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CORRESP

Simpson Thacher & Bartlett LLP

 900 G STREET NW

WASHINGTON, D.C. 20001

 TELEPHONE: +1-212-455-2000

 FACSIMILE: +1-212-455-2502

 Direct Dial Number

 (202) 636-5879

 E-mail Address

christopher.healey@stblaw.com

 August 31, 2023

 Via
EDGAR

 Securities and Exchange Commission

 Division of
Investment Management

 100 F Street, N.E.

 Washington, D.C.
20549

Attn:
 Anu Dubey

Ken Ellington

Re:
 Carlyle Credit Income Fund

Registration Statement on Form N-2

(File Nos. 333-272426 and 811-22554)

Ladies and Gentlemen:

 On behalf of Carlyle
Credit Income Fund (the “Fund”), a registered closed-end fund, we hereby file with the staff (the “Staff”) of the Division of Investment Management of the U.S. Securities and Exchange
Commission (the “Commission”) Pre-Effective Amendment No. 2 ( “Amendment No. 2”) to the above-referenced shelf registration statement on Form
N-2 (the “Registration Statement”) in connection with the registration of the offer and sale from time to time of common shares, preferred shares, subscription rights, and debt securities of the
Fund. Amendment No. 2 includes revisions to the Registration Statement in response to the Staff’s comments received by telephone on August 1, 2023 and August 9, 2023 relating to the Registration Statement and certain other
revisions.

 For convenience of reference, the Staff’s comments have been reproduced herein. Please note that all page numbers in our
responses are references to the page numbers of Amendment No. 2. All capitalized terms used but not defined in this letter have the meanings given to them in Amendment No. 2.

Prospectus Cover

1.
 Please disclose that the Fund will not invest more than 15% of net assets in LAFs, if LAFs are private
funds that rely on 3(c)(1) or 3(c)(7) of the 1940 Act or alternatively, explain to why the Fund should be able to invest without limit in LAFs.

Securities and Exchange Commission

August 31, 2023

 Response: The Fund advises the Staff on a supplemental basis that loan accumulation
facilities generally rely on the exemptions available in Section 3(c)(7) of the 1940 Act. The Fund believes, however, that loan accumulation facilities should not be subject to a 15% limit because they are structured similarly to CLOs and
possess certain attributes that distinguish them from typical private investment funds, including the following: (i) they pursue narrowly defined long-only investment mandates, (ii) they provide complete transparency to their investors,
(iii) the management and performance fee structure is not based on unrealized gains from underlying investments and (iv) their securities are actively traded on secondary markets. The Fund respectfully adds that other funds, including the
Fund’s peers such as OFS Credit Company, Inc., do not limit their investment in LAFs to 15% of net assets. (See OFS Credit Company, Inc. Correspondence
, dated July 2, 2019.)

2.
 Regarding the statement about the leverage LAFs incur, please clarify what it means to “incur leverage
between four and six times.”

 Response: In response to the Staff’s comment, the Fund has revised the
relevant disclosure to clarify that “incur leverage between four and six times” means four and six times equity value.

3.
 Replace the phrase “is expected to consider” with “considers.”

Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

4.
 Regarding the list of instruments that the Fund considers credit and credit-related instruments, please remove
“(viii) other credit-related instruments” and identify any other credit-related instruments that are part of the Fund’s principal investments.

Response: The Fund respectfully declines to make the requested revision. For purposes of the Fund’s investment policy of investing
at least 80% of its assets in credit-related instruments, the Fund includes credit instruments of any kind. The Fund has highlighted those categories of credit instruments that it expects to constitute its most significant investments. “Other
credit-related instruments” is intended to clarify that a credit instrument that does not fall within one of the other enumerated categories would still be a permitted investment for the Fund consistent with its 80% policy. This language also
is intended to provide the Fund with the flexibility to invest in new types of credit instruments that may be developed in the future. The Fund respectfully notes that the Fund previously responded to this comment in its letter dated
February 13, 2023, in connection with the Fund’s preliminary proxy statement.

5.
 Please disclose what “other instruments designed to obtain indirect exposure to credit and credit-related
instruments” are.

 Response: The Fund respectfully declines to make the requested change to its disclosure.
The Fund notes that “other instruments designed to obtain indirect exposure to credit and credit-related instruments” is intended to clarify that a credit instrument that does not fall

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Securities and Exchange Commission

August 31, 2023

within one of the other enumerated categories would still be a permitted investment for the Fund consistent with its 80% policy, and is also is intended to provide the Fund with the flexibility
to invest in new types of credit instruments that may be developed in the future.

6.
 Please confirm supplementally that derivatives counted toward the 80% bucket will be valued based on market
value. (See Rule 35d-1).

 Response: The Fund acknowledges the
Staff’s comment and confirms that any derivatives counted toward the 80% bucket will be valued according to their market value.

7.
 Please disclose the Fund’s former name and the date on which it was changed. (See Item 16 of Form N-2.)

 Response: The Fund has revised its disclosure accordingly in response to
the Staff’s comment.

 Prospectus Summary

Page 1

8.
 Please reconcile the first bullet point of the Prospectus Summary that indicates the Fund is
“diversified,” with the rest of the document which indicates that the Fund is “non-diversified.”

Response: The Fund has revised its disclosure to indicate that the Fund is non-diversified.

9.
 Please insert into the Prospectus Summary for the description of the Fund’s principal strategies a heading
which include the phrase “Principal Strategies.” (See Instruction to Item 3.2 of Form N-2).

Response: The Fund has revised the Prospectus Summary to incorporate the heading “Principal Strategies.”

Page 2

10.
 Please disclose whether the Control Share Statute applies to Carlyle’s expected holding and if not, please
disclose why not.

 Response: In response to the Staff’s comment, the Fund has revised its disclosure to
indicate that the Board has exempted shares owned by an affiliate of CGCIM from the Control Share Statute.

11.
 Please disclose that joint venture vehicles include only those in which the Fund and another party have equal
control of the vehicle.

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Securities and Exchange Commission

August 31, 2023

 Response: The Fund has revised its disclosure accordingly in response to the
Staff’s comment.

12.
 Please disclose which fees will be rebated, who fees are paid by, and who they will be rebated to.

 Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

Page 3

13.
 The Prospectus Summary makes reference to the “OneCarlyle” platform. Please disclose what the
OneCarlyle platform is.

 Response: The Fund has revised its disclosure accordingly in response to the Staff’s
comment.

14.
 Please explain supplementally if the Fund will primarily control any CLOs.

Response: The Fund does intend to hold more than 25% of the equity tranche of any CLO.

Page 4

15.
 Please disclose what “active carry fund investors” means.

Response: The Fund has revised its disclosure for clarity to refer to “active fund investors.”

16.
 Please disclose the maturity of the Fund’s credit investments in the Principal Strategies section.

 Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

17.
 Where CLO asset holdings are discussed, please specify the “asset concentration limits” that the CLOs
will be subject to.

 Response: The Fund respectfully declines to revise disclosure as concentration limits are CLO
specific and vary from CLO to CLO. The Fund notes that the Fund’s peers, including Eagle Point Credit Company Inc. and Oxford Lane Capital Corp, do not provide such disclosure in their respective registration statements.

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Securities and Exchange Commission

August 31, 2023

 Page 6

18.
 Please identify the specific types of leverage the Fund will obtain within the disclosed 25% to 40% range of
leverage and identify any corresponding risks of such leverage in the principal risks section.

 Response: The Fund
respectfully declines to revise its disclosure and notes that later in the Registration Statement it discloses that it may incur leverage, directly or indirectly, through one or more special purpose vehicles, indebtedness for borrowed money, as well
as leverage in the form of Derivative Transactions, preferred shares, debt securities and other structures and instruments, in significant amounts and on terms that the Adviser and the Board deem appropriate, subject to applicable limitations under
the 1940 Act and describes the corresponding risks in the risk factor entitled, “We may leverage our portfolio, which would magnify the potential for gain or loss on amounts invested and will increase the risk of investing in us.”
The Fund also notes that its disclosure is consistent with the Fund’s peers, including Eagle Point Credit Company Inc. and Oxford Lane Capital Corp.

19.
 Please disclose the other “investment . . . purposes” for which the Fund would engage in derivative
transactions.

 Response: The Fund respectfully declines to revise its disclosure. Although the Fund acknowledges
the Staff’s concerns, the existing disclosure is consistent with peer disclosure and essential to allowing the Fund needed flexibility in responding to market conditions. The Fund notes that it is subject to certain rules and restrictions on
such derivative transactions as set forth in the “Risk Factors” section. (See “Risk Factors — Risks Related to Our Investments — We are subject to risks associated with any hedging or Derivative Transactions
in which we participate.”)

 Page 8

20.
 Please disclose in plain English what “carry funds” are.

Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

Page 9

21.
 Please clarify the “conflict” discussed with respect to the Adviser and the Shareholders.

 Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

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Securities and Exchange Commission

August 31, 2023

 Summary of Fees and Expenses

Page 15

22.
 Regarding the Fee Table, please explain why the following line items are higher in the N-2 Fee Table than in Proxy Statement pro forma fee table: (1) Management fee, (2) Incentive fee, (3) Other Expenses. (See Item 22(a)(3)(iv) instruction 2).

Response: The Fund respectfully notes that the line items in the Fee Table of the N-2 (the Fee
Table”) are higher than in the definitive proxy statement pro forma fee table (“Pro Forma Fee Table”) because the expenses in the Fee Table are estimated amounts based on annualizing estimates for the three-month period ending
December 31, 2023, whereas the expenses in the Pro Forma Fee Table were based on the actual expenses of the Fund as of the fiscal year ended September 30, 2022.

23.
 Please explain why expenses in the fee table are estimated amounts based on annualizing estimates for the
three-month period ending December 31, 2023. In your explanation, please address both the use of the 3-month period and the use of a future period that has not happened yet. (See Instruction 6 to
Item 3.1 of Form N-2, which says, “State in the narrative following the table that “Other Expenses” are based on estimated amounts for the current fiscal year.”) The Staff respectfully
notes that the Fund’s current fiscal year ends September 30, 2023.

 Response: The Fund annualized
estimated expenses for the three-month period ending December 31, 2023 instead of the current fiscal year because the Fund’s investment adviser, investment strategy and investment advisory agreement all changed effective upon the closing
of the Transaction on July 14, 2023. Additionally, the Fund incurred significant non-recurring expenses in connection with the Transaction in the current fiscal year. Accordingly, basing the expenses in
the fee table on expenses in the current fiscal year would not be an accurate reflection of the Fund’s go-forward fee and expense structure. Instead, the Fund annualized the estimated expected expenses
for the first full quarter following the closing of the Transaction.

24.
 Consider shortening Footnote 6 by providing cross reference to the incentive fee disclosure instead of
disclosing in the footnote.

 Response: The Fund has considered the Staff’s comment and respectfully notes
that this level of disclosure is consistent with disclosure in other Carlyle funds, for example the Carlyle AlpInvest Private Markets Fund, and the Fund’s peers, including Eagle Point Credit Company Inc. and Oxford Lane Capital Corp.

25.
 If the Fund currently intends to issue preferred shares and/or debt securities at any point within one year of
the effective date of the N-2, please revise the fee table to reflect the costs of such issuances.

Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

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Securities and Exchange Commission

August 31, 2023

 Page 16

26.
 Please remove Footnote 9 from the fee table and disclose elsewhere.

Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

Risk Factors

 Page 19

27.
 The Fund discusses covenant-lite loans in the Risk Factors section. If covenant-lite loans are part of the
Fund’s principal strategies, please also identify in the Principal Strategies section.

 Response: The Fund
respectfully notes that while it may invest in covenant-lite loans, there is no current intent to invest a significant amount in such loans and therefore the Fund does not consider covenant-lite loans to be a part of its principal strategies.

Page 20

28.
 Please clarify the meaning of “negative loan ratings migration.”

Response: The Fund has revised its disclosure accordingly in response to the Staff’s comment.

Page 26

29.
 Please explain supplementally why the Fund will use special purpose vehicles (“SPVs”) for leverage
instead of investing directly.

 Response: The Fund respectfully notes that the use of wholly-owned
bankruptcy-remote SPVs for leverage purposes has become quite common in the industry, and that the use of one or more SPVs may enable the Fund to be able to obtain financing on more favorable terms than if the Fund were to invest directly.

30.
 Please define “special purpose vehicles” as any entity that primarily engages in investment
activities in securities or other assets that is either (i) wholly owned and/or majority owned by the Fund or (ii) primarily controlled by the Fund. If the definition of SPV is limited to wholly owned entities only or wholly owned and
majority owned entities only, please also disclose that the Fund does not intend to create or acquire primary control of any entity that primarily engages in investment activities in securities or other assets other than entities wholly owned by the
fund or wholly owned/majority owned by the fund.

 Response: In response to the Staff’s comment, the Fund has
revised its disclosure to define “special purpose vehicles” as “wholly-owned” by the Fund and incorporated the requested additional disclosure.

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Securities and Exchange Commission

August 31, 2023

 Additionally,

a.
 Please disclose any of the principal strategies or principal ris