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CORRESP
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Point
Capital. Inc.

September
18, 2015

BY
EDGAR

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Cristina Fettig

    Re:
    Point Capital,
    Inc.

    File No. 814-01038

Dear
Ms. Fettig:

The
following sets forth the responses of Point Capital, Inc. (the "Company") to the questions raised by the Securities
and Exchange Commission (the "Commission") on a conference call held August 26, 2015 among Cristina Fettig, Adam Wasserman,
chief financial officer of the Company, and David Lubin, general counsel to the Company.

 1. Section
                                         23(a) of the Investment Company Act of 1940 (the "Investment Act") prohibits
                                         a closed-end fund from issuing securities for services or property other than for cash
                                         or securities. The 6,126,240 shares which were issued in March 2014 were issued to Network
                                         1 Financial Services as part of the offering costs; such shares were issued as part of
                                         the securities issued by the Company to Network 1. The offering through Network 1 was
                                         done prior to the Company electing to be treated as a business development company (the
                                         N-54A was filed by the Company on October 4, 2013; the Form D filed by the Company in
                                         September 10, 2013 regarding the offering). The 500,000 shares issued to a consultant
                                         in July 2014 were issued for introductions said individual made on behalf of the Company.
                                         There were no services provided, only introductions and contact information to investment
                                         bankers and other potential capital sources. We could have paid said consultant entirely
                                         in cash, but since he expressed an interest in acquiring equity in the Company we compensated
                                         him partially in cash and partially by issuing him shares. The offering price was based
                                         on an above marked price as well as an increase from the prior offering price.

 2. The
                                         Company disclosed that it paid offering costs of approximately $1.2 million in an offering
                                         which generated approximately $2.2 million. The Company determined that the offering
                                         costs were reasonable as Network 1 was the only investment banker willing to raise funds
                                         for the Company; after negotiating the terms of the offering, including their compensation,
                                         the Company determined it was reasonable to pay such offering expenses as compared to
                                         not having any funds to operate. Although the shareholders of the Company did not approve
                                         these offering expenses, the expenses of the offering were provided in the private placement
                                         documentation received by all the investors. As stated above, the offering commenced
                                         prior to the Company electing to become a BDC.

 Point Capital, Inc.

285
Grand Avenue, 5 Patriot Center, Fl. 2 Englewood, NJ 07631 O: (201)408-5126 F: (201)408.5125

 3. Item
                                         9-A of the Form 10-K indicates that the Company has material weakness as a result of
                                         inadequate segregation of duties and ineffective controls. The Company has begun to rectify
                                         this situation by appointing two independent members to the Board who will also be on
                                         the audit committee. Moreover, the Company recently appointed Adam Wasserman as the Company's
                                         Chief Financial Officer. Since 1999, Mr. Wasserman has been Chief Executive Officer for
                                         CFO Oncall, Inc., which provides chief financial officer services to various public companies.
                                         Currently, Mr. Wasserman also serves as the chief financial officer of Cleantech Solutions
                                         International, Inc. a position he has held since December 2012, Pen, Inc. a position
                                         he has held since September 24, 2014 and LegacyXChange, Inc., a position he has held
                                         since November 2014. In addition to Mr. Wasserman's time, CFO Oncall has full-time dedicated
                                         professional associates who assist Mr. Wasserman with our financial matters and controls
                                         and procedures. Mr. Wasserman is currently setting up procedures to segregate cash functions,
                                         approval functions, and other controls and procedures to ensure that the initiation of
                                         transactions, the custody of assets and the recording of transactions will be performed
                                         by separate individuals

 4. Prior
                                         to the execution of a custody agreement with U.S. Bank National Association in August
                                         2014, the securities held in the name of the Company were held in deposit in the custody
                                         of the Company in a locked safe. Although the former Chief Financial Officer of the Company
                                         was the sole custodian of the securities during this time, the Company acknowledges that
                                         this procedure was not in compliance with the rules and regulations of the Investment
                                         Act.

 5. Section
                                         56(a) of the Investment Act requires that at least a majority of the Board of Directors
                                         be composed of independent directors. Upon the appointment of Messrs. Stone and Schiller
                                         on July 30, 2014, the Company had a Board which consisted of a majority of independent
                                         directors. Moreover, upon the appointment of said two individuals and the resignation
                                         of Mr. Brand from the audit committee, the Company had an audit committee which consisted
                                         solely of independent directors.

 6. Section
                                         (a)(2)(C) of the Investment Act requires that the holders of the senior securities have
                                         the right to elect at least two directors. Section 4(b) of the Certificate of Designation
                                         of the Series A Convertible Preferred Stock (the "Preferred") provides that
                                         if at any time the holders of the Preferred are otherwise entitled under the Investment
                                         Act to elect a majority of the Board, the number of directors shall be automatically
                                         increased and the holders of the Preferred shall be entitled to elect additional directors,
                                         together with the two directors that the holders are entitled to elect. Therefore, the
                                         Preferred provides that not only do the holders of the Preferred have the right to two
                                         directors, but if the number of directors are increased the holder of the Preferred has
                                         the right to elect a majority of the Board. Although the holder of the Preferred has
                                         not elected to exercise their right to elect at least two directors, the holder of the
                                         Preferred has such right.

Section
(a)(2)(E) of the Investment Act requires that the class of stock shall have complete priority over any other class as to distribution
of assets and payments of dividends. Section 5 of the Certificate of Designation of the Preferred provides that the holders of
the Preferred shall be entitled to a priority before any distribution or payment to the holders of junior securities. Although
Section 3(a) of the Certificate of Designation provides that the holders of the Preferred are entitled to dividends on an as-converted
basis, the Company has no intention to pay dividends and with the consent of the holder of the Preferred said section can be amended.

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Section
61(a)(3)(B) of the Investment Act provides that a business development company can issue stock options to officers and directors
under certain specified circumstances. Although the Company issued the options as disclosed in the Company's Form 10-Q for the
quarter ended June 30, 2015, the Company obtained the approval of the shareholders for the executive compensation at the annual
meeting of its shareholders held on May 20, 2015. As disclosed in the Current Report on Form 8-K filed by the Company on May 29,
2015, 27,887,025 of the 28,068,692 of the votes adopted the non-binding proposal and received the approval of its shareholders
for the issuance thereof.

 8. As
                                         indicated on the schedule of investments filed with the Form 10-K, the Company does not
                                         possess any non-qualifying assets.

 9. On
                                         the consolidated statement of operations filed with the Form 10-K, all individual expenses
                                         in excess of 5% of total expenses are disclosed separately pursuant to Regulation S-X
                                         Article 607 (2)(b).

 10. The
                                         statement of assets and liabilities consists of cash and cash equivalents which includes
                                         cash deposits and a money market account held at our bank and brokerage firms in accordance
                                         with Article 604 (12)(b) of Reg. S-X.

 11. There
                                         are currently no open payables to directors or trustees of the Company.

 12. The
                                         taxes indicated in the cash flow statement related to minimum state taxes paid to the
                                         State of New Jersey.

13.	  In
accordance with audit guide of investment companies Chapter 7, Section 75, we believe the carrying amount reported in the consolidated
balance sheets for Redeemable Series A, Convertible Preferred stock, $0.0001 par value, 5,000,000 shares authorized, 1,000,000
shares designated; 4,000 and none issued and outstanding ($100 per share redemption value) approximate the fair market value of
$400,000 based on the short-term maturity of these instruments, which also equals the redemption value reflected on the consolidated
balance sheets. We will disclose such information in future filings in our notes to consolidated financial statements.

 14. Attached
                                         to this letter please find a copy of the Board resolution authorizing the amount and
                                         the form of the bond as disclosed in the Form 40-17G filed with the Commission on January
                                         26, 2014.

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The Company
hereby acknowledges that:

1.	        Should
the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, have
no further questions or comments, it does not foreclose the Commission from taking any action with respect to the filing of the
reports filed by the Company with the Commission.

2.        	The
action of the Commission or the staff, acting pursuant to delegated authority, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in their filings.

3.        	The
Company may not assert the staff's comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

The
Company respectfully submits via EDGAR the foregoing responses to the Commission. Please address any further questions or comments
to the undersigned at the above-referenced telephone and fax numbers. Thank you very much.

    Very truly yours,

    /s/
    Richard Brand

    Richard
    Brand

    Chief
    Executive Officer

    cc:
    Adam Wasserman

    David Lubin

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