SEC Company Response from WhiteHorse Finance, Inc. (WHF, WHFCL) (CIK 0001552198) (WHF) — Sep 16, 2014
WhiteHorse Finance, Inc. (WHF, WHFCL) (CIK 0001552198)
Date: Sept. 16, 2014 · CIK: 0001552198 · Accession: 0001144204-14-056287
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-196436, 814-00967
Letter
1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
Thomas Friedmann
thomas.friedmann@dechert.com
+1 202 261 3313 Direct
+1 202 261 3016 Fax
September 16, 2014
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Edward P. Bartz
Re: WhiteHorse Finance, Inc.
Registration Statement on Form N-2
File Numbers 333-196436; 814-00967
Ladies and Gentlemen:
On September 3, 2014, WhiteHorse Finance, Inc., a Delaware corporation (the “Fund”), filed with the Securities and Exchange Commission (the “Commission”) Pre-effective Amendment No. 2 to its Registration Statement on Form N-2 (File Number 333-196436) (the “Registration Statement”). On behalf of the Fund, we hereby respond to the comment raised by the staff of the Commission (the “Staff”) pursuant to a telephone call on September 4, 2014 between Edward P. Bartz of the Staff and Thomas J. Friedmann of Dechert LLP, outside counsel to the Fund. For your convenience, the Staff’s comment is included in this letter, followed by the Fund’s response.
Comment: The Staff requests that the Fund undertake that it will either: (i) only issue debt securities titled “senior” debt if there exists other outstanding debt on the date of issuance which is subordinated in right of payment to the securities being issued or (ii) will submit to the Staff for its review and comment prior to publication a copy of the prospectus supplement with respect to any such offering of debt securities.
Response: As requested by the Staff, the Fund undertakes that it will either: (i) only issue debt securities titled “senior” debt if there exists other outstanding debt on the date of issuance which is subordinated in right of payment to the securities being issued or (ii) will submit to the Staff for its review and comment prior to publication a copy of the prospectus supplement with respect to any such offering of debt securities.
* * * * * * * * * *
United States Securities and Exchange Commission
September 16, 2014
Page 2
The Fund hereby acknowledges that (1) it is responsible for the adequacy and accuracy of the disclosure in its filings with the Commission, (2) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to any filing and (3) the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * * * * * * * * *
If you have any questions, please feel free to contact the undersigned by telephone at 202.261.3313 (or by email at thomas.friedmann@dechert.com). Thank you for your cooperation and attention to this matter.
Sincerely,
/s/ Thomas J. Friedmann
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1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
Thomas Friedmann
thomas.friedmann@dechert.com
+1 202 261 3313 Direct
+1 202 261 3016 Fax
September 16, 2014
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Edward P. Bartz
Re: WhiteHorse Finance, Inc.
Registration Statement on Form
N-2
File Numbers 333-196436; 814-00967
Ladies and Gentlemen:
On September 3, 2014, WhiteHorse Finance, Inc., a Delaware corporation
(the “Fund”), filed with the Securities and Exchange Commission (the “Commission”) Pre-effective
Amendment No. 2 to its Registration Statement on Form N-2 (File Number 333-196436) (the “Registration Statement”).
On behalf of the Fund, we hereby respond to the comment raised by the staff of the Commission (the “Staff”)
pursuant to a telephone call on September 4, 2014 between Edward P. Bartz of the Staff and Thomas J. Friedmann of Dechert LLP,
outside counsel to the Fund. For your convenience, the Staff’s comment is included in this letter, followed by the Fund’s
response.
Comment: The Staff requests that the Fund undertake that
it will either: (i) only issue debt securities titled “senior” debt if there exists other outstanding debt on the date
of issuance which is subordinated in right of payment to the securities being issued or (ii) will submit to the Staff for its review
and comment prior to publication a copy of the prospectus supplement with respect to any such offering of debt securities.
Response: As requested by the Staff, the Fund undertakes
that it will either: (i) only issue debt securities titled “senior” debt if there exists other outstanding debt on
the date of issuance which is subordinated in right of payment to the securities being issued or (ii) will submit to the Staff
for its review and comment prior to publication a copy of the prospectus supplement with respect to any such offering of debt securities.
* * * * * * * * * *
United States Securities and Exchange Commission
September 16, 2014
Page 2
The Fund hereby acknowledges that (1) it is responsible for
the adequacy and accuracy of the disclosure in its filings with the Commission, (2) Staff comments or changes to disclosure in
response to Staff comments do not foreclose the Commission from taking any action with respect to any filing and (3) the Fund may
not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.
* * * * * * * * * *
If you have any questions, please feel free to contact the undersigned
by telephone at 202.261.3313 (or by email at thomas.friedmann@dechert.com). Thank you for your cooperation and attention to this
matter.
Sincerely,
/s/ Thomas J. Friedmann
Thomas J. Friedmann
Cc: Jay Carvell, WhiteHorse Finance, Inc.
David J. Harris, Dechert LLP