June 8, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Attention: Jeffrey Foor / Tony Burak

100 F Street, N.E.

Washington, D.C. 20549

Registration Statement on Form N-2

(File No. 333-237974)

Dear Messrs. Foor and Burak:

On behalf of Newtek Business Services Corp. (the “Company”), set forth below are the Company’s responses to the oral comments provided by the Staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) regarding the Company’s Registration Statement on Form N-2 (File No. 333-237974) and the prospectus contained therein (the “Prospectus”). The Staff’s comments are set forth below in bold italics and are followed by the Company’s responses.

Legal Comments

Response: The Company has revised the disclosure accordingly.

Response: The Company refers the Staff to the risks factor entitled “Due to the COVID-19 pandemic or other disruptions in the economy, we may not be able to increase our dividends and may reduce or defer our dividends and choose to incur US federal excise tax in order preserve cash and maintain flexibility” included in the Prospectus. In that risk factor, the Company states that “[d]ue to the COVID-19 pandemic or other disruptions in the economy, we may take certain actions with respect to the timing and amounts of our distributions in order to preserve cash and maintain flexibility.  For example, we may not be able to increase our dividends.  In addition, we may reduce our dividends and/or defer our dividends to later in the year or the following taxable year.  If we defer our dividends, we may choose to utilize the spillover dividend rules discussed above and incur the 4% U.S. federal excise tax on such amounts.  To further preserve cash, we may combine these reductions or deferrals of dividends with one or more distributions that are payable partially in our stock . . . .”

Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.

Response: The Company respectfully advises the Staff that it may use offering proceeds to fund distributions. The Company has included the following risk factor in the Prospectus:

Distributions on our common stock may exceed our taxable earnings and profits. Therefore, portions of the distributions that we pay may represent a return of capital to you. A return of capital is a return of a portion of your original investment in shares of our common stock. As a result, a return of capital will (i) lower your tax basis in your shares and thereby increase the amount of capital gain (or decrease the amount of capital loss) realized upon a subsequent sale or redemption of such shares, and (ii) reduce the amount of funds we have for investment in portfolio companies. We have not established any limit on the extent to which we may use offering proceeds to fund distributions.

We may pay our distributions from offering proceeds, which may constitute a return of your capital and will lower your tax basis in your shares, thereby increasing the amount of capital gain (or decreasing the amount of capital loss) realized upon a subsequent sale or redemption of such shares, even if such shares have not increased in value or have, in fact, lost value.

Accounting Comments

Response: The Company has revised the disclosure to reflect 0.61% of expenses in the acquired funds fees and expenses line item. The accompanying footnote has been revised to state as follows:

“Our stockholders indirectly bear the expenses of underlying funds or other investment vehicles that would be investment companies under section 3(a) of the Investment Company Act but for the exceptions to that definition provided for in sections 3(c)(1) and 3(c)(7) of the Investment Company Act in which we invest. This amount is estimated based on the estimated annual fees and operating expenses, including interest expense, of Newtek Conventional Lending, LLC, our joint venture with BlackRock TCP Capital Corp., as of March 31, 2020.”

Response: The Company has revised the disclosure accordingly.

Response: The Company respectfully advises the Staff that the expense item interest payments on borrowed funds is accurate, and reflected the Company’s estimate of its interest expense based on its actual interest as a percentage of net asset value (“NAV”) as of December 31, 2019. The Company has revised this item of expense to reflect the Company’s estimate of its interest expense based on actual interest as a percentage of NAV as of March 31, 2020.

Response: The Company respectfully advises the Staff that the asset coverage ratio per unit column for the 2024 Notes should reflect $12,044. The Company will correct this figure on a going forward basis.

Response: The Company hereby confirms to the Staff that it believes that its assets provide adequate coverage to satisfy all of the Company’s unfunded commitments. The Company may use its cash, liquidate a cash equivalent or draw on its credit facility in order to satisfy any such unfunded commitments.

Response: The Company has a commitment to fund 50% of the remaining portions of the joint venture investments that were not fully funded by the joint venture at origination. As of March 31, 2020, this amounted to an approximately $1.35 million commitment.

Response: The Company confirms unfunded commitments are accounted for in accordance with ASC 820. In its Quarterly Report on Form 10-Q for the quarter ended March 31, 2020, the Company included unfunded commitments of the joint venture which were measured at the joint venture’s net asset value.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will separately show any unfunded commitments and the amount of such commitments in the Company’s Notes to the Financial Statements on a going forward basis.

Response: The Company respectfully advises the Staff that the SBA 7(a) loans issued by NSBF do not contain a full set of financial covenants and, therefore, may be considered “covenant-lite” loans. The Company has revised the Prospectus to include the following risk factor:

The SBA 7(a) loans issued by NSBF may be considered “covenant-lite” loans, which may provide NSBF with fewer rights against borrowers and may have a greater risk of loss compared to investments with financial maintenance covenants.

The SBA 7(a) loans issued by NSBF generally do not contain financial maintenance covenants and, therefore, may be considered to be “covenant-lite” loans.  Covenants are contractual restrictions that lenders place on companies to limit the corporate actions a company may pursue, and lenders generally use financial covenants to proactively address materially adverse changes in a borrowers company's financial performance.  The term "covenant-lite" generally refers to loans that do not have a complete set of financial maintenance covenants. Generally, "covenant-lite" loans provide borrower companies more freedom to negatively impact lenders because their covenants are incurrence-based, which means they are only tested and can only be breached following an affirmative action of the borrower, rather than by a deterioration in the borrower's financial condition. Since the SBA 7(a) loans issued by NSBF generally may be considered “covenant-lite” loans, NSBF may have fewer rights against a borrower and may have a greater risk of loss on such investments as compared to investments in or exposure to loans with financial maintenance covenants.

The Company also has revised the Prospectus to note that the SBA 7(a) loans may be considered “covenant-lite” loans.

Response: The Company confirms that none of its holdings are PIK.

Response: The Company respectfully advises the Staff that there were no outstanding balances on these loans as of December 31, 2019. Regarding the term loan to CDS, the loan was outstanding during 2019, but had been repaid as of December 31, 2019. On a go forward basis, the CDS term loan will be removed from the Schedule of Investments. The International Professional Marketing line of credit available to the borrower, and remains an outstanding loans, but had a zero outstanding balance at December 31, 2019.

Response: The Company respectfully advises the Staff that it believes footnote 19 was omitted as the result of a processing error. Footnote 19 should state as follows: “6.04% owned by Wilshire Holdings I, Inc. (a subsidiary of Newtek Business Services Corp.).” The Company will include in future filing on a go forward basis.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will revise the Schedule of Investments on a going forward basis.

Response: The Company respectfully advises the Staff that the reference to Premier was included because both NMS and Premier were previously reported as wholly-owned subsidiaries or NHSH Holdings, LLC. On a going forward basis, the Company will remove the reference to Premier.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will remove footnote 23 on a going forward basis as the # denotes all investments using significant unobservable inputs.

Response: The Company respectfully advises the Staff that the initial acquisition date for EMCAP Loan Holdings, LLC was April 25, 2018, and a second investment was made on July 3, 2018. The Company will include the initial acquisition dates for restricted securities on a going forward basis.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will revise the Schedule of Investments on a going forward basis.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will prepare the affiliates table in accordance with Article 12-14 of Regulation S-X.

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If you have any questions or additional comments concerning the foregoing, please contact the undersigned at (202) 383-0218.