SecProbe.io

CORRESP
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    1900 K Street NW

    Washington, DC 20006-1110

    +1 202 261 3300 Main

    +1 212 261 3333 Fax

    www.dechert.com

        william J. bielefeld

    william.bielefeld@dechert.com

    +1 202 261 3386 Direct

    +1 202 261 3333 Fax

August 27, 2024

VIA
EDGAR

Karen Rossotto

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-0504

Re: MA Specialty Credit Income Fund (the “Fund”)

File No. 811-23978; 333-280620

Dear Ms. Rossotto:

We are writing in response to comments provided
by the staff of the Division of Investment Management (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”)
in a letter dated August 9, 2024, regarding the Fund’s submission of an initial registration statement on Form N-2 that
was filed with the SEC on July 1, 2024 (the “Registration Statement”). The Fund has considered these comments and has
authorized us to make the responses discussed below on its behalf.

Each of the Staff’s comments is presented
below and each comment is followed by the applicable response. Undefined capitalized terms used herein have the same meaning as in the
Registration Statement.

GENERAL

 1. Comment: We note that portions of the registration statement are incomplete. We may have additional
comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response to this letter, on information
supplied supplementally, or on exhibits added in any amendments.

Response:
The Fund understands and acknowledges this comment.

 2. Comment: We note disclosure on the Cover stating that the Fund has submitted an application for
an exemptive order to, among other things, permit the Fund to offer multiple classes of shares. Please supplementally explain if the Fund
has submitted or intends to submit any additional exemptive applications or a no-action request in connection with the registration statement.
Please inform us of the anticipated timing of any applications or requests for relief.

Response:
On July 17, 2024, the Fund and the Adviser submitted an exemptive application seeking relief for a fund to issue multiple classes
of shares (File No. 812-15603). Additionally, on July 23, 2024, the Fund, the Adviser and certain of their affiliates submitted
an exemptive application seeking relief with respect to co-investments (File No. 812-15604). The Fund does not anticipate making
any other exemptive relief applications or no-action letter requests.

 3. Comment: Please confirm that the Fund does not intend to issue debt securities or preferred shares
within a year from the effective date of the registration statement. If the Fund plans to issue preferred shares within a year from the
effectiveness of the registration statement, please include additional disclosure of risks to shareholders in the event of a preferred
shares offering.

Response:
The Fund does not intend to issue debt securities or preferred shares within a year from the effective date of the registration statement,
but the Fund intends to enter into a credit facility within the first year after the effective date of its registration statement.

 4. Comment: Please tell us if you have presented or will present any “test the waters”
materials to potential investors in connection with this offering. If so, please provide us with copies of such materials.

Response:
The Fund confirms that it has not presented and will not present any “test-the-water” materials to potential investors in
connection with this offering.

PROSPECTUS

Prospectus Cover

 5. Comment: In Interval Fund, please disclose the intervals between deadlines for repurchase
requests, pricing and repayment and the anticipated timing of the Fund’s initial repurchase offer. Please also provide a cross-reference
to the sections of the prospectus that discuss the Fund’s repurchase policies and the attendant risks. See Guide 10 to Form N-2.

Response:
The disclosure has been revised accordingly.

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 6. Comment: Please address the following comments concerning the disclosure in Principal Investment
Strategies:

 a. The Fund states that it will invest primarily in “specialty credit, asset-based finance or diversified
private credit” investments. Please clarify this disclosure to explain the types of investments included in each of these categories.
Also, the disclosure states that the Adviser believes these Loans have “bespoke or differentiated features.” Either here or
at an appropriate place within the registrations statement please explain what these features are.

Response:
The disclosure has been revised accordingly.

 b. You define a Non-Bank Finance Company as a “non-bank originator”. Please explain what a non-bank
originator is.

Response:
The disclosure has been revised accordingly.

 c. Please explain what “asset-based finance verticals”, “risk-adjusted returns” and
 “forward flow programs” are. In general, please avoid the use of technical terms and complex language in the disclosure.

Response:
The disclosure has been revised accordingly.

 d. Please explain what “specialized (or esoteric) Loans” are.

Response:
The disclosure has been revised accordingly.

 e. Please clarify the term “best-in-class lending opportunities”.

Response:
The disclosure has been revised accordingly.

 f. Does the term “high-yielding” refer to Loans rated below investment-grade? If so, please disclose
these investments are known as “junk”.

Response:
The term high-yielding refers to both below investment-grade and unrated Loans. Accordingly, the Fund respectfully submits that no disclosure
revision is necessary in response to this comment.

 g. The disclosure states “the Adviser seeks to further diversify the overall risk and duration
of the Fund’s portfolio….[emphasis added].” As the Fund is characterized as non-diversified under the 1940 Act, please
delete or replace the term “diversify” as used here.

Response:
The disclosure has been revised accordingly.

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 h. The disclosure refers to “the substantial growth of non-bank finance opportunities.” Please
disclose the basis for this statement.

Response:
The disclosure has been revised accordingly.

 i. The disclosure states the Fund will invest in “certain types of tradeable instruments.” Please
disclose what these instruments are.

Response:
The disclosure has been revised accordingly.

 j. The disclosure in the last line states “The Fund may invest in additional strategies in the future.”
Please delete this disclosure or state specifically investments the Fund anticipates making in the future and when it may do so.

Response:
To clarify, the disclosure has been updated to state: “The Fund may invest in additional strategies in the future as opportunities
in different strategies present.” The Fund respectfully submits that no other disclosure revisions are necessary in response to
this comment.

 7. Comment: At the top of page ii, in the bolded language discussing credit instruments rated
below investment grade, please include a cross-reference to the disclosure regarding the risks associated with these investments. See
Form N-2, Item 1.1.j. and the Guidelines to Form N-2, Guide 6.

Response:
The disclosure has been revised accordingly.

 8. Comment: On page ii, regarding the bolded bullets disclosing risks of investing in the Fund,
please address the following comments:

 a. The fourth bullet refers to a Shareholder’s ability to “sell its Shares outside the quarterly
repurchase process….” Please disclose how this might be done.

Response:
The referenced disclosure has been deleted.

 b. The fifth bolded bullet states “Class S Shares and Class F Shares are not subject to a
sales load.” Is this a risk of investing in the Fund? If not, please delete this disclosure, or otherwise revise as appropriate.

Response:
The referenced disclosure has been deleted.

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 c. In the seventh bullet, the disclosure states that distributions may be funded from offering proceeds.
Please confirm to us the Board has determined this is an appropriate use of offering proceeds.

Response:
The Fund confirms that the Board would be apprised of any distribution to be funded from offering proceeds prior to such distribution.

Summary of Terms

The Fund (page 1)

 9. Comment: In the second paragraph, the disclosure states “[p]rior to the Fund’s registration
as an investment company” private funds managed by the Adviser transferred their assets to the Fund in exchange for cash and shares.
Please explain supplementally if this transaction meets the definition of a fund acquisition as described in S-X Rule 6-11(a)(2).
In your response, please also address the following questions:

Response:
The Fund respectfully advises the Staff that the acquisition of the assets of certain private funds is not a fund acquisition as defined
in Article 6-11 of Regulation S-X. The Fund’s acquisition of the assets in each private fund constituted less than substantially
all of the private fund’s portfolio investments at the time of the transaction and, consequently, was not a fund acquisition pursuant
to Rule 6-11(a)(2) of Regulation S-X. In accordance with Regulation S-X 6-11(a)(2), whether an acquisition constituted “substantially
all” of the portfolio investments of an entity is inherently a facts and circumstances based analysis. The Fund further notes that
the private funds are pre-existing affiliated entities of the Fund that were not established by the Fund or established for the purpose
of a transaction with the Fund. The private funds have continued, and intend to continue, their operations and investment strategy after
the transaction.

 a. What is the underlying business purpose of the transaction?

Response:
The underlying purpose of the transaction was to give certain private fund investors the ability to invest in a registered investment
company and to allow for the transfer of certain assets from the private fund to the Fund prior to its registration as an investment company.

 b. What is the nature of the relationship between the transacting parties?

Response:
The Fund and the private funds are managed by the Adviser.

 c. What are the future operating plans of the Private Funds and the retained assets?

Response:
The private funds will continue operations in accordance with their investment strategies.

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 d. Will the Private Funds continue their operations? Will they wind down? If not, will they change their
strategies?

Response:
The private funds will continue operations in accordance with their investment strategies.

 e. Did any limited partnerships from the Private Funds transfer assets into the Fund?

Response:
Yes. One of the private funds in the transaction is a limited partnership.

 f. Is any of the Private Funds management involved with the Fund following the transaction?

Response:
There is overlap in the management team of the private funds and the Fund.

 g. Please provide more detail concerning the strategies and objectives of the Private Funds.

Response:
The strategies and objectives of the private funds are similar to those of the Fund. As stated above, the transaction is not a fund acquisition
as defined in Article 6-11 of Regulation S-X.

Investment Opportunities and
Strategies (page 2)

 10. Comment: The disclosure states the Fund makes Loans “directly to borrowers”. With respect
to this strategy, please address the following:

 a. Please describe here or at an appropriate place within the registration statement, the origination process
and the nature of borrowers the Fund will provide Loans to, the typical size and duration of the Loans and the diligence the Fund performs
in determining who to lend to and the amount of the Loans.

Response:
The Fund believes the current disclosure (starting on page 18) sufficiently describes the Fund’s origination process, the nature
of borrowers and the diligence the Fund performs. The Fund confirms that there is no limit on the size or duration of the loans that the
Fund will originate. The Fund respectfully submits that no disclosure revision is necessary in response to this comment.

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 b. Please disclose, if accurate, that the Fund will be responsible for all expenses associated with originating
(including research, due diligence, use of experts, structuring and negotiations) and servicing the Loans (to the extent not borne by
the borrowers).

Response:
The Fund confirms that it will be responsible for expenses associated with originating loans, and that such expenses will be reflected
in the fee table. The Fund respectfully submits that no disclosure revision is necessary in response to this comment.

 c. Please also disclose the following:

 i. any limits on Loan origination by the Fund, including a description of any limits imposed by the Fund’s
fundamental investment restrictions (e.g., concentration limits);

Response:
The disclosure has been revised accordingly.

 ii. the Loan selection process, including any limits or targets on maturity and duration of individual Loans,
borrower, asset class, segment, collateral, and loan types and geographic location of the borrower;

Response:
The Fund believes the current disclosure (starting on page 18) sufficiently describes the Fund’s loan selection process. The
Fund respectfully submits that no disclosure revision is necessary in response to this comment.

 iii. the underwriting standards for the Loans;

Response:
The Fund believes the current disclosure sufficiently describes the Fund’s underwriting standards. The Fund respectfully submits
that no disclosure revision is necessary in response to this comment.

 iv. whether and to what extent the Fund expects to originate noninvestment grade or subprime loans;

 v. whether the Fund will be involved in servicing the Loans and, if so, a description of its servicing obligations;
and

 vi. whether the Fund will set up its own online lending platform to originate these Loans.

Response:
The Fund confirms that it has no current plans to be involved in servicing the loans, has no current plans to set up its own online lending
platform to originate loans and does not currently expect to originate noninvestment grade or subprime loans and, thus, no additional
disclosure was added with respect to items (iv)-(vi).

We may have further comments or questions
after reviewing your responses.

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Portfolio Composition (page 2)

 11. Comment: Please disclose the percentage of the portfolio the Adviser anticipates investing in each
of the three “verticals”. In particular, how much of the Fund’s portfolio may be attributed to direct Loans? Please
also briefly explain how the Fund evaluates investments to achieve its objective and the portfolio construction parameters it uses to
construct the portfolio as a whole.

Response:
While the Fund expects to invest in all three verticals, the amount invested in each may vary from time to time based on the Adviser’s
view of the best investment opportunities for the Fund and intends to have a dynamic allocation process between the three verticals which
will change over time. Because of the dynamic nature of the portfolio, the Fund declines to include estimates of such amounts in the Prospectus
and notes that such disclosure is not required.

 12. Comment: In the penultimate bullet on page 2, the disclosure describes the Fund’s investments
in tradeable instruments as being “aligned to the broader specialty credit and asset-based finance strategy of the Fund….”
Please clarify this disclosure.

Response:
The disclosure has been revised accordingly.

Valuations (page 8)

 13. Comment: In the first line of this section, the disclosure states that the “Board has designated
the Adviser as the Fund’s valuation designee” and that “[t]he Adviser is responsible for the valuation of the Fund’s
portfolio investments for which market quotations are not readily available.” Please disclose the Adviser’s conflic