SEC Company Response from ARES CAPITAL CORP (ARCC) (CIK 0001287750) (ARCC) — Apr 9, 2008
ARES CAPITAL CORP (ARCC) (CIK 0001287750)
Date: April 9, 2008 · CIK: 0001287750 · Accession: 0001047469-08-004350
AI Filing Summary & Sentiment
File numbers found in text: 333-149139
Letter
United States Securities and Exchange Commission Division of Investment Management Mail Stop 4720 Washington, D.C. 20549 Attention: Christian T. Sandoe, Senior Counsel Re:Ares Capital Corporation (File No. 333-149139)
Dear Mr. Sandoe:
Ares Capital Corporation (the "Fund") has today filed Amendment No. 2 to its registration statement on Form N-2 last filed on March 14, 2008 (the "Registration Statement"). The amendment sets forth responses to questions we discussed on a telephone conversation on April 3, 2008 as well as additional information.
Two copies of the amended filing, marked to show changes from the Registration Statement filed on March 14, 2008, are enclosed for your convenience with the hard copy of this letter.
Set forth below are written responses to your verbal comments.
You asked the Fund to confirm that it would file any prospectus supplement to effect a rights offering (a "Rights Offering") pursuant to the Registration Statement with the Securities and Exchange Commission (the "Commission") using a post-effective amendment to the Registration Statement prior to any such offering.
The Fund confirms that it will file any prospectus supplement to effect a Rights Offering pursuant to the Registration Statement with the Commission using a post-effective amendment to the Registration Statement prior to any such offering unless the Commission expressly tells the Fund that no such post-effective amendment is necessary.
We look forward to discussing with you any additional questions you may have regarding the Registration Statement. Please do not hesitate to call me at 310.284.4544. In addition, we would greatly appreciate any additional written comments by facsimile to 310.557.2193.
Very truly yours,
/s/ MONICA J. SHILLING Monica J. Shilling
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CORRESP
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[PROSKAUER ROSE LLP LETTERHEAD]
April 9,
2008
United
States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.W.
Mail Stop 4720
Washington, D.C. 20549
Attention: Christian T. Sandoe, Senior Counsel
Re:Ares Capital Corporation (File No. 333-149139)
Dear
Mr. Sandoe:
Ares
Capital Corporation (the "Fund") has today filed Amendment No. 2 to its registration statement on Form N-2 last filed on March 14, 2008 (the
"Registration Statement"). The amendment sets forth responses to questions we discussed on a telephone conversation on April 3, 2008 as well as additional information.
Two
copies of the amended filing, marked to show changes from the Registration Statement filed on March 14, 2008, are enclosed for your convenience with the hard copy of this
letter.
Set
forth below are written responses to your verbal comments.
You asked the Fund to confirm that it would file any prospectus supplement to effect a rights offering (a "Rights Offering") pursuant to the Registration
Statement with the Securities and Exchange Commission
(the "Commission") using a post-effective amendment to the Registration Statement prior to any such offering.
The
Fund confirms that it will file any prospectus supplement to effect a Rights Offering pursuant to the Registration Statement with the Commission using a post-effective
amendment to the Registration Statement prior to any such offering unless the Commission expressly tells the Fund that no such post-effective amendment is necessary.
We
look forward to discussing with you any additional questions you may have regarding the Registration Statement. Please do not hesitate to call me at 310.284.4544. In addition, we
would greatly appreciate any additional written comments by facsimile to 310.557.2193.
Very truly yours,
/s/ MONICA J. SHILLING Monica J. Shilling
Enclosures
cc:Michael
J. Arougheti, Ares Capital Corporation
Michael D. Weiner, Ares Capital Corporation
Michael A. Woronoff