SIMPSON THACHER & BARTLETT LLP
900 G STREET, NW
WASHINGTON, DC 20001
(202) 636-5500
FACSIMILE (202) 636-5502
DIRECT DIAL NUMBER |
| E-MAIL ADDRESS |
| November 17, 2015 |
VIA EDGAR
Re: | Acceleration Request for CIFC LLC |
| Registration Statement on Form S-4 |
| File No. 333-206441 |
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention: David Lin
Ladies and Gentlemen:
We are enclosing the acceleration request of CIFC LLC, a Delaware limited liability company, relating to the above-referenced Registration Statement pursuant to Rule 461 under the Securities Act of 1933, as amended.
As indicated in the acceleration request, it is respectfully requested that the above-referenced Registration Statement be declared effective at 5:00 pm Washington, DC time, on November 17, 2015, or as soon thereafter as practicable.
We thank you for your assistance in this matter. Please do not hesitate to call me at (202) 636-5804 with any questions or further comments you may have regarding the Registration Statement.
| Very truly yours, |
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| /s/ Joshua Ford Bonnie |
| Joshua Ford Bonnie |
CIFC LLC
250 Park Avenue, 4th Floor
New York, NY 10177
| November 17, 2015 |
VIA EDGAR
Re: CIFC LLC
Registration Statement on Form S-4
File No. 333-206441
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention: David Lin
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), CIFC LLC (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 5:00 pm Washington, DC time, on November 17, 2015, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Securities Act.
The Company acknowledges that:
· should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
· the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; 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.
[Signature Page Follows]
| Very truly yours, | ||
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| CIFC LLC | ||
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| By: | /s/ Raul Agarwal | |
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| Name: | Raul Agarwal |
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| Title: | Chief Financial Officer |
[Signature Page –Acceleration Request]
