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ngreene@shearman.com (212) 848-4668 | July 28th, 2017 |
Ms. Lisa Larkin
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: SkyBridge Multi-Adviser Hedge Fund Portfolios LLC (the “Company”)
(File Nos. 333-196706 and 811-21190)
Dear Ms. Larkin:
Thank you for your comments regarding the Company’s registration statement1 on Form N-2 filed with the Securities and Exchange Commission (“SEC”) on July 27, 2017. Please note our responses (below) to your comments.
| 1. | COMMENT: You asked us to advise how the sale of the Adviser will be communicated to the Company’s shareholders once consummated. |
RESPONSE: The Company will file a supplement to the prospectus and will forward a hardcopy of such supplement (along with a cover letter) to all shareholders to communicate information with respect to the sale of the Adviser.
| 2. | COMMENT: Upon completion of the sale of the Adviser, you asked us to send in separate correspondence to the SEC confirming that Items 20.1(a) and (b) of Form N-2 are complied with, and to provide any updates as necessary. |
RESPONSE: The Company hereby confirms that it will do so.
| 3. | COMMENT: You asked us to confirm that, as required, all the disclosures for restricted securities required by footnote 8 to Rule 12-12 of Regulation S-X will be included in the Company’s financial statements. |
RESPONSE: The Company confirms that such disclosures will be included in its financial statements as required.
Should you have any questions, please do not hesitate to contact me at (212) 848-4668.
Very truly yours,
/s/ Nathan J. Greene
Nathan J. Greene (as attorney for the Company)
cc: | A. Marie Noble (Chief Compliance Officer of the Company and General Counsel of the Adviser) Christopher Hutt (Vice President of the Company and the Adviser) Paul Schreiber (Shearman & Sterling LLP) Thomas Majewski (Shearman & Sterling LLP) Catherine Sum (Shearman & Sterling LLP) Aviva Grossman (Perkins Coie LLP) Carl Frischling (Perkins Coie LLP) |
1 Capitalized terms used herein but not defined have the meaning ascribed to them in the Registration Statement.
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