PennantPark Floating Rate Capital Ltd. (PFLA, PFLT) – Company response

Staff comment: In the Schedule of Investments, please disclose the class of shares held of other registered funds as part of the title of “issue.” The Company will revise future disclosure to include the class of shares of each of its investments in other registered funds. letter →

Staff comment: The Staff notes that the Company engaged in more than one kind of debt transaction. The Staff notes that the average dollar amounts of borrowings and average interest rate was disclosed individually by type of debt but not disclosed in aggregate across the Company. Please update in future filings to also include the aggregate disclosure required by Regulation § S-X 6-07.3. The Company acknowledges the Staff’s comment. The Company respectfully directs the Staff to the language of Regulation § S-X 6-07.3 which states (emphasis added): “ Provide in the body of the statements or in the footnotes , the average dollar amount of borrowings and the average interest rate .” The Company has provided… letter →

Staff comment: Please discuss in correspondence how the Company has complied with the Financial Highlights presentation requirements given the Company has filed a registration statement pursuant to General Instruction A.2 of Form N-2. See Division of Investment Management Dear CFO Item 2023-01 (“Item 2023-01”). The Company supplementally confirms that, while its registration statement on Form N-2 (File No. 333-279726, declared effective by the Staff on July 17, 2024) includes 10 years of financial highlights on page 9, the Company will revise future disclosures on Form 10-K to comply with Item 2023-01. * * * If you have any questions, please feel free to contact the undersigned by telephone at (617)… letter →