UNITED STATES OF AMERICA
BEFORE THE
SECURITIES AND EXCHANGE COMMISSION

INVESTMENT COMPANY ACT OF 1940

Release No. 32897 / November 7, 2017

In the Matter of

STEADFAST ALCENTRA GLOBAL CREDIT FUND
STEADFAST INVESTMENT ADVISER, LLC

18100 Van Karman Avenue, Suite 500
Irvine, CA 92612

(812-14725)

ORDER UNDER SECTION 6(c) OF THE INVESTMENT
COMPANY ACT OF 1940
GRANTING AN EXEMPTION FROM SECTIONS 18(a)(2),
18(c) AND 18(i) OF THE ACT,
UNDER SECTIONS 6(c) AND 23(c) OF THE ACT GRANTING
AN EXEMPTION FROM
RULE 23c-3 UNDER THE ACT AND PURSUANT TO
SECTION 17(d) AND RULE 17d-1
UNDER THE ACT

Steadfast Alcentra Global Credit Fund and Steadfast
Investment Adviser, LLC filed an application on
December 8, 2016, and amendments to the application
on April 13, 2017, August 18, 2017 and September 28,
2017, requesting an order under section 6(c) of the
Investment Company Act of 1940 ("Act") granting an
exemption from sections 18(a)(2), 18(c) and 18(i) of the
Act, under sections 6(c) and 23(c) of the Act granting an
exemption from rule 23c-3 under the Act and pursuant
to section 17(d) of the Act and rule 17d-1 under the Act.
The order permits certain registered closed-end
management investment companies to issue multiple
classes of shares and to impose asset-based distribution
and/or service fees, early withdrawal charges and
repurchase fees.

On October 12, 2017, a notice of the filing of the
application was issued (Investment Company Act
Release No. 32860). The notice gave interested persons
an opportunity to request a hearing and stated that an
order disposing of the application would be issued
unless a hearing was ordered. No request for a hearing
has been filed, and the Commission has not ordered a
hearing.

The matter has been considered and it is found, on the
basis of the information set forth in the application, as
amended, that granting the requested exemption is
appropriate in the public interest and consistent with
the protection of investors and the purposes fairly
intended by the policy and provisions of the Act.
It is further found that proposed repurchases will be
made in a manner which does not unfairly discriminate
against any holders of the class or classes of securities
to be purchased. It is further found that the investment
company's proposed institution of asset-based
distribution and/or service fees is consistent with the
provisions, policies, and purposes of the Act, and will
not be on a basis different from or less advantageous
than that of other participants.

Accordingly, in the matter of Steadfast Alcentra Global
Credit Fund and Steadfast Investment
Adviser, LLC (File No. 812-14725),

IT IS ORDERED, under section 6(c) of the Act, that the
requested exemption from sections 18(a)(2), 18(c) and
18(i) of the Act is granted, effective immediately,
subject to the condition in the application, as amended.

IT IS ALSO ORDERED, under sections 6(c) and 23(c) of
the Act, that the requested exemption from rule 23c-3
is granted, effective immediately, subject to the
condition contained in the application, as amended.

IT IS ALSO ORDERED, under section 17(d) and rule 17d-
1, that the investment company's institution of asset-
based distribution and/or service fees is approved,
effective immediately, subject to the condition
contained in the application, as amended.

For the Commission, by the Division of Investment
Management, under delegated authority.

Eduardo A. Aleman
Assistant Secretary