UNITED STATES OF AMERICA

BEFORE THE

SECURITIES AND EXCHANGE COMMISSION

INVESTMENT COMPANY ACT OF 1940

Release No. 35158 / March 20, 2024

In the Matter of

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
2

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
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.
4

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

BPCC Holdings, Inc.

300 South Tryon Street, Suite 2500

Charlotte, NC 28202

(812-15488)

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

1940 AND RULE 17d-1 UNDER THE ACT

Barings Corporate Investors, et al. filed an application on July 20, 2023, and amendments to the 

application on October 25, 2023, and December 4, 2023, requesting an order to amend a prior 

order under sections 17(d) and 57(i) of the Investment Company Act of 1940 (the “Act”) and 

rule 17d-1 under the Act (“Prior Order”). The Prior Order permitted certain joint transactions 

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

particular, the Prior Order permitted certain business development companies and 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 February 14, 2024, a notice of the filing of the application was issued (Investment Company 

Act Release No. 35131). 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. 
5

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 Barings Corporate Investors, et al. (File No. 812-15488) 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.

Sherry R. Haywood,

Assistant Secretary.