Correspondence 0001829126-24-002964 from Sound Point Meridian Capital, Inc. (SPMC)
Sound Point Meridian Capital, Inc.
Date: May 1, 2024 · CIK: 0001930147 · Accession: 0001829126-24-002964
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-272541, 811-23881
Letter
Via EDGAR Division of Investment Management 100 Pearl Street, Suite 20-100 New York, NY 10004 Attn: Ms. Mindy Rotter Re: Sound Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)
Dear Ms. Rotter:
This letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) on April 25, 2024, in connection with your review of the amended registration statement on Form N-2 (the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital, LLC) (the “Fund”) filed with the Securities and Exchange Commission (“SEC”) on April 15, 2024. The Fund has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement on its behalf.
The Fund will file Pre-Effective Amendment No. 3 to its Registration Statement (the “Amended Registration Statement”), which will reflect the disclosure changes discussed below. Capitalized terms have the meanings attributed to such terms in the Registration Statement.
On behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such comments, as requested.
1. Comment: The Staff notes that reference was not made to financial highlights in Pre-Effective Amendment No. 2 to the Registration Statement. Please confirm in correspondence that a statement regarding the financial highlights (i.e., that the Fund is newly organized, the Fund does not have any financial history as of the date of this prospectus, and that the Fund’s financial highlights will be available in the Fund’s annual, semiannual reports, etc.) will be included in the Amended Registration Statement.
Response: The Fund will revise the disclosure accordingly in the Amended Registration Statement.
2. Comment: The Staff notes that portions of the Registration Statement remain incomplete and reminds the Fund that a full financial review must be completed before the Amended Registration Statement can be declared effective. The Staff may have additional comments following a review of the Amended Registration Statement.
Response: The Fund respectfully acknowledges the Staff’s comment and confirms that the Amended Registration Statement will contain all information required for the Staff to complete a full financial review.
* * *
May 1, 2024
Page 2
Should you have any questions or comments, please contact me at 202.261.3460.
Sincerely,
/s/
Philip T. Hinkle
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CORRESP
1
filename1.htm
1900 K Street,
NW
Washington, DC 20006
+1 202 261 3300
Main
+1 202 261 3333
Fax
www.dechert.com
Philip
T. Hinkle
philip.hinkle@dechert.com
+1
202 261 3460 Direct
+1
202 261 3050 Fax
May
1, 2024
Via
EDGAR
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
Attn: Ms. Mindy Rotter
Re: Sound
Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)
Dear
Ms. Rotter:
This
letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “SEC”) on April 25, 2024, in connection with your review of the amended registration statement on Form
N-2 (the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital,
LLC) (the “Fund”) filed with the Securities and Exchange Commission (“SEC”) on April 15, 2024.
The Fund has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement
on its behalf.
The
Fund will file Pre-Effective Amendment No. 3 to its Registration Statement (the “Amended Registration Statement”),
which will reflect the disclosure changes discussed below. Capitalized terms have the meanings attributed to such terms in the Registration
Statement.
On
behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such
comments, as requested.
1.
Comment: The Staff notes that reference was not made to financial highlights in
Pre-Effective Amendment No. 2 to the Registration Statement. Please confirm in correspondence
that a statement regarding the financial highlights (i.e., that the Fund is newly
organized, the Fund does not have any financial history as of the date of this prospectus,
and that the Fund’s financial highlights will be available in the Fund’s annual,
semiannual reports, etc.) will be included in the Amended Registration Statement.
Response:
The Fund will revise the disclosure accordingly in the Amended Registration Statement.
2.
Comment: The Staff notes that portions of the Registration Statement remain incomplete
and reminds the Fund that a full financial review must be completed before the Amended Registration
Statement can be declared effective. The Staff may have additional comments following a review
of the Amended Registration Statement.
Response:
The Fund respectfully acknowledges the Staff’s comment and confirms that the Amended Registration Statement will contain all
information required for the Staff to complete a full financial review.
*
* *
May 1, 2024
Page 2
Should
you have any questions or comments, please contact me at 202.261.3460.
Sincerely,
/s/
Philip T. Hinkle
Philip
T. Hinkle