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CORRESP
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corresp

Main Street Capital Corporation

1300 Post Oak Boulevard, Suite 800

Houston, TX 77056

(713) 350-6000

October 2, 2007

U.S. Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, DC 20549

Attn: Mary Cole

          Re:

    Main Street Capital Corporation

Registration Statement on Form N-2 (File No. 333-141497)

Dear Ms. Cole:

     In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, Main Street Capital Corporation (the “Company”) respectfully requests
acceleration of effectiveness of the above-captioned registration statement (the “Registration
Statement”), including all amendments thereto, to 4:00 p.m. eastern standard time on October 4,
2007 or as soon thereafter as practicable.

     In connection with the submission of the Company’s request for accelerated effectiveness of
the above-referenced Registration Statement, the Company hereby acknowledges that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff
thereof (the “Staff”), acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the Commission from taking
any action with respect to the Registration Statement;

    •

    the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the
disclosure in the Registration Statement; and

    •

    the Company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

    MAIN STREET CAPITAL CORPORATION

    By:

/s/ Rodger A. Stout

    Rodger A. Stout

    Chief Accounting Officer

and Chief Compliance Officer

Morgan Keegan

Morgan Keegan & Company, Inc.

Morgan Keegan Tower

Fifty North Front Street

Memphis, Tennessee 38103

901/524-4100 Telex 69-74324

WATS 800/366-7426

Members New York Stock Exchange, Inc.

October 2,
2007

Securities
and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

         Re:

    Main Street Capital Corporation, a Delaware corporation (the “Company”)

Registration Statement on Form N-2 (File No. 333-142879)

Ladies and Gentlemen:

     Acting on behalf of the several underwriters, we hereby join in the request of the
Company that the effective date of its Registration Statement be accelerated so that it will become
effective at 4:00 p.m., Eastern Time, on October 4, 2007, or as soon thereafter as possible.

     Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange
Commission under the Securities Act of 1933, as amended, we, acting on behalf of the several
underwriters, wish to advise you that, between September 21, 2007 and October 2, 2007, we
distributed 10,000 copies of the Preliminary Prospectus dated September 21, 2007, of which 5,950
copies were distributed to other underwriters, 0 to other securities dealers and approximately
3,700 to investors, including individuals and institutions. Copies of the Preliminary Prospectus
were available to anyone requesting the same at the offices of the underwriters.

     We confirm that we are aware of our obligations under the Securities Act of 1933, as amended,
and that we have and will comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended, with respect to the distribution of Prospectuses. We have been informed by the other
underwriters and dealers participating in the distribution of this offering that such persons have
and will comply with Rule 15c2-8 with respect to the distribution of Prospectuses.

    Very truly yours,

Morgan Keegan & Company, Inc.

acting on behalf of the several underwriters

    By:

/s/ Clancy Cashion

    Name:
    Clancy Cashion

    Title:
    Investment Banking Analyst