One International Place, 40th Floor
100 Oliver Street
Boston, MA 02110-2605
+1 617 728 7100 Main
+1 617 426 6567 Fax
www.dechert.com
Thomas J. Friedmann
thomas.friedmann@dechert.com
+1 617 728 7120 Direct
+1 617 426 6567 Fax
| |
One International Place, 40th Floor +1 617 728 7100 Main +1 617 426 6567 Fax www.dechert.com
|
Thomas J. Friedmann
thomas.friedmann@dechert.com +1 617 728 7120 Direct +1 617 426 6567 Fax |
March 3, 2022
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Attn: Karen Rossotto and Chad Eskildsen
| Re: | Franklin BSP Lending Corporation, f/k/a Business Development Corporation of America | |
| Registration Statement on Form N-2 | ||
| File Number: 333-233803 |
Dear Ms. Rossotto and Mr. Eskildsen:
On behalf of Franklin BSP Lending Corporation, f/k/a Business Development Corporation of America (the “Company”), we hereby respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission received from Karen Rossotto of the Staff on March 3, 2022 relating to Post-Effective Amendment No. 4 (“Post-Effective Amendment No. 4”) to the Company’s Registration Statement on Form N-2 (Registration No. 333-233803) (the “Registration Statement”). For your convenience, a transcription of the Staff’s comments is included in this letter, and each comment is followed by the applicable response. Except as provided in this letter, terms used but not defined herein shall have the meaning set forth in the Registration Statement.
| 1. | Please confirm that expenses for the joint venture are included in affiliated fund fees and expenses (“AFFE”) row of the Fees and Expenses table. |
Response:
The Registrant confirms that on a go-forward basis, it will include fees related to the joint venture in the AFFE row.
| 2. | Please include greater disclosure in the Registration Statement and public filings regarding the allocation of gains and fees of the joint venture. |
Response: The Registrant confirms that on a go-forward basis, it will increase disclosure regarding the fees incurred by the joint venture.
| 3. | On page 20, please refer to General Instruction 3 for Selected Financials. |
Response: The Registrant confirms that on a go-forward basis, it will include ten years of financials, as required by the form.
| |
Karen Rossotto and Anu Dubey March 3, 2022 Page 2
|
* * * * * * * * * *
If you have any questions, please feel free to contact the undersigned by telephone at 617.728.7120 (or by email at thomas.friedmann@dechert.com) or Thomas J. Cheeseman at 617.728.7162 (or by email at thomas.cheeseman@dechert.com). Thank you for your cooperation and attention to this matter.
Very truly yours,
/s/ Thomas J. Friedmann
Thomas J. Friedmann
cc:
Richard J. Byrne, Franklin BSP Lending Corporation
Nina K. Baryski, Franklin BSP Lending Corporation
Michael Frick, Franklin BSP Lending Corporation
Matthew J. Carter, Dechert LLP
Jonathan H. Gaines, Dechert LLP
Thomas J. Cheeseman, Dechert LLP
Yian Pan, Dechert LLP