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SEC Company Response from Stellus Capital Investment Corp (SCM) (CIK 0001551901) (SCM) — Feb 21, 2017

Stellus Capital Investment Corp (SCM) (CIK 0001551901)
Date: Feb. 21, 2017 · CIK: 0001551901 · Accession: 0001144204-17-009950

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SEC Posture
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Summary

Reasoning

Date
February 21, 2017
Author
/s/ Steven B. Boehm
Form
CORRESP
Company
Stellus Capital Investment Corp (SCM) (CIK 0001551901)

Letter

Via EDGAR eversheds-sutherland.com Re: Stellus Capital Investment Corporation – Registration Statement on Form N-2

Dear Sir or Madam:

On behalf of Stellus Capital Investment Corporation (the “Company”), we are transmitting herewith for filing under the Securities Act of 1933, as amended (the “Securities Act”), a registration statement on Form N-2 (the “Registration Statement”). The Registration Statement relates to the shelf offering of the Company’s securities under Rule 415 of the Securities Act.

The Company respectfully asks that the staff of the Securities and Exchange Commission afford the Registration Statement selective review in accordance with Securities Act Release No. 6510 (February 15, 1984). The disclosure contained in the Registration Statement is substantially similar to the disclosure contained in the Registration Statement as declared effective on December 12, 2014, except for the updating of financial information and certain other data.

Please let us know if you would like a courtesy copy of the Registration Statement. If you have any questions or comments regarding the Registration Statement, please do not hesitate to contact the undersigned at (202) 383-0176 or Stephani Hildebrandt at (202) 383-0845.

Sincerely,
/s/ Steven B. Boehm

Show Raw Text
CORRESP
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filename1.htm

        February 21, 2017

        Via EDGAR

        U.S. Securities and Exchange Commission

        100 F Street, NE

        Washington, D.C. 20549

        Eversheds Sutherland (US) LLP

        700 Sixth Street, NW, Suite 700

        Washington, DC 20001-3980

        D: +1 202.383.0176

        F: +1 202.637.3593

        stevenboehm@

        eversheds-sutherland.com

    Re:

        Stellus Capital Investment Corporation –

        Registration Statement on Form N-2

Dear Sir or Madam:

On behalf of Stellus Capital Investment Corporation (the “Company”),
we are transmitting herewith for filing under the Securities Act of 1933, as amended (the “Securities Act”), a registration
statement on Form N-2 (the “Registration Statement”). The Registration Statement relates to the shelf offering of the
Company’s securities under Rule 415 of the Securities Act.

The Company respectfully asks that the staff of the Securities
and Exchange Commission afford the Registration Statement selective review in accordance with Securities Act Release No. 6510 (February
15, 1984). The disclosure contained in the Registration Statement is substantially similar to the disclosure contained in the Registration
Statement as declared effective on December 12, 2014, except for the updating of financial information and certain other data.

Please let us know if you would like a courtesy copy of the
Registration Statement. If you have any questions or comments regarding the Registration Statement, please do not hesitate to contact
the undersigned at (202) 383-0176 or Stephani Hildebrandt at (202) 383-0845.

    Sincerely,

    /s/ Steven B. Boehm

    Steven B. Boehm

    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.