CORRESP

Portman Ridge Finance Corporation

650 Madison Avenue, 23rd Floor

New York, New York 10022

December 1, 2021

VIA EDGAR CORRESPONDENCE

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549-4644

 

Attention:    David Orlic
   David Manion

 

Re:

Portman Ridge Finance Corporation (the “Company”)

File No. 333-260074

Request for Acceleration of Effectiveness of Pre-Effective Amendment No. 1 (the “Amendment”) to the Company’s Registration Statement on Form N-14 as filed on November 23, 2021

Dear Messrs. Orlic and Manion:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby respectfully request that the effectiveness of the above-captioned Amendment be accelerated so that the same will become effective immediately or as soon as practicable thereafter.

Please contact Harry S. Pangas at Dechert LLP at (202) 261-3466 with any comments or questions concerning this correspondence.

Very truly yours,

 

Portman Ridge Finance Corporation
By:  

/s/ Jason T. Roos

Name:   Jason T. Roos
Title:   Chief Financial Officer, Secretary and Treasurer

 

cc:

Harry S. Pangas, Dechert LLP

Alexander C. Karampatsos, Dechert LLP