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SEC Company Response from Crescent Capital BDC, Inc. (CCAP, FCRX) (CIK 0001633336) (CCAP) — Oct 3, 2019

Crescent Capital BDC, Inc. (CCAP, FCRX) (CIK 0001633336)
Date: Oct. 3, 2019 · CIK: 0001633336 · Accession: 0001193125-19-261905

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File numbers found in text: 333-233995

Date
October 3, 2019
Author
/s/ Monica Shilling
Form
CORRESP
Company
Crescent Capital BDC, Inc. (CCAP, FCRX) (CIK 0001633336)

Letter

United States VIA EDGAR SUBMISSION Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Attention: Vince Di Stefano, Esq.

Dear Mr. Di Stefano:

We write on behalf of Crescent Capital BDC, Inc. (“Crescent Capital BDC”) and Alcentra Capital Corporation (“Alcentra Capital”) to inform the staff (the “Staff”) of the Division of Investment Management of the U.S. Securities and Exchange Commission (the “SEC”) that today each of Crescent Capital BDC and Alcentra Capital have filed a preliminary merger proxy statement on PREM14A in respect of the registration statement on Form N-14 (File No. 333-233995) filed by Crescent Reincorporation Sub, Inc., a wholly owned subsidiary of Crescent Capital BDC (“Crescent Capital Maryland BDC”), on September 30, 2019 (the “Registration Statement”). The Registration Statement relates to the previously announced merger transaction involving Crescent Capital BDC and Alcentra Capital. The Registration Statement contains preliminary proxy statements of each of Crescent Capital BDC and Alcentra Capital for their anticipated special stockholder meetings in connection with the proposed transactions.

Crescent Capital BDC and Alcentra Capital filed the preliminary proxy statements solely to make it easier for their respective stockholders to access the preliminary proxy statements contained in the Registration Statement during the pendency of the Staff’s review. They also will not file with the SEC or mail to their respective stockholders a definitive merger proxy statement relating to the above-referenced transaction until the Registration Statement has been declared effective by the Staff and understand that the SEC’s time goals for registration statements (and not proxy statements) will apply thereto.

If you have any questions, do not hesitate to contact me at (310) 552-4355 or via email monica.shilling@kirkland.com.

Sincerely,
/s/ Monica Shilling

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 Monica J. Shilling, P.C.

To Call Writer Directly:

 +1 310 552
4355

 monica.shilling@kirkland.com

 2029 Century Park East

Suite 1400N

 Los Angeles, CA
90067

 United States

+1 310 552 4200

www.kirkland.com

 Facsimile:

+1 310 552 5900

 October 3, 2019

VIA EDGAR SUBMISSION

 Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

 Attention: Vince Di Stefano, Esq.

Dear Mr. Di Stefano:

 We write on behalf of
Crescent Capital BDC, Inc. (“Crescent Capital BDC”) and Alcentra Capital Corporation (“Alcentra Capital”) to inform the staff (the “Staff”) of the Division of Investment Management of the U.S.
Securities and Exchange Commission (the “SEC”) that today each of Crescent Capital BDC and Alcentra Capital have filed a preliminary merger proxy statement on PREM14A in respect of the registration statement on Form N-14 (File No. 333-233995) filed by Crescent Reincorporation Sub, Inc., a wholly owned subsidiary of Crescent Capital BDC (“Crescent Capital Maryland
BDC”), on September 30, 2019 (the “Registration Statement”). The Registration Statement relates to the previously announced merger transaction involving Crescent Capital BDC and Alcentra Capital. The Registration
Statement contains preliminary proxy statements of each of Crescent Capital BDC and Alcentra Capital for their anticipated special stockholder meetings in connection with the proposed transactions.

Crescent Capital BDC and Alcentra Capital filed the preliminary proxy statements solely to make it easier for their respective stockholders to
access the preliminary proxy statements contained in the Registration Statement during the pendency of the Staff’s review. They also will not file with the SEC or mail to their respective stockholders a definitive merger proxy statement
relating to the above-referenced transaction until the Registration Statement has been declared effective by the Staff and understand that the SEC’s time goals for registration statements (and not proxy statements) will apply thereto.

If you have any questions, do not hesitate to contact me at (310) 552-4355 or via email
monica.shilling@kirkland.com.

 Sincerely,

/s/ Monica Shilling

Cc:
 Jason A. Breaux, Crescent Capital BDC

Suhail A. Shaikh, Alcentra Capital

Harry Pangas, Dechert LLP

Gregory Schernecke, Dechert LLP

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