BXPBXP, Inc.

Please expand your discussion of the reasons you believe that your leadership structure is appropriate, addressing your specific characteristics or circumstances. In your discussion, please also address how the experience of the Lead Independent Director is brought to bear in connection with your board’s role in risk oversight.

We acknowledge the Staff’s comment and confirm that the Company will expand its future proxy statement disclosures to address the topics referenced in Comment No. 1. Read in the reply ↗

Please expand upon the role that your Lead Independent Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Independent Director: • represent the board in communications with shareholders and other stakeholders; or • require board consideration of, and/or override your CEO on, any risk matters.

We acknowledge the Staff’s comment and confirm that the Company will expand its future proxy statement disclosures to address the topics referenced in Comment No. 2. Read in the reply ↗

Please expand upon how your board administers its risk oversight function. For example, please disclose: • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you

Rest of the question

re-assess your risk environment; • how the board interacts with management to address existing risks and identify significant emerging risks; • whether you have a Chief Compliance Officer and to whom this position reports; and • how your risk oversight process aligns with your disclosure controls and procedures.

We acknowledge the Staff’s comment and confirm that the Company will enhance its future proxy statement disclosures to address the topics referenced in Comment No. 3.

In addition to the foregoing responses, the Company also commits to enhancing its future proxy statement disclosures to address any material developments in the Company’s risk oversight structure. Read in the reply ↗