Funds & BDCs (ASC 946, N-CSR)

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: 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 →

Company response: The Fund hereby confirms that Ashmi Mehrotra is the Fund’s principal executive officer and Christopher Clienti is the Fund’s principal financial officer and that it will include such titles in future certifications. response letter →

Company response: The Fund will make the requested change in future reports. Please call me (202-636-5806) with any questions you may have regarding this filing or if you wish to discuss the above responses. response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that future annual reports on Form 20-F, including our Annual Report on Form 20-F for the fiscal year ending September 30, 2026, will present managed service renewal rates and 12-month backlog as key performance indicators (until and unless we conclude in the future that such metrics are no longer key performance indicators for our business and cease disclosing them). For the Staff’s reference, here is a markup of the relevant language we expect to include in our future filings (with this language reflecting what would have been included in the Annual Report): Revenue from managed services arrangements is a significant… response letter →

Company response: Response : The Company advises the Staff on a supplemental basis that the percentage of its net assets invested in unitranche loans (which is comprised of first out term loans and last out term loans) is 6.31%, comprised of first out term loans of 3.66% and last out term loans of 2.65%. response letter →

Company response: The Company advises the Staff on a supplemental basis that the Company's earnings per share (“ EPS ”) amounts have been computed based on the weighted-average number of shares of common stock outstanding for the period under the two-class method in a ccordance with Accounting Standards Codification (“ ASC ”) 260-10-45-60A. Basic EPS is computed by dividing net increase (decrease) in net assets resulting from operations applicable to common shareholders (adjusted for income allocated to participating securities, which relates to the unvested shares of restricted stock awarded pursuant to the Company’s equity compensation plans) by the weighted average number of shares of common stock… response letter →

Company response: The Company advises the Staff on a supplemental basis that the Tranche C Loan to Lift Brands, Inc. and the Third Lien loan to U.S. Telepacific Corp. are non-interest bearing until the occurrence of specific trigger events as set forth in the governing credit agreements, and as of March 31, 2025, both investments were non-interesting bearing. Instruction 4 to Rule 12-12 under Regulation S-X requires registrants to only disclose the “end of period interest rate” and therefore the Company respectfully advises the Staff that no further footnote disclosure with respect to such investments was required as of March 31, 2025. 5. Within the Consolidated Schedule of Investments as of March 31, 2025,… response letter →

Company response: , please confirm if cross-trades were executed in any of these securities during the relevant period pursuant to Rule 17a-7 of the Investment Company Act of 1940, as amended. Response: The Fund’s cash equivalents as of September 30, 2025 consisted of an investment in a single money market fund. In future filings, the Fund will identify the active markets used as a basis for determining that its cash equivalents are categorized as Level 1. The Fund, as well as other funds that are managed by an affiliate of the Fund’s investment adviser, actively transact in these money market funds on a daily basis. The Fund does not engage in cross-trades pursuant to Rule 17a-7 of the Investment Company… response letter →

Company response: 1 . The Registrant acknowledges the staff’s comment. In future filings, the line graph will be updated to reflect the minimum initial investment for the relevant share Class as reflected in the Registrant’s registration statement. response letter →

Company response: 3 . The Registrant confirms that its benchmark has not changed. The NFI-ODCE Net Total Return Index serves as the Registrant’s performance index because the Adviser believes it is representative of the Registrant’s investment strategy. The Registrant inadvertently omitted the S&P 500 Index from the Form N-CSR. This index serves as the Registrant’s regulatory index and provides a broad measure of market performance. The Bloomberg Barclays U.S. Aggregate Bond Index serves as a supplemental index for the Registrant. The Registrant will include the performance of these indices and the rationale for the inclusion of each of these indices in its next Form N-CSR filing. response letter →

Company response: 4 . The Registrant will revise the Schedule of Investments in future filings to disclose the cost of each restricted private real estate investment in accordance with footnote 8 of Article 12-12 under Regulation S-X. response letter →

Company response: 5 . The Registrant synchronizes the frequency that the receivable from the Adviser is settled with the settlement terms of payments to the Adviser, such that such payments will be made on a monthly basis. The Registrant notes that as of December 31, 2025, the receivable due from the Adviser has decreased to approximately $168,000 from approximately $606,000 as of June 30, 2025. response letter →

Company response: 6 . To comply with ASC 820-10-50-6A, the Registrant discloses: – 2 – 1. The valuation method used (practical expedient)—i.e., net asset value per share reported by each private fund. 2. Circumstances under which the practical expedient may not be appropriate (e.g., redemption suspensions or stale pricing). 3. Qualitative and quantitative disclosures on price transparency, redemption frequency, and any restrictions. 4. A statement that valuation levels were not adjusted unless further validation was required. In future filings, the Registrant will update the valuation disclosures to reference ASC 820 explicitly and include each required component. response letter →

Company response: 7 . In future filings, the Registrant will revise the disclosure to specify that the Registrant’s chief operating decision maker is the Adviser’s Executive Committee (comprising the CEO, CFO, General Counsel and COO), which regularly evaluates performance and resource allocation decisions for the Registrant. response letter →

Company response: 9 . The Registrant allocates income, expenses, and gains on a class-by-class basis in proportion to the relative net asset value of each share class at the start of the period, consistent with ASC 946-235-50-2. The Registrant will include this disclosure in the notes to financial statements in future filings. response letter →

Company response: 10 . The Registrant will disclose tax basis information for the two most recent fiscal year ends in future filings, in accordance with ASC 946-505-50-5. response letter →

Company response: 11 . Going forward, the Registrant will remove or replace terms such as “yield” and “dividends” to describe the Registrant’s distributions, including on the Registrant’s website and in marketing materials and regulatory disclosures, to accurately reflect that distributions include a return of capital. response letter →

Company response: 14 . In future filings, the Registrant will revise the response to Item 11 to refer to the disclosure included under Item 1. response letter →

Company response: 17 . The Registrant will ensure future filings clearly state that all data required by Items 13(a)(3) and (4) reflect the most recently completed fiscal year-end, as required. response letter →

Company response: 18 . The Registrant acknowledges this comment and will include this information in its next Form N-CSR annual report and Form N-CEN filings. response letter →

Company response: 21 . The Registrant acknowledges the staff’s comment. The Registrant’s investment adviser and sub-adviser are Accordant Investments LLC and IDR Investment Management, LLC, respectively. The Registrant will correct this disclosure in future Form N-CEN filings. response letter →

Company response: 22 . The Registrant confirms that a market price should not have been disclosed in response to Item D.10. The Registrant will revise this disclosure in future Form N-CEN filings. response letter →

Company response: 25 . The Registrant will include an acquired fund fees and expenses line item in the fees and expenses table. The Registrant confirms that the hypothetical expense examples were calculated using the correct acquired fund fees and expenses and, as a result, has not made any changes to such examples. response letter →

Company response: 26 . The Registrant notes that the current footnote was intended to communicate that the one-year expense example reflects application of the Operating Expense Limitation Agreement. The Registrant further notes that the lead-in paragraph to the expense example also communicates this point by stating that it reflects “application of the Operating Expense Limitation Agreement through October 30, 2026.” In order to avoid confusion as to the fee rate that is used to calculate the expense example, the Registrant will retain the statement in the lead-in paragraph to the expense example but will remove the footnote. response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in connection with management’s evaluation of the Company’s internal control over financial reporting as of the end of the period ending December 31, 2024, management concluded that as of such date, our internal control over financial reporting was effective. In addition, the registered public accounting firm that audited the financial statements included in our Form 10-K issued an attestation report that included an opinion that we maintained, in all material respects, effective internal control over financial reporting as of December 31, 2024, based on criteria established in the 2013 Internal Control – Integrated… response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Fund hereby confirms that the preferred equity investment in Pearland is a senior equity contribution by the Fund and characterizing the investment as Preferred Equity in the Fund’s Consolidated Schedule of Investments is appropriate because it represents an ownership interest with preferential rights (e.g., priority returns, liquidation preference). 5(a). Please confirm whether Pearland was properly classified as a note payable in the subsidiary’s financial statements. Response : The Fund respectfully submits that the investment is properly recorded as a note payable in Pearland’s property financial statements since Pearland received capital and has a contractual obligation to pay a… response letter →

Company response: As previously discussed with you and Meghan Ryan, Assistant Chief Accountant at the SEC, at telephonic meetings held on June 2, 2025 and June 17, 2025 (together, the “Previous Calls”), the Fund believed initially that Napa Green and Monarch required audited financials in accordance with Regulation S-X Rule 3-09. Upon reviewing the final testing, it was determined that Napa Green and Monarch did not meet the Rule 3-09 standard, and therefore, no audited financials were required. The Fund included unaudited financials for Napa Green and Monarch in the Amended Annual Report to continue to satisfy the Regulation S-X Rule 4-08(g) disclosures, which requires summary financial information of the… response letter →

Company response: As discussed on the Previous Calls, with respect to Pearland, the primary reason for the changes in figures and disclosures relate to the difference in the basis of accounting from fair value to a historical cost presentation. None of the changes were a result of an error and/or misstatement. Also, please note that because underlying entity financial statements are shown at historical cost and the Fund records its investment in the entity at fair value, the differences have no impact to the Fund’s financial statements. With respect to East Gate, the primary reason for the changes in figures and disclosures relate to immaterial classifications in the purchase price allocation between land,… response letter →

Company response: While the Fund’s equity investment in Pearland was included within Note 5, the preferred equity portion was unintentionally omitted. All future preferred equity investments will be included within the Transactions with Affiliated Companies table. Please note that as of the June 30, 2025 reporting period, the Fund has sold its preferred equity position in Pearland. The Fund confirms that the preferred equity investment in Pearland was included in the significant subsidiary test. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: In future filings, the Fund will identify a more specific group within the Manager, or an individual, as the CODM. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: Reference to the Fund’s preferred shares outstanding was unintentionally omitted. The Fund will include such reference in the Fund’s next Form N-CEN filing. Please call me (212-455-3728) with any questions you may have regarding this filing or if you wish to discuss the above responses. response letter →

Company response: The Registrant so confirms. PROSPECTUS Fees and Expenses Table 2. Comment : Please add “Dividend and Interest Expenses” as a line item to the Fee Table. Response : The Registrant notes that “Dividends and Interest Expenses” is included as a line item to the Fee Table. Please see Appendix A attached. 1 Portfolio Turnover 3. Comment : Please update the Predecessor Fund’s portfolio turnover as of its fiscal year ended August 31, 2025. Response : The Registrant has revised the disclosure as follows: For the fiscal year ended August 31, 2025, the Predecessor Fund’s (defined below) portfolio turnover rate was 0% of the average value of its portfolio. response letter →