Griffin-Benefit Street Partners BDC Corp.
1520 Grand Avenue
El Segundo, CA 90245
(310) 469-6100
January 20, 2015
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Attn: Patrick Scott
Re: Griffin-Benefit Street Partners BDC Corp.
Registration Statement on Form N-2 (File No. 333-196520)
Dear Mr. Scott:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Griffin-Benefit Street Partners BDC Corp. (the“Company”) respectfully requests acceleration of effectiveness of the above-captioned registration statement (the“Registration Statement”), including all amendments thereto, to 4:00 p.m., Eastern Time, on January 20, 2015 or as soon thereafter as possible.
In connection with the submission of the Company’s request for accelerated effectiveness of the above-referenced Registration Statement, the Company hereby acknowledges that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | should the Securities and Exchange Commission (the “Commission”) or the staff thereof (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| • | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and |
| • | the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Griffin-Benefit Street Partners BDC Corp. | ||
By: | /s/ Kevin A. Shields | |
Kevin A. Shields | ||
President | ||
