SEC Company Response from ARES CAPITAL CORP (ARCC) (CIK 0001287750) (ARCC) — Oct 26, 2011
ARES CAPITAL CORP (ARCC) (CIK 0001287750)
Date: Oct. 26, 2011 · CIK: 0001287750 · Accession: 0001104659-11-057848
AI Filing Summary & Sentiment
File numbers found in text: 333-174716, 814-663
Letter
United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.W. Washington, D.C. 20549 Attention: John M. Ganley, Senior Counsel Re: Ares Capital Corporation (File Nos. 333-174716 & 814-663)
Dear Mr. Ganley:
Ares Capital Corporation (the “Fund”) has today filed Amendment No. 4 (“Amendment No. 4”) to its registration statement first filed on Form N-2 on June 3, 2011 (as thereafter amended, the “Registration Statement”). As we discussed yesterday, the Fund would like to go effective as soon as possible.
The Fund understands that:
(a) the Fund is responsible for the adequacy and accuracy of the disclosure in the filings;
(b) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and
(c) the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
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.
Very truly yours,
/s/ Monica J. Shilling
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CORRESP 1 filename1.htm Proskauer Rose LLP 2049 Century Park East, 32nd Floor Los Angeles, CA 90067-3206 Monica J. Shilling Member of the Firm d 310.284.4544 f 310.557.2193 mshilling@proskauer.com www.proskauer.com October 26, 2011 United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.W. Washington, D.C. 20549 Attention: John M. Ganley, Senior Counsel Re: Ares Capital Corporation (File Nos. 333-174716 & 814-663) Dear Mr. Ganley: Ares Capital Corporation (the “Fund”) has today filed Amendment No. 4 (“Amendment No. 4”) to its registration statement first filed on Form N-2 on June 3, 2011 (as thereafter amended, the “Registration Statement”). As we discussed yesterday, the Fund would like to go effective as soon as possible. The Fund understands that: (a) the Fund is responsible for the adequacy and accuracy of the disclosure in the filings; (b) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and (c) the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. 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. Very truly yours, /s/ Monica J. Shilling Monica J. Shilling Boca Raton | Boston | Chicago | Hong Kong | London | Los Angeles | New Orleans | New York | Newark | Paris | São Paulo | Washington, D.C. United States Securities and Exchange Commission October 26, 2011 Page 2 Enclosures cc: Michael J. Arougheti, Ares Capital Corporation Joshua M. Bloomstein, Ares Capital Corporation