SEC Company Response from WhiteHorse Finance, Inc. (WHF, WHFCL) (CIK 0001552198) (WHF) — Jul 29, 2022
WhiteHorse Finance, Inc. (WHF, WHFCL) (CIK 0001552198)
Date: July 29, 2022 · CIK: 0001552198 · Accession: 0001104659-22-084308
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-265864, 814-00967
Letter
One International Place, 40th Floor
100 Oliver Street
Boston, MA 02110-2605
+1 617 728 7100 Main
+1 617 426 6567 Fax
www.dechert.com
THOMAS FRIEDMANN
thomas.friedmann@dechert.com
+1 617 728 7120 Direct
+1 617 275 8389 Fax
July 29, 2022
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Kenneth Ellington
Re: WhiteHorse Finance, Inc.
Amendment No. 1 to Registration Statement on Form N-2
File Numbers 333-265864 and 814-00967
Gentlemen:
On behalf of WhiteHorse Finance, Inc., a Delaware corporation (the “Company”), we hereby respond to the comments raised by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) pursuant to a telephone call on July 28, 2022, between Kenneth Ellington of the Staff and Thomas Friedmann of Dechert LLP, outside counsel to the Company, relating to the Company’s Amendment No. 1 to Registration Statement on Form N-2 filed with the Commission on July 27, 2022 (the “Registration Statement”).
For your convenience, the Staff’s comments are summarized in this letter, and each comment is followed by the applicable response. Capitalized terms used in this letter and not otherwise defined herein shall have the meanings specified in the Registration Statement.
Accounting Comment
1.
Based upon the percentages of 22.2% and 9.2% of net and total assets comprising unitranche loans, it appears that the Company invests significantly in such loans. Please add risk disclosure related to unitranche loans and specifically identify such loans as unitranche loans on the schedule of investments going forward.
Response:
The Company hereby acknowledges the Staff’s comment and confirms that the Company will include risk disclosure related to unitranche loans and will specifically identify such loans as unitranche loans on the schedule of investments going forward.
* * * * * * * * *
If you have any questions, please feel free to contact the undersigned by telephone at 617.728.7100 or by email at thomas.friedmann@dechert.com or Michael Darby by telephone at 215.994.2088 or by email at michael.darby@dechert.com. Thank you for your cooperation and attention to this matter.
Very truly yours,
Thomas Friedmann
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filename1.htm
One International Place, 40th Floor
100 Oliver Street
Boston, MA 02110-2605
+1 617 728 7100 Main
+1 617 426 6567 Fax
www.dechert.com
THOMAS FRIEDMANN
thomas.friedmann@dechert.com
+1 617 728 7120 Direct
+1 617 275 8389 Fax
July 29, 2022
VIA
EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Kenneth Ellington
Re:
WhiteHorse Finance, Inc.
Amendment No. 1 to Registration
Statement on Form N-2
File Numbers 333-265864 and
814-00967
Gentlemen:
On behalf of WhiteHorse Finance, Inc., a Delaware
corporation (the “Company”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) pursuant to a telephone call on July 28, 2022, between
Kenneth Ellington of the Staff and Thomas Friedmann of Dechert LLP, outside counsel to the Company, relating to the Company’s Amendment
No. 1 to Registration Statement on Form N-2 filed with the Commission on July 27, 2022 (the “Registration Statement”).
For your convenience, the Staff’s comments
are summarized in this letter, and each comment is followed by the applicable response. Capitalized terms used in this letter and not
otherwise defined herein shall have the meanings specified in the Registration Statement.
Accounting Comment
1.
Based upon the percentages of 22.2% and 9.2% of net and total assets comprising unitranche loans, it appears that the Company invests significantly in such loans. Please add risk disclosure related to unitranche loans and specifically identify such loans as unitranche loans on the schedule of investments going forward.
Response:
The Company hereby acknowledges the
Staff’s comment and confirms that the Company will include risk disclosure related to unitranche loans and will specifically identify
such loans as unitranche loans on the schedule of investments going forward.
* * * * * * * * *
If you have any questions, please feel free to
contact the undersigned by telephone at 617.728.7100 or by email at thomas.friedmann@dechert.com or Michael Darby by telephone at 215.994.2088
or by email at michael.darby@dechert.com. Thank you for your cooperation and attention to this matter.
Very truly yours,
Thomas Friedmann
cc:
Stuart Aronson
Joyson C. Thomas
Richard Siegel
WhiteHorse Finance, Inc.
David Harris
Michael Darby
Dechert LLP