SEC Company Response from FIDUS INVESTMENT Corp (FDUS) (CIK 0001513363) (FDUS) — Mar 18, 2020
FIDUS INVESTMENT Corp (FDUS) (CIK 0001513363)
Date: March 18, 2020 · CIK: 0001513363 · Accession: 0001193125-20-077140
AI Filing Summary & Sentiment
File numbers found in text: 814-00861
Letter
VIA EDGAR Division of Investment Management Washington, DC 20549 Re: Fidus Investment Corporation Preliminary Proxy Statement on Schedule 14A filed February 27, File No. 814-00861
Dear Ms. Brutlag:
On behalf of Fidus Investment Corporation (the “Company”), set forth below is the Company’s response to the oral comment provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to the Company on March 4, 2020, with respect to the Company’s preliminary proxy statement on Schedule 14A (File No. 814-00861), filed with the SEC on February 27, 2020 (the “Preliminary Proxy Statement”). The Staff’s comment is set forth below and is followed by the Company’s response.
1. Comment: Please confirm that all applicable information required by Item 22(b) of Schedule 14A is included in the Preliminary Proxy Statement.
Response: The Company respectfully confirms that all applicable information required by Item 22(b) of Schedule 14A is included in the Preliminary Proxy Statement.
* * * * *
If you have any questions or additional comments concerning the foregoing, please contact me at (202) 383-0278.
Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.
March 18, 2020
Page 2
Sincerely,
/s/ Payam Siadatpour
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CORRESP
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CORRESP
Eversheds Sutherland (US) LLP
700 Sixth Street, NW, Suite 700 Washington, DC 20001-3980
D: +1 202.383.0278
F: +1 202.637.3593
payamsiadatpour@
eversheds-sutherland.com
March 18, 2020
VIA EDGAR
Ms. Samantha Brutlag
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Fidus Investment Corporation
Preliminary Proxy Statement on Schedule 14A filed February 27,
2020
File
No. 814-00861
Dear Ms. Brutlag:
On behalf of Fidus Investment Corporation (the “Company”), set forth below is the
Company’s response to the oral comment provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to the Company on
March 4, 2020, with respect to the Company’s preliminary proxy statement on Schedule 14A (File No. 814-00861), filed with the SEC on February 27, 2020 (the “Preliminary Proxy
Statement”). The Staff’s comment is set forth below and is followed by the Company’s response.
1. Comment: Please confirm that all applicable information required by
Item 22(b) of Schedule 14A is included in the Preliminary Proxy Statement.
Response: The Company respectfully confirms that all applicable information required by Item 22(b) of Schedule
14A is included in the Preliminary Proxy Statement.
*
* *
* *
If you have any questions or additional comments concerning the foregoing, please contact me at (202) 383-0278.
Eversheds Sutherland (US) LLP is part of
a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.
March 18, 2020
Page 2
Sincerely,
/s/ Payam Siadatpour
Payam Siadatpour
cc:
Edward H. Ross, Chief Executive Officer, Fidus Investment Corporation
Shelby E. Sherard, Chief Financial Officer, Fidus Investment Corporation
Steve B. Boehm, Eversheds Sutherland (US) LLP