Correspondence 0001193125-24-011077 from Ecofin Tax-Exempt Private Credit Fund, Inc. (CIK 0001725295)
Ecofin Tax-Exempt Private Credit Fund, Inc. (CIK 0001725295)
Date: Jan. 19, 2024 · CIK: 0001725295 · Accession: 0001193125-24-011077
AI Filing Summary & Sentiment
File numbers found in text: 811-23318
Letter
RE: Ecofin Tax-Exempt Private Credit Fund, Inc.
ECOFIN TAX-EXEMPT PRIVATE CREDIT FUND, INC.
January 19, 2024
Form N-CSR for the fiscal year ended September 30, 2023, filed on December 8, 2023
File No. 811-23318
VIA EDGAR
Kenneth Ellington
United States Securities and Exchange Commission
Division of Investment Management
Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549
Mr. Ellington:
This letter sets forth the response of Ecofin Tax-Exempt Private Credit Fund, Inc. (the “Company”) to the comment of the staff of the Securities and Exchange Commission (the “Staff”) received on a telephone call on January 8, 2024, relating to the above-referenced filing. To assist your review, we have retyped the text of the Staff’s comment in italics below and provided the Company’s response thereto immediately below the comment.
Form N-CSR for the Fiscal Year Ended September 30, 2023
1. Please explain why the fund has not stated that it follows the accounting and reporting requirements of investment companies under ASC 946 (ASC 946-10-50-1).
In response to the Staff’s comment, the Company will expand the disclosure in future filings of its annual and semi-annual Form N-CSR reports to clarify that it does follow the accounting and reporting requirements of investment companies under ASC 946. The following is an excerpt from Note 2. Significant Accounting Policies from the Company’s Form N-CSR. The new text, to be added in future filings, is presented in blue/underlined font.
2. Significant Accounting Policies
The Fund is an investment company and follows accounting and reporting guidance under Financial Accounting Standards Board Accounting Standards Codification (“ASC”) Topic 946, “Financial Services-Investment Companies.” The following is a summary of significant accounting policies followed by the Fund in the preparation of its financial statements. These policies are in conformity with generally accepted accounting principles in the United States of America (“GAAP”).
If you should have any questions regarding the item discussed in this response letter, please contact me at badams@tortoiseecofin.com, or, in my absence, Courtney Gengler, the Company’s Principal Financial Officer at cgengler@tortoiseecofin.com.
Sincerely,
/s/ P. Bradley Adams
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CORRESP 1 filename1.htm ECOFIN TAX-EXEMPT PRIVATE CREDIT FUND, INC. January 19, 2024 RE: Ecofin Tax-Exempt Private Credit Fund, Inc. Form N-CSR for the fiscal year ended September 30, 2023, filed on December 8, 2023 File No. 811-23318 VIA EDGAR Kenneth Ellington United States Securities and Exchange Commission Division of Investment Management Disclosure Review Office 100 F Street, N.E. Washington, D.C. 20549 Mr. Ellington: This letter sets forth the response of Ecofin Tax-Exempt Private Credit Fund, Inc. (the “Company”) to the comment of the staff of the Securities and Exchange Commission (the “Staff”) received on a telephone call on January 8, 2024, relating to the above-referenced filing. To assist your review, we have retyped the text of the Staff’s comment in italics below and provided the Company’s response thereto immediately below the comment. Form N-CSR for the Fiscal Year Ended September 30, 2023 1. Please explain why the fund has not stated that it follows the accounting and reporting requirements of investment companies under ASC 946 (ASC 946-10-50-1). In response to the Staff’s comment, the Company will expand the disclosure in future filings of its annual and semi-annual Form N-CSR reports to clarify that it does follow the accounting and reporting requirements of investment companies under ASC 946. The following is an excerpt from Note 2. Significant Accounting Policies from the Company’s Form N-CSR. The new text, to be added in future filings, is presented in blue/underlined font. 2. Significant Accounting Policies The Fund is an investment company and follows accounting and reporting guidance under Financial Accounting Standards Board Accounting Standards Codification (“ASC”) Topic 946, “Financial Services-Investment Companies.” The following is a summary of significant accounting policies followed by the Fund in the preparation of its financial statements. These policies are in conformity with generally accepted accounting principles in the United States of America (“GAAP”). If you should have any questions regarding the item discussed in this response letter, please contact me at badams@tortoiseecofin.com, or, in my absence, Courtney Gengler, the Company’s Principal Financial Officer at cgengler@tortoiseecofin.com. Sincerely, /s/ P. Bradley Adams P. Bradley Adams Chief Executive Officer cc: Rajib Chanda, Simpson Thacher & Bartlett LLP Benjamin Wells, Simpson Thacher & Bartlett LLP 2