Kayne Anderson BDC, Inc. (KBDC) – Company response

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will revise the footnote to the Schedule of Investments in its Quarterly Reports on Form 10-Q and its next Annual Report on Form 10-K to reflect that the value of Level 3 holdings was determined using significant unobservable inputs as required by Article 12-12, footnote 9 of Regulation S-X consistent with the following: Unless otherwise noted, security is a Level 3 holding. As of December 31, 2025, the aggregate value of Level 3 securities held by the Company was $2,151,743. The value of each investment was determined using unobservable inputs. See Note 5 – Fair Value. response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will include disclosure regarding non-recurring income in the MD&A or in the notes to its financial statements in its Quarterly Reports on Form 10-Q and its next Annual Report on Form 10-K consistent with the following: Revenue Recognition We do not accrue as a receivable interest on loans and debt securities for accounting purposes if we have reason to doubt our ability to collect such interest. OIDs, upfront loan origination fees, amendment fees, market discounts or premiums are accreted or amortized using the effective interest method as interest income. We record prepayment premiums on loans and debt… response letter →

Company response: As of March 31, 2026, the Company invested 4.6% of its net assets in unitranche loans, consisting of debt investments in three entities: Arborworks Acquisition, LLC; PMFC Holding, LLC; and Centerline Communications, LLC. response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will include incentive fee examples in its next Annual Report on Form 10-K consistent with the examples provided on pages 127-134 of its Registration Statement on Form N-2 (File No. 333-278414), filed by the Company with the Commission on May 13, 2024, and declared effective on May 21, 2024. * * * * response letter →