SecProbe.io

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     April 17, 2015  Thomas Friedmann Dechert LLP 1900 K Street, NW Washington, DC 20006-1110   Re:  Eagle Point Credit Company Inc.
Registration Statement on Form N-2  File Numbers: 333-202914; 811-22974
Dear Mr. Friedmann:   Eagle Point Credit Company Inc. (the “Fund”) filed a registration statement on March 20, 2015
(the “Registration Statement”).  The filing wa s made for the purpose of registering Series A
Term Preferred Stock of the Fund.  Based on our re view of the Registration Statement, we have
the following comments.  The captions used belo w correspond to the captions the Fund uses in
its Registration Statement.  Please note, however, that the comments we gi ve in one section are
applicable to other sections of the Registration Statement that contain similar disclosure, unless
otherwise indicated.

General

1. We note that portions of the Registration Statement are incomplete.  We may have
additional comments on such portions when  you complete them in a pre-effective
amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits added in any pre-effective amendments.

2. Please advise us if you have submitted any exemptive application(s) or no-action
request(s) in connection with your Registration Statement.

3. Please state in your response letter whethe r FINRA has reviewed or will review the
proposed underwriting terms and arrangements of the tr ansaction involved in the
Registration Statement.

4. Please advise the Staff whether the Fund inte nds to supplement its registration statement
pursuant to which its common shares are currentl y offered, in order to reflect the issuance
of preferred stock. We may have additional comments.

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 Cover Page

1. It is disclosed that the CLOs in which th e Fund seeks to invest are collateralized by a
diverse portfolio consisting prim arily of below investment grade U.S. senior loans. Since
the Fund is classified as “non-diversified” as th e term is defined in Section 5(b) (2) of the
1940 Act, please use alternative language to avoid confusion.  Pleas e make this change
throughout the Registration Statement. With re spect to references to unrated or below
investment grade securities, please define such securities as “junk.”

2. It is disclosed that the Fund “may” also invest  in other securities a nd instruments, to the
extent such investments are consistent with  the Fund’s objectives, including senior debt
tranches of CLOs and loan accumulation fac ilities.  To what extent does the Adviser
expect to make such investments? Do inve stments in loan accumulation facilities and
other direct investment s constitute part of the Fund’s pr incipal strategy?  We may have
additional comments.

3. The disclosure states that the Fund intends to  pay monthly dividends on its Series A Term
Preferred Stock at a specified rate.  Please incl ude a clarification that the payment of such
dividend may be suspended by the Board indefin itely, subject to the requirements of the
1940 Act.

4. It is disclosed that the Series A Term Preferred Stock “will rank senior in right of
payment to our common stock and will rank equally in right of payment with any shares of preferred stock that we may issue.” Please disclose that the Series A Term Preferred
Stock is subordinated to the rights of any se nior indebtedness and state the extent to
which such indebtedness is  currently outstanding.

Prospectus

Prospectus Summary – Ea gle Point Credit Company

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5. It is stated that the Adviser may exercise cer tain protective rights associated with holding
a majority position in a CLO equity tranche.  How frequently has the Adviser exercised such rights in the past? Please remove the statement if such rights are exercised only
infrequently.
6. The disclosure states that the Fund seeks to “construct a portfolio of  CLO securities that
is diverse across a number of key categories.” Please revise the disclosure in accordance
with Comment 1.
7. Under the “Initial Public Offe ring” subsection, it is stated th at the Fund has declared two
quarterly distributions on shares of the F und’s common stock at a 12% annualized rate
based on the price of the common stock in th e initial public offering. Please disclose the
extent to which such quarterly distribu tions included any return of capital.

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Prospectus Summary – Eagl e Point Credit Management

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5. In discussing the Senior Investment Team’s qua lifications, it is stated that members of the
team have “collectively” been involved in the CLO market in various roles.  In your
response, please explain the use of the term  “collectively”: please indicate which team
member held each of the positions that ar e listed. We may have additional comments.

Prospectus Summar y – CLO Overview

Page 4

6. The disclosure states that “in the current market environment, we expect investment
opportunities in CLO equity to present more attractive risk adjusted returns than CLO
debt.” Please explain what aspects of the “cu rrent market environment” form the basis for
the statement. Furthermore, it is stated th at the Fund expects CLO equity to “provide
potential protection against ri sing interest rates after LI BOR has increased above the
average LIBOR floor on a CLO’s assets.” Would a rising interest rate environment result
in higher credit risk and default rates for a CLO’s asset portfolio because it is comprised of “junk” bonds? If so, would more senior tranches of the CLO require additional
collateralization and thus redu ce cash flows, and thereby impa ir the value of, the equity
tranches of a CLO?  We may have additional comments.
 Prospectus Summar y – Our Structure

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7. The structure chart indicates that the Fund in vests in two wholly-owned subsidiaries.
Please include a description of such subs idiaries and the reason for structuring
investments through the subsidiaries.  What percent of its total assets is the Fund
permitted to invest in each subsidiary and on a combined basis? We may have additional comments.
 The Offering – Ranking

8. Please include an additional bullet to state th at the Series A Term Preferred Stock is
subordinated to the rights  of any senior indebtedness.  See Comment 4.

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 Risk Factors

Page 31
9. The subsection titled “Historically  Low Interest Rate Environment” should be revised to
reflect risks associated with a rising interest rate environment. Please see IM Guidance
Update No. 2014-1 .

Business – CLO Market Opportunity

Page 52
10. The disclosure states that “based on the A dviser’s analysis of market data, the Adviser
believes that only approximately 4% of U.S.  cash flow CLOs issued between 2002 and
2011 will have a negative internal  rate of return, or “IRR,” wh ereas nearly half of such
CLOs are projected to have IRRs over 15%.”  To what extent does the Fund invest in
CLOs issued in the applicable period? What sources/market data form the basis for the Adviser’s belief?
Page 57
11. In the sub-section titled “Leverage Effects” , please confirm that the assumption amounts
borrowed is representative of the Fund’s expected use of leverage.
 Page 58
12. In the “Co-Investment with Affiliates” subs ection, please include a brief summary of the
conditions set forth in the SEC order to whic h the Fund and its affilia tes are subject when
making co-investments.

Exhibit N: Consent of Independent Registered Public Accounting Firm

13. Please state the city and state where the consent was issued.

Financial Statements filed on Form N-CSR:

Letter to Shareholders:

14. The Fund discloses the following in the shar eholder letter regardi ng the dividend paid:

“On October 15, 2014, the Company declared an initial dividend of $0.55 per common
share for Q4 2014.  This represents an appr oximate 12% yield based on the IPO price of
$20 per share.  The Company expects to contin ue a base quarterly dividend of 12% of the
IPO price, or $0.60 per common share per quarte r, for the foreseeable future given its
current portfolio positions, though actual divide nd payments are subject to variation from
time to time.”

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  In future reports and on the website, pl ease remove the term yield, as 45% of the
distribution is expected to  be return of capital.

Statement of Assets and Liabilities:

15. Please add a Commitments and Contingencies lin e item to the Statement of Assets and
Liabilities, with a parenthetical refere nce to the note th at discloses unfunded
commitments and other commitments and/or co ntingencies.  See Re gulation S-X, Article
6-04.15.
 Schedule of Investments:

16. Please confirm the $63,734,284 of cash is not in a money market fund or other
investment that should be reported on the schedule of investments.
 Notes to Financial Statements:

17. Disclose whether or not the Fund had any tr ansfers between Level 1, Level 2 and Level 3
securities during the period.
18. Please disclose the following related to new accounting standards that have been issued
but not yet adopted:
a. A brief description of the new standard, th e date that adoption is required, and the
date that the registrant pl ans to adopt, if earlier.

b. A discussion of the methods of adopti on allowed by the standard and the method
expected to be utilized by th e registrant, if determined.

c. A discussion of the impact that adoption of  the standard is expected to have on the
financial statements of the Fund, unless not known or reason ably estimable. In
that case, a statement to that effect ma y be made. If applicable, companies are
encouraged to disclose that a standard has been issued and that its adoption will
not have a material effect on its financ ial position or results of operations.

d. Disclosure of the potential impact of other significant matters that the Fund
believes might result from the adoption of the standard (such as technical
violations of debt covenant agreements , planned or intended changes in business
practices, etc.) is encouraged.

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You are reminded that the burden of full and fair disclosure re sts with each registrant, its
counsel, and others engaged in th e preparation of the Registration Statement. As a matter of law,
this burden cannot be shifted to  the Commission or its staff.

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 Notwithstanding our comments, please furn ish a letter with respect to the Fund
acknowledging that:

 the Fund is responsible for the adequacy and accuracy of the disclosure in its
filings;

 should the Commission or the staff, acting pursuant to delegate d authority, declare
the filing effective, it does not forecl ose the Commission from taking any action
with respect to the filing;

 the action of the Commission or the staff, acting pursuant to dele gated authority, in
declaring the filing effective,  does not relieve the Fund fr om full responsibility for
the adequacy and accuracy of the disclosure in the filings;

 the Fund may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the Federal securities laws of  the United States.
         In addition, please be advised th at the Division of Enforcement has access to all
information you provide the staff of  the Division of Investment Management in connection with
our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the registration
statements as confirmation that those request ing acceleration are aware of their respective
responsibilities.
 Please respond to this letter in the form of  a pre-effective amen dment for the Fund.
Please respond to all comment letters in a letter  filed in the form of EDGAR correspondence.
Where no changes will be made in response to a comment, please so state in your letter and
explain the basis for your posi tion.  The staff may have furthe r comments after reviewing your
responses.

 Should you have any questions regarding this  letter, please contac t me at (202) 551-
6908.
Sincerely,
         / s /  A s e n  P a r a c h k e v o v
Attorney Adviser