Report of Independent Registered Public
Accounting Firm
To the Shareholders and Board of Trustees of Barings
Participation Investors:
In planning and performing our audit of the financial
statements of Barings Participation Investors and
subsidiary (collectively, the "Trust"), as of and for the
year ended December 31, 2019, in accordance with the
standards of the Public Company Accounting Oversight
Board (United States), we considered the Trust's internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our
opinion on the consolidated financial statements and to
comply with the requirements of Form N-CEN, but not
for the purpose of expressing an opinion on the
effectiveness of the Trust's internal control over financial
reporting. Accordingly, we express no such opinion.
Management of the Trust is responsible for establishing
and maintaining effective internal control over financial
reporting. In fulfilling this responsibility, estimates and
judgments by management are required to assess the
expected benefits and related costs of controls. A trust's
internal control over financial reporting is a process
designed to provide reasonable assurance regarding the
reliability of financial reporting and the preparation of
financial statements for external purposes in accordance
with generally accepted accounting principles. A trust's
internal control over financial reporting includes those
policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and
dispositions of the assets of the trusts; (2) provide
reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements
in accordance with generally accepted accounting
principles, and that receipts and expenditures of the
trusts are being made only in accordance with
authorizations of management and Trustees of the trusts;
and (3) provide reasonable assurance regarding
prevention or timely detection of unauthorized
acquisition, use, or disposition of a trust's assets that
could have a material effect on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in
conditions, or that the degree of compliance with the
policies or procedures may deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees, in the normal course
of performing their assigned functions, to prevent or
detect misstatements on a timely basis. A material
weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting,
such that there is a reasonable possibility that a material
misstatement of the Trust's annual or interim financial
statements will not be prevented or detected on a timely
basis.
Our consideration of the Trust's internal control over
financial reporting was for the limited purpose described
in the first paragraph and would not necessarily disclose
all deficiencies in internal control that might be material
weaknesses under standards established by the Public
Company Accounting Oversight Board (United States).
However, we noted no deficiencies in the Trust's internal
control over financial reporting and its operation,
including controls over safeguarding securities that we
consider to be a material weakness as defined above as
of December 31, 2019.

 KPMG LLP is a Delaware limited liability
partnership and the U.S. member firm of the
KPMG network of independent member firms
affiliated with KPMG International Cooperative
("KPMG International"), a Swiss entity. KPMG
LLP Two Financial Center 60 South Street
Boston, MA 02111 2

This report is intended solely for the information and use
of management and the Board of Trustees of the Trust
and the Securities and Exchange Commission and is not
intended to be and should not be used by anyone other
than these specified parties.



/s/KPMG LLP


Boston, Massachusetts February 27, 2020