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		THOMAS FRIEDMANN thomas.friedmann@dechert.com +1 617 728 7120 Direct

April 26, 2019

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Attn: John Ganley and Megan Miller

Ladies and Gentlemen:

On behalf of PennantPark Investment Corporation, a Maryland corporation (the “Company”), we hereby respond to the comments raised by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) pursuant to a telephone call on April 15, 2019 between Megan Miller of the Staff and Stephen Pratt of Dechert LLP, outside counsel to the Company, regarding Pre-Effective Amendment No. 1 to the Company’s Registration Statement on Form N-2 (Registration No. 333-230014) (as amended, the “Registration Statement”) and the prospectus included therein.

For your convenience, a transcription of the Staff’s comments is included in this letter, and each comment is followed by the applicable response. Capitalized terms used in this letter and not otherwise defined herein shall have the meanings specified in the Registration Statement.

ACCOUNTING COMMENTS

Response:

The Company hereby acknowledges the Staff’s comment. The Company has historically calculated asset coverage in the Senior Securities table using the fair value of senior securities based on prior discussions with the Staff. The Company will calculate asset coverage for future periods included in the Senior Securities table based on par, not fair value.

Supplementally, enclosed as Exhibit A is an updated Senior Securities table showing all asset coverage calculations based on par.

		United States Securities and Exchange Commission April 26, 2019 Page 2

Response:

The Company hereby acknowledges the Staff’s comment. The Company redeemed 100% of its $250.0 million aggregate principal amount of 4.500% notes due 2019 (the “2019 Notes”) on March 4, 2019. Pursuant to the indenture governing the 2019 Notes, the make-whole premium payable upon redemption of the 2019 Note could not be calculated until immediately prior to such redemption. Accordingly, the make-whole premium was recorded on the Company’s books and records at that time when it was both certain and determinable and will be reflected in the Company’s quarterly financial statements for the fiscal quarter ending March 31, 2019. Supplementally, the Company notes that the redemption of the 2019 Notes was funded in part with proceeds from a new credit facility which was approved by the Company’s board of directors and closed in February 2019.

Response:

The Company hereby acknowledges the Staff’s comment and supplementally confirms that it considered ASU 2016-01 and the September 19, 2017 AICPA Expert Panel Meeting Minutes for liabilities recorded at fair value on its balance sheet. The Company respectfully submits that, although the Company marks its liabilities considering instrument specific risks, changes in instrument specific-risks were immaterial for the periods covered. The Company will continue to monitor instrument-specific risks going forward and make appropriate disclosures pursuant to ASU 2016-01 and the September 19, 2017 AICPA Expert Panel Meeting Minutes to the extent applicable.

* * * * * * * * * *

If you have any questions, please feel free to contact the undersigned by telephone at 617.728.7120 (or by email at thomas.friedmann@dechert.com). Thank you for your cooperation and attention to this matter.

Sincerely,

/s/ Thomas J. Friedmann

Thomas J. Friedmann

Aviv Efrat, PennantPark Investment Corporation

Exhibit A

SENIOR SECURITIES