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CORRESP
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CORRESP

2049 Century Park East

Los Angeles, CA 90067

Monica J. Shilling, P.C.

United States

To Call Writer Directly:

Facsimile:

+1 310 552 4355

+1 310 552 4200

+1 310 552 5900

monica.shilling@kirkland.com

www.kirkland.com

July 30, 2026

 United States Securities and Exchange Commission

Division of Investment Management

 100 F Street, N.E.

Washington, DC 20549-3628

 Attention: David Manion, CPA,
CAIA, MST

Re:
 Vista Credit Strategic Lending Corp.

Annual Report on Form 10-K for the year ending December 31, 2025

File No. 814-01651

Ladies and Gentlemen:

 This letter is sent on
behalf of Vista Credit Strategic Lending Corp. (the “Fund”) in response to the comments of the Staff (the “Staff”) of the United States Securities and Exchange Commission (the “SEC” or
“Commission”) regarding the Fund’s Annual Report on Form 10-K for the year ending December 31, 2025 (the “Annual Report”) communicated via teleconference to
Monica J. Shilling of Kirkland & Ellis LLP on June 22, 2026.

 For convenience, we have set forth below, in italics, the text
of the Staff’s comments prior to each of the Fund’s responses. Capitalized terms used but not defined herein have the meanings set forth in the Annual Report. We acknowledge that the Fund and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Please note that revisions with respect to one portion of the Annual Report are applicable to all similar portions of the
Annual Report.

 Accounting Comments

Critical Accounting Policies – Page 87

1.
 Comment: The second paragraph of the section entitled “Revenue
Recognition” discusses loans placed on non-accrual status. Please supplementally describe how the statements in this paragraph align with U.S. GAAP, specifically describing the
appropriateness of applying payments from non-accrual loans that are recognized as income. Additionally, describe if non-accrual interest receivables are kept as an
asset even if the loan stops paying interest income based on this policy. Please cite U.S. GAAP in your response.

Response: The Fund advises the Staff that its accounting policy for loans placed on
non-accrual status is intended to be consistent with U.S. GAAP, including the guidance in ASC 310, Receivables (“ASC 310”), and ASC 326, Financial Instruments—Credit Losses
(“ASC 326”).

 United States Securities and Exchange Commission

Division of Investment Management

 July 30, 2026

Page 2

 When a loan is placed on non-accrual status because
collection of contractual principal or interest is no longer considered probable, the Fund ceases accruing interest income. Accrued but unpaid interest is generally reversed when the loan is placed on
non-accrual status. Accordingly, the Fund does not continue to recognize interest income on a non-accrual loan unless cash is received and recognition is appropriate
based on the facts and circumstances.

 Consistent with ASC 310-10-35-41 through ASC 310-10-35-45, cash payments received on non-accrual loans are evaluated based on the Fund’s assessment of collectability. When collection of the remaining contractual principal is considered reasonably assured, cash receipts may be recognized as
interest income to the extent appropriate. Conversely, when collectability of principal remains uncertain, cash receipts are generally applied as a reduction of the recorded investment in the loan (cost recovery method) until such uncertainty has
been resolved. Accordingly, the Fund’s policy that interest payments received on non-accrual loans “may be recognized as income or applied to principal depending upon our judgment regarding
collectability” reflects this assessment and is intended to be applied in a manner consistent with U.S. GAAP.

 With respect to
accrued interest receivable, the Fund generally reverses accrued but unpaid interest when a loan is placed on non-accrual status. Therefore, non-accrual interest
receivables are generally not maintained as assets after a loan is placed on non-accrual status. To the extent accrued interest is outstanding, the Fund evaluates such amounts in accordance with ASC 326. If it
becomes probable that accrued interest will not be collected, and the amount of the loss can be reasonably estimated, the accrued interest is written off. Accordingly, the Fund’s policy is not to continue recognizing accrued interest
receivable as an asset while simultaneously ceasing the recognition of interest income.

 The Fund believes its accounting policy is
consistent with U.S. GAAP, including the guidance in ASC 310 and ASC 326. In response to the Staff’s comment, the Fund will revise its future disclosure to provide additional clarity regarding its accounting policy for non-accrual loans. Specifically, the Fund will expand its disclosure to clarify that (i) accrued but unpaid interest is generally reversed when a loan is placed on
non-accrual status, (ii) cash receipts on non-accrual loans are recognized as interest income only when collection of principal is reasonably assured and otherwise
are applied as a reduction of the loan’s recorded investment, and (iii) accrued interest receivable is generally not carried as an asset once a loan is placed on non-accrual status unless collection
is considered probable under the applicable U.S. GAAP guidance.

 Expense Support and Conditional Reimbursement Agreement – Page 124

2.
 Comment: The Staff notes the $1.331 million of Fund expenses that were disclosed
as “Due to Adviser” on the Fund’s Consolidated Statements of Assets and Liabilities for the year ended December 31, 2025 are not subject to the
Expense Support Agreement. These amounts appear to be unrecorded in the expense support and waivers caption in the Consolidated Statements of Operations for the same period. As of December 31, 2025, the
Fund had a payable related to $3.6 million of expense payments incurred by the Adviser in the following increments: $600,000 in 2025, $1.72 million in 2023 (recorded prior to
June 30, 2023) and $1.283 million in 2022.

 United States Securities and Exchange Commission

Division of Investment Management

 July 30, 2026

Page 3

(a)
 Please describe in correspondence the accounting entries for the $1.331 million Fund expenses noted
above and subsequent payments to the Adviser.

 Response: The Fund advises the Staff that the
$1.331 million included in “Due to Adviser” as of December 31, 2025 represents amounts due to the Adviser under the Administration Agreement, which requires the Fund to reimburse the Adviser for certain expenses it incurs in
connection with the administration of the Fund.

 These amounts are not related to, and are not subject to, the Expense Support and
Conditional Reimbursement Agreement (the “ESA Agreement”). Accordingly, when incurred, they are recorded as operating expenses in the applicable expense captions within the Consolidated Statements of Operations, with a
corresponding entry under “Due to Adviser.” Subsequently, when the Fund reimburses the Adviser for these expenses, the amount presented as “Due to Adviser” is reduced, and a corresponding credit is made to cash to reflect the
payment of these expenses. Accordingly, the “Due to Adviser” balance reflects the Fund’s obligation to reimburse the Adviser for expenses incurred pursuant to the Administration Agreement and does not represent expense support,
expense waivers or conditional reimbursements under the ESA Agreement.

(b)
 What is the character of the $600,000 expenses recorded in 2025 and the entire $3.6 million liability
at December 31, 2025.

 Response: The Fund advises the Staff that in 2023, the Adviser entered into the
ESA Agreement with the Fund, pursuant to which the Adviser may elect to pay certain of the Fund’s expenses on the Fund’s behalf, provided that no portion of the payment will be used to pay any interest expense or distribution and/or
shareholder servicing fees. The Adviser elected to provide $3.0 million of expense support to the Fund in the fourth quarter of 2023. The initial $3.0 million of expense support related to organizational and offering costs incurred in
connection with the establishment of the Fund. In 2025, the Adviser elected to provide an additional $600,000 of expense support under the ESA Agreement in the first quarter of 2026 to fund certain professional fees incurred by the Fund.

Accordingly, as of December 31, 2025, the aggregate liability of approximately $3.6 million represents amounts advanced by the
Adviser pursuant to the ESA Agreement, consisting of approximately $3.0 million of organizational and offering costs and approximately $600,000 of professional fees. These amounts are subject to the terms of the ESA Agreement, including the
Fund’s conditional reimbursement obligations as set forth therein.

(c)
 Were any expenses from 2023 included in this $3.6 million liability incurred prior to June 16,
2023? If so, if the Fund is liable for these amounts, please include a discussion in your response regarding any agreements or disclosures discussing these amounts as the Staff notes the following two dates: the effective date of the Fund was August
2023 and the initial filing of the Form 10-12(g) was June 16, 2023.

 United States Securities and Exchange Commission

Division of Investment Management

 July 30, 2026

Page 4

 Response: The Fund advises the Staff that of the approximately $3.6 million of
Expense Payments covered under the ESA Agreement, approximately $3.0 million relates to organizational and offering costs incurred in connection with the formation of the Fund, and substantially all of those underlying costs were incurred prior
to June 16, 2023. The remaining approximately $600,000 relates to professional fees and other Fund operating expenses incurred between August and December 2025.

Although the underlying organizational and offering costs were incurred prior to June 16, 2023, the Adviser did not make the related
Expense Payments to or on behalf of the Fund until the fourth quarter of 2023, after execution of the ESA Agreement. The Expense Payments relating to the $600,000 of professional fees were made to or on behalf of the Fund during the fourth quarter
of 2025 and the first quarter of 2026.

 Pursuant to the ESA Agreement, Expense Payments made by the Adviser are eligible for reimbursement
by the Fund until the last business day of the calendar quarter that is three years after the date of the applicable Expense Payment, provided that, at the end of the applicable calendar quarter, the Fund has Excess Operating Funds and satisfies the
additional reimbursement conditions set forth in the ESA Agreement. As of December 31, 2025, the Fund had not made any reimbursement payments to the Adviser.

(d)
 Given the terms of the Expense Support and Conditional Reimbursement Agreement, explain why the Fund would
continue to be liable for any 2022 expenses.

 Response: The Fund confirms that a portion of the
organizational and offering costs subject to the ESA Agreement relate to legal and other formation costs that were incurred over a number of years in connection with the establishment of the Fund, including certain costs incurred during 2021 and
2022.

 Although the underlying services giving rise to these costs were performed prior to the execution of the ESA Agreement, the Adviser
did not make the related Expense Payments until after the ESA Agreement became effective. Pursuant to the ESA Agreement, the Adviser elected to designate these payments as Expense Payments and paid the related amounts on the Fund’s behalf in
December 2023. Accordingly, the Fund’s conditional reimbursement obligation arises from the Expense Payments made by the Adviser under the ESA Agreement, rather than from the dates on which the underlying legal and other organizational
services were performed or the related invoices were received.

 Under the ESA Agreement, Expense Payments are eligible for reimbursement
only if the conditions specified in the agreement are satisfied, including that the Fund has Excess Operating Funds, satisfies the applicable reimbursement conditions, and the applicable Expense Payment remains within the contractual reimbursement
period. As of December 31, 2025, the Fund had not made any reimbursement payments to the Adviser.

 United States Securities and Exchange Commission

Division of Investment Management

 July 30, 2026

Page 5

(e)
 The $3.6 million is recorded as due from the Adviser and due to the Adviser. Please explain why these
amounts are recorded to the balance sheet if these amounts are subject to the standard recoupment terms.

Response: The Fund advises the Staff that the “Expense Support Reimbursement” and “Due to Adviser” balances
arise from different aspects of the ESA Agreement and are not duplicative.

 The “Expense Support Reimbursement” balance
represents the cumulative Expense Payments made by the Adviser that reduced the Fund’s expenses in the period incurred, for which cash had not yet changed hands as of the balance sheet date. These amounts are recognized when the related
expense reduction is recorded, not when cash settles.

 The corresponding “Due to Adviser” balance represents the Fund’s
conditional obligation to reimburse the Adviser for Expense Payments made pursuant to the ESA Agreement. While reimbursement is subject to the conditions set forth in Section 2 of the ESA Agreement, including the availability of Excess
Operating Funds and satisfaction of the applicable reimbursement conditions, the Fund has recorded the reimbursement obligation as management has concluded that repayment is probable in accordance with ASC
450-20. The Fund reassesses this conclusion each period and will reverse or adjust the liability if reimbursement becomes less than probable.

Accordingly, the Fund believes that recognizing the respective asset and payable balances appropriately reflects the rights and obligations
established under the ESA Agreement, while the current disclosures describe the conditions governing reimbursement. The Fund also believes the current gross presentation provides more decision-useful information to investors than a net presentation
would. Presenting the items separately allows a reader to distinguish the cumulative economic benefit the Adviser has provided to the Fund’s shareholders in the form of expense support from the Fund’s potential future cash outflow
obligation to the Adviser, which is contingent on the Fund’s future operating performance and is not assured to be paid in full, or at all, within the three-year window contemplated by the ESA Agreement. Netting these amounts would obscure
both the magnitude of support the Adviser has provided and the magnitude of the contingent future claim on the Fund’s cash flows.

(f)
 Please ensure disclosure of any amounts waived by the Adviser, paid by the Adviser or paid to the Adviser
and reasons why the Fund may be liable for older amounts are included in future financial statements.

Response: In response to the Staff’s comment, the Fund will enhance its future disclosures to disclose any expenses or other
amounts owed to, and waived by, the Adviser, expenses or other amounts paid by the Adviser or paid to the Adviser, and any applicable reasons why the Fund may be liable for older expenses or other amounts that are reflected in future financial
statements.

 United States Securities and Exchange Commission

Division of Investment Management

 July 30, 2026

Page 6

 Financial Highlights Footnote – Page 129

3.
 Comment: The Staff notes footnote 5 to the Financial Highlights footnote (Note
8 to the Fund’s Consolidated Financial Statements). Please discuss in correspondence how this description conforms to the requirements of General Instruction 15 to Item 4 of Form N-2, specifically how financial highlights are calculated.

 Response: The
Fund confirms that