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SEC Company Response from Stellus Capital Investment Corp (SCM) (CIK 0001551901) (SCM) — Apr 6, 2018

Stellus Capital Investment Corp (SCM) (CIK 0001551901)
Date: April 6, 2018 · CIK: 0001551901 · Accession: 0001144204-18-019664

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
April 6, 2018
Author
/s/ Stephani M.
Form
CORRESP
Company
Stellus Capital Investment Corp (SCM) (CIK 0001551901)

Letter

Via Edgar 100 F Street, NE Washington, D.C. 20549 Re: Stellus Capital Investment Corporation – Preliminary Proxy Statement on Schedule 14A

Dear Sir or Madam:

On behalf of Stellus Capital Investment Corporation (the “Company”), we are filing a revised Preliminary Proxy Statement on Schedule 14A (the “Revised Preliminary Proxy Statement”) pursuant to the rules and regulations of the Securities Exchange Act of 1934. The Company is filing the Revised Preliminary Proxy Statement to permit the staff of the Securities and Exchange Commission an opportunity to review disclosure related to an additional proposal that has been approved by the Company’s board of directors for inclusion in the agenda for the Company’s 2018 annual stockholders’ meeting.

Please call me at the above number if you have any questions or comments regarding the foregoing.

Sincerely,
/s/ Stephani M.
Hildebrandt

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CORRESP
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    Eversheds
                                  Sutherland (US) LLP

700 Sixth Street, NW, Suite 700

Washington, DC 20001-3980

D: +1 202.383.0845

F: +1 202.637.3593

stephanihildebrandt@

eversheds-sutherland.com

April 6, 2018

Via Edgar

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:
    Stellus Capital Investment Corporation – Preliminary Proxy Statement on

                                            Schedule 14A

Dear Sir or Madam:

On behalf of Stellus Capital Investment
Corporation (the “Company”), we are filing a revised Preliminary Proxy Statement on Schedule 14A (the “Revised
Preliminary Proxy Statement”) pursuant to the rules and regulations of the Securities Exchange Act of 1934. The Company is
filing the Revised Preliminary Proxy Statement to permit the staff of the Securities and Exchange Commission an opportunity to
review disclosure related to an additional proposal that has been approved by the Company’s board of directors for inclusion
in the agenda for the Company’s 2018 annual stockholders’ meeting.

Please call me at the above number if you
have any questions or comments regarding the foregoing.

Sincerely,

/s/ Stephani M.
Hildebrandt

    cc:
    Robert T. Ladd

    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.