0001144204-15-043422.txt : 20150903 0001144204-15-043422.hdr.sgml : 20150903 20150721141540 ACCESSION NUMBER: 0001144204-15-043422 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 2 FILED AS OF DATE: 20150721 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BUSINESS DEVELOPMENT Corp OF AMERICA II CENTRAL INDEX KEY: 0001606657 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 405 PARK AVENUE STREET 2: 3RD FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 BUSINESS PHONE: 212-415-6500 MAIL ADDRESS: STREET 1: 405 PARK AVENUE STREET 2: 3RD FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 FORMER COMPANY: FORMER CONFORMED NAME: BDCA Senior Capital, Inc. DATE OF NAME CHANGE: 20140428 CORRESP 2 filename2.htm

  

Three Copley Place

Boston, MA 02116

 

July 21, 2015

 

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-4041

Attention: John M. Ganley

 

  Re: Business Development Corporation of America II

Post-Effective Amendment No. 2 to Registration Statement on Form N-2

File No. 333-197447

 

Dear Mr. Bartz:

 

Acting as dealer manager of Business Development Corporation of America II (the “Registrant”) and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, we hereby join in the request of the Registrant to request the acceleration of the effective date of the Post-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-2 to 10:00 a.m. Eastern Time on July 22, 2015, or as soon thereafter as is practicable.

 

 

  Sincerely,
   
  By: Realty Capital Securities, LLC
   
   
   
  By:/s/  Louisa  Quarto
  Name: Louisa Quarto
  Title: President

 

 

 

 CORRESP 1 filename1.htm

 

405 Park Avenue, 14th Floor

New York, NY 10022

 

July 21, 2015

 

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-4041

Attention: John M. Ganley

 

  Re: Business Development Corporation of America II

Post-Effective Amendment No. 2 to Registration Statement on Form N-2

File No. 333-197447

 

Dear Mr. Bartz:

 

On behalf of Business Development Corporation of America II (the “Registrant”) and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, I hereby request acceleration of the effective date of the Post-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-2 to 10:00 a.m. Eastern Time on July 22, 2015, or as soon thereafter as is practicable.

 

The disclosure in the referenced filing is the responsibility of the Registrant. The Registrant represents to the U.S. Securities and Exchange Commission (the “Commission”) that should the Commission, or the staff acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing, and the Registrant represents that it will not assert staff comments or the action of the staff to declare the filing effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

The Registrant further acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing.

 

Should you have any questions concerning this request, please contact me at (212) 415-6500 or, our counsel, Martin H. Dozier at Alston & Bird LLP at (404) 881-4932.

 

 

  Sincerely,
   
   

 

 

 BUSINESS DEVELOPMENT CORPORATION OF
AMERICA II
   
  By: /s/ Peter M. Budko
  Name: Peter M. Budko
  Title: Chairman and Chief Executive Officer