SRSEC Reporting Desk

Blackstone Secured Lending Fund (BXSL) – Company response

2025-12-04 · Re: ( · Accession 0001213900-25-118274 · Partly revised / explained

with respect to the ability of “advisers or other sponsoring entities to recapture fees waived or expenses reimbursed under an expense limitation plan” and whether such ability to recapture should be recorded as a liability under FASB ASC 450 -20-25-2 , that “[t]he staff has generally not objected to an accounting analysis that concludes that the recapture of waived fees or reimbursements does not meet the criteria for recording a liability . . . if there is no evidence that recapture of waived or reimbursed amounts is probable and the period of recapture is limited to a sufficiently short…

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