Correspondence 0001104659-24-002312 from Eagle Point Credit Co (ECC)
Eagle Point Credit Co
Date: Jan. 8, 2024 · CIK: 0001604174 · Accession: 0001104659-24-002312
AI Filing Summary & Sentiment
File numbers found in text: 811-22974
Letter
1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
Alexander C. Karampatsos
alexander.karampatsos@dechert.com
+1 202 261 3402 Direct
+1 617 275 8365 Fax
January 8, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Christopher R. Bellacicco
Re: Eagle Point Credit Company Inc.
Preliminary Proxy Statement
File Number: 811-22974
Ladies and Gentlemen:
On behalf of Eagle Point Credit Company 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”) in a telephonic conversation on January 8, 2024 between Christopher R. Bellacicco of the Staff and Alexander Karampatsos and Claire Hinshaw of Dechert LLP, relating to the Company’s preliminary proxy statement on Schedule 14A filed with the Commission on December 22, 2023 (the “Proxy Statement”) and the Company’s responses to comments raised by the Staff on January 3, 2024, filed with the Commission on January 4, 2024.
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 Proxy Statement.
1. Please identify in the Proxy Card whether the matter to be voted on was proposed by the Company or by security holders as required by subsection (a)(3) of Rule 14a-4 under the Securities Exchange Act of 1934.
Response: The Company respectfully declines to make any changes in response to the Staff’s comment. The Company notes that the Proxy Statement states that the proposal was proposed by the Company and further notes that the Proxy Card states the proxy is solicited on behalf of the Company’s Board of Directors. The Company notes that it will undertake to add the requested language to future proxy cards.
Christopher R. Bellacicco January 8, 2024 Page 2
2. Please explain why there are two separate Proxy Cards for the holders of the Company’s preferred stock.
Response: The Company notes that there is a separate Proxy Card for each of the Company’s 6.50% Series C Term Preferred Stock due 2031 and 6.75% Series D Preferred Stock.
* * * * * * * * *
If you have any questions, please feel free to contact the undersigned by telephone at 202.261.3402 or by email at alexander.karampatsos@dechert.com. Thank you for your cooperation and attention to this matter.
Sincerely,
/s/ Alexander C. Karampatsos
Show Raw Text
CORRESP
1
filename1.htm
1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
Alexander C. Karampatsos
alexander.karampatsos@dechert.com
+1 202 261 3402 Direct
+1 617 275 8365 Fax
January 8, 2024
VIA
EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Christopher R. Bellacicco
Re: Eagle Point Credit Company Inc.
Preliminary Proxy Statement
File Number: 811-22974
Ladies and Gentlemen:
On behalf of Eagle Point Credit Company 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”) in a telephonic conversation on January 8, 2024
between Christopher R. Bellacicco of the Staff and Alexander Karampatsos and Claire Hinshaw of Dechert LLP, relating to the Company’s
preliminary proxy statement on Schedule 14A filed with the Commission on December 22, 2023 (the “Proxy Statement”)
and the Company’s responses to comments raised by the Staff on January 3, 2024, filed with the Commission on January 4,
2024.
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 Proxy Statement.
1. Please identify in the Proxy Card whether the matter to be voted on was proposed by the Company or
by security holders as required by subsection (a)(3) of Rule 14a-4 under the Securities Exchange Act of 1934.
Response:
The Company respectfully declines to make any changes in response to the Staff’s comment. The Company notes that the
Proxy Statement states that the proposal was proposed by the Company and further notes that the Proxy Card states the proxy is solicited
on behalf of the Company’s Board of Directors. The Company notes that it will undertake to add the requested language to future
proxy cards.
Christopher R. Bellacicco
January 8, 2024
Page 2
2. Please explain why there are two separate Proxy Cards for the holders of the Company’s preferred
stock.
Response:
The Company notes that there is a separate Proxy Card for each of the Company’s 6.50% Series C Term Preferred Stock
due 2031 and 6.75% Series D Preferred Stock.
* * * * * * * * *
If you have any questions, please feel free to
contact the undersigned by telephone at 202.261.3402 or by email at alexander.karampatsos@dechert.com. Thank you for your cooperation
and attention to this matter.
Sincerely,
/s/ Alexander C. Karampatsos
Alexander C. Karampatsos
cc: Thomas P. Majewski, Chief Executive Officer, Eagle Point Credit
Company Inc.
Nauman S. Malik, Chief Compliance
Officer, Eagle Point Credit Company Inc.
Philip T. Hinkle, Dechert
LLP