SecProbe.io

CORRESP
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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

        Philip
        T. Hinkle

        philip.hinkle@dechert.com

        +1 202 261 3460 Direct

        +1 202 261 3050 Fax

May 20, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Ken Ellington and Christopher Bellacicco

 Re: Eagle Point Credit Company Inc.

Registration Statement
on Form N-2

File Numbers: 333-237586;
811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in telephonic conversations on April 14, 2020
between Ken Ellington of the Staff and Philip T. Hinkle of Dechert LLP and May 4, 2020 between Christopher Bellacicco of the Staff
and Philip T. Hinkle and Cynthia C. Bien of Dechert LLP, relating to the Fund’s registration statement on Form N-2 filed
with the Commission on April 6, 2020 (the “Registration Statement”).

For your convenience, the Staff’s
comments are summarized in this letter, and each comment is followed by the applicable response. The Fund intends to file Pre-Effective
Amendment No. 1 to the Registration Statement (“Pre-Effective Amendment No. 1”) at a future date, which will
reflect the responses below.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

 1. Please confirm that the Fund has received or will receive a FINRA no objections letter.

Response:

The Fund confirms it will use its reasonable
best efforts to obtain a FINRA no objections letter. The Fund will address and resolve any FINRA comments prior to effectiveness
of the Registration Statement.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 2

 2. The Staff notes the name of the Fund includes the word “Credit.” Please include
an investment policy with respect to the name “Credit” in accordance with Rule 35d-1 under the Investment Company Act
of 1940, as amended (the “1940 Act”).

Response:

While the Fund believes the term “credit”
does not necessarily implicate the requirements of Rule 35d-1 under the 1940 Act, it will add the following 80% policy to the description
of its principal investment strategy in accordance with Rule 35d-1.

“Under normal circumstances,
the Fund invests at least 80% of the aggregate of its net assets and borrowings for investment purposes in credit and credit related
instruments. For purposes of this policy, the Fund considers credit and credit related instruments to include, without limitation:
(i) equity and debt tranches of collateralized loan obligations, or “CLOs,” loan accumulation facilities and securities
issued by other securitization vehicles, such as credit-linked notes and collateralized bond obligations or “CBOs”;
(ii) secured and unsecured floating rate and fixed rate loans; (iii) investments in corporate debt obligations, including bonds,
notes, debentures, commercial paper and other obligations of corporations to pay interest and repay principal; (iv) debt issued
by governments, their agencies, instrumentalities, and central banks; (v) commercial paper and short-term notes; (vi) preferred
stock; (vii) convertible debt securities; (viii) certificates of deposit, bankers’ acceptances and time deposits; and (ix)
other credit-related instruments. The Fund’s investments in derivatives, other investment companies, and other instruments
designed to obtain indirect exposure to credit and credit related instruments are counted towards the Fund’s 80% investment
policy to the extent such instruments have similar economic characteristics to the investments included within that policy.”

In addition, the Fund will add the following
explanatory disclosure elsewhere in the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“The Fund’s 80% policy
with respect to investments in credit and credit related instruments is not fundamental and may be changed by our board of directors
without stockholder approval. Stockholders will be provided with sixty (60) days’ notice in the manner prescribed by the
SEC before making any change to this policy. The Fund’s investments in derivatives, other investment companies, and other
instruments designed to obtain indirect exposure to credit and credit related instruments are counted towards the Fund’s
80% investment policy to the extent such instruments have similar economic characteristics to the investments included within that
policy.”

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 3

 3. Please discuss in correspondence how the Fund’s portfolio, liquidity and creditworthiness
has changed since early March 2020. Please confirm whether any of the securities and underlying collateralized loan obligations
(“CLOs”) have been downgraded or are in default. If there have not been downgrades or defaults, please explain if that
is attributable to government support and, if so, please describe the Fund’s plans for the expiration of such support.

Response:

The Fund has not substantially repositioned
its portfolio in response to the COVID-19 pandemic or related government actions. As disclosed in the Registration Statement, the
Fund’s portfolio investments are generally less liquid than high yield bonds in normal market conditions. Since March 2020,
we have observed a modest decline in liquidity, which has primarily affected distressed assets.

During the first quarter, essentially all
of the Fund’s CLO investments experienced a decrease in the value of their underlying corporate loan portfolios. Indeed,
the S&P/LSTA Leveraged Loan Index had one of its worst months ever in March 2020. In essentially all cases, however, the value
of the corporate loan portfolios has increased since April 1, 2020, though typically not to levels from the beginning of the year.

None of the securities held by the Fund
have defaulted. This is attributable, in part, to the fact that the Fund’s CLO investments do not have liquidation triggers
based on the market value of non-defaulted corporate loans. Certain CLO debt investments held by the Fund have been placed on “negative
watch” by Moody’s or S&P, indicating that such rating agency is currently reviewing these assets for potential
future downgrade. However, only one CLO debt investment has been downgraded between March 1, 2020 and May 1, 2020. The Fund’s
investments in CLO equity, which comprise the majority of the Fund’s portfolio, are not rated. We do not believe any of our
CLO investments have received government support though certain obligors of the loans underlying our CLO investments may participate
in recent government programs. Based on our limited knowledge of the extent of underlying obligors’ reliance on COVID-19
government support measures, we do not believe the expiration of those measures would result in a material increase in defaults
on the Fund’s CLO investments or their underlying collateral.

 4. Please confirm that the Fund does not plan on issuing preferred stock within the next year.

The Fund has no current plans to issue
preferred stock within the next 12 months. However, as noted in the Registration Statement, the Fund may issue preferred stock
or otherwise incur leverage in accordance with the 1940 Act at any time.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 4

 5. Please update the December 31, 2019 or February 29, 2020 information to March 31, 2020, as applicable,
throughout the Registration Statement for disclosure relating to closing price, net asset value (“NAV”), portfolio
composition (including industries affected by the COVID-19 pandemic), credit facility compliance, effective leverage, price range
of common stock, senior securities, and the lagging 12-month default rate by principal amount.

The Fund will update the relevant December
31, 2019 and February 29, 2020 disclosure (including the items noted in this comment 5) in the Registration Statement prior to
filing Pre-Effective Amendment No. 1.

 6. In the “Efficient vehicle for gaining exposure to CLO securities” bullet point under
the Competitive Advantages section, please explain what a CLO reset transaction is in plain English.

Response:

The Fund will add the following disclosure
in the applicable section of the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“In a CLO reset, the CLO’s
indenture, which sets forth the terms governing the CLO, is “re-opened” (e.g., the terms of the indenture and the various
tranches of the CLO can be re-negotiated). Among other potential benefits, resetting a CLO renews the reinvestment period on the
CLO.”

 7. In the Financing and Hedging Strategy section of the Registration Statement, please disclose
if the Fund has failed to meet its asset coverage ratio requirements. Please prominently disclose the risk of a failure to meet
the asset coverage ratio requirements, such as an inability to pay certain dividends or make additional borrowings.

Response:

The Fund notes that it had satisfied applicable
asset coverage requirements as of March 31, 2020. The Fund will include the following disclosure in the Financing and Hedging Strategy
section of the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“As of March 31, 2020, the
Company’s asset coverage ratios in respect of (i) senior securities representing indebtedness and (ii) our outstanding preferred
stock, each as calculated pursuant to Section 18 of the 1940 Act, were 330% and 220%, respectively. In the event we fail to meet
our applicable asset coverage ratio requirements, we may not be able to incur additional debt and/or issue preferred stock, and
could be required by law or otherwise to sell a portion of our investments to repay some debt or redeem shares of preferred stock
(if any) when it is disadvantageous to do so, which could have a material adverse effect on our operations, and we may not be able
to make certain distributions or pay dividends of an amount necessary to continue to qualify as a RIC for U.S. federal income tax
purposes.”

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 5

 8. Please include a COVID-19 risk factor in the Risk Factor Summary section.

Response:

The Fund will add the following disclosure
in the Risk Factor Summary section of the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“COVID-19
Pandemic Risk. The emergence of the global outbreak of the COVID-19 pandemic has created economic and financial disruptions
and contributed to increased volatility in global financial markets and likely will affect countries, regions, companies, industries
and market sectors more dramatically than others. It is not known how long the impact of the COVID-19 pandemic will last or the
severity thereof.”

 9. In the Fees and Expenses table, the management fee is based on actual amounts incurred during
the three months ended December 31, 2019, annualized for a full year, and reflects the pro forma effect of the issuance of 1,107,612
shares of the Fund’s common stock from January 1, 2020 through April 2, 2020 in the Fund’s “at-the-market”
offering, yielding net proceeds of approximately $16.3 million, as if such shares were issued at the start of such period. Please
discuss in correspondence whether the disclosure would change materially if the management fee was based on managed assets as of
a more recent date.

Response:

The management fee line item in the Fees
and Expenses table will be updated to reflect amounts actually incurred during the three months ended March 31, 2020 prior to filing
Pre-Effective Amendment No. 1.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 6

 10. Please include a discussion in the Risk Factors section of the Fund’s exposure to industries
that have been impacted by recent market events, if applicable.

Response:

The Fund will enhance the risk disclosure
in the Registration Statement in accordance with this comment, as reflected in its response to comment 22, below.

 11. Please revise the “Low Interest Rate Environment” paragraph in the Risk Factors
section in light of current developments.

Response:

The Fund will replace the “Low Interest
Rate Environment” paragraph prior to filing Pre-Effective Amendment No. 1 with the following:

“As of the date of this
prospectus, interest rates in the United States are at historic lows due to the U.S. Federal Reserve’s recent lowering of
certain interest rates as part of its efforts to ease the economic effects of the COVID-19 pandemic. With the historically low
interest rates, there is a risk that interest rates will rise once the COVID-19 pandemic abates.”

 12. The Staff references the Risk Factor “[w]e are subject to risks associated with defaults
on an underlying asset held by a CLO.” Please discuss in correspondence whether such defaults have been occurring and if
so, please explain the circumstances.

Response:

Owing to the large number of corporate
loans underlying our CLOs, even in benign markets, we expect a certain amount of loan defaults each year. Due to the unexpected
decrease in revenue at companies due to COVID-19 related shut-downs and other business disruptions, defaults of assets underlying
CLOs have begun to increase. For example, we note that in April 2020, 11 constituents out of the over 1400 loans in the S&P/LSTA
Leveraged Loan Index experienced a default. We have observed that defaults have been concentrated in the retail, telecommunications,
healthcare and travel sectors. Year to date, the energy sector has had among the highest default rates compared to other industries
due to decreased demand caused by COVID-19 related travel restrictions and a price war among major oil producing nations; however,
the CLOs comprising the Fund’s investment portfolio generally have minimal exposure to energy obligors.

From March 1, 2020 to April 30, 2020, underlying
loans held by the Fund’s CLO investments which were in default increased by approximately 31 basis points, from 1.03% to
1.34%. Despite this increase, the current overall default rate on the Fund’s underlying investments remains below the historical
default rate for senior secured loans according to data provided by S&P Leveraged Commentary & Data. The Fund is monitoring
activity in the underlying loan market, including defaults, carefully.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 7

 13. The Staff references the Risk Factor “[a]ny unrealized losses we experience on our portfolio
may be an indication of future realized losses, which could reduce our income available for distribution or to make payments on
our other obligations.” Please describe supplementally any expected impact on the Fund’s ability to pay distributions
and any expectations of higher percentages of returns of capital than distributed in previous fiscal periods in making such distributions.

Response:

This Risk Factor is intended to highlight
the general inverse correlation between a decline in a CLO’s market value and an increase in the perceived risk of loan defaults
and/or lower recoveries from defaulted loans. Market prices of a CLO’s loans reflect market participants’ views of
each loan’s value on any given day. However, CLOs are not required to sell assets due to price movements of performing loans.
In addition, CLO liabilities typically have maturity dates beyond those of the CLO’s loan assets, thereby mitigating risk
associated with a loan’s price volatility prior to repayment. Thus, while unrealized losses o