United States securities and exchange commission logo
December 23, 2020
Mark Tipton
Chief Financial Officer
TriLinc Global Impact Fund, LLC
1230 Rosecrans Avenue
Suite 605
Manhattan Beach, CA 90266
Re: TriLinc Global
Impact Fund, LLC
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed March 30,
2020
File No. 000-55432
Dear Mr. Tipton:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Year ended December 31, 2019
Consolidated Statements of Cash Flows, page F-7
1. Please revise future
filings to present the purchase and maturity of investments in the
investing section.
Refer to ASC 230-10-45 for guidance.
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Polices
Valuation of Investments, page F-17
2. We note your disclosure
that market quotations may be deemed not to represent fair
value. As of each
period end presented, for each investment in which a market quotation
was deemed not to
represent fair value, please tell us the specific reasons why, the
amortized cost, the
value based on the market quotation and the actual fair value
Mark Tipton
TriLinc Global Impact Fund, LLC
December 23, 2020
Page 2
measurement used. Please tell us how you concluded that your fair
value measurement
was consistent with the guidance in ASC 820-10-35-41C.
Form 10-Q for the Quarter ended September 30, 2020
Consolidated Financial Statements
Consolidated Schedule of Investments, As of September 30, 2020, page 5
3. We note your description of your receivable from IIG TOF B.V. as short
term. Please tell
us how you determined this receivable should be classified as a short
term investment
considering the bankruptcy of IIG TOF B.V. and related uncertainty of
recovery.
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Polices
Valuation of Investments, page 11
4. Please tell us and revise future filings to explain why fair value
equals amortized cost for
many of your non-watch list investments. Please more clearly describe
how you assess
whether unobservable inputs change during a period, describe the
variability in the
unobservable inputs (e.g. how often you typically observe changes in
unobservable inputs)
and describe how you determine if you should revise an input based on
your assessment.
5. Noting your disclosure on page 10 related to the significant impact of
COVID-19, please
tell us how the increased uncertainty and risk related to the impact
of COVID-19 was
considered in your fair value measurements at September 30, 2020 and
why this would
not result in a change in fair value from December 31, 2019 for many
investments.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact William Schroeder, Staff Accountant at 202-551-3294 or
Michael
Volley, Staff Accountant at 202-551-3437 with any questions.
FirstName LastNameMark Tipton Sincerely,
Comapany NameTriLinc Global Impact Fund, LLC
Division of
Corporation Finance
December 23, 2020 Page 2 Office of
Finance
FirstName LastName