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        www.dechert.com

        Thomas Friedmann

        thomas.friedmann@dechert.com

        +1 617 728 7120 Direct

        +1 617 275 8389 Fax

August 14, 2015

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 August 14, 2015, WhiteHorse Finance, Inc., a Delaware corporation
(the “Fund”), filed with the Securities and Exchange Commission (the “Commission”) Post-effective
Amendment No. 2 (“Amendment No. 2”) to its Registration Statement on Form N-2 filed by the Fund with the Commission
on June 2, 2014 (File Number 333-196436) (the “Registration Statement”). On behalf of the Fund, we hereby respond
to the comments raised by the staff of the Commission (the “Staff”) pursuant to telephone calls on July 6, 2015
and July 7, 2015, between Edward P. Bartz of the Staff and Thomas J. Friedmann of Dechert LLP, outside counsel to the Fund. For
your convenience, a transcription of the Staff’s comments is included in this letter, and each comment is followed by the
applicable response. Except as provided in this letter, terms used in this letter have the meanings given to them in the Registration
Statement.

Prospectus Cover Page

 1. Delete the parenthetical in the last sentence of the first paragraph stating that the approximate amount of capital under
management of H.I.G. Capital, L.L.C. as of March 31, 2015 was “based on capital commitments” and restate the amount
of capital under management of H.I.G. Capital, L.L.C. as of such date (or a more recent date) excluding undrawn commitments of
capital.

Response: As discussed, the Fund respectfully submits
that a restatement of the amount of capital under management by H.I.G. Capital, L.L.C. based upon the actual amount of capital
drawn and funded as of the applicable date would be inconsistent with the disclosure requirements of Form ADV (which requires inclusion
of undrawn commitments of capital in the calculation of assets under management). The Fund has revised the applicable disclosure
to be consistent with the amount of assets under management as calculated for Form ADV.

        United States Securities and Exchange Commission

        August 14, 2015

        Page 2

 2. Include in your response letter to the comments of the Staff to be filed with Amendment No. 2 a supplemental undertaking
that the Fund will 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.

Response: As requested, the Fund hereby agrees that,
in the future, it will 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.

 3. Explain why no preliminary proxy was filed by the Fund with the Commission in connection with the Fund’s proposal
to its stockholders in connection with its 2014 proxy solicitation to be permitted to issue shares of common stock at a price below
the net asset value (“NAV”) per share subject to certain limitations.

Response: The Fund acknowledges that it should have filed
a preliminary proxy with the Commission prior to soliciting proxies from its stockholders in connection with its 2014 annual meeting
of stockholders. The Fund identified this oversight in preparing its 2015 proxy statement and submitted a preliminary proxy for
review by the Commission prior to soliciting proxies from its stockholders for its 2015 stockholders’ meeting, as is appropriate
under the guidance of the Staff in connection with non-routine matters such as approval of the appointment of an independent audit
firm and election of directors. The Fund hereby confirms to the Staff that, while the stockholders of the Fund did approve by the
margin required under the 1940 Act the Fund’s proposal to be able to issue and sell shares of common stock at a price below
NAV, the Fund did not utilize such flexibility during the period covered by such approval. The Fund hereby undertakes to file a
preliminary proxy statement for review by the Staff of the Commission in connection with any future submission to stockholders
of any non-routine matters.

 4. Include in your response letter to the comments of the Staff to be filed with Amendment No. 2 a supplemental undertaking
(1) to file as an exhibit to the Registration Statement an unqualified opinion of counsel with respect to the legality of any class
of securities registered under the Registration Statement and (2) to make appropriate filings with the Financial Industry Regulatory
Authority (“FINRA”) so as to qualify with FINRA any underwritten offerings of securities registered under the
Registration Statement.

        United States Securities and Exchange Commission

        August 14, 2015

        Page 3

Response: The Fund hereby undertakes (1) to file as an
exhibit to the Registration Statement an unqualified opinion of counsel with respect to the legality of any class of securities
registered under the Registration Statement and (2) to make appropriate filings with FINRA so as to qualify any underwritten offerings
of securities registered under the Registration Statement.

Fees and Expenses Table

 5. In the item on the table captioned “Base management fees, net of fees waived,” delete the words “net
of fees waived” and revise the amount shown in the table for such item on a gross basis excluding the effect of any fee waivers.

Response: As requested, the Fund has restated the captioned
item in the Fees and Expenses Table and revised in Amendment No. 2 the amount of base management fees incurred by the Fund to the
Adviser during the applicable period on a gross basis without giving effect to any fee waiver then in effect.

 6. Review and revise the amounts shown in the Example following the Fees and Expenses Table for the periods indicated as
well as in the disclosure immediately following such Example.

Response: As requested, the Fund has recalculated and
revised the amounts set forth in the Example following the Fees and Expenses Table as well as in the disclosure following the Example.

 7. Disclose that the Example following the Fees and Expenses Table does not include any sales load. Further confirm supplementally
that if, in the future, the Fund issues and sells any shares of common stock to which the Fees and Expenses Table relates with
a sales load, the Fund will include in the prospectus supplement related to such issuance a revised example that reflects the effect
of such sales load.

Response: As requested, the Fund has added disclosure
in the Example following the Fees and Expenses Table stating that the amounts shown do not include any sales load. The Fund hereby
confirms supplementally that if, in the future, the Fund issues and sells any shares of common stock under the Registration Statement
with a sales load, the Fund will include in the prospectus supplement related to such issuance a revised example that reflects
the effect of such sales load.

        United States Securities and Exchange Commission

        August 14, 2015

        Page 4

Risk Factors

 8. Under the caption “Risk Factors—Risks Relating to an Investment in our Common Stock—There is a risk
that investors in our equity securities may not receive distributions or that our distributions may not grow over time and a portion
of our distributions may be a return of capital,” please add back the sentence which appeared in the prior shelf registration
statement of the Fund stating, “A return of capital is a return to investors of a portion of their original investment in
the Company rather than income or capital gains.”

Response: As requested, the Fund has added the requested
disclosure.

Distributions

 9. Add a separate column to the right side of the table under the caption “Distributions” setting forth the
estimated return of capital, if any, for each period. If such return of capital is not available for interim periods, include annual
sums/totals for each annual period covered by the table.

Response: The Fund respectfully submits that there has
been no return of capital for any period presented in the table. Accordingly, the Fund has disclosed immediately after the table
that, for all periods presented, there was no return of capital included in any distribution. If, in the future, the Fund experiences
a return of capital, it will add a separate column to the table enumerating the amount of such return of capital.

Management’s Discussion and Analysis of Financial
Condition and Results of Operations

 10. In the section captioned “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Consolidated
Results of Operations” and in the Fund’s future financial statements, disclose the amount of total investment income
of the Fund that is non-recurring and describe the impact of non-recurring fee income on the Fund’s net investment income
and yield. See the Minutes of the AICPA Expert Panel Meeting of September 16, 2014.

Response: As requested, the Fund has included under the
caption “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Results
of Operations” the amount of total investment income of the Fund that is non-recurring. The Fund respectfully submits
that it does not include non-recurring fee income in its calculation of yield and that any non-recurring fee income is treated
as a one-time fee.

        United States Securities and Exchange Commission

        August 14, 2015

        Page 5

Price Range of Common Stock

 11. Revise the table set forth under the caption “Price Range of Common Stock,” to correctly indicate that each
entry under the columns Premium/(Discount) of High Sales price to NAV and (Discount) of Low Sales Price to NAV has a parenthetical
around it, reflecting a negative percentage.

Response: As requested, the Fund has revised the Price
Range of Common Stock table to reflect correctly which percentages are negative. Additionally, the Fund has disclosed immediately
after the table that, for all periods presented, there was no return of capital included in any distribution.

Sales of Common Stock Below Net Asset Value

 12. In the tables under the captions, “Sales of Common Stock Below Net Asset Value —Impact on Existing Stockholders
who do not Participate in the Offering” and “—Impact on New Investors,” add an additional column indicating
the effect of a 25% Offering at a 100% Discount to NAV. Alternatively, state affirmatively that the Fund will not offer below a
certain percentage discount and include an example reflecting such discount and a 25% offering.

Response: As requested, the Fund has added an additional
column to the tables specified above setting forth the effect of a 25% Offering at a 100% Discount to NAV. The Fund has also added
disclosure stating that such example is included for illustrative purposes only and that its directors would be unable to approve
such an offering under Delaware law.

Portfolio Companies

 13. Under the caption “Portfolio Companies,” include more a more detailed description of each portfolio company
that exceeds five percent of the Fund’s assets. See Instruction 1 to Item 6A of Form N-2.

Response: As requested, the Fund has provided additional
information regarding the specified portfolio companies.

 14. With respect to the portfolio company NMFC Senior Loan Program I LLC, explain why the Fund has not marked this investment
as an affiliate of the Fund in the Table of Investments and in the Consolidated Schedule of Investments included in the Fund’s
financial statements and why information required under Item 12-14 under Regulation S-X for the periods ended December 31, 2014
and March 31, 2015 is not included with respect to such investment. In addition, the Staff notes that two other investors in this
portfolio company, both of which are business development companies (Business Development Corporation of America (“BDCA”)
and New Mountain Finance Corporation (“New Mountain”)), have determined that the fair value of this investment
is less than its initial cost. Explain supplementally in the Fund’s response to these comments why the Fund continues to
value this investment at cost.

        United States Securities and Exchange Commission

        August 14, 2015

        Page 6

Response: As requested, the Fund has revised
its Table of Investments and Consolidated Schedule of Investments to reflect the fact that NMFC Senior Loan Program I LLC is
an affiliate and has included appropriate disclosure regarding such investment in the Table of Investments and in
the Consolidated Schedule of Investments for the period ended June 30, 2015. In addition, the Fund undertakes to include
such additional information with respect to this investment in its annual financial statements in future periods for as long
as such investment exceeds the applicable reporting threshold. The Fund respectfully submits that its adviser and the board
of directors of the Fund determined that, in accordance with the Fund’s established valuation procedures, the fair
value of this portfolio company as of June 30, 2015 was the same as the Fund’s cost basis in such portfolio company.
The Fund notes that the valuations for this investment determined by BDCA and New Mountain as of June 30, 2015, while lower
than the fair value determined by the Fund, did not significantly differ from such fair value. Additionally, NMFC was
selected for independent third party valuation for the quarter ended June 30, 2015, which valuation was consistent with that
of the Fund’s adviser and considered by the Fund’s  board of directors in its determination of the Fund’s
net asset value, and modifications to the fair value of NMFC are reflected in the Fund’s interim financial statements
for the three months ended June 30, 2015.

 15. Include in footnote 7 to the Table of Investments the total percentage of assets of the Fund that did not qualify as
investments in eligible portfolio companies for the period ended June 30, 2015 and in all future periods. Also include such disclosure
in the equivalent footnote to the Consolidated Schedule of Investments in the Fund’s financial statements in future periods.

Response: As requested, the Fund has added to its Table
of Investments the total percentage of Fund investments that were not in eligible portfolio companies as of June 30, 2015 and undertakes
to include such disclosure for each relevant balance sheet date in the Table of Investments and in the Consolidated Schedule of
Investments included in the Fund’s financial statements.

 16. With reference to Note 7 in the Notes to Consolidated Financial Statements of the Fund, please provide the following
information:

 a. Does the Fund treat its unfunded commitments as senior securities and, if not, explain why?

 b. If the Fund does not treat its unfunded commitments as senior securities, confirm that the Fund has cash or other liquid
assets sufficient to cover the aggregate amount of its unfunded commitments outstanding as of the relevant balance sheet date.

 c. Confirm that the Fund will not issue and sell additional securities under the Registration Statement unless, at the time
of such issuance and sale, the Fund has cash or other liquid assets sufficient to cover its unfunded commitments then outstanding.

 d. Alternatively, if the Fund has determined that its unfunded commitments are senior securities, confirm that the Fund
does and will, at the time of any issuance and sale of