December 15, 2016 |  |
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Attn: AshleyVroman-Lee
| Re: | PennantPark Floating Rate Capital Ltd. |
| Registration Statement on FormN-2 |
Ladies and Gentlemen:
PennantPark Floating Rate Capital Ltd., a Maryland corporation (the “Company”), has today filed with the Securities and Exchange Commission a Registration Statement on FormN-2, which registers an aggregate $500 million of securities that may be offered by the Company from time to time in reliance on Rule 415 under the Securities Act of 1933, as amended.
If you have any questions, please feel free to contact Thomas J. Friedmann at 617.728.7120 (or by email at thomas.friedmann@dechert.com) or the undersigned by telephone at 202.261.3352 (or by email at william.tuttle@dechert.com). Thank you for your cooperation and attention to this matter.
Sincerely,
/s/ William J. Tuttle
William J. Tuttle
| cc: | Arthur H. Penn, PennantPark Floating Rate Capital Ltd. |
| Aviv Efrat, PennantPark Floating Rate Capital Ltd. |
| Thomas J. Friedmann, Dechert LLP |