SecProbe.io

CORRESP
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 Eversheds Sutherland (US) LLP
 700 Sixth Street, NW, Suite 700
 Washington, DC 20001-3980

 D: +1 202.383.0176
 F: +1 202.637.3593

 stephanihildebrandt@eversheds-
sutherland.com

 April 7, 2025

 Via EDGAR

 Securities and Exchange Commission

 Division of Investment Management

 Attention: Kim McManus

 100 F Street NE

 Washington, DC 20549

 Re: Stellus Capital Investment
Corporation – Preliminary Proxy Statement on Form PRE 14A

 Dear Ms. McManus:

 On behalf of Stellus Capital Investment Corporation
(the "Company"), set forth below are the Company's responses to the oral comments provided by the staff of the Division
of Investment Management (the "Staff") of the Securities and Exchange Commission (the "SEC") on April 2,
2025 regarding the Company's preliminary proxy statement on Form PRE 14A (the "Proxy Statement"), which was filed
on March 24, 2025. The Staff's comments are set forth below and are followed by the Company's responses. Capitalized
terms used but not defined herein have the meanings ascribed to such terms in the Proxy Statement.

 PROSPECTUS

 1. On page 26 of the Proxy Statement under the heading "Principal Accountant Fees and Services,"
the first table indicates that the Company paid fees to Deloitte & Touche LLP for services billed in 2023 and 2024 fiscal years.
Please provide, in the introductory paragraph, a reference to both years. Similarly, the next table has the same information for Grant
Thornton LLP, however the introductory paragraph only refers to one year. Please revise.

 Response: As indicated on
Exhibit A, the Company has revised the disclosure above the Deloitte & Touche LLP table as follows: "The
following aggregate fees by Deloitte, the Company's independent registered public accounting firm for the fiscal year ended
December 31, 2024 were billed to the Company for work attributable to audit, tax and other services in each of the fiscal years
ended December 31, 2024 and December 31, 2023."

 As indicated on Exhibit A, the
Company has revised the disclosure above the Grant Thornton LLP table as follows: "The following aggregate fees by Grant
Thornton LLP ("GT"), the Company's independent registered public accounting firm for the fiscal year ended
December 31, 2023 were billed to the Company for work attributable to audit, tax and other services in each of the fiscal years
ended December 31, 2024 and December 31, 2023."

 * 	 * 	 *

 If you have any questions or additional comments concerning the foregoing,
please contact me at (202) 383-0845.

 1

 Via EDGAR
 Ken Ellington, Staff Accountant
April 7, 2025
Page 2

 Sincerely,

 /s/ Stephani M. Hildebrandt

 Stephani M. Hildebrandt

 cc: Robert T. Ladd, Stellus Capital Investment Corporation
 Todd Huskinson, Stellus Capital Investment
Corporation

 Exhibit A

 The material contained in the foregoing
Audit Committee Report is not "soliciting material," is not deemed "filed" with the SEC, and is not to be incorporated
by reference into any filing of the Company under the Securities Act of 1933, as amended, or the Exchange Act, whether made before or
after the date hereof and irrespective of any general incorporation language in any such filing.

 PRINCIPAL ACCOUNTANT FEES AND SERVICES

 The following aggregate fees by Deloitte,
the Company's independent registered public accounting firm for the fiscal year ended December 31, 2024 were billed to the
Company for work attributable to audit, tax and other services in each of the fiscal years ended December 31, 2024 and December 31,
2023.

 Fiscal Year
 Fiscal Year

 Ended
 End

 December 31,
 December 31,

 2024
 2023

 Audit Fees
 $ 102,500
 $ -

 Audit-Related Fees
 $ 337,500
 $ -

 Tax Fees
 286,264
 290,259

 All Other Fees
 -
 -

 Total
 Fees
 $ 726,264
 $ 290,259

 The following aggregate fees by Grant
Thornton LLP ("GT"), the Company's independent registered public accounting firm for the fiscal year ended December 31,
2023 were billed to the Company for work attributable to audit, tax and other services in each of the fiscal years ended December 31,
2024 and December 31, 2023.

 Fiscal Year
 Fiscal Year

 Ended
 End

 December 31,
 December 31,

 2024
 2023

 Audit Fees
 $ -
 $ 383,720

 Audit-Related Fees
 $ 194,196
 $ 243,800

 Tax Fees
 -
 -

 All Other Fees
 -
 -

 Total
 Fees
 $ 194,196
 $ 627,520

 Services rendered by Deloitte and GT in connection with
fees presented above were as follows:

 Audit Fees. Audit fees include
fees for services that normally would be provided by the accountant in connection with statutory and regulatory filings or engagements
and that generally only the independent accountant can provide. In addition to fees for the audit of our annual financial statements,
the audit of the effectiveness of our internal control over financial reporting and the review of our quarterly financial statements in
accordance with generally accepted auditing standards, this category contains fees for comfort letters, statutory audits, consents, and
assistance with and review of documents filed with the SEC.

 Audit-Related Fees. Audit
related fees are assurance related services that traditionally are performed by the independent accountant, such as attest services that
are not required by statute or regulation.

 Tax Fees. Tax
fees include professional fees for tax compliance and tax advice.

 All
Other Fees. Fees for other services would include fees for products and services other than the services reported above.

 It is expected that a representative of
Deloitte will be present at the Meeting, have an opportunity to make a statement if he or she chooses to do so, and be available to answer
questions.

 Pre-Approval Policy

 The Audit Committee has established a
pre-approval policy that describes the permitted audit, audit-related, tax and other services to be provided by Deloitte, the Company's
independent registered public

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