proskauer.com . Sincerely, /s/ John J. Mahon     John J. Mahon, Esq. cc:     Daniel B. Wolfe / 180 Degree Capital Corp.     Kevin M. Rendino / 180 Degree Capital Corp.         Nikita Klassen / Mount Logan Capital Inc.     Joshua A. Apfelroth / Proskauer Rose LLP     Michael E. Ellis / Proskauer Rose LLP     Kenneth E. Young / Dechert LLP     Stephen R. Pratt / Dechert LLP 3

 Larger Balance Sheet. New Mount Logan will have a larger balance sheet that is expected to allow New Mount Logan to scale through investment into other organic and inorganic growth opportunities across its asset management and insurance solutions businesses. For example, on an organic basis, New Mount Logan currently expects to use a portion of 180 Degree Capital’s cash and proceeds from the disposition of 180 Degree Capital’s investments to invest in its insurance solutions business. This increased revenue and cost synergies resulting from the Business Combination is expected to strengthen the independent balance sheet of New Mount Logan. Leadership and Governance. At closing, Mount Logan’s current chief executive officer, Edward (Ted) Goldthorpe, is expected to serve as chairman and chief executive officer of New Mount Logan. New Mount Logan will have a seven-member board of directors, comprised of Edward (Ted) Goldthorpe as Chairman, four additional independent directors designated by Mount Logan, one independent director designated by 180 Degree Capital, and one independent director mutually agreed to by Mount Logan and 180 Degree Capital. Ownership of New Mount Logan. Under the terms of the Merger Agreement, shareholders of each of Mount Logan and 180 Degree Capital will receive an amount of newly issued shares of New Mount Logan Common Stock based on the ratio of Mount Logan’s transaction equity value at signing of $67.4 million, subject to certain pre- closing adjustments, relative to the net asset value of 180 Degree Capital at closing. Based on the estimated net asset value of 180 Degree Capital as of July 8, 2025, the estimated post-transaction shareholder ownership of New Mount Logan is expected to be approximately 60% for MLC Shareholders and 40% for 180 Degree Capital shareholders. 180 Degree Capital Investment Capabilities and Network of Relationships. 180 Degree Capital’s track record of investing in public markets and its deep network of relationships are expected to help fuel expansion of Mount Logan’s bespoke private credit solutions into publicly traded companies. New Mount Logan’s alternative asset management platform would retain Mount Logan’s fee generating $2.4 billion assets under management (as of September 30, 2024) and would have expanded sourcing opportunities in public markets supported by 180 Degree Capital’s capabilities and deep network of relationships.180 Degree Capital Investment Capabilities and Network of Relationships. 180 Degree Capital’s track record of investing in public markets and its deep network of relationships are expected to help fuel expansion of Mount Logan. Expected Tax Treatment of the MLC Merger. The MLC Merger is anticipated to be treated as a tax-free exchange for U.S. federal income tax purposes and Canadian federal income tax purposes and MLC Shareholders are not expected to recognize any gain or loss for U.S. federal income tax purposes or Canadian federal income tax purposes as a result of the MLC Merger (subject to the qualifications set forth under “Certain U.S. Federal Income Tax Consequences of the Mergers” and “The Mergers - Certain Canadian Federal Income Tax Consequences”). Support by Directors, Officers and Shareholders. Directors, officers and shareholders of Mount Logan who collectively hold approximately 29% of the outstanding MLC Common Shares as of January 16, 2025, entered into Voting Agreements pursuant to which they have agreed to vote in favor of the MLC Merger and the MLC Domestication. Ability to Respond to Superior Proposals. Under the terms of the Merger Agreement, the Mount Logan Board is able to respond to any unsolicited bona fide written proposal that, having regard for all the terms and conditions of such proposal, is or is reasonably likely to lead to an MLC Superior Proposal. Implied Breakeven Return on Equity. Due to the fixed cost nature of running a public company, the required return on equity to shareholders of Mount Logan in order for the Business Combination to be accretive to them is limited. Comparison to Similarly Contemplated Transactions. Mount Logan’s management team has spent several years evaluating transactions similar to the Business Combination and has been vigilant, patient and prudent in determining the best transaction for its shareholders. As part of its ongoing evaluation of Mount Logan’s business, management had analyzed potential strategic transactions, however, in each such instance but one, management’s analysis never progressed beyond early stages, as a result of a combination of due diligence or valuation issues or an absence of strategic fit. These discussions with counterparties were preliminary and had not progressed to the point Table of Contents 124

 CONTROL PERSONS AND PRINCIPAL SHAREHOLDERS OF MOUNT LOGAN The following table sets forth certain information with respect to the beneficial ownership of MLC Common Shares as of July 8, 2025, for: • each member of the Mount Logan Board; • each named executive officer of Mount Logan; • the members of the Mount Logan Board and Mount Logan’s current executive officers as a group; and • each person known by Mount Logan to beneficially own 5% or more of the outstanding MLC Common Shares. Mount Logan has determined beneficial ownership in accordance with the rules of the SEC, and therefore it represents sole or shared voting or investment power with respect to Mount Logan’s securities. Unless otherwise indicated below, to Mount Logan’s knowledge, the persons and entities named in the table below have sole voting and sole investment power with respect to all MLC Common Shares that they beneficially own, subject to community property laws where applicable. Mount Logan has deemed MLC Common Shares subject to restricted stock units and dividend equivalent units outstanding as of July 8, 2025 that were exercisable or issuable or will become exercisable or issuable within 60 days of the closing of the Business Combination to be outstanding and to be beneficially owned by the person holding the restricted stock unit or dividend equivalent unit for the purpose of computing the percentage ownership of that person, but has not treated them as outstanding for the purpose of computing the percentage ownership of any other person. Mount Logan has based percentage ownership of MLC Common Shares on 29,182,452 MLC Common Shares outstanding as of July 8, 2025. Security Ownership of Other Beneficial Owners Based on information available to Mount Logan as of July 8, 2025, Mount Logan knew of no person who beneficially owned 5% of the outstanding MLC Common Shares, except as set forth below. 5% Shareholders Shares Beneficially Owned Ownership Percentage(1) EQUINITI TRUST COMPANY LLC AS AGENT FOR RUNWAY GROWTH CAPITAL LLCLLC(2) 48 WALL ST FL 22, NEW YORK NY 10005-2984 2,693,071 9.23% EJF CAPITAL LLCLLC(3) 2107 WILSON BLVD STE 410, ARLINGTON VA 22201-3042 2,381,814 8.16% H-CA HOLDINGS LLCLLC(4) 415 BEDFORD RD STE 102, PLEASANTVILLE NY 10570-3014 1,579,671 5.41% (1) As of July 8, 2025, there were 29,182,452 MLC Common Shares outstanding. (2) David Spreng, Greg Greifeld and Thomas Raterman have shared voting and dispositive power over the shares held by Runway Growth Capital LLC. (3) Neal J. Wilson has sole voting and dispositive power over the shares held by EJF Capital LLC. (4) Kenneth King has sole voting and dispositive power over the shares held by H-CA Holdings LLC. Security Ownership of Mount Logan Directors and Executive Officers Unless otherwise indicated, the address of each beneficial owner listed in the table below is c/o Mount Logan Capital Inc., 650 Madison Avenue, 3rd Floor, New York, NY 10022. Table of Contents 372

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 SEC Response Letter - Corp Fin 7pm Comments July 10 2025

 Proskauer Rose LLP 1001 Pennsylvania Avenue, NW Suite 600 South Washington, DC 20004-2533 July 10, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, NE Washington, DC 20549 Attention : Robert Arzonetti Re:    Yukon New Parent, Inc. Amendment No. 3 Registration Statement on Form S-4 Dear Mr. Arzonetti: On behalf of Yukon New Parent, Inc. (the “Company” ), per our conversation this afternoon with the staff of the Division of Corporation Finance (the “Staff” ) of the Securities and Exchange Commission (the “Commission” ), attached as an exhibit hereto are additional changed pages reflecting further edits made in response to the Staff’s prior comment no. 1 included in its letter, dated July 10, 2025, with respect to the Company’s amended registration statement on Form S-4 (the “Registration Statement” ) and the Company's response letter addressing the Staff's prior comments with respect to the Registration Statement filed on July 9, 2025. The Company confirms that the revisions reflected in the attached changed pages will be included in the definitive proxy statement/prospectus filed pursuant to Rule 424 following the effectiveness of the Registration Statement. * * * Beijing | Boca Raton | Boston | Chicago | Hong Kong | London | Los Angeles | New Orleans | New York | Paris | São Paulo | Washington, DC If you have any questions or additional comments concerning the foregoing, please contact the undersigned by phone at 202.416.6828 or by email at jmahon@proskauer.com . Sincerely, /s/ John J. Mahon     John J. Mahon, Esq. cc:     Daniel B. Wolfe / 180 Degree Capital Corp.     Kevin M. Rendino / 180 Degree Capital Corp.         Nikita Klassen / Mount Logan Capital Inc.     Joshua A. Apfelroth / Proskauer Rose LLP     Michael E. Ellis / Proskauer Rose LLP     Kenneth E. Young / Dechert LLP     Stephen R. Pratt / Dechert LLP 2

 modified), including the Business Combination, see the sections entitled “The Mergers—180 Degree Capital’s Reasons for the Mergers” and “Recommendation of the 180 Degree Capital Board.” Mount Logan’s Reasons for the Mergers and Recommendation of the Mount Logan Board The Mount Logan Board consulted with Mount Logan’s management as well as its legal and other advisors and considered numerous factors and, as a result, the Mount Logan Board, including its independent directors, determined that the MLC Merger is in Mount Logan’s best interests and the best interests of Mount Logan’s shareholders. Certain material factors considered by the Mount Logan Board, including its independent directors, that favored the conclusion of the Mount Logan Board that the MLC Merger is in Mount Logan’s best interests and the best interests of Mount Logan’s shareholders included, among others: • 180 Degree Capital’s track record of investing in public markets and its deep network of relationships, which are expected to help further expand New Mount Logan’s business; • New Mount Logan will have a larger balance sheet that will support future investment; • the Business Combination will result in continuity of the management team, with Mount Logan’s current CEO, Edward (Ted) Goldthorpe, expected to serve as Chairman and CEO of New Mount Logan, and Mount Logan will be entitled to appoint four independent directors (as defined in Nasdaq Listing Rule 5605(a)(2)) on New Mount Logan’s seven-person board; • MLC Shareholders will receive proportionate ownership of New Mount Logan determined by reference to Mount Logan’s $67.4 million transaction equity value at signing of the Merger Agreement, subject to certain pre-closing adjustments, relative to 180 Degree Capital’s net asset value at Closing; • the expected tax treatment of the MLC Merger; • support of the Business Combination from directors, officers and shareholders of Mount Logan who collectively held approximately 29% of the outstanding MLC Common Shares as of January 16, 2025; • Mount Logan’s ability to respond to an unsolicited bona fide written proposal that is or is reasonably likely to lead to an MLC Superior Proposal; • the implied breakeven return on equity to shareholders of Mount Logan taking into account the economics and structuring of the Business Combination, which the Mount Logan Board believed would be positive if the Business Combination is completed; • the vigilance, patience and prudence of the Mount Logan management team in evaluating similar transactions; • the Merger Agreement is the result of an arm’s length negotiation process and has been unanimously recommended by the Mount Logan Board, including independent directors; • the required approvals of the shareholders of Mount Logan to the Business Combination is protective of their rights; • shareholders of Mount Logan who do not vote in favor of the Arrangement Resolution will have dissent rights with respect to the Arrangement pursuant to the OBCA and the Interim Order; • the potential for Mount Logan to deliver near and long term value to shareholders of Mount Logan as a result of the Business Combination, when compared to not consummating the Business Combination; • the uncertainty surrounding Mount Logan’s ability to raise required financing if the Business Combination is not consummated; • the absence of required material regulatory approvals, other than customary regulatory approvals; Table of Contents 21

 Larger Balance Sheet. New Mount Logan will have a larger balance sheet that is expected to allow New Mount Logan to scale through investment into other organic and inorganic growth opportunities across its asset management and insurance solutions businesses. For example, on an organic basis, New Mount Logan currently expects to use a portion of 180 Degree Capital’s cash and proceeds from the disposition of 180 Degree Capital’s investments to invest in its insurance solutions business, which the Mount Logan Board expected would generate a positive return on invested capital in the insurance solutions business through the additional generation of spread- related earnings and fee-related earnings over time. This increased revenue and cost synergies resulting from the Business Combination is expected to strengthen the independent balance sheet of New Mount Logan. Leadership and Governance. At closing, Mount Logan’s current chief executive officer, Edward (Ted) Goldthorpe, is expected to serve as chairman and chief executive officer of New Mount Logan. New Mount Logan will have a seven-member board of directors, comprised of Edward (Ted) Goldthorpe as Chairman, four additional independent directors designated by Mount Logan, one independent director designated by 180 Degree Capital, and one independent director mutually agreed to by Mount Logan and 180 Degree Capital. Ownership of New Mount Logan. Under the terms of the Merger Agreement, shareholders of each of Mount Logan and 180 Degree Capital will receive an amount of newly issued shares of New Mount Logan Common Stock based on the ratio of Mount Logan’s transaction equity value at signing of $67.4 million, subject to certain pre- closing adjustments, relative to the net asset value of 180 Degree Capital at closing. Based on the estimated net asset value of 180 Degree Capital as of July 8, 2025, the estimated post-transaction shareholder ownership of New Mount Logan is expected to be approximately 60% for MLC Shareholders and 40% for 180 Degree Capital shareholders. 180 Degree Capital Investment Capabilities and Network of Relationships. 180 Degree Capital’s track record of investing in public markets and its deep network of relationships are expected to help fuel expansion of Mount Logan’s bespoke private credit solutions into publicly traded companies. New Mount Logan’s alternative asset management platform would retain Mount Logan’s fee generating $2.4 billion assets under management (as of September 30, 2024) and would have expanded sourcing opportunities in public markets supported by 180 Degree Capital’s capabilities and deep network of relationships.180 Degree Capital Investment Capabilities and Network of Relationships. 180 Degree Capital’s track record of investing in public markets and its deep network of relationships are expected to help fuel expansion of Mount Logan. Expected Tax Treatment of the MLC Merger. The MLC Merger is anticipated to be treated as a tax-free exchange for U.S. federal income tax purposes and Canadian federal income tax purposes and MLC Shareholders are not expected to recognize any gain or loss for U.S. federal income tax purposes or Canadian federal income tax purposes as a result of the MLC Merger (subject to the qualifications set forth under “Certain U.S. Federal Income Tax Consequences of the Mergers” and “The Mergers - Certain Canadian Federal Income Tax Consequences”). Support by Directors, Officers and Shareholders. Directors, officers and shareholders of Mount Logan who collectively hold approximately 29% of the outstanding MLC Common Shares as of January 16, 2025, entered into Voting Agreements pursuant to which they have agreed to vote in favor of the MLC Merger and the MLC Domestication. Ability to Respond to Superior Proposals. Under the terms of the Merger Agreement, the Mount Logan Board is able to respond to any unsolicited bona fide written proposal that, having regard for all the terms and conditions of such proposal, is or is reasonably likely to lead to an MLC Superior Proposal. Implied Breakeven Return on Equity. Due to the fixed cost nature of running a public company, the required return on equity to shareholders of Mount Logan in order for the Business Combination to be accretive to them is limitednot significant, and therefore the Mount Logan Board expected the Business Combination to generate a positive return on equity to shareholders of Mount Logan. Comparison to Similarly Contemplated Transactions. Mount Logan’s management team has spent several years evaluating transactions similar to the Business Combination and has been vigilant, patient and prudent in determining the best transaction for its shareholders. As part of its ongoing evaluation of Mount Logan’s business, Table of Contents 124

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<TEXT>
 July 8, 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
 Response dated July 3, 2025
 File No. 333-286043
Dear Daniel B. Wolfe:

 We have reviewed your correspondence dated July 3, 2025 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 July 1, 2025
letter.

Response dated July 3, 2025
Summary, page 11

1. We note multiple references to 180 Degree Capital Corp. being an
investment
 company registered under the 1940 Act with the SEC, and the plan to
deregister.
 Refer to comment 5 of our June 3, 2025 letter. Please revise here and
where
 appropriate to summarize the timeline for transitioning between
regulatory regimes. In
 this regard, it appears that dispositions may be required in order to
fall within the
 40% test. Please revise to clarify.
 July 8, 2025
Page 2
General

2. We note your response to prior comment 1 regarding the 26% return on
equity
 disclosed in the January 2025 presentation about the merger and assuming
 the "hypothetical $10 million capital contribution from Mount Logan."
Please revise
 as requested in prior comment 1 or advise us why you believe the 26% ROE
is not
 inconsistent with the references on pages 20 and 121 of the registration
statement to
 an "Implied Breakeven Return on Equity." Additionally, please revise
Background of
 the Merger and where appropriate to address the hypothetical $10 million
capital
 contribution from Mount Logan or advise us why you believe that element
of the
 investor presentation is not material to investors.
3. Please revise Management of New Mount Logan on page 197 to identify the
directors
 currently omitted in brackets. In this regard, we note the Form 425
dated June 27,
 2025, which refers to a "Director Election Special Meeting." Please
revise Summary
 and where appropriate to address the Director Election Special Meeting
and related
 shareholder demand. Revise to explain the assumed timing of delivering
proxy
 materials and conducting meetings. With a view to clarifying disclosure,
advise us
 why the director election is not being conducted at the special meeting
for the merger.

 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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 Document Proskauer Rose LLP 1001 Pennsylvania Avenue, NW Suite 600 South Washington, DC 20004-2533 July 3, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, NE Washington, DC 20549 Attention : Robert Arzonetti Re:    Yukon New Parent, Inc. Amendment No. 2 Registration Statement on Form S-4 Dear Mr. Arzonetti: On behalf of Yukon New Parent, Inc. (the “Company” ), set forth below are the Company’s responses to the comments provided by the staff of the Division of Corporation Finance (the “Staff” ) of the Securities and Exchange Commission (the “Commission” ) to the Company in its letter dated July 1, 2025 with respect to Amendment No. 2 to the Company’s registration statement on Form S-4 (the “Registration Statement” ) and the Company's response letter addressing the Staff's prior comments with respect to the Registration Statement filed concurrently therewith. The Staff’s comments are set forth below in italics and are followed by the Company’s responses. Capitalized terms used below but not otherwise defined herein shall have the meanings ascribed to them in the Registration Statement. Where revisions to the Registration Statement are referenced in the below response, such revisions have been included in the changed pages attached as an exhibit hereto. Form S-4 Filed June 12, 2025 General 1. Comment : 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. Response : The Company acknowledges the Staff's comment and respectfully notes on a supplemental basis that the reference to a “~26% Return on Equity” reflects an illustrative and hypothetical example of the potential economics arising from an integrated asset management and insurance “flywheel” structure, strategy, and integration. It does not represent a forecast, target, or projection of actual or expected returns of Mount Logan's stock performance, nor an expected return of the Business Combination. The referenced example on page 14 of the “MLC-TURN Executive Summary” investor presentation demonstrates, under a stylized set of assumptions, the potential output from a hypothetical $10 million capital contribution from Mount Logan, the asset manager, into its wholly owned insurance company, Ability, assuming specific parameters for Beijing | Boca Raton | Boston | Chicago | Hong Kong | London | Los Angeles | New Orleans | New York | Paris | São Paulo | Washington, DC operating expenses, liabilities, asset yield, and fee generation. These inputs were based on generalized assumptions including regulatory permissible leverage, illustrative asset management fee rates, and estimated net asset yields informed by historical and peer-based data. This example is completely independent from 180 Degree Capital and the Business Combination itself. This example was presented with a footnote disclaimer stating its illustrative and non-predictive nature. Its intent was to explain how the economics of a vertically integrated platform, with both asset management and insurance businesses, which Mount Logan is prior to the Business Combination, could conceptually compound returns on capital within its platform with additional capital to invest into its insurance business. In an effort to remove any ambiguities regarding the interpretation of the slide, the Company advises the Staff that it plans to file an updated presentation on Form 425 that includes the changes shown as attached as an exhibit hereto. About This Preliminary Joint Proxy Statement/Prospectus, page i 2. Comment : 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. Response : The Company advises the Staff that it has revised the disclosure on page i of the Registration Statement in response to the Staff’s comment. The Mergers Mount Logan's Reasons for the Mergers, page 120 3. Comment : 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. Response : The Company advises the Staff that Mount Logan has revised the disclosure on page 123 of the Registration Statement in response to the Staff’s comment to clarify that the aforementioned proposed business combination with Canaccord Genuity G Ventures Corp. was mutually abandoned when it was determined that certain required regulatory review processes would prevent the transaction from being executed on a timeline acceptable to both parties. Opinion of 180 Degree Capital's Financial Advisor MLC Projections, page 134 4. Comment : 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 2 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. Response : The Company advises the Staff that Mount Logan has revised the disclosure on page 136 of the Registration Statement in response to the Staff’s comment. 5. Comment : 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. Response : The Company has revised the above-referenced statements included beginning on page 136 of the Registration Statement in response to the Staff’s comment. Regulatory Approvals and Related Matters, page 135 6. Comment : 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. Response : The Company advises the Staff that Mount Logan has revised the disclosure on page 138 of the Registration Statement in response to the Staff’s comment. Critical Accounting Estimates - Insurance Solutions Segment Goodwill, page 295 7. Comment : 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. Response : The Company advises the Staff that Mount Logan has revised the disclosure beginning on pages 305 and 339 of the Registration Statement in response to the Staff’s comment. 3 Management's Discussion and Analysis, page 340 8. Comment : 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. Response : The Company advises the Staff that 180 Degree Capital has revised the disclosure on page 353 of the Registration Statement in response to the Staff’s comment. Index to Financial Statements 180 Degree Capital Corp., page F-1 9. Comment : 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. Response : The Company advises the Staff that the page numbers referencing 180 Degree Capital's financial statements for the period ending March 31, 2025, have been updated to reflect the correct page references. The Company further advises the Staff on a supplemental basis that it does not believe that 180 Degree Capital, as a registered investment company, is required to include financial statements for the period ending March 31, 2024. Specifically, the financial statements included in the Registration Statement for the period ending March 31, 2025 meet the technical requirement of Item 3-01(e) of Regulation S-X, which requires a balance sheet dated within 135 days of the date of filing. As a registered investment company, however, 180 Degree Capital is not otherwise typically required to prepare or report similar interim quarterly information. Additionally, the financial statements included for the period ending March 31, 2025 conform to the requirements under Regulation S-X applicable to registered investment companies. The inclusion of comparison data in the MD&A for the three months ended March 31, 2025 and 2024 was included solely because such comparative period was required to conform with Item 303 of 4 Regulation S-X. The Company advises the Staff that it has removed the reference to the three months ended March 31, 2024 from the index to the financial statements of 180 Degree Capital. The Company also advises the Staff that 180 Degree Capital has revised the disclosure in the Registration Statement on page F-228 to conform with the requirements of Rule 3-03(d) of Regulation S-X. * * * 5 If you have any questions or additional comments concerning the foregoing, please contact the undersigned by phone at 202.416.6828 or by email at jmahon@proskauer.com . Sincerely, /s/ John J. Mahon     John J. Mahon, Esq. cc:     Daniel B. Wolfe / 180 Degree Capital Corp.     Kevin M. Rendino / 180 Degree Capital Corp.         Nikita Klassen / Mount Logan Capital Inc.     Joshua A. Apfelroth / Proskauer Rose LLP     Michael E. Ellis / Proskauer Rose LLP     Kenneth E. Young / Dechert LLP     Stephen R. Pratt / Dechert LLP 6

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<TEXT>
 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.
</TEXT>
</DOCUMENT>

<DOCUMENT>
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<TEXT>
 June 3, 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. 1 to the Registration Statement on Form S-4
 Filed May 6, 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.

Form S-4 Filed May 6, 2025
Management of New Mount Logan, page 22

1. Please revise your disclosure to provide a clearer overview of who will
lead the
 combined company. In this regard, we note the reference on page 16 to
New Mount
 Logan relying on "BCPA and Key BCPA Personnel."
Risk Factors, page 36

2. Please disclose any material risks resulting from the deregistration of
180 Degree
 Capital as a business development company under the Investment Company
Act of
 1940. For example, it is unclear if key consequences of deregistration
may involve the
 loss of restrictions on affiliated transactions and self-dealing,
elimination of
 limitations on the use of leverage, etc.
 June 3, 2025
Page 2

3. Please revise to address the extent to which there is a material risk
that 180 Degree
 Capital or the combined company may not be successfully "excluded from
the
 definition of an investment company by Section 3(c)(1) or Section
3(c)(7) of the 1940
 Act," as referenced on page 10.
Sales of shares of New Mount Logan Common Stock after the completion, page 36

4. Please revise to disclose whether any lock-up agreements or resale
restrictions apply
 to shares issued in the merger. Quantify the number or percentage of
freely tradeable
 shares that could enter the market post-closing.
Regulations governing 180 Degree Capital's operation as a registered CEF, page
66

5. We note your disclosure that references limitations under the Investment
Company
 Act of 1940, including the 300% asset coverage requirement. We also note
that 180
 Degree Capital will deregister as a business development company in
connection with
 the merger. Please revise where appropriate to summarize the timeline
for
 transitioning between regulatory regimes and clarify the extent to which
the 300%
 requirement or 1940 Act requirements will continue to apply.
Background of the Mergers, page 111

6. We note your disclosure of a "Discount Management Program." Please
revise here or
 where appropriate to briefly describe such program and its purpose.
7. Please ensure your disclosure is clear about the persons involved in
negotiations
 or meetings. For example, where you refer to the "board" or
"management,"
 please clarify which members of the board were in attendance or
otherwise list the
 members in attendance.
8. We note your disclosure that initially a NAV-for-NAV transaction was
proposed but
 then was ultimately changed to a fixed value for Mount Logan that would
be adjusted
 by subsequent distributions, share issuances and certain debt refinance
expenses.
 Please expand your discussion as to clarify which party initiated the
change and how
 this change is expected to impact the consideration for each party to
the merger.
The Mergers
Mount Logan's Reasons for the Mergers, page 120

9. You state that Mount Logan "spent several years evaluating transactions
similar to the
 Business Combination" and concluded that this was the "best outcome" for
 shareholders. Please revise your disclosure to describe any alternative
transactions
 that were considered, and why they were rejected. If no specific
alternatives were
 formally evaluated, please disclose that fact.
180 Degree Capital's Reasons for the Mergers, page 124

10. We note the reference to the Mount Logan platform on page 124.
Please revise here
 and where appropriate to clarify what this term is meant to cover. For
example, is it
 restricted to Mount Logan, which has approximately $2.3 billion AUM, or
does it
 include BCPA and its affiliates, which collectively manage approximately
$40 billion
 of assets according to page 290.
 June 3, 2025
Page 3

11. Please revise here and where appropriate to explain how Mount Logan s
business
 model is highly complementary to 180 Degree Capital s business
model. Include a
 discussion of relevant, material factors regarding complementarity. For
example, it is
 unclear to what extent the entities have significantly different
geographic exposure,
 investor bases, type of fee-based models, type of fee generating
vehicles, size or
 nature of portfolio businesses, use of leverage, and so forth.
12. You state that the merger will enable "accelerated expansion of sourcing
 investments...through existing 180 Degree Capital relationships." Please
revise your
 disclosure to clarify what type of sourcing opportunities were
identified and how the
 Mount Logan Capital base enhances these opportunities.
Opinion of 180 Degree Capital's Financial Advisor, page 126

13. We note your disclosure on page 127 that Mount Logan Capital provided
financial
 projections to the 180 Degree Capital Special Committee and its
financial advisor in
 connection with the merger. However, the registration statement does not
include
 these projections or a summary thereof. Please revise your disclosure to
include these
 projections along with a description of the key assumptions underlying
them.
14. We note your disclosure on page 128 that the financial advisor to the
180 Degree
 Capital Special Committee reviewed certain closed-end fund merger
transactions as
 part of the fairness opinion. Please revise the disclosure to describe
the criteria used to
 select these transactions and explain why the selected transactions were
considered
 comparable. If any material differences exist between the precedent
transactions and
 the proposed merger, please explain. Similarly, we note the disclosure
on page 129
 that the financial advisor to 180 Degree Capital Special Committee
reviewed selected
 public companies comparable to Mount Logan Capital Inc. Please provide
equivalent
 disclosure for these comparable public companies. Similarly revise for
Mount Logan
 Capital's disclosures on pages 130 and 131.
15. We note that the majority of the implied equity values of Mount Logan
addressed by
 the financial advisor, Fenchurch, are higher than Mount Logan's $67.4
million
 transaction equity value agreed upon for the merger. As non-exclusive
examples, we
 note a $82 million to $121 million range of implied equity value for
2026 using
 trading comparables, a $76 million to $139 million range of implied
equity value for
 2025 using transactional analysis and an implied equity value of $104.5
million on
 January 1, 2025 using discounted cash flow. Please state whether the
board of Mount
 Logan considered these factors in arriving at its recommendation.
Regulatory Approvals and Related Matters, page 133

16. Please expand this section to clarify the status of required filings or
notices and the
 expected timing of remaining approvals. If material, address the
consequences or risks
 if the required approvals are delayed or not received.
The Merger Agreement
Merger Consideration, page 149

17. Please revise your disclosure to provide additional detail regarding the
in-kind
 distribution mechanism that may be used to reduce 180 Degree Capital's
NAV if its
 June 3, 2025
Page 4

 shareholders would otherwise receive more than 50% of the New Mount
Logan
 common stock. Specifically, please clarify:
 the types of assets that may be distributed in-kind;
 the methodology for selecting and valuing such assets;
 whether any shareholder consent or notice is required in connection
with the
 distribution; and
 when and how the determination will be made that a distribution is
required.

 Additionally, consider including a simplified numerical example to
illustrate how this
 mechanism could affect TURN's NAV and resulting ownership percentage in
the
 combined company.
Unaudited Pro Forma Combined Balance Sheet, page 177

18. Please revise your table on page 177 to include a subtotal for your
Asset Management
 total assets as of December 31, 2024 and ensure mathematical accuracy of
the
 information in the table.
19. We note your disclosure on page 179 that you present an adjustment to
total equity in
 the amount of $(11,829). Please revise your footnotes to include an
explanation and
 reconciliation for how this adjustment is calculated. In addition,
please ensure
 mathematical accuracy of your pro forma information. For example, it is
unclear as
 to how the adjustments to (i) total shareholders equity, (ii) total
equity and (iii) total
 liabilities and equity foot.
Unaudited Pro Forma Condensed Combined Statement of Operations, page 180

20. We note your presentation of Net Income (Loss) Attributable to Mount
Logan Capital
 Inc. Per Share of Common Shares and Weighted Average Shares of Common
Shares
 Outstanding. Please revise your disclosures to include adjustments and
footnotes
 explaining how you calculated the pro forma amounts compared from
historical. For
 example, explain how you considered all of the Mount Logan RSUs that
will have
 been vested upon completion of the merger in your calculation,
adjustments and
 presentation.
21. Please ensure the mathematical accuracy of the your pro forma statement
of
 operations for all columns and rows. For example, it is unclear as to
how the Income
 (loss) before income taxes and net income (loss) lines cross-foot and
the pro forma
 adjustments column does not appear to foot.
Notes to Unaudited Pro Forma Condensed Combined Financial Information
Note 1 - Basis of Pro Forma Presentation, page 184

22. We note the amounts disclosed on page 185 for the change in control
liabilities and
 business combination-related expenses of $2,107 and $5,577,
respectively, differ from
 those disclosed in footnote 3(B) on page 186. Please explain this
discrepancy and
 revise your disclosure to clarify accordingly.
 June 3, 2025
Page 5
Compensation and Benefits, page 265

23. We note your disclosure that Mount Logan s compensation arrangements
with certain
 employees contain a significant performance-based incentive component.
Please
 revise to disclose the terms of the performance-based incentive
compensation and
 how it is determined. To the extent applicable, discuss any
circumstances
 where incentive fees could be subject to clawback provisions.
Results of Operations, page 270

24. Please revise to further clarify the reasons underlying the 149%
increase in incentive
 fees, as disclosed on page 270.
Asset Management Segment
Revenues, page 271

25. We note the $1.9 million increase in OCIF incentive fees from 2023 to
2024 due to
 improved fund performance in 2024 compared to 2023. Please expand your
disclosure
 to provide further discussion of the factors or holdings contributing to
the improved
 fund performance. In addition, clarify if these were realized incentives
fees.
Assets Under Management, page 275

26. Please revise to include a roll-forward of assets under management by
fee generating
 vehicle showing inflows, outflows, market/asset appreciation, and if
material the
 effects of foreign currency translation. In addition, include
discussion, quantification
 and trends in your fee rates or weighted average fee rates by vehicle
over the periods
 presented.
Management's Discussion and Analysis of Financial Condition
Liquidity and Capital Resources, page 277

27. Please revise the discussion of Mount Logan s liquidity outlook to
address the
 negative cash flows from operations and investing activities.
Certain Relationships and Related Person, page 289

28. We note the statement on page 289 that BCPA owns a minority interest in
Mount
 Logan, as well as the statement on page 290 that Mount Logan s senior
management
 team "is comprised of substantially the same personnel as the senior
management
 team of BCPA." Please advise us why BCPA is not reflected in the
ownership table
 on page 313. Additionally, please revise this section to disclose, with
quantification,
 the material terms of the Servicing, Staffing, Senior Management and
other
 agreements. In this regard, please file such agreements as exhibits.
Management's Discussion and Analysis of Financial Condition
Results of Operations, page 302

29. We note your statement that owing to the structure and objectives of 180
Degree
 Capital's business you generally expect to experience net investment
losses and seek
 to generate increases in net assets from operations through long-term
appreciation.
 Please revise, where appropriate, to clarify the reasons for expected
net investment
 losses and how in light of net investment losses, increases in net
assets from
 June 3, 2025
Page 6

 operations can be achieved.
30. We note you attribute the increase in investment income for the year
ended December
 31, 2024 to receipt of board fees. Please revise, where appropriate, to
discuss in more
 detail these board fees. Address the following:
 Generally discuss whether or not board fees are contractually
governed and how
 they are determined, including the timing and amounts.
 Clarify whether 180 Degree Capital employees, such as Mr. Rendino,
receive
 any other payments outside of those remitted to 180 Degree Capital
in their roles
 as Board members of your portfolio companies.
 Generally discuss the form and quantify the portions of board fees
that are paid in
 cash and stock grants.
 Clarify whether the board fees are subject to clawback and under
what
 circumstances if so.
31. We note the statement on page 300 that 180 Degree Capital does not
believe the
 increase or decrease in the value of its investments materially impacts
its day-to-day
 operations or its daily liquidity. Please revise to clarify what
factors do materially
 impact 180 Degree Capital s liquidity.
32. We note your disclosure on page 303 that professional fees increased
75.1% for the
 year ended December 31, 2024 as compared with the year ended December
31, 2023,
 primarily as a result of an increase in legal expenses related to the
proposed Business
 Combination. Please revise here or where appropriate to discuss details
regarding the
 nature of the professional fees. In addition, include quantification
disaggregation
 expense amounts relating to the business combination activities as
opposed to normal,
 recurring professional fees, if any.
Mount Logan Capital Inc.
Notes to Consolidated Financial Statements
Note 2. Basis of Presentation
Goodwill, page F-21

33. We note goodwill of $55,697 relating to your Insurance Solutions
reportable segment,
 which includes two reporting units: long-term care insurance ( LTC )
and multi-year
 guaranteed annuity products ( MYGA ). We also note your disclosure
on page F-83
 that you have a concentration of revenue from the MYGA product line,
which are
 assumed solely from two insurance companies, ACL and SSL. Further, we
note that
 you made a decision to no longer assume business from ACL and SSL as of
June 30,
 2024. Please provide us with a summary of your goodwill impairment
analysis,
 specifically as it relates to your MYGA reporting unit. Please include
the following
 details in your response:
 the percentage by which fair value exceeded carrying value as of the
date of the
 most recent test;
 the amount of goodwill allocated to the reporting units;
 a description of the methods and key assumptions used and how the
key
 assumptions were determined, including those assumptions relating to
your
 revenue from the MYGA product line after June 30, 2024; and
 June 3

<DOCUMENT>
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<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 26, 2025

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

 Re: Yukon New Parent, Inc.
 Registration Statement on Form S-4
 Filed March 24, 2025
 File No. 333-286043
Dear Daniel B. Wolfe:

 Our initial review of your registration statement indicates that it
fails in numerous
material respects to comply with the requirements of the Securities Act of
1933, the rules and
regulations thereunder and the requirements of the form. More specifically, the
registration
statement does not include the financial statements of Mount Logan Capital Inc.

 We will provide more detailed comments relating to your registration
statement
following our review of a substantive amendment that addresses these
deficiencies.

 Please contact Madeleine Joy Mateo at 202-551-3465 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: John Mahon, Esq.
</TEXT>
</DOCUMENT>