Correspondence 0001104659-24-083481 from Monroe Capital Income Plus Corp (CIK 0001742313)
Monroe Capital Income Plus Corp (CIK 0001742313)
Date: July 29, 2024 · CIK: 0001742313 · Accession: 0001104659-24-083481
AI Filing Summary & Sentiment
File numbers found in text: 814-01301
Letter
Division of Investment Management, New York, NY 10004-2616 Re: Monroe Capital Income Plus Corporation Annual Report on Form 10-K File No. 814-01301
Dear Ms. Rotter:
On behalf of Monroe Capital Income Plus Corporation (the “Registrant”), set forth below are the Registrant’s responses to the comments of the staff of the Division of Investment Management, Disclosure Review and Accounting Office (the “Staff”) of the Securities and Exchange Commission (the “SEC”) that we received on July 11, 2024, in connection with the SEC’s review of the Registrant’s annual report on Form 10-K filed on March 12, 2024, as required by Section 408 of Sarbanes-Oxley Act of 2002, as amended. The Staff’s comments are set forth below and are followed by the Registrant’s responses.
1. Comment: Please confirm in correspondence that going forward the Registrant will disclose in its financial statements how the weighted average was calculated in the significant unobservable inputs table regarding valuations techniques.
Response: The Registrant confirms that it will disclose in its financial statements how the weighted average was calculated in the significant unobservable inputs table regarding valuations techniques in its future filings.
2. Comment: Investment companies are required to disclose if there were changes in the valuation techniques or if any additional techniques were used and reasons for those changes. Please confirm in correspondence that there were no changes required to be disclosed.
Response: The Registrant confirms that there were no material changes to valuation techniques outside of normal course of business changes in valuation approaches for certain positions, which is in line with the Registrant’s valuation policy, and that no additional valuation techniques were required to be disclosed.
Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.
Ms. Mindy Rotter, Esq., CPA
July 29, 2024
Page 2
3. Comment: Please confirm in correspondence that the Registrant’s investments remained consistent with its diversification status for regulated investment company (“RIC”) and tax purposes.
Response: The Registrant confirms that its investments have remained consistent with its diversification status as a RIC and for tax purposes.
* * * * *
If you have any questions or additional comments concerning the foregoing, please contact me at (202) 383-0845.
Sincerely,
/s/ Stephani Hildebrandt
Show Raw Text
CORRESP
1
filename1.htm
Eversheds Sutherland (US) LLP
700 Sixth Street, NW, Suite 700
Washington, DC 20001-3980
D: +1 202.383.0845
F: +1 202.637.3593
stephanihildebrandt@
eversheds-sutherland.com
July 29, 2024
Ms. Mindy Rotter, Esq., CPA
U.S. Securities and Exchange Commission
Division of Investment Management,
Disclosure Review and Accounting Office
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Re:
Monroe Capital
Income Plus Corporation
Annual Report on Form 10-K
File No. 814-01301
Dear Ms. Rotter:
On behalf of Monroe Capital
Income Plus Corporation (the “Registrant”), set forth below are the Registrant’s responses to the comments
of the staff of the Division of Investment Management, Disclosure Review and Accounting Office (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) that we received on July 11, 2024, in connection
with the SEC’s review of the Registrant’s annual report on Form 10-K filed on March 12, 2024, as required by Section 408
of Sarbanes-Oxley Act of 2002, as amended. The Staff’s comments are set forth below and are followed by the Registrant’s
responses.
1. Comment: Please confirm in correspondence
that going forward the Registrant will disclose in its financial statements how the weighted
average was calculated in the significant unobservable inputs table regarding valuations
techniques.
Response: The Registrant
confirms that it will disclose in its financial statements how the weighted average was calculated in the significant unobservable inputs
table regarding valuations techniques in its future filings.
2. Comment: Investment companies are
required to disclose if there were changes in the valuation techniques or if any additional
techniques were used and reasons for those changes. Please confirm in correspondence that
there were no changes required to be disclosed.
Response: The Registrant
confirms that there were no material changes to valuation techniques outside of normal course of business changes in valuation approaches for certain positions, which is in line with the Registrant’s
valuation policy, and that no additional valuation techniques were required to be
disclosed.
Eversheds Sutherland (US) LLP is part
of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description
of the structure and a list of offices, please visit www.eversheds-sutherland.com.
Ms. Mindy Rotter, Esq., CPA
July 29, 2024
Page 2
3. Comment: Please confirm in correspondence
that the Registrant’s investments remained consistent with its diversification status
for regulated investment company (“RIC”) and tax purposes.
Response: The Registrant
confirms that its investments have remained consistent with its diversification status as a RIC and for tax purposes.
* * * * *
If you have any questions
or additional comments concerning the foregoing, please contact me at (202) 383-0845.
Sincerely,
/s/ Stephani Hildebrandt
Stephani M. Hildebrandt
cc:
Theodore M. Koenig / Monroe Capital
Income Plus Corporation
Lewis W. Solimene / Monroe Capital Income Plus
Corporation