SEC Company Response from MidCap Financial Investment Corp (MFIC, MFICL) (CIK 0001278752) (MFIC) — Jul 17, 2020
MidCap Financial Investment Corp (MFIC, MFICL) (CIK 0001278752)
Date: July 17, 2020 · CIK: 0001278752 · Accession: 0001193125-20-194473
AI Filing Summary & Sentiment
File numbers found in text: 333-238518, 814-00646
Letter
VIA EDGAR Securities and Exchange Commission Division of Investment Management Attn: Christina DiAngelo Fettig and Raymond Be Re: Apollo Investment Corporation Pre-Effective Amendment No. 2 on Form N-2, File No. 333-238518 Annual Report on Form 10-K, File No. 814-00646
Dear Ms. Fettig:
On behalf of Apollo Investment Corporation (the “Registrant”), we are providing the following responses to comments received by telephone from you on July, 2020 relating to the Registrant’s pre-effective amendment filed with the Securities and Exchange Commission on Form N-2 on July 14, 2020 (the “Registration Statement”). All capitalized terms used but not defined in this letter have the meanings given to them in the Registration Statement.
1. In the expense example, assuming a 5% annual return completely in the form of net realized capital gains on investments under the Fees and Expense table, please confirm the calculation of the 1, 3, 5 and 10-year expenses.
The Registrant has recalculated the 1, 3, 5 and 10-year expenses assuming a 5% annual return completely in the form of net realized capital gains on investments and will update the table as disclosed below in a filing pursuant to Rule 424 or 497:
1 year
3 years
5 years
10 years
You would pay the following expenses on a $1,000 investment, assuming a 5% annual return (all of which is subject to a capital gains incentive fee)
$
$
$
$
2. In future prospectus filings pursuant to Rule 424 or 497, please include a heading “Selected Financial and Other Information” and include appropriate incorporation by reference disclosure.
The Registrant will make the requested change in future filings.
3. In future prospectus filings pursuant to Rule 424 or 497, please include footnote (3) beside the Carbonfree Chemicals SA LLC (“Carbonfree”) investment because the Registrant does not control Carbonfree.
The Registrant will make the requested change in future filings.
Please call me (202-636-5592) with any questions you may have regarding this filing or if you wish to discuss the above responses.
Very truly yours,
/s/ STEVEN GRIGORIOU
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CORRESP 1 filename1.htm CORRESP Simpson Thacher & Bartlett LLP 900 G STREET, NW WASHINGTON, D.C. 20001 TELEPHONE: +1-202-636-5500 FACSIMILE: +1-202-636-5502 July 17, 2020 VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.W. Washington, D.C. 20549 Attn: Christina DiAngelo Fettig and Raymond Be Re: Apollo Investment Corporation Pre-Effective Amendment No. 2 on Form N-2, File No. 333-238518 Annual Report on Form 10-K, File No. 814-00646 Dear Ms. Fettig: On behalf of Apollo Investment Corporation (the “Registrant”), we are providing the following responses to comments received by telephone from you on July, 2020 relating to the Registrant’s pre-effective amendment filed with the Securities and Exchange Commission on Form N-2 on July 14, 2020 (the “Registration Statement”). All capitalized terms used but not defined in this letter have the meanings given to them in the Registration Statement. 1. In the expense example, assuming a 5% annual return completely in the form of net realized capital gains on investments under the Fees and Expense table, please confirm the calculation of the 1, 3, 5 and 10-year expenses. The Registrant has recalculated the 1, 3, 5 and 10-year expenses assuming a 5% annual return completely in the form of net realized capital gains on investments and will update the table as disclosed below in a filing pursuant to Rule 424 or 497: 1 year 3 years 5 years 10 years You would pay the following expenses on a $1,000 investment, assuming a 5% annual return (all of which is subject to a capital gains incentive fee) $ 114 $ 320 $ 499 $ 849 2. In future prospectus filings pursuant to Rule 424 or 497, please include a heading “Selected Financial and Other Information” and include appropriate incorporation by reference disclosure. The Registrant will make the requested change in future filings. 3. In future prospectus filings pursuant to Rule 424 or 497, please include footnote (3) beside the Carbonfree Chemicals SA LLC (“Carbonfree”) investment because the Registrant does not control Carbonfree. The Registrant will make the requested change in future filings. Please call me (202-636-5592) with any questions you may have regarding this filing or if you wish to discuss the above responses. Very truly yours, /s/ STEVEN GRIGORIOU cc: David Blass Joseph Glatt 2