0001752724-24-052110.txt : 20240312 0001752724-24-052110.hdr.sgml : 20240312 20240312151904 ACCESSION NUMBER: 0001752724-24-052110 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20231231 FILED AS OF DATE: 20240312 DATE AS OF CHANGE: 20240312 EFFECTIVENESS DATE: 20240312 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Apollo Diversified Credit Fund CENTRAL INDEX KEY: 0001676197 ORGANIZATION NAME: IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-23159 FILM NUMBER: 24741735 BUSINESS ADDRESS: STREET 1: APOLLO CAPITAL CREDIT ADVISER, LLC STREET 2: 9 W 57TH ST CITY: NEW YORK STATE: NY ZIP: 10019 BUSINESS PHONE: 212-515-3200 MAIL ADDRESS: STREET 1: APOLLO CAPITAL CREDIT ADVISER, LLC STREET 2: 9 W 57TH ST CITY: NEW YORK STATE: NY ZIP: 10019 FORMER COMPANY: FORMER CONFORMED NAME: Griffin Institutional Access Credit Fund DATE OF NAME CHANGE: 20161027 FORMER COMPANY: FORMER CONFORMED NAME: Griffin-Bain Institutional Access Credit Fund DATE OF NAME CHANGE: 20161021 FORMER COMPANY: FORMER CONFORMED NAME: Griffin Institutional Access Global Credit Fund DATE OF NAME CHANGE: 20160602 N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001676197 XXXXXXXX 811-23159 true N-2 Apollo Diversified Credit Fund 811-23159 0001676197 549300OM28GL3UQRWD92 9 W 57th St 42nd Floor New York 10019 US-NY US 212-515-3200 ALPS Fund Services, Inc. 1290 Broadway, Suite 1000 Denver 80203 1-855-298-4236 Fund Accounting, Financial Reporting and Legal Records Apollo Capital Credit Adviser, LLC 9 West 57th Street New York 10019 212-515-3200 Compliance Records SS&C GIDS, Inc. 333 W. 11th Street Kansas City 64105 1-888-926-2688 Transfer Agent Records The Bank of New York Mellon Trust Company 601 Travis Street, 16th Floor Houston 77002 713-483-6519 Custody Records N N N-2 Y Carl J. Rickertsen N/A N Christine Gallagher N/A N Earl Hunt 004844393 Y Meredith Coffey N/A N Michael Porter N/A N Ryan Louis Michael Del Giudice 006010994 200 S. Orange Avenue Orlando 32801 XXXXXX N N N N N N ALPS Distributors, Inc. 8-34626 000016853 N/A N N Deloitte & Touche LLP 34 N/A N N N N N Apollo Diversified Credit Fund 549300OM28GL3UQRWD92 N Interval Fund N N N N/A N/A N/A Rule 18f-4 (17 CFR 270.18f-4) Rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4)) Rule 18f-4(e) (17 CFR 270.18f-4(e)) Rule 18f-4(f)(17 CFR 270.18f-4(f)) Rule 22d-1 (17 CFR 270.22d-1) Rule 32a-4 (17 CFR 270.32a-4) Y Y Y N Apollo Capital Credit Adviser, LLC 801-108959 000286485 N/A N Apollo Credit Management, LLC 801-72098 000156115 549300Z3PY7QPJ1L3S27 Y N SS&C GIDS, Inc. 84-00448 21B7QCD05XOK0YTYOP98 N N N Bloomberg Global Markets Services LLC 254900X21QX3H0T4HC32 N Merrill Lynch Valuations, LLC 54930015EWCI4VNCZP82 N PricingDirect Inc. 549300WIC0TOJ7N7GD54 N Refinitiv US, LLC 254900TF5VKTJ141VZ73 N S & P Global Inc. Y6X4K52KMJMZE7I7MY94 N N The Bank of New York Mellon Trust Company, National Association WFLLPEPC7FZXENRZV188 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N SS&C GIDS, Inc. 21B7QCD05XOK0YTYOP98 N N N ALPS Fund Services, Inc. N/A N N N Griffin Capital Securities, LLC 008-47891 000037739 N/A 0 Apollo Global Securities, LLC 008-68542 000153502 N/A 0 0 GOLDMAN SACHS & CO. LLC 8-129 000000361 FOR8UP27PHTHYVLBNG30 88319783 JEFFERIES LLC 8-15074 000002347 58PU97L1C0WSRCWADL48 43296617 DEUTSCHE BANK SECURITIES INC. 8-17822 000002525 9J6MBOOO7BECTDTUZW19 43848929 UBS SECURITIES LLC 8-22651 000007654 T6FIZBDPKLYJKFCRVK44 34333149 CITICORP SECURITIES SERVICES, INC. 8-32117 000015387 549300N0SOX9OZVKG341 66645595 BARCLAYS CAPITAL INC. 8-41342 000019714 AC28XWWI3WIBK2824319 119156450 JPMORGAN DISTRIBUTION SERVICES, INC. 8-52700 000104234 N/A 135166439 WELLS FARGO SECURITIES, LLC 8-65876 000126292 PBLD0EJDB5FWOLXP3B76 43724639 MORGAN STANLEY 8-68191 000149777 IGJSJL3JD5P30I6NJZ34 74098263 BOFA SECURITIES, INC. 8-69787 000283942 549300HN4UKV1E2R3U73 138136718 966133296 N 664076340 Common stock Class C Common stock Class F Common stock Class L Common stock Class M Common stock Class I Common stock Class A N N Common stock N N N 1.50 3.69 N/A 21.79 true INTERNAL CONTROL RPT 2 fp0087363-1_g1aiii.htm INTERNAL CONTROL LETTER

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders and Board of Trustees of Apollo Diversified Credit Fund:

In planning and performing our audit of the consolidated financial statements of Apollo Diversified Credit Fund. (the "Fund") as of and for the year ended December 31, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund’s internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the consolidated financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of consolidated financial statements for external purposes in accordance with generally accepted accounting principles. A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and directors of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of a fund’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions or that the degree of compliance with the policies or procedures may deteriorate.

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the fund’s annual or interim financial statements will not be prevented or detected on a timely basis.

Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB. However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness, as defined above, as of December 31, 2023.

This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

/s/ Deloitte & Touche LLP

New York, New York

February 23, 2024