SECURITIES AND EXCHANGE COMMISSION

Investment Company Act Release No. 35131; File No. 812-15488

Barings Corporate Investors, et al. 

February 14, 2024 

AGENCY: Securities and Exchange Commission (“Commission” or “SEC”).

ACTION: Notice.

Notice of application for an order (“Order”) under sections 17(d) and 57(i) of the Investment

Company Act of 1940 (the “Act”) and rule 17d-1 under the Act to permit certain joint

transactions otherwise prohibited by sections 17(d) and 57(a)(4) of the Act and rule 17d-1 under 

the Act.

Summary of Application: Applicants request an order to amend a previous order granted by the 

Commission that permits certain business development companies (“BDCs”) and closed-end

management investment companies to co-invest in portfolio companies with each other and with 

certain affiliated investment entities.

Applicants: Barings Corporate Investors, Barings Global Short Duration High Yield Fund, CI 

Subsidiary Trust, Barings Participation Investors, PI Subsidiary Trust, Barings LLC, 

Massachusetts Mutual Life Insurance Company, C.M. Life Insurance company, Barings Finance 

LLC, Tower Square Capital Partners IV, L.P., Tower Square Capital Partners IV-A, L.P., 

Barings BDC, Inc., Energy Hardware Holdings, Inc., SIC Investment Holdings LLC, Barings 

Private Credit Corporation, Barings Capital Investment Corporation, BCIC Holdings, Inc., 

Barings Private Equity Opportunities and Commitments Fund, Barings Global Credit Fund 

(LUX) – Segregated Loan Account 5, Barings Segregated Loans 5 S.À R.L., BAYVK R Private 

Debt SCS, SICAV-FIS, BAYVK R PD 1 Loan S.À R.L., Barings Umbrella Fund plc – Barings 
European High Yield Bond Fund, Barings Global Investment Funds plc – Barings European 

Loan Fund, Barings European Loan Limited, BCF Europe Funding Limited, BCF Senior 

Funding I Designated Activity Company, BCF Senior Funding I LLC, MassMutual Global 

Floating Rate Fund, Barings Umbrella Fund plc – Barings Global High Yield Bond Fund, 

Barings Global Investment Funds 2 plc – Barings Global High Yield Credit Strategies Fund, 

Barings Global High Yield Credit Strategies Limited, Barings Global Investment Funds plc –

Barings Global Loan Fund, Barings Global Loan Limited, Barings Global Credit Fund (LUX) –

Barings Global Private Loan Fund, Barings Global Private Loans 1 S.À R.L., Barings Umbrella 

Fund plc – Barings Global Senior Secured Bond Fund, Barings CMS Fund, LP, Barings 

Umbrella Fund plc – Barings U.S. High Yield Bond Fund, Barings Direct Lending 2018 LP, 

Barings European Direct Lending 1 L.P., Barings European Direct Lending 1 S.À R.L., Barings 

Global Credit Fund (LUX) – Barings European Private Loan Fund II, Barings European Private 

Loans 2 S.À R.L., Barings Global Credit Fund (LUX) – Barings European Private Loan Fund III, 

Barings European Private Loans 3 S.À R.L., Barings Global Credit Fund (LUX) – Barings 

European Private Loan Fund III (A), Barings European Private Loans 3A S.À R.L., Barings 

Global Investment Funds plc – Barings Global Loan and High Yield Bond Fund, Barings Global 

Loan and High Yield Bond Limited, Barings Global Investment Funds plc - Barings Global Loan 

Select Responsible Exclusions Fund, Barings Global Loan Select Responsible Exclusions 

Limited, Barings Global Credit Fund (LUX) – Barings Global Private Loan Fund 2, Barings 

Global Private Loans 2 S.À R.L., Barings Global Credit Fund (LUX) – Barings Global Private 

Loan Fund 3, Barings Global Private Loans 3 S.À R.L., Barings Global Private Loan Fund 4 

SCSp, Barings Global Private Loans 4 S.À R.L., Barings Global Private Loan Fund 4(S) SCSp, 

Barings Global Private Loans 4(S) S.À R.L., Barings Global Credit Fund (LUX) – Segregated 
Loan Account 3, Barings Segregated Loans 3 S.À R.L., Barings Global Credit Fund (LUX) –

Segregated Loan Account 1, Barings Segregated Loans 1 S.À R.L., Barings Global Credit Fund 

(LUX) – Segregated Loan Account 2, Barings Segregated Loans 2 S.À R.L., Barings Global 

Investment Funds plc - Global Private Loan Strategy Fund 1, Barings Global Private Loan 

Strategy 1 Limited, Barings Global Credit Fund (LUX) – Segregated Loan Account 4, Barings 

Global Credit Fund (LUX) – Segregated Loan Account 6, Barings Segregated Loans 6 S.À R.L., 

Barings SLA 6 LLC, Barings SS4 (LUX) LLC, Barings Umbrella Fund (LUX) – Barings Global 

Special Situations Credit Fund 4 (LUX) Fund, Barings Global Special Situations Credit 4 (LUX) 

S.À R.L., Barings Global Credit Fund (LUX) – Barings Global Special Situations Credit Fund 3, 

Barings Global Special Situations Credit 3 S.À R.L., Barings Global Umbrella Fund - Barings 

Developed and Emerging Markets High Yield Bond Fund, Barings - MM Revolver Fund LP, 

Barings North American Private Loan Fund (Cayman)-A, L.P., Barings North American Private 

Loan Fund, L.P., Barings North American Private Loan Fund (Cayman), LP, Barings Small 

Business Fund, L.P., Barings Middle Market CLO Ltd. 2017-I, Barings CLO Ltd. 2018-I, 

Barings CLO Ltd. 2018-II, Barings CLO Ltd. 2018-III, Barings CLO Ltd. 2018-IV, Barings 

Middle Market CLO Ltd. 2018-I, Barings CLO Ltd. 2019-I, Barings CLO Ltd. 2019-II, Barings 

CLO Ltd. 2019-III, Barings Middle Market CLO Ltd. 2019-I, Barings CLO Ltd. 2020-1, Barings 

CLO Ltd. 2020-IV, Barings CLO Ltd. 2021-I, Barings CLO Ltd. 2021-II, Barings CLO Ltd. 

2021-III, Barings Middle Market CLO Ltd. 2021-I, Barings CLO Ltd. 2016-II, Babson CLO Ltd. 

2014-I, Barings CLO Ltd. 2015-I, Barings CLO Ltd. 2016-I, Barings CLO Ltd. 2017-I, Barings 

U.S. High Yield Collective Investment Fund, MassMutual High Yield Fund, MassMutual 

Ascend Life Insurance Company, MassMutual Trad Private Equity LLC, Barings Global 

Investment Funds plc - Global Multi-Credit Strategy Fund 1, Barings Global Multi-Credit 
Strategy 1 Limited, Barings Global Investment Funds 2 plc - Global Multi-Credit Strategy Fund 

3, Barings Global Multi-Credit Strategy 3 Limited, Barings Global Investment Funds plc -

Global Multi-Credit Strategy Fund 4, Barings Global Multi-Credit Strategy 4 Limited, BME 

SCSp, BME Investment S.À R.L., Barings North American Private Loan Fund II (Cayman)-A, 

LP, NAPLF (Cayman)-A Senior Funding I LLC, Barings North American Private Loan Fund II 

(Cayman), L.P., NAPLF (Cayman) Senior Funding I LLC, Barings North American Private 

Loan Fund II (Unlevered), L.P., NAPLF Senior Funding I LLC, NAPLF (Cayman)-A Senior 

Funding II LLC, NAPLF (Cayman) Senior Funding II LLC, OTPP - BNAPLF II LP, OTPP -

BNAPLF II Funding LP, Barings Global Special Situations Credit Fund 4 (Delaware) L.P., 

Tryon Street Funding III Ltd., Barings Global Investment Funds plc - European Loan Strategy 

Fund 1, Barings European Loan Strategy 1 Limited, BPC Funding LLC, and BPCC Holdings, 

Inc. 

Filing Dates: The application was filed on July 20, 2023, and amended on October 25, 2023 and 

December 4, 2023. 

Hearing or Notification of Hearing: An order granting the requested relief will be issued unless

the Commission orders a hearing. Interested persons may request a hearing on any application 

by e-mailing the SEC’s Secretary at Secretarys-Office@sec.gov and serving the Applicants with

a copy of the request by e-mail, if an e-mail address is listed for the relevant Applicant below, or 

personally or by mail, if a physical address is listed for the relevant Applicant below. Hearing 

requests should be received by the Commission by 5:30 p.m. on March 11, 2024, and should be 

accompanied by proof of service on applicants, in the form of an affidavit or, for lawyers, a 

certificate of service. Pursuant to rule 0-5 under the Act, hearing requests should state the 

nature of the writer’s interest, any facts bearing upon the desirability of a hearing on the matter, 
the reason for the request, and the issues contested. Persons who wish to be notified of a hearing 

may request notification by emailing the Commission’s Secretary at Secretarys-Office@sec.gov.

ADDRESSES: The Commission: Secretarys-Office@sec.gov. Applicants: Jill Dinerman, 

Chief Legal Officer, Barings LLC at jill.dinerman@barings.com.

FOR FURTHER INFORMATION CONTACT: Matthew Cook, Senior Counsel, or Terri 

Jordan, Branch Chief, at (202) 551-6825 (Division of Investment Management, Chief Counsel’s 

Office).

SUPPLEMENTARY INFORMATION: For Applicants’ representations, legal analysis, and

conditions, please refer to Applicants’ second amended and restated application, dated December 

4, 2023, which may be obtained via the Commission’s website by searching for the file number at

the top of this document, or for an Applicant using the Company name search field, on the SEC’s 

EDGAR system. The SEC’s EDGAR system may be searched at 

http://www.sec.gov/edgar/searchedgar/legacy/companysearch.html. You may also call the 

SEC’s Public Reference Room at (202) 551-8090.

For the Commission, by the Division of Investment Management, under delegated authority.

Sherry R. Haywood,

Assistant Secretary.