SecProbe.io

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    Dechert LLP

    1900 K Street, N.W.

    Washington, DC   20006-1110

    +1 202 261 3300  Main

    +1 202 261 3333  Fax

    William Bielefeld

    Partner

william.bielefeld@dechert.com

    +1 202 261 3386  Direct

    +1 202 261 3333  Fax

September 26, 2025

Lisa N. Larkin

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549-0504

    Re:
    Stone Point Credit Income Fund - Select

    Registration Statement on Form 10

    File No. 000-56766

Dear Ms. Larkin:

On behalf of Stone Point Credit Income Fund -
Select (the “Fund”), a closed-end management investment company that has elected to be treated as a business development
company (“BDC”), we are writing in response to comments provided on August 27, 2025 with respect to the registration
statement on Form 10 filed by the Fund with the Securities and Exchange Commission (“SEC”) on July 30, 2025 (the “Registration
Statement”). Changes to the Registration Statement noted below will be reflected in a subsequent submission of the Registration
Statement.

For your convenience, the Staff’s comments
are included in this letter, and each comment is followed by the response of the Fund. Capitalized terms used in this letter and not otherwise
defined herein shall have the meanings specified in the Registration Statement.

Legal Comments

Page i – Explanatory Note

 1. Comment: In the second bullet-pointed section, please add the following:

 · Investment in the Fund is suitable only for sophisticated investors and requires the financial ability
and willingness to accept the high risks and lack of liquidity inherent in an investment in the Fund.

Response.
The Fund respectfully acknowledges the Staff’s comment and has revised the relevant disclosure accordingly.

    Division of Investment Management

    September 26, 2025

    Page 2

Page iii – Summary Risk Factors

 2. Comment: We note the statement that “Employees of the Adviser may serve as directors
of some portfolio companies and, as such, may have duties to persons other than the Fund, including other shareholders of such portfolio
companies.” Please tell us more about the types of investments contemplated by this disclosure, including any special policies and
procedures in place to manage conflicts and prevent overreach. Please also consider enhancing the related risk factor to address the potential
negative impact board representation could have on your position as a creditor in a bankruptcy, workout, or similar proceeding.

Response. The Fund
respectfully acknowledges the Staff’s comment. As a BDC and in accordance with the 1940 Act, the Fund makes available to its portfolio
companies significant managerial assistance, including utilizing appropriate personnel of the Adviser to, among other things, monitor
the operations of the Fund’s portfolio companies, participate in board and management meetings, consult with and advise officers
of portfolio companies and provide other organizational and financial consultation. The Fund and the Adviser have each adopted a written
code of ethics pursuant to Rule 17j-1 under the 1940 Act and Rule 204A-1 under the Advisers Act, respectively, that contain provisions
reasonably necessary to prevent its Access Persons and Advisory Persons (as defined therein) from engaging in any conduct prohibited by
applicable law, including Rule 17j-1(b) under the 1940 Act. In addition, the Fund has adopted a code of business conduct and ethics pursuant
to the Sarbanes-Oxley Act applicable to its senior executive and financial officers to establish policies, guidelines and procedures that
promote ethical practices and conduct. Such codes of ethics generally require persons subject to the codes to discuss and report any actual
or potential conflicts of interests, including but not limited to the Fund’s portfolio companies and related corporate opportunities,
with the Fund’s Chief Compliance Officer and the Board. The Fund has revised the Registration Statement to include enhanced risk
disclosure as requested.

Page 1 – The Fund; Investment Objective
and Strategy

 3. Comment: The Fund’s 80% policy refers to “other credit instruments.” Please
tell us what the “other” credit instruments are. Please also revise to clarify such investments so that an investor understands
which instruments are included in the Fund’s strategy.

Response.
The Fund supplementally confirms to the Staff that in “Item 1. Business – “The Fund; Investment Objective and Strategy”
the Fund, in the paragraph immediately following the paragraph with the 80% Policy, that “…the Adviser believes that the
Fund’s investment objective can be achieved by primarily investing in senior secured loans, including first lien, second lien and
unitranche loans, or unsecured loans and, to a lesser extent, subordinated loans, mezzanine loans, notes, senior secured bonds, unsecured
bonds and equity-related securities including warrants, preferred stock and similar forms of senior equity, which may or may not be convertible
into common equity.” The Fund has clarified the relevant disclosure accordingly.

    Division of Investment Management

    September 26, 2025

    Page 3

Page 2 – The Fund; Investment Objective
and Strategy

 4. Comment: In the second paragraph, disclosure refers to “other similar private credit
transactions.” Please specify what the “other” transactions may be.

Response.
The Fund respectfully acknowledges the Staff’s comment and has revised the relevant disclosure accordingly.

 5. Comment: Please revise to explain how the Adviser makes investment decisions and intends
to construct the portfolio.

Response.
The Fund respectfully acknowledges the Staff’s comment and directs the Staff to disclosure in Item 1. Business – “The
Fund; Investment Objective and Strategy” of the Registration Statement that provides that the Adviser will construct and manage
the Fund’s portfolio in accordance with the 80% Policy, that the Fund generally expects to invest in middle market companies with
EBITDA between $30 million and $250 million annually, the targeted maturities of the Fund’s investments, and the Fund’s non-fundamental
policy to invest, under normal market conditions, at least 75% of the value of its total assets (measured at the time of each such investment)
in investments that are in the financial services, business services, software and technology or healthcare services sectors, as defined
and determined by the Adviser. The Fund has revised the relevant disclosure to include a cross-reference to Item 1. Business –
 “Market Opportunity and Competitive Advantages” for more information on the Adviser’s investment process.

 6. Comment: In the fourth paragraph, disclosure states that the Fund may enter into one or
more warehousing transactions.

 A. Please tell us whether any of the entities involved in a warehousing transaction may be affiliated with
the Fund or the Adviser. See section 2(a)(3) of the 1940 Act. To the extent there is any affiliation, please provide an analysis of whether
any of the warehousing transactions between the Fund and other entities may constitute a joint enterprise or other joint arrangement within
the meaning of rule 17d-1 under the 1940 Act.

Response.
The Fund respectfully acknowledges the Staff’s comment and supplementally advises the Staff that neither the Fund, the Adviser,
nor any of their affiliates have entered into nor do they currently propose to enter into any transaction meeting the description set
forth above.

 B. Please tell us whether affiliates of the Fund or Adviser may enter into any agreements, including back-stop
style agreements, with any entities involved in warehousing transactions.

    Division of Investment Management

    September 26, 2025

    Page 4

Response.
The Fund respectfully acknowledges the Staff’s comment and supplementally advises the Staff that neither the Fund, the Adviser,
nor any of their affiliates have entered into nor do they currently propose to enter into any transaction meeting the description set
forth above.

 C. Please tell us whether any affiliates of the Fund will co-invest alongside the warehouse vehicle and,
if so, whether the Fund intends to rely on its co-investment exemptive order to engage in warehousing transactions. If so, provide the
legal basis for such reliance.

Response.
The Fund respectfully acknowledges the Staff’s comment and confirms that it does not intend to rely on the exemptive relief granted
by the SEC to certain affiliates of the Fund on June 14, 2022, with respect to any warehousing transactions.

 D. Please provide a legal analysis of whether or not the warehousing transactions may constitute “unfunded
commitment agreements” as defined in rule 18f-4 under the 1940 Act.

Response.
The Fund respectfully acknowledges the Staff’s comment and supplementally advises the Staff that it does not expect that any warehousing
transaction would fall within the definition of “unfunded commitment agreements” as defined in Rule 18f-4 under the 1940 Act.

 E. Please clarify who selects investments to be deposited into a warehouse and the parties and general terms
of any contemplated warehouse transaction.

Response.
The Fund undertakes to disclose in its Exchange Act reports the material terms of any warehouse transaction meeting the description set
forth above.

Page 3 – The Adviser

 7. Comment: In the second paragraph, disclosure refers to a resource sharing agreement between
Stone Point Capital and the Adviser. If the Adviser uses investment professionals employed by any affiliate of the Fund or Adviser to
manage the Fund under a resource sharing arrangement with the Adviser, please describe to us the following:

 A. The specific services any affiliate of the Fund or Adviser and such affiliate’s employees will provide
on the Adviser’s behalf and why those services do not amount to investment advisory services provided to the Fund;

 B. The extent to which the Adviser will depend on such affiliate’s personnel in providing investment
advisory services;

    Division of Investment Management

    September 26, 2025

    Page 5

 C. Whether personnel of such affiliate who provide investment advice with respect to the Fund will be supervised
persons of the Adviser under section 202(a)(25) of the Investment Advisers Act of 1940;

 D. Whether and what fees are paid to such affiliate for the described services and whether or not they are
paid pursuant to a personnel or resource sharing agreement;

 E. Whether such affiliate is considered to be a fiduciary with respect to the Fund in connection with providing
the described services;

 F. By whom the personnel being provided for use by the Adviser for advisory services to the Fund are employed
and how such employer is affiliated with the Adviser and the Fund (i.e., a controlled subsidiary, wholly or majority owned subsidiary);
and

 G. The registration status of such affiliate and where such affiliate is domiciled.

Response. The Fund
submits that in connection with its obligations to the Fund under the Investment Advisory Agreement, the Adviser has entered into a Resource
Sharing Agreement with Stone Point Capital LLC, a limited liability company organized under the laws of the state of Delaware that is
registered with the SEC as an investment adviser under the Advisers Act (“Stone Point Capital”) that is under common
control with the Adviser, and pursuant to which Stone Point Capital will make the investment professionals on the Stone Point Credit Investment
Team available to the Adviser for purposes of originating and identifying investment opportunities, conducting research and due diligence
on prospective investments, analyzing and underwriting investment opportunities, structuring investments and monitoring and servicing
the Fund’s investments in accordance with the services provided by the Adviser under the Investment Advisory Agreement (“Credit
Activities”). On an as needed basis, certain other investment professionals on the Stone Point Capital Private Equity Investment
Team will contribute a portion of their time, effort and knowledge to support Credit Activities. The Fund respectfully advises the Staff
that the Resource Sharing Agreement does not constitute an advisory agreement under the 1940 Act and that there are no advisory services
being furnished to the Fund through Stone Point Capital itself, but rather solely through shared employees subject to the supervision
and oversight of the Adviser and its officers. The Fund also respectfully advises the Staff that the Adviser maintains its own separate
investment personnel, who are shared employees of Stone Point Capital solely for human resources and administrative purposes but do not
provide services to Stone Point Capital, and that the Adviser pursues a materially distinct strategy from Stone Point Capital. The Fund
notes that Stone Point Capital does not provide any services directly to the Fund. The Fund respectfully advises the Staff, on a supplemental
basis, that all personnel who will provide investment advice with respect to the Fund will be supervised persons of the Adviser under
Section 202(a)(25) under the Advisers Act; that the Fund pays no fees to Stone Point Capital; and that Stone Point Capital is not considered
a fiduciary with respect to the Fund.

    Division of Investment Management

    September 26, 2025

    Page 6

 8. Comment: Please explain to us if the Fund or Adviser are relying on any no-action relief
with respect to any resource sharing arrangement between the Fund, the Adviser, and Stone Point Capital.

Response.
The Fund supplementally confirms to the Staff that neither the Fund nor the Adviser are relying on any no-action relief with respect to
any resource sharing arrangement between the Fund, the Adviser, and Stone Point Capital.

 9. Comment: Please provide a copy of any agreement reflecting the resource sharing arrangement.

Response.
The Fund respectfully acknowledges the Staff’s comment and has supplementally provided the Staff with a copy of the Resource Sharing
Agreement.

Page 4 – The Private Offering

 10. Comment: Disclosure states that the Fund intends to enter into separate subscription agreements
relating to its shares. Please explain:

 A. What you mean by “separate.” Please tell us whether the material terms of each agreement will
be identical.

 B. How having subscription agreements with separate terms would comply with section 18 under the 1940 Act
(e.g., could it result in an investor having priority over any other investor as to distribution of assets or payment of dividends);

 C. Whether separate terms in any subscription agreements could have a material, negative effect on other
Fund investors;

 D. Whether the terms of separate subscription agreements will be disclosed to all Fund investors, and how
they will be disclosed including the timing of such disclosure;

 E. Whether the terms of these subscription agreements include preferential redemption or withdrawal rights,
or about portfolio holdings or exposures; and

 F. Whether the terms of these subscription agreements have a direct or indirect effect on the management
fee attributable to the applicable shareholders with whom such agreements are made.

    Division of Investment Management

    September 26, 2025

    Page 7

Response.
The Fund respectfully acknowledges the Staff’s comment and supplementally confirms that it will not enter into subscription agreements
that differ in ways that would result in any investor having priority over other investors as to the distribution of assets or payment
of dividends in violation of Section 18 of the 1940 Act, and has revised the relevant disclosure to remove “separate” when
describing subscription agreements that the Fund enters into with other investors. Similarly, the Fund will not enter into subscription
agreements that have a material, negative effect on ot