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August 11, 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: 333-205540; 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 August 6, 2015 from Asen
Parachkevov of the Staff to Thomas Friedmann of Dechert LLP, 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. 2 (“Amendment No. 2”) 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. 2, as submitted and marked to show the changes from pre-effective amendment
no. 1 to the Registration Statement.

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

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.

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 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 and that the FINRA examiner has notified the Staff verbally that 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 and preferred 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 public offerings of the Fund’s common stock and preferred stock closed in October 2014 and May 2015, respectively,
and the Fund is not currently offering shares of either its common stock or its preferred stock. The Fund undertakes to reflect
outstanding preferred stock, if any, in future registration statements.

 5. Please explain in your response whether the CLO vehicles in which the Fund invests would be
deemed to be investment companies under the 1940 Act but for the exceptions set forth in Section 3(c)(1) or 3(c)(7). Please explain
to us why the Fund should not be subject to the same limits regarding investor qualifications (e.g. accredited investors and investment
minimums) as registered funds of hedge funds and registered funds of private equity funds. In your explanation, please explain
how the CLO vehicles are similar to, and different from, private funds, such as hedge funds and private equity funds. As part of
your explanation, please also discuss: (1) the amount of leverage in the Fund’s CLO investments, including the average leverage
of the Fund’s CLO investments that has the highest leverage (e.g. 10 times leverage); (2) whether the Fund has any limits
on investment in a CLO investments that exceeds a certain amount of leverage, and (3) whether the managers of the CLO are generally
entitled to performance fees, and what those performance fees are based on (e.g. limited to income, or also include performance
fees on capital gains).

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Response: 	Although we expect
that substantially all of the CLOs whose securities the Fund may acquire would be deemed to be investment companies under the 1940
Act but for the exception set forth in Section 3(c)(7) of the 1940 Act,1
the Fund notes that it invests in securities issued in capital market transactions and not hedge fund or private equity fund interests.
As noted by the Staff, the Fund acknowledges that registered funds of private investment funds2
(each a “Registered FOPF”) have historically adhered to certain investor eligibility standards and investment
minimums and, as such, have historically not listed their shares on a national securities exchange.3
However, the Fund respectfully notes that not all issuers that rely on Section 3(c)(7) of the 1940 Act are private investment funds
and many issuers that rely on Section 3(c)(7) do not present the same risks or considerations as private investment funds.4
In many cases, issuers choose to rely on Section 3(c)(7) because doing so is simple, convenient and well-understood. Such issuers
may not have considered whether another exception would be available.

 1 In our experience, some issuers that appear to be relying on Section
3(c)(7) based on their disclosures and offering practices could also potentially rely on other exceptions such as Section 3(c)(5)
or Rule 3a-7.

 2 For ease of reference, hedge funds and private equity funds are referred to collectively in this
letter as “private investment funds”.

 3 See Implications of the Growth of Hedge Funds, Staff
Report to the United States Securities and Exchange Commission (Sep. 29, 2003) at nn. 237 and 250 (and accompanying text)
(“2003 Hedge Fund Report”). The Fund notes that the Staff expressly stated that certain of these investor qualifications
are not required by law. Id. at n. 239 (and accompanying text) (“[r]egistered [funds of hedge funds], however, may
lower or eliminate the investment minimum at any time because this investment qualification is not required by law.”)
(emphasis added).

 4 Many issuers that are not private investment funds rely on Section 3(c)(7) as a default matter
as it is a relatively simpler exception to meet from investment company regulation than the other available exceptions and exemptions
under the 1940 Act, which require detailed analysis of an issuer’s characteristics. For an issuer to rely on Section 3(c)(7),
all of the outstanding securities of the issuer must be owned by persons who are “qualified purchasers” at the time
of acquisition of the securities. In this respect, an issuer’s reliance on Section 3(c)(7) to issue its securities can be
seen as being similar to an issuer’s reliance on Rule 144A under the Securities Act of 1933, as amended, to issue unregistered
securities to “qualified institutional buyers.” As the Staff is aware, open-end and closed-end registered investment
companies routinely invest in Rule 144A securities that a retail investor could not otherwise directly acquire.

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The Fund respectfully submits that: (i) the
Fund is fundamentally different from a Registered FOPF; and (ii) the CLOs themselves are clearly distinguishable from the private
investment funds in which a typical Registered FOPF invests. As detailed further below, CLOs possess certain attributes that distinguish
them from a typical private investment fund, including the following: (i) CLOs pursue narrowly defined long-only investment
mandates, (ii) CLOs provide complete transparency to their investors, (iii) the management and performance fee structure of CLOs
is not based on unrealized gains from underlying investments and (iv) CLO securities are issued with CUSIPs and are actively traded
on a secondary market.

Accordingly, the Fund believes that restricting
the ability of investors to invest in the Fund (whether by imposing certain eligibility criteria or by requiring higher investment
minimums) is neither necessary nor desirable for the protection of retail investors in the Fund. The Fund respectfully submits
that any such restriction could adversely impact the Fund’s stockholders by impairing the ability of the Fund to raise capital
and the ability of the Fund’s stockholders to freely liquidate their shares, among other adverse effects.5

 · A CLO’s investment strategy is more straightforward than that of a typical private
investment fund. CLOs, like nearly all forms of securitization, are long only vehicles that may only invest in a narrowly
defined set of assets (e.g., secured corporate loans).6
CLOs are subject to numerous portfolio compliance tests that must be adhered to and that are detailed in a CLO’s indenture.
Compliance with these tests is monitored by each CLO’s trustee. These tests are discussed in more detail in the Prospectus.
In addition, CLOs have contractual limitations on levels of trading activity. CLOs also do not hedge or leverage their positions
through the use of derivatives (with a limited exception for hedging of interest rate risk for corporate loans). As a result, a
CLO’s return is principally derived from the interest income received from its loan portfolio rather than from capital gains
on that portfolio. Given these attributes, a CLO’s investment strategy (and the Fund’s strategy of investing in securities
issued by CLOs) is relatively straightforward to understand as compared to a typical private investment fund’s investment
strategy. Further, a CLO’s investment program is contractually required to remain consistent over time.

 5 The Fund’s common stock and preferred stock are listed on the New York Stock Exchange. Accordingly,
in response to information reported by the Fund or for any other reason, the Fund’s current stockholders may freely sell
their shares on the open market. As of August 10, 2015, the Fund’s common stock traded at an approximate 9% premium to its
estimated net asset value as of June 30, 2015. We believe the Fund’s transparency into the underlying loan portfolios of
its CLO investments (as discussed below) is a significant reason why investors may be willing to pay a premium to NAV for the Fund’s
common stock.

 6 By contrast, and as discussed below, most hedge funds are permitted to invest in nearly any kind
of investment. Although some have investment objectives and restrictions that serve as practical limits on the types of investments
that can be made, very few, if any, hedge funds are as restricted in their investment activities.

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By contrast, many hedge funds
reserve the ability to engage in complex and varied trading strategies and may utilize hedging techniques to either increase returns
or modify portfolio risk profiles. Such private investment funds typically may engage in significantly higher levels of trading
activity than CLOs. In addition, unlike a CLO which generates its returns primarily from interest income received from its loan
portfolio, typical private equity funds, and many hedge funds, primarily generate a significant portion of returns from capital
gains on underlying portfolio investments.

Because of their simpler and
more consistent investment strategy and approach, the Fund respectfully submits that CLOs do not raise issues regarding the ability
of a retail investor to understand a CLO’s core investment strategy in the same way that a typical private investment fund
does.7

 · On a monthly basis, the Fund has complete transparency into the underlying loan portfolios
and loan portfolio transactions of the CLOs whose securities the Fund holds. By contrast, transparency for private investment funds
is dependent upon the reporting provided by the private investment fund’s sponsor or the contents of the annual audit report.
The Fund receives a monthly report from each CLO’s trustee that lists all of the loans held in that CLO’s portfolio
as well as all portfolio transactions that occurred in the portfolio during the month.8
The trustee that provides this report is an independent third party unrelated to the CLO’s collateral manager. This information
allows the Fund to report summary underlying portfolio characteristics, including the Fund’s top 10 overall loan obligor
and industry exposures. The Fund has begun to report this information on a monthly basis from May 2015. The ability of Fund investors
to have access to such information, and the ability of the Fund to report such information on a regular basis, significantly distinguishes
the Fund from typical Registered FOPFs that invest predominantly in hedge funds.

 7 As noted in the 2003 Hedge Fund Report, Registered FOPFs “typically disclose the various
investment strategies that the underlying hedge funds may employ, including, in some cases, the impact of style shifts in underlying
hedge funds on the [Registered FOPF’s] ability to achieve its stated investment objective.” 2003 Hedge Fund Report
at 72. As described above, each CLO has the same (or substantially similar) investment strategy and the need to explain multiple
investment strategies and issues relating to style shift are not applicable to CLOs.

 8 The Fund notes that this level of transparency exceeds even that which registered investment companies
are required to make available both in terms of frequency and level of information as these reports are produced monthly and provide
not only a snapshot of portfolio positions, but also information regarding each portfolio transaction during the reporting period.

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Registered FOPFs typically do
not have this level of information regarding the portfolio holdings and characteristics of the underlying private investment funds
(and to the extent any such information is provided to a Registered FOPF, such information would likely be provided by a private
investment fund’s manager or sponsor rather than a third party).9
As a result, such Registered FOPFs would be unable to provide reporting that may be important to retail investors or that otherwise
provides insight on the private investment fund’s overall risk profile.

 · The SEC specifically distinguished CLOs (which are nearly always “securitized
asset funds”) from “hedge funds” and “private equity funds” through definitions of these terms in
Form ADV and Form PF. In requiring issuers that rely on Section 3(c)(7) under the 1940 Act to be classified on Form ADV
and Form PF, the Commission has expressly recognized that not all Section 3(c)(7) issuers are alike. Form ADV and Form PF identify
several categories of such issuers, including “hedge fund,” “private equity fund” and “securitized
asset fund.” A “securitized asset fund” is defined as any private fund whose primary purpose is to issue asset
backed securities and whose investors are primarily debt-holders.10
In practice, based on our understanding of how CLOs are operated, all CLOs should be classified as “securitized asset funds”
and, as a result, no CLO will be classified as a hedge fund or private equity fund for purposes of Form ADV and Form PF. The Commission’s
definitions for purposes of classifying private funds make clear that the Commission recognizes a meaningful distinction between
issuers such as