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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CORRESP
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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.