UNITED STATES OF AMERICA

BEFORE THE

SECURITIES AND EXCHANGE COMMISSION

INVESTMENT COMPANY ACT OF 1940

Release No. 35166 / April 2, 2024

In the Matter of

ANTARES PRIVATE CREDIT FUND

ANTARES STRATEGIC CREDIT FUND

ANTARES CAPITAL ADVISERS LLC

ANTARES CAPITAL CREDIT ADVISERS LLC

ANTARES CLO 2017-1, LTD.

ANTARES CLO 2017-2, LTD. 

ANTARES CLO 2018-1, LTD.

ANTARES CLO 2018-2, LTD.

ANTARES CLO 2018-3, LTD.

ANTARES CLO 2019-1, LTD.

ANTARES CLO 2019-2, LTD.

ANTARES CLO 2020-1, LTD. 

ANTARES CLO 2021-1, LTD.

ANTARES CLO 2023-1, LTD. 

ANTARES CLO 2023-2, LTD.

ORION CLO 2023-1, LTD. 

ORION CLO 2023- 2, LTD.

AUF FUNDING LLC 

ANTARES CANADA SMA LP

ANTARES CREDIT FUND I LP

ANTARES CREDIT OPPORTUNITIES IV LLC

ANTARES CREDIT OPPORTUNITIES MA I LLC

ANTARES CREDIT OPPORTUNITIES MA II LP

ANTARES CREDIT OPPORTUNITIES MA III LLC 

ANTARES CREDIT OPPORTUNITIES MA V LP

ANTARES SENIOR LOAN MASTER FUND LP

ANTARES SENIOR LOAN PARALLEL MASTER FUND LP

ANTARES UNITRANCHE MASTER FUND I LP

ANTARES CREDIT OPPORTUNITIES VI LLC

ANTARES CREDIT OPPORTUNITIES CA LLC

ANTARES STRATEGIC CREDIT I MASTER LP

ANTARES K CO-INVESTMENT FUND LP 

ANTARES K CO-INVESTMENT 2 FUND II LP 

ANTARES SENIOR LOAN MASTER FUND II LP 

ANTARES SENIOR LOAN PARALLEL MASTER FUND II LP 

WM ALTERNATIVES ANTARES PRIVATE SENIOR 

 LENDING FUND LLC 
2

ANTARES SENIOR LOAN EF MASTER II (CAYMAN) LP

ANTARES VESTA FUNDING LP 

ANTARES ASSETCO LP 

ANTARES COMPLETE FINANCING SOLUTION LLC

ANTARES HOLDINGS LP, ANTARES VENUS FUNDING LP 

ANTARES SENIOR LOAN PARALLEL FUND SPV LLC 

ANTARES SENIOR LOAN PARALLEL FUND II SPV LLC 

ANTARES CREDIT OPPORTUNITIES FUNDING IV LLC

ANTARES CREDIT OPPORTUNITIES FUNDING VI LLC 

ANTARES STRATEGIC CREDIT SPV LLC

WM ALTERNATIVES ANTARES PRIVATE SENIOR 

 LENDING FUND SPV LLC

1601 Utica Avenue South

Suite 1000

Minneapolis, MN 55416

(File No. 812-15464)

ORDER UNDER SECTIONS 17(d) AND 57(i) OF THE INVESTMENT COMPANY ACT OF 

1940 AND RULE 17d-1 UNDER THE ACT

Antares Private Credit Fund, et al. filed an application on May 10, 2023, and amendments to the 

application on September 13, 2023 and February 26, 2024, requesting an order under sections 

17(d) and 57(i) of the Investment Company Act of 1940 (the “Act”) and rule 17d-1 under the Act 

that would permit certain joint transactions otherwise prohibited by sections 17(d) and 57(a)(4) 

of the Act and rule 17d-1 under the Act. The order would permit certain business development 

companies and registered closed-end management investment companies (collectively, the 

“Regulated Funds”) to co-invest in portfolio companies with each other and with certain 

affiliated investment entities. 

On March 5, 2024, a notice of the filing of the application was issued (Investment Company Act 

Release No. 35152). The notice gave interested persons an opportunity to request a hearing and 

stated that an order disposing of the application would be issued unless a hearing was ordered. 

No request for a hearing has been filed, and the Commission has not ordered a hearing. 

The matter has been considered and it is found on the basis of the information set forth in the 

application, as amended, that participation by the Regulated Funds in the proposed transactions 

is consistent with the provisions, policies and purposes of the Act and is on a basis no less 

advantageous than that of other participants.
3

Accordingly,

IT IS ORDERED, under sections 17(d) and 57(i) of the Act and rule 17d-1 under the Act, that 

the relief requested by Antares Private Credit Fund, et al. (File No. 812-15464) is granted, 

effective immediately, subject to the conditions contained in the application, as amended.

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

authority.

J. Matthew DeLesDernier,

Deputy Secretary.