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CORRESP

 [Letterhead of Eversheds Sutherland (US) LLP]

April 30, 2021

 VIA EDGAR

Christina DiAngelo Fettig, Senior Staff Accountant

 Division of
Investment Management

 U.S. Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549-4720

Re:
 Fidus Investment Corporation

Registration Statement on Form N-2 (File
No. 333-253525)

 Annual Report on Form 10-K for
the Fiscal Year Ended December 31, 2020 (File No. 814-00861)

 Dear Ms. Fettig:

On behalf of Fidus Investment Corporation (the “Company”), set forth below are the Company’s responses to the
accounting comments received during a telephone call on March 25, 2021 with the staff of the Division of Investment Management (the “Staff”) of the U.S. Securities and Exchange Commission (the
“SEC”) relating to the Company’s Registration Statement on Form N-2 (File No. 333-253525) (the “Registration
Statement”), and the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2020 (File No. 814-00861) (the
“Annual Report”), both of which were filed with the SEC on February 25, 2021.

 The Staff’s comments are
set forth below in italics and are followed by the Company’s responses. Where revisions to the Registration Statement are referenced in the Company’s responses set forth below, such revisions are included in Amendment No. 1 to the
Registration Statement (the “Amended Registration Statement”). Where revisions to the Annual Report are referenced in the Company’s responses set forth below, such revisions will be included in the Company’s
subsequent Annual Report on Form 10-K for the fiscal year ended December 31, 2021 (the “Subsequent Annual Report”) as well as the Company’s Annual Reports on Forms 10-K going forward (collectively with the Subsequent Annual Report, the “Subsequent Annual Reports”). Capitalized terms used in this letter but not otherwise defined herein have the meanings
specified in the Registration Statement and the Annual Report.

 Accounting Comments – Registration Statement

General Comments

1.
 Comment: When future initial registration statement filings are made, please file an
accompanying cover letter as correspondence that includes the Company’s contact information.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will file a cover
letter as correspondence with future initial registration statement filings.

2.
 Comment: If the Company’s Quarterly Report on Form
10-Q for the period ended March 31, 2021 (the “March 31, 2021 10-Q”) is filed prior to
the effectiveness of the Registration Statement, please update the Amended Registration Statement to include data as of March 31, 2021, as applicable.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that it will update the
Amended Registration Statement to include data as of the period ended March 31, 2021 if the March 31, 2021 10-Q is on file prior the effectiveness of the Registration Statement.

3.
 Comment: Please include an updated consent from the Company’s independent
registered public accounting firm with the Amended Registration Statement.

 Response:
The Company acknowledges the Staff’s comment and confirms to the Staff that it will include an updated consent from the Company’s independent registered public accounting firm, RSM US LLP, in the Amended Registration Statement.

4.
 Comment: “RSM US LLP” is referenced in “Part C – Other
Information” of the Registration Statement, but the consent filed as Exhibit(n)(1) to the Registration Statement does not specify this heading in the list of headings under which the firm is referenced. In the updated consent that is filed with
the Amended Registration Statement, please consider including the “Part C – Other Information” in the list of headings, or please consider revising the consent such that RSM US LLP does not specify each heading and generally consents
to all references to its firm in the Registration Statement.

 Response: The Company
acknowledges the Staff’s comment and confirms to the Staff that the updated consent filed with the Amended Registration Statement will specify the “Part C – Other Information” heading in its list of headings to which RSM US LLP
consents to the reference to its firm.

5.
 Comment: On the cover of the Registration Statement, please check the following two
boxes, if applicable: “Check box if this Form is a registration statement pursuant to General Instruction A.2 or a post-effective amendment thereto” and “A.2 Qualified (qualified to register securities pursuant to General Instruction
A.2 of this Form).”

 Response: The Company acknowledges the Staff’s comment and
confirms to the Staff that it has checked both boxes in the Amended Registration Statement, as the Company is a seasoned issuer.

6.
 Comment: The Registration Statement and the Annual Report state that the Company is non-diversified. Please confirm whether the Company is non-diversified and, if so, explain how the Company qualifies as
non-diversified. Please consider modifying the disclosure in the Amended Registration Statement and Subsequent Annual Reports, as necessary.

Response: The Company acknowledges the Staff’s comment and recognizes that, as of December 31, 2020, the
Company’s portfolio would meet the definition of “diversified” under Section 5 of the Investment Company Act of 1940, as amended. Nevertheless, the Company maintains an investment policy that allows it to operate as non-diversified, which also affords it the flexibility to operate as diversified. In addition, the Company has updated the cover page and page 1 of the Amended Registration Statement to provide
additional disclosure regarding the Company’s ability to operate as a diversified or non-diversified company, notwithstanding that it is
a non-diversified company. The Company confirms to the Staff that it will similarly update the disclosure in Subsequent Annual Reports to include this additional disclosure.

 Prospectus Summary

7.
 Comment: Referring to the third paragraph of page 1 of the Registration Statement,
wherever a weighted average yield on debt investments is disclosed that excludes investments on non-accrual status, please update the disclosure to also include a yield on the entire portfolio. Please reflect
this updated disclosure in the Company’s subsequent Quarterly Reports on Form 10-Q, as applicable, and Subsequent Annual Reports.

Response: The Company respectfully advises the Staff on a supplemental basis that the weighted average yield on the
entire portfolio is not materially different than the weighted average yield on its debt investments excluding those investments on non-accrual status. Going forward, if the difference between the weighted average yield on the entire portfolio and
weighted average yield on its debt investments excluding those investments on non-accrual status becomes material, the Company will adjust its disclosure accordingly. In addition, the Company has revised the disclosure on page 1 of the Amended
Registration Statement to include the Company’s total return based on its net asset value and its total return based on its market value.

The Offering

8.
 Comment: Referring to the “Taxation” section on page 4 of the Registration
Statement, the disclosure indicates that the Company will not pay U.S. federal income taxes at the corporate level. The Staff notes that the Company has Taxable Subsidiaries that may be subject to excise tax. Please consider modifying the disclosure
in this paragraph to reference the Taxable Subsidiaries and the potential payment of excise tax.

Response: The Company has revised pages 4 and 40, of the Amended Registration Statement to reflect the Staff’s
comment.

 Fees and Expenses

9.
 Comment: With respect to the Fees and Expenses table on page 7 of the Registration
Statement, the incentive fee is presented as net of the income incentive fee waiver. Please consider whether the incentive fee should be presented as gross, rather than net, of the income incentive fee waiver.

Response: The Company has revised page 7 of the Amended Registration Statement to reflect the Staff’s comment.

10.
 Comment: Referring to footnote 9 on page 8 of the Registration Statement, the Staff
notes that “Other expenses” do not include the taxes listed in the Statement of Operations in the Annual Report. The Fees and Expenses table should include all expenses, including any taxes from such Statement of Operations.

 Response: The Company has revised the “Other expenses” line item of the Fees and
Expenses table on page 7 of the Amended Registration Statement as well as footnote 9 on page 8 of the Amended Registration Statement to reflect the Staff’s comment.

11.
 Comment: On a supplemental basis, please confirm that the “Example” table on
page 9 of the Registration Statement will be updated in subsequent prospectus supplement filings to include the effective transaction expenses.

Response: The Company respectfully advises the Staff on a supplemental basis that it will update the
“Example” table on page 9 of the Amended Registration Statement to include the effective transaction expenses in subsequent prospectus supplement filings.

12.
 Comment: In the “Example” table on page 9 of the Registration Statement,
using an expense ratio of 12.53%, the Staff calculated $121, $335, $519, and $869 for 1 year, 3 years, 5 years and 10 years, respectively, for the first line item in that table. Please consider revising such line item to reflect these values.

 Response: The Company respectfully advises the Staff on a supplemental basis that the
amounts in the first line item of the “Example” table have been updated to account for the change made to the Fees and Expenses table in response to Comment 10 and to clarify the calculation used to reach such amounts.

13.
 Comment: On a supplemental basis, please provide the Staff with the expense ratio that
was used to reach the values provided in the second line item of the “Example” table on page 9 of the Registration Statement.

Response: The Company respectfully advises the Staff on a supplemental basis that an expense ratio of 12.53% had
been used to reach the values provided in the second line item of the “Example” table on page 9 of the Registration Statement, and an expense ratio of 12.75% was used to reach the values provided in the second line item of the
“Example” table on page 9 of the Amended Registration Statement. The Company respectfully advises the Staff on a supplemental basis that the amounts in the second line item of the “Example” table have been updated to account for
the change made to the Fees and Expenses table in response to Comment 10 and to clarify the calculation used to reach such amounts.

14.
 Comment: On a supplemental basis, please confirm that the Fees and Expenses table in
the Company’s filings going forward (e.g., Subsequent Annual Reports, prospectus supplements, and any other applicable filings) will be updated to reflect the Staff’s comments on the Fees and Expenses table in the Registration Statement,
as applicable.

 Response: The Company respectfully advises the Staff on a supplemental
basis that it will update the Fees and Expenses table in the Company’s filings going forward (e.g., Subsequent Annual Reports, prospectus supplements, and any other applicable filings) to reflect the Staff’s comments on the Fees and
Expenses table in the Registration Statement, as applicable.

 Senior Securities

15.
 Comment: If the Company’s March 31, 2021 10-Q is filed prior to the effectiveness of the Registration Statement, please confirm to the Staff whether an updated Senior Securities table will be included in the Registration Statement or the
March 31, 2021 10-Q to include such quarterly data as of March 31, 2021. Please see Form N-2, Item 4.3, Instruction 1.

 Response: The Company respectfully advises the Staff on a supplemental basis that the
updated Senior Securities table will be included in the Amended Registration Statement if the March 31, 2021 10-Q is filed prior to the effectiveness of the Registration Statement.

Portfolio Companies

16.
 Comment: On page 24 of the Registration Statement, please update the “Portfolio
Companies” section to include the list of portfolio companies, rather than incorporating by reference to the Annual Report. The Staff notes that in the Schedule of Investments in the Annual report, the address and the percentage of class
ownership are not denoted for each portfolio company. Please see Form N-2, Item 8.6. In addition, on a supplemental basis, please explain why Pinnergy, Ltd. is not categorized as a Control Investment
given that the Company owns more than 25% of this portfolio company.

 Response: The
Company has revised page 24 of the Amended Registration Statement to reflect the Staff’s comment. In addition, the Company respectfully advises the Staff on a supplemental basis that, pursuant to the 1940 Act, a company must own more than 25%
of the company’s voting securities in order to be deemed to control such company. The Company owns less than 25% of the voting securities of Pinnergy, Ltd.; therefore, the Company does not control such portfolio company, and as a result, it is
categorized as an Affiliate Investment and not a Control Investment.

 Incorporation of Certain Information by Reference

17.
 Comment: On page 81 of the Registration Statement, please remove references to the
Small Business Credit Availability Act, as such legislation is now in effect.

 Response:
The Company has revised pages 6 and 83 of the Amended Registration Statement to reflect the Staff’s comment.

18.
 Comment: If any additional information is on file prior to the filing of the Amended
Registration Statement, please update the “Incorporation of Certain Information by Reference” section on page 81 of the Registration Statement to incorporate such information by reference, as necessary.

Response: The Company acknowledges the Staff’s comment and confirms to the Staff that to the extent any
additional information is on file prior to the filing of the Amended Registration Statement, the Company will update the “Incorporation of Certain Information by Reference” section to incorporate such information by reference, as
necessary.

 Accounting Comments – Annual Report

General Comments

19.
 Comment: Given that the Company is a seasoned issuer, please explain why not all of the
disclosure requirements for seasoned issuers (e.g., Senior Securities table, Fees and Expenses table, and Price Range of Common Stock and Distributions table) are not each included in the Annual Report. The Staff notes that the Price Range of Common
Stock and Distributions table starting on page 14 of the Registration Statement is not included in the Annual Report. Please include such table in Subsequent Annual Reports, or alternatively, please explain on a supplemental basis why such table is
not required to be included in Subsequent Annual Reports. Please see Form N-2, Item 24, Instruction 4(h).

Response: The Company respectfully advises the Staff on a supplemental basis that the Senior Securities
table and the Fees and Expenses table are included in the Annual Report and will continue to be included in Subsequent Annual Reports, and that the Price Range of Common Stock and Distributions table is included in the Company’s most recent
Definitive Proxy Statement on Schedule 14A and will continue to be included in the Company’s subsequent Definitive Proxy Statement on Schedule 14A filings. The Company also confirms to the Staff that it will include the Price Range of Common
Stock and Distributions Table (Form N-2, Item 8.5) in Subsequent Annual Reports.

20.
 Comment: Because the Registration Statement will forward-incorporate the Subsequent
Annual Reports by reference, please confirm to the Staff that the Company will file with the Subsequent Annual Report the required consent from its independent registere