SEC Company Response from PROSPECT CAPITAL CORP (PSEC, PSEC-PA) (CIK 0001287032) (PSEC) — Aug 31, 2017
PROSPECT CAPITAL CORP (PSEC, PSEC-PA) (CIK 0001287032)
Date: Aug. 31, 2017 · CIK: 0001287032 · Accession: 0001287032-17-000240
AI Filing Summary & Sentiment
File numbers found in text: 333-213391
Letter
Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 RE: Prospect Capital Corporation
Dear Mr. Williamson:
On August 30, 2017, Prospect Capital Corporation (the "Company") filed a reviewable post-effective amendment (the "Amendment") to the Registration Statement on Form N-2 (File No. 333-213391) (the "Registration Statement") under the Securities Act of 1933, as amended (the "Securities Act"). When declared effective pursuant to Section 8(c) of the Securities Act, the Amendment is intended to update the Registration Statement.
The Company represents that the Amendment is substantially similar to its Pre-Effective Amendment No. 2, filed November 1, 2016 and declared effective on November 3, 2016, to the Registration Statement and that the only substantive changes made to the disclosure contained in the Amendment are as follows:
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Financial statements and the notes thereto, the MD&A, dividends declared by the Company, selected financial data, price range of common stock and other related updates were included in the base prospectus (as of the Company's fiscal year end June 30, 2017).
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The Risk Factors section was updated to reflect certain factual updates related to the Company, current regulatory conditions and current market conditions.
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The Sales of Common Stock Below Net Asset Value section was revised to show the current ability of the Company, as approved by its shareholders, to
issue shares below net asset value. The section is substantively similar to the corresponding section in the Company’s current shelf registration statement.
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The Business section was revised to show current information about the Company’s investments.
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The Management section was revised to show current information about the Company's Directors and Officers.
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Compensation paid to Directors and Officers was updated.
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Fees paid to the Company's investment adviser and its administrator were updated.
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The Portfolio Companies chart was revised to show information as of June 30, 2017.
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The tax disclosure was revised slightly.
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Other minor factual updates.
As such, the Company hereby requests expedited review of its Registration Statement. If you have any questions, please contact me at (416) 777-4727 or Richard Prins at (212) 735-2790.
Sincerely,
/s/ Steven Grigoriou
Steven Grigoriou
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CORRESP 1 filename1.htm Document [Letterhead of Skadden, Arps, Slate, Meagher & Flom LLP] August 30, 2017 Jay Williamson, Senior Counsel Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 RE: Prospect Capital Corporation Dear Mr. Williamson: On August 30, 2017, Prospect Capital Corporation (the "Company") filed a reviewable post-effective amendment (the "Amendment") to the Registration Statement on Form N-2 (File No. 333-213391) (the "Registration Statement") under the Securities Act of 1933, as amended (the "Securities Act"). When declared effective pursuant to Section 8(c) of the Securities Act, the Amendment is intended to update the Registration Statement. The Company represents that the Amendment is substantially similar to its Pre-Effective Amendment No. 2, filed November 1, 2016 and declared effective on November 3, 2016, to the Registration Statement and that the only substantive changes made to the disclosure contained in the Amendment are as follows: ◦ Financial statements and the notes thereto, the MD&A, dividends declared by the Company, selected financial data, price range of common stock and other related updates were included in the base prospectus (as of the Company's fiscal year end June 30, 2017). ◦ The Risk Factors section was updated to reflect certain factual updates related to the Company, current regulatory conditions and current market conditions. ◦ The Sales of Common Stock Below Net Asset Value section was revised to show the current ability of the Company, as approved by its shareholders, to issue shares below net asset value. The section is substantively similar to the corresponding section in the Company’s current shelf registration statement. ◦ The Business section was revised to show current information about the Company’s investments. ◦ The Management section was revised to show current information about the Company's Directors and Officers. ◦ Compensation paid to Directors and Officers was updated. ◦ Fees paid to the Company's investment adviser and its administrator were updated. ◦ The Portfolio Companies chart was revised to show information as of June 30, 2017. ◦ The tax disclosure was revised slightly. ◦ Other minor factual updates. As such, the Company hereby requests expedited review of its Registration Statement. If you have any questions, please contact me at (416) 777-4727 or Richard Prins at (212) 735-2790. Sincerely, /s/ Steven Grigoriou Steven Grigoriou 2 1495658-NYCSR03A - MSW