SecProbe.io

CORRESP
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April 29, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

  Registration Statement on Form N-2

  File Numbers: 333-202914; 811-22974

Dear Mr. Parachkevov:

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 the letter dated April 17, 2015 from Asen
Parachkevov, Attorney Adviser, to Thomas Friedmann, outside counsel to the Fund.

For your convenience, the Staff’s
comments are repeated in this letter, and each comment is followed by the applicable response. Concurrently, the Fund is filing
pre-effective amendment no. 1 (“Amendment No. 1”) to its registration statement on Form N-2 (the “Registration
Statement” and the prospectus contained therein, the “Prospectus”) via EDGAR. We will also provide
under separate cover courtesy copies of Amendment No.1, as submitted and marked to show the changes from the initial filing of
the Registration Statement.

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

April 29, 2015

Page 2

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.

Response:	The Fund acknowledges
the Staff’s comment.

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

Response:	Although no
exemptive or no-action relief has been, or is expected to be, requested with respect to the Registration Statement, the Fund
received an order from the Commission on March 17, 2015 that granted the Fund an exemption from section 17(d) of the
Investment Company Act of 1940, as amended (the “1940 Act”), and rule 17d-1 under the 1940 Act permitting
the Fund to participate in certain negotiated co-investments alongside other accounts
managed by Eagle Point Credit Management LLC, the Fund’s investment adviser (the “Adviser”), subject to
certain conditions.

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

Response:	The Fund hereby confirms
that the Registration Statement has been filed with FINRA. The Fund or underwriters’ counsel will address and resolve any
FINRA comments prior to effectiveness of the Registration Statement, and underwriters’ counsel will ask the FINRA examiner
to notify the Staff once verbal no objections have been issued by FINRA with respect to the underwriting terms and arrangements.

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

Response:	The Fund respectfully
submits that the initial public offering of the Fund’s common stock closed on October 17, 2014 and the Fund is not currently
offering shares of its common stock. The Fund undertakes to reflect outstanding preferred stock, if any, in future registration
statements pursuant to which common stock is offered.

April 29, 2015

Page 3

Cover Page

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

Response: The Fund has revised its
disclosure consistent with this comment.

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

Response: As noted in
the Prospectus, the Fund seeks to achieve its investment objectives by primarily investing in CLO equity and junior
debt tranches. However, the Fund may invest in other securities and instruments to the extent such investments are consistent
with the Fund’s objectives. The Fund’s total investment in these other securities and instruments as a percentage
of its total assets may vary from time to time depending on the Adviser’s assessment of prevailing market conditions
and available investment opportunities. In certain circumstances, such investments could comprise a material percentage of
the Fund’s investment portfolio. As of December 31, 2014, for example, investments in loan accumulation
facilities comprised 14% of the Fund’s portfolio by value, although the Fund only held one such position. As such, the
Prospectus includes a discussion of risks associated with those CLO-related securities and instruments that the Adviser
expects could, from time to time, constitute a material percentage of the Fund’s investment portfolio (see
“Risk Factors—Risks Related to Our Investments — We are subject to risks associated with loan accumulation
facilities.”). The Fund notes that it has revised its disclosure consistent with this response to clarify its
investment in such other securities and instruments.

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

April 29, 2015

Page 4

Response: The Fund has revised its
disclosure under the heading “The Offering—Dividends” to note that the Fund’s board of directors may determine
not to declare a dividend for any given month. However, the Fund supplementally notes that, as stated elsewhere in the disclosure,
any unpaid dividends (whether or not declared) must be paid upon the redemption of the Series A Term Preferred Stock, that the
Fund may not pay cash distributions to its common stockholders until all dividends on the Series A Term Preferred Stock for past
dividend periods have been declared and paid and that failure by the Fund to pay dividends equal to two full years will result
in the holders of the Series A Term Preferred Stock obtaining the right to elect a majority of the Funds’ board of directors.

 8. 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 senior indebtedness and state the extent to
which such indebtedness is currently outstanding.

Response: The Fund has revised its
disclosure consistent with this comment.

Prospectus

Prospectus Summary—Eagle Point Credit Company

Page 2

 9. It is stated that the Adviser may exercise certain 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.

Response:  The Adviser has exercised
protective rights on behalf of the Fund in one instance since the Fund’s inception and members of the Senior Investment Team
have exercised protective rights on behalf of other persons previously over the course of their careers. While these protective
rights are expected to be exercised a minority of the time, the Fund believes that these rights confer meaningful protective value
to the Fund if and when they are exercised. Accordingly, securing certain protective rights is an important aspect of the Fund’s
investment strategy. Given such importance, the Fund respectfully submits that disclosure regarding protective rights is appropriate
to include in the Prospectus. However, the Fund has revised its disclosure to clarify that, under normal market conditions, such
rights would be expected to be exercised only a minority of the time.

 10. 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 [5].

Response: The Fund has revised its
disclosure consistent with this comment.

April 29, 2015

Page 5

 11. Under the “Initial Public Offering” subsection, it is stated that the Fund has declared
two quarterly distributions on shares of the Fund’s common stock at a 12% annualized rate based on the price of the common
stock in the initial public offering. Please disclose the extent to which such quarterly distributions included any return of capital.

Response: The Fund has revised its
disclosure consistent with this comment.

Prospectus Summary—Eagle Point Credit Company

Page 3

 12. In discussing the Senior Investment Team’s qualifications, 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 are listed. We may
have additional comments.

Response: The Fund notes that the
term “collectively” as used in the context noted in the Staff’s comment is intended to provide an overall description
of the aggregate experience of the members of the Senior Investment Team in the CLO market rather than to itemize each member’s
individual involvement in the CLO market (which information is described in each Senior Investment Team member’s biography
included on pages 60 and 61 of the Prospectus).

Please see below a table setting forth
the members of the Senior Investment Team that have held each of the positions noted in the disclosure:

    Position

        Senior Investment Team Member

    Head of the CLO business at various investment banks

        Thomas P. Majewski (U.S. Head of CLO Banking at RBS Securities,
        Inc.; Head of CLO Banking at Merrill Lynch Pierce Fenner & Smith Inc.)

        Lead CLO structurer and collateralized debt obligation workout
        specialist at an investment bank

        Daniel W. Ko (Vice President of the CLO structuring group at
        Bank of America Merrill Lynch)

    CLO equity and debt investor

        Thomas P. Majewski (U.S. country head at AE Capital Advisers
        (US) LLC)

    Principal investor in CLO collateral management firms

        Daniel M. Spinner (Co-Founder and President of Structured Capital
        Partners, Inc.)

        Lender and merger and acquisitions adviser to CLO collateral
        management firms

    Daniel M. Spinner (Managing Director, Bear, Stearns & Co.)

April 29, 2015

Page 6

Prospectus Summary—CLO Overview

Page 4

 13. 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 “current
market environment” form the basis for the statement. Furthermore, it is stated that the Fund expects CLO equity to “provide
potential protection against rising interest rates after LIBOR 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 reduce cash flows, and thereby impair the value of, the equity tranches of a CLO? We may have additional comments.

Response: In Amendment No. 1, the
Fund has removed the disclosure regarding the Fund’s expectation that CLO equity will present more attractive risk adjusted
returns than CLO debt in the current market environment.

The Fund has revised its disclosure
under the heading “Prospectus Summary—CLO Overview” to provide cross references to “Risk
Factors—Risks Related to Our Investments—We and our investments are subject to interest rate risk” and
“Business—CLO Overview” which respectively (i) discuss the risk that defaults in the loans underlying the
Fund’s CLO investments may increase in a rising interest rate environment and (ii) explain that if losses from defaults
were significant enough to cause a CLO to breach its overcollateralization test, excess cash flow that would
otherwise be available for distribution to the CLO equity tranche investors is diverted to prepay CLO debt investors in order
of seniority until such time as the covenant breach is cured.

April 29, 2015

Page 7

Prospectus Summary—Our Structure

Page 6

 14. The structure chart indicates that the Fund invests in two wholly-owned subsidiaries. Please
include a description of such subsidiaries 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.

Response: The Fund has revised its
disclosure consistent with this comment. While there is no express limit on the percentage of the Fund’s assets that may
be invested in any of the wholly-owned subsidiaries noted in the structure chart (or on a combined basis between the two subsidiaries),
the Fund does not currently expect to invest more than 45% of its total assets in any single subsidiary. As of December 31, 2014,
1.5% of the Fund’s total assets were invested in Eagle Point Credit Company Sub LLC. To date, the Fund has not invested in
Eagle Point Credit Company Sub (Cayman) Ltd. Because each subsidiary noted on the structure chart is wholly-owned by the Fund and
would likely be, but for Section 3(c)(7) of the 1940 Act, an investment company, the Fund will consolidate the subsidiaries on
its financial statements and for purposes of complying with the limitations of the 1940 Act.

The Offering—Ranking

 15. Please include an additional bullet to state that the Series A Term Preferred Stock is subordinated
to the rights of any senior indebtedness. See Comment [8].

Response: The Fund has revised its
disclosure consistent with this comment.

Risk
Factors

Page 31

 16. 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.

Response: The Fund has revised its
disclosure consistent with this comment.

April 29, 2015

Page 8

Business—CLO Market Opportunity

Page 52

 17. The disclosure states that “based on the Adviser’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,” whereas 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?

Response: The Fund does not currently
hold any interests in CLOs issued during the 2002 to 2011 period. However, the Fund is invested in U.S. cash flow CLOs i