CORRESP

LOGO

Monica J. Shilling, P.C.

To Call Writer Directly:

+1 310 552 4355

monica.shilling@kirkland.com

2049 Century Park East

Los Angeles, CA 90067

United States

+1 310 552 4200

www.kirkland.com

Facsimile:

+1 310 552 5900

January 19, 2023

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-3628

Attention: Ms.

Lisa Larkin

Mr. David Manion

Re:

Crescent Capital BDC, Inc.

Registration Statement on Form N-14

File No. 333-268153

Ladies and Gentlemen:

This letter is sent on behalf of Crescent Capital BDC, Inc., a Maryland corporation (the “Company”), in response to the comments of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) communicated via teleconference to Monica J. Shilling, outside counsel to the Company, on December 27, 2022 regarding Pre-effective Amendment No. 1 to the Company’s Registration Statement on Form N-14 (the “Registration Statement”). For convenience, we have set forth below, in italics, the text of the Staff’s comment prior to each of the Company’s responses. Capitalized terms used but not defined herein have the meanings set forth in the Registration Statement.

Concurrent herewith, the Company is filing via EDGAR Pre-Effective Amendment No. 2 (the “Amendment”) to the Registration Statement.

Accounting Comments

Comment: The Staff notes the Company’s response to Comment #22 in the Company’s letter dated December 22, 2022 (the “Prior Letter”). Please also add disclosure stating that any contribution by CCAP Advisor will be treated as an “adviser contribution” under U.S. GAAP by the surviving entity post-Merger.

Response: The Company has added the requested disclosure in the Amendment.

Austin Bay Area Beijing Boston Brussels Chicago Dallas Hong Kong Houston London Los Angeles Munich Paris Salt Lake City Shanghai Washington, D.C.