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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 27, 2018

Via EDGAR

Securities and Exchange Commission

Division of Investment Management

Attn. Jay Williamson, Esq.

100 F Street, N.E.

Washington, DC 20549

 Re: Stellus Capital Investment Corporation

   Amended Preliminary Proxy Statement – filed
April 6, 2018

Dear Mr. Williamson:

On behalf of Stellus Capital Investment Corporation (the “Company”),
set forth below are the Company’s responses to the additional comments provided by the staff of the Division of Investment
Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”)
to the Company on April 20, 2018 and April 23, 2018 relating to the Company’s Amended Preliminary Proxy Statement on Schedule
14A (File No. 814-00971) (the “Preliminary Proxy Statement”) and responses to the Staff’s comments
previously provided on April 13, 2018 and April 20, 2018 (the “Prior Response Letter”). The Staff’s
comments are set forth below in italics and are followed by the Company’s responses. Where indicated, revised disclosure
will be included in the definitive proxy statement on Schedule 14A to be filed by the Company (the “Definitive Proxy
Statement”).

 1. We note the text proposed in response to comment 3 in the Prior Response Letter and believe that
the suggested disclosure in the Staff’s comment is clearer to investors. Please consider revising this disclosure as recommended
by the Staff.

Response: The Company has revised its
disclosure in accordance with the Staff’s comment.

 2. Based on your response to comment 4 in the Prior Response Letter it appears the purpose of Proposal 3 included in the Preliminary
Proxy Statement is to request stockholder approval to reduced asset coverage ratio prior to April 4, 2019. As drafted, the proposal
is broader than its purpose. Please revise the proposal so that it seeks authority for only the period prior to April 4, 2019 or
explain why you have not done so.

Response: The Company acknowledges the
Staff’s comment and respectfully advises the Staff that it does not believe that the proposal is broader than its purpose.
Proposal 3, if permitted would reduce the Company’s required minimum asset coverage ratio from 200% to 150% with immediate
effect. If Proposal 3 is not approved, then the reduced minimum asset coverage ratio will not take effect until the statutory one-year
waiting period has expired. The Company has revised Proposal 3 to indicate that the reduced minimum asset coverage ratio will take
immediate effect.

    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.

        Mr. Jay Williamson

        April 27, 2018

        Page 2

The Company further advises the Staff that it does
not believe that Proposal 3 amounts to a ratification of the Board’s action to approve the Company’s required minimum
asset coverage ratio effective April 4, 2019, such that stockholder approval would change the Board’s responsibility for
taking action on the proposal. The Company’s Board has recommended that stockholders vote to approve Proposal 3, which would
take effect immediately as permitted under the SBCA, and have done so in exercise of their fiduciary duty to stockholders. This
recommendation reflects the Board’s determination that the adoption of Proposal 3 by the Company’s stockholders is
in the best interest of the Company and its stockholders and is based on the same grounds as the Board’s decision to adopt
the reduced minimum asset coverage ratio subject to the expiration of the statutory one-year waiting period.

 3. We note your response to comment 5 in the Prior Response Letter. Please revise your disclosure to more clearly explain how
the additional borrowings make the incentive hurdle easier to meet. Also please quantify the potential increase in base management
fee assuming the company increases its leverage to the maximum extent permitted.

Response: The Company
has revised the disclosure in accordance with the Staff’s comment.

 4. We reissue comment 6. We believe the disclosure is helpful to understanding the proposal and should be provided using reasonable
assumptions that are disclosed and explained for investors.

Response: The Company acknowledges the
Staff’s comment and respectfully disagrees with the Staff’s analysis. The Company believes that the assumptions required
in drafting the disclosure requested by the Staff’s comment are inherently unreasonable and speculative. However, the Company
agrees to comply with the Staff’s comment and has included the disclosure requested in the Staff’s prior comment 6.

*	*	*

If you have any questions or additional comments concerning
the foregoing, please contact me at (202) 383-0845 or Adam Park at (202) 383-0937.

Sincerely,

Stephani M. Hildebrandt