SecProbe.io

CORRESP
 1
 filename1.htm

 1900 K Street, NW
 Washington, DC 20006-1110
 +1 202 261 3300 Main
 +1 202 261 3333 Fax
 www.dechert.com

 Alexander
 C. Karampatsos

 alexander.karampatsos@dechert.com

 May 8, 2025
 +1 202 261 3402 Direct

 VIA EDGAR

 Brian Szilagyi
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review and Accounting
100 F Street, NE
Washington, DC 20549

 Re: Eagle Point Credit Company Inc. (811-22974) (the "Registrant")

 Dear Mr. Szilagyi:

 This letter responds to comments you provided
telephonically to Alexander C. Karampatsos and Antonio G. Fraone of Dechert LLP on Thursday, April 10, 2025, with respect to your
review pursuant to the Sarbanes-Oxley Act of 2002 of the report filed on Form N-CSR and other filings for the Registrant, relating
to the fiscal year ended December 31, 2024. Unless explicitly provided, we understand that your comments are intended to apply to
disclosure in the Registrant's future filings. We have reproduced your comments below, followed by the Registrant's responses.
Capitalized terms used in this letter and not otherwise defined herein shall have the meanings specified in the report filed on Form N-CSR.

 1. Comment :      The Staff reminds
you that the Registrant and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review,
comments, action or absence of action by the Staff.

 Response :        The
Registrant acknowledges this comment.

 2. Comment :       For closed-end
funds, the average annual total returns for the one-, five-, and ten-year periods should be presented in the Management's Discussion
of Fund Performance section pursuant to Instruction 4(g)(2)(B) to Item 24 of Form N-2. The average annual total return for the
ten-year period ending December 31, 2024 was not presented in the Registrant's annual report. Please include this disclosure
in future annual reports.

 Response :       The Registrant confirms that this disclosure will be updated in future filings.

 May 8, 2025
 Page 2

 3. Comment :      The title of
the individuals signing the certifications contained in Form N-CSR does not specifically include the title of principal executive
officer or principal financial officer. Please confirm in correspondence that the individuals who sign the certifications provided with
the filings on Form N-CSR are the principal executive officer and principal financial officer. Additionally, and going forward, please
confirm that the Registrant will include such titles in the certifications.

 Response :  
 The Registrant confirms that Thomas P. Majewski and Kenneth P. Onorio serve as principal executive
officer and principal financial officer of the Registrant, respectively, and these titles will be reflected in future filings.

 4. Comment :      It
appears that more than 25% of the value of the Fund's total assets is invested in the securities of one issuer. Please describe
the process the Fund uses to determine if the Fund is in compliance with IRS diversification rules regarding qualifications as a
regulated investment company for tax purposes ( See IRC Section 851(b)(3)(B)). Please also confirm whether the Fund is in
compliance with such rules as of the Fund's taxable year ended November 30, 2024.

 Response:  
 Eagle Point Credit Company Sub (Cayman) Ltd. ("the subsidiary") is a disregarded entity
for U.S. tax purposes. For tax diversification testing, the underlying assets of the subsidiary are tested by issuer rather than the
subsidiary itself as a single issuer. As a result, no more than 25% of the value of the Fund's total assets is invested in the
securities of one issuer. The Fund confirms it is in compliance with such rules as of the Fund's taxable year ended November 30,
2024.

 *                      *                      *

 Please do not hesitate to contact the undersigned
at (202) 261-3402 with any questions or comments concerning this correspondence.

 Sincerely,

 /s/ Alexander C. Karampatsos

 Alexander C. Karampatsos

 cc: Nauman S. Malik, Eagle Point Credit Management LLC
 Joshua M. Katz, Eagle Point Credit Management LLC

 Brooke A. Clark, Eagle Point Credit Management LLC

 Philip T. Hinkle, Dechert LLP

 Antonio G. Fraone, Dechert LLP

CORRESP
1
filename1.htm

    1900 K Street, NW

                                                            Washington, DC 20006-1110

    +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

April 23, 2024

VIA
EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Laura J. Riegel

Re: Eagle Point Credit Company Inc., et al.

File Number: 812-15512

Dear Ms. Riegel:

We are writing in response to your written comments
with respect to an application pursuant to Sections 17(d) and 57(i) of the Investment Company Act of 1940 (the “Act”)
and Rule 17d-1 under the Act permitting certain joint transactions otherwise prohibited by sections 17(d) and 57(a)(4) and
Rule 17d-1, thereunder (the “Application”) filed with the Securities and Exchange Commission (the “SEC”)
on October 10, 2023 on behalf of Eagle Point Credit Company Inc., Eagle Point Income Company Inc., Eagle Point Institutional Income
Fund, Eagle Point Credit Management LLC, Eagle Point Income Management LLC and other applicants named in the Application (collectively,
the “Applicants”). The Applicants have considered your comments and authorized us, on their behalves, to make the
responses and changes discussed below to the Application.

On
behalf of the Applicants, set forth below are the SEC staff’s comments along with our responses to or any supplemental explanations
of such comments, as requested. Capitalized terms have the same meaning as in the Application unless otherwise indicated.

 1. Please insert the full file number
                                            throughout the Application, where appropriate.

Response:

The disclosure has been revised accordingly.

    Laura J. Riegel

    April 23, 2024

    Page 2

 2. On the cover page of the Application,
                                            please insert “FIRST AMENDED AND RESTATED” before “APPLICATION”.

Response:

The disclosure has been revised accordingly.

 3. To
                                            the extent the Commission issues a notice of the filing of this Application giving interested
                                            persons an opportunity to request a hearing on the matter, if the Applicants would like to
                                            receive any hearing requests by e-mail, please provide email address(es) for the Applicants.
                                            Such e-mail address(es) will be included in any notice issued of this Application. See Division
                                            of Investment Management Staff Statement on Hearing Requests on Applications Filed Under
                                            the Investment Company Act of 1940 and the Investment Advisers Act of 1940, IM-INFO-2020-03
                                            (Apr. 2020), https://www.sec.gov/files/im-info-2020-03.pdf.

Response:

The Applicants respectfully decline to consent
to receive any hearing requests by e-mail.

 4. On
                                            page 1 of the Application, please revise the parenthetical from (“EPIIF”)
                                            to (“EPIIF” and together with ECC and EIC, the “Existing Regulated Funds”).

Response:

The disclosure has been revised accordingly.

 5. Please supplementally explain why
                                            the application names ECC Sub Cayman, ECC Sub II Cayman, ECC Sub II, EIC Sub Cayman, EIC
                                            Sub, EPIIF Sub Cayman, and EPIIF Sub II Cayman as Applicants. If appropriate, please name
                                            and discuss these entities as Applicants in Section II of the Application and clarify
                                            whether each is a Wholly-Owned Investment Sub of the applicable Existing Regulated Fund.

Response:

The Applicants note that each such entity is
a Wholly-Owned Investment Sub of ECC, EIC, and EPIIF, each an Existing Regulated Fund, and each is listed as an Applicant because it
is expected that it may be appropriate for such a Wholly-Owned Investment Sub to participate in Co-Investment Transactions in lieu of
the applicable parent Regulated Fund that owns it (e.g., for tax structuring reasons). The Applicants have added reference to such entities
in Section II.

    Laura J. Riegel

    April 23, 2024

    Page 3

 6. On page 2 of the Application,
                                            please delete “the” before “ECC” in the following sentence: “Eagle
                                            Point Credit Management LLC (“EPCM”), a Delaware limited liability company that
                                            serves as the investment adviser to the ECC, EPIIF and certain of the Existing Affiliated
                                            Funds (as defined below), on behalf of itself and its successors.”

Response:

The disclosure has been revised accordingly.

 7. On page 2 of the Application,
                                            please insert a footnote after the term “successors” that reads “The term
                                            ‘successor,’ as applied to each Adviser means an entity which results from reorganization
                                            into another jurisdiction or change in the type of business structure.”

Response:

The disclosure has been revised accordingly.

 8. On
                                            page 2 of the Application, please revise the parenthetical from “(‘EPIM’)”
                                            to “(‘EPIM’ and together with EPCM, the ‘Existing Advisers’).”

Response:

The disclosure has been revised accordingly.

 9. On page 2 of the Application,
                                            please delete “the” before “EIC” in the following sentence: “Eagle
                                            Point Income Management LLC (“EPIM”), a Delaware limited liability company that
                                            serves as the investment adviser to the EIC on behalf of itself and its successors.”

Response:

The disclosure has been revised accordingly.

    Laura J. Riegel

    April 23, 2024

    Page 4

 10. On page 2 of the Application,
                                            please delete “and their affiliates” from the following sentence: “The
                                            accounts identified in Schedule B hereto that the Advisers and their affiliates use to hold
                                            various financial assets in a principal capacity (together, “Existing Proprietary Accounts”).”

Response:

The disclosure has been revised accordingly.

 11. On
                                            page 2 of the Application, please revise the parenthetical from “(together, ‘Existing
                                            Proprietary Accounts’)” to “(together, ‘Existing Proprietary Accounts’
                                            and together with any Future Proprietary Accounts (as defined below), the Proprietary Accounts
                                            (as defined below)).”

Response:

The disclosure has been revised accordingly.

 12. On page 2 of the Application,
                                            please replace “EPCM, EPIM” with “the Existing Advisers” in the definition
                                            of “Adviser.”

Response:

The disclosure has been revised accordingly.

 13. On page 3 of the Application,
                                            please revert to the precedent on which the Application is modeled (KKR Real Estate Select
                                            Trust, et al., File No. 812-15181, “KKR Application”), deleting “applicable”
                                            before “Regulated Fund” in the definition of “Board.”

Response:

The disclosure has been revised accordingly.

 14. On page 4 of the Application,
                                            please replace “any of the Advisers” with “an Existing Adviser” in
                                            the definition of “Future Adviser.”

Response:

The disclosure has been revised accordingly.

    Laura J. Riegel

    April 23, 2024

    Page 5

 15. On
                                            page 4 of the Application, please delete the “and that controls, is controlled
                                            by, or is under common control with, any of the Advisers” from the following portion
                                            of the definition of “Future Advisers”: “(b) is a relying adviser
                                            of an investment adviser that is registered under the Advisers Act and that controls, is
                                            controlled by, or is under common control with, any of the Advisers. . .”

Response:

The disclosure has been revised accordingly.

 16. On
                                            page 4 of the Application, please revert to the KKR Application, deleting “Form 10
                                            or” from the definition of “Objectives and Strategies.”

Response:

The Applicants respectfully acknowledge the SEC
staff’s comment and note that reference to Form 10 is included in the Application in the event that a private business development
company is formed and required to register with the SEC. The Applicants also respectfully note that the inclusion of Form 10 in
the Application is consistent with the application for Fidelity Private Credit Fund., et al., which is cited in the footnote 24 of the
Application.

 17. On
                                            page 5 of the Application, please replace “ECC, EIC, EPIIF” with “the
                                            Existing Regulated Funds” in the definition of “Regulated Funds.”

Response:

The disclosure has been revised accordingly.

 18. On page 6 of the Application,
                                            please insert “Existing” before “Regulated” in the heading to Section II.A
                                            of the Application.

Response:

The disclosure has been revised accordingly.

 19. On page 6 of the Application,
                                            please delete the second, third, fourth and fifth sentences of the first paragraph of Section II.A
                                            of the Application. They provide historical information on ECC which obscures necessary representations.

Response:

The disclosure has been revised accordingly.

    Laura J. Riegel

    April 23, 2024

    Page 6

 20. On page 6 of the Application,
                                            please delete the second, third, fourth and fifth sentences of the second paragraph of Section II.A
                                            of the Application. They provide historical information on EIC which obscures necessary representations.

Response:

The disclosure has been revised accordingly.

 21. On page 6 of the Application,
                                            please delete the following language from the third paragraph of Section II. A: “EPIIF
                                            commenced operations on June 1, 2022 and is offering its shares of beneficial interest
                                            on a continuous basis at the applicable period end net asset value per share plus any applicable
                                            sales loads and”. It provides historical information on EPIIF which obscures necessary
                                            representations.

Response:

The disclosure has been revised accordingly.

 22. Please supplementally cite to precedent,
                                            if any, where an investment company applicant operated as a tender offer fund, and include
                                            that citation in Section III.D. of the Application, if it is not currently cited. Otherwise,
                                            please supplementally address how EPIIF’s operation as a tender offer fund would affect
                                            its complying with and/or other Applicants complying with the terms and conditions of the
                                            Application.

Response:

The Applicants respectfully note that KKR Real
Estate Select Trust Inc. is operated as a tender offer fund (among other applicants over time). The order issued to KKR Real Estate Select
Trust Inc. is cited in Section III.D (the “KKR Order”). Similar to the application for the KKR Order, the Applicants
have removed reference to the operations of EPIIF as operating as a tender offer fund.

    Laura J. Riegel

    April 23, 2024

    Page 7

 23. Please supplementally provide a
                                            structure chart of various business groups that clearly shows all ownership and advisory
                                            relationships between legal entities in the corporate family; please supplementally explain
                                            how the various investment advisers operate within their business groups. The SEC staff reserves
                                            additional comments on Section II.C of the Application pending its review of the structure
                                            chart.

Response:

Please see structure chart attached as Exhibit I
to this letter. Each of the Existing Advisers other than EPCM is party to a personnel and resources agreement, whereby EPCM makes available
personnel and resources, including portfolio managers and investment personnel, to such other Existing Adviser as it may determine to
be reasonably necessary to the conduct of its operations.

 24. On page 7 of the Application,
                                            please revert to the KKR Application, replacing “pursuant to Section 203 of the
                                            Advisers Act” with “under the Advisers Act” in the first sentence of each
                                            of the first and second paragraphs in Section II.C.

Response:

The disclosure has been revised accordingly.

 25. Please supplementally confirm that
                                            any Existing Proprietary Account that currently intends to rely on any Order that may be
                                            granted has been named as an Applicant and that the Application contains a description of
                                            all such Applicants, including in such description whether each such Applicant is an Adviser.
                                            With respect to any Existing Proprietary Account that is not an Adviser, whether existing
                                            now or in the future, please explain supplementally how the Adviser will ensure compliance
                                            by each such entity with the conditions of the Application.

Response:

The
Applicants hereby confirm that any Existing Proprietary Account that currently intends to rely on any Order that may be granted has been
named as an Applicant and that the Application contains a description of all such Applicants. The Applicants also confirm that none of
the Advisers is an Existing Proprietary Account. Any Existing Proprietary Account will be subject to oversight by an Adviser.
As a result, an Adviser will ensure compliance by each Existing Proprietary Account with the conditions of the Application in the same
manner in which the Adviser will ensure compliance by each Affiliated Fund.

    Laura J. Riegel

    April 23, 2024

    Page 8

 26. Please update Schedule B to add

CORRESP
1
filename1.htm

    1900 K Street, NW

    Washington, DC 20006-1110

    +1 202 261 3300 Main

    +1 202 261 3333 Fax

    www.dechert.com

Alexander C. Karampatsos

    alexander.karampatsos@dechert.com

    +1 202 261 3402 Direct

    +1 617 275 8365 Fax

January 8, 2024

VIA
EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Christopher R. Bellacicco

 Re: Eagle Point Credit Company Inc.

Preliminary Proxy Statement

File Number: 811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company Inc.,
a Delaware corporation (the “Company”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in a telephonic conversation on January 8, 2024
between Christopher R. Bellacicco of the Staff and Alexander Karampatsos and Claire Hinshaw of Dechert LLP, relating to the Company’s
preliminary proxy statement on Schedule 14A filed with the Commission on December 22, 2023 (the “Proxy Statement”)
and the Company’s responses to comments raised by the Staff on January 3, 2024, filed with the Commission on January 4,
2024.

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

 1. Please identify in the Proxy Card whether the matter to be voted on was proposed by the Company or
by security holders as required by subsection (a)(3) of Rule 14a-4 under the Securities Exchange Act of 1934.

Response:
The Company respectfully declines to make any changes in response to the Staff’s comment. The Company notes that the
Proxy Statement states that the proposal was proposed by the Company and further notes that the Proxy Card states the proxy is solicited
on behalf of the Company’s Board of Directors. The Company notes that it will undertake to add the requested language to future
proxy cards.

    Christopher R. Bellacicco
 January 8, 2024
 Page 2

 2. Please explain why there are two separate Proxy Cards for the holders of the Company’s preferred
stock.

Response:
The Company notes that there is a separate Proxy Card for each of the Company’s 6.50% Series C Term Preferred Stock
due 2031 and 6.75% Series D Preferred Stock.

* * * * * * * * *

If you have any questions, please feel free to
contact the undersigned by telephone at 202.261.3402 or by email at alexander.karampatsos@dechert.com. Thank you for your cooperation
and attention to this matter.

Sincerely,

/s/ Alexander C. Karampatsos

Alexander C. Karampatsos

 cc: Thomas P. Majewski, Chief Executive Officer, Eagle Point Credit
Company Inc.

Nauman S. Malik, Chief Compliance
Officer, Eagle Point Credit Company Inc.

Philip T. Hinkle, Dechert
LLP

CORRESP
1
filename1.htm

    1900 K Street, NW

    Washington, DC 20006-1110

    +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 26, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Lisa Larkin and Megan Miller

 Re: Eagle Point Credit Company Inc.

Registration Statement on
Form N-2

File Numbers: 333-269139 and
811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company Inc.,
a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in telephonic conversations on January 25, 2023 between
Megan Miller of the Staff and Alexander Karampatsos and Kathleen Hyer of Dechert LLP and on February 1, 2023 between Lisa Larkin of the
Staff and Alexander Karampatsos and Kathleen Hyer of Dechert LLP, relating to the Fund’s registration statement on Form N-2 filed
with the Commission on January 6, 2023 (the “Registration Statement”).

For your convenience, the Staff’s comments
are summarized in this letter, and each comment is followed by the applicable response. Concurrently with this letter, the Fund is filing
Pre-Effective Amendment No. 1 to the Registration Statement (“Pre-Effective Amendment No. 1”), which reflects the responses
below.

Capitalized terms used in this letter and not
otherwise defined herein shall have the meanings specified in the Registration Statement.

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
2

Registration Statement Comments –
Lisa Larkin

 1. Please confirm that acquired fund fees and expenses do not need to be included in the Fund’s
fee and expense table as a result of the Fund’s investments in “securities of other investment companies, including closed-end
funds, BDCs, mutual funds, and ETFs”.

Response:

The Fund confirms that acquired fund fees and
expenses do not need to be included in the Fund’s fee and expense table pursuant to General Instruction 10 to Item 3 of Form N-2.

 2. Please supplementally explain what is meant by “joint venture vehicle,” as used in the
Registration Statement, and whether any exemptive relief is required.

Response:

Supplementally, the Fund notes that “joint
venture vehicle,” as used in the Registration Statement, was intended to refer to Double Eagle Holdings JV LLC, an unconsolidated
Delaware limited liability company (“Double Eagle JV”). Double Eagle JV was established to enable the Fund to invest
alongside an unaffiliated third-party in securities that are consistent with the Fund’s investment objective and strategies. The
Fund has not made any investments through Double Eagle JV to date and no longer intends to do so in the future. Accordingly, the Fund
intends to dissolve Double Eagle JV and the relevant disclosure has been removed from the Registration Statement. Supplementally, the
Fund notes that it had concluded that exemptive relief would not be required for transactions between the Fund and Double Eagle JV pursuant
to Rule 17a-6 and Rule 17d-1(d)(5) under the Investment Company Act of 1940, as amended (the “1940 Act”).

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
3

 3. Please supplementally describe the nature of the fee rebates received from collateralized loan obligation
(“CLO”) issuers, including the amounts of the fee rebates and the reasons why the fee rebates were issued. Please also
supplementally confirm whether these fee rebates, including their terms, are disclosed to other CLO investors.

Response:

The Fund has revised its disclosure regarding
the principal investments that it makes to remove specific references to “fee rebates” as such investments comprise a non-material
portion of the Fund’s investment portfolio and are expected to be non-material in the future. The Fund also notes that a brief description
of instruments, which can be colloquially referred to as “fee rebates,” is elsewhere included in the Registration Statement
under the caption “Additional Investments and Techniques – Class M Notes, Fee Notes and Participation Agreements,” which
section of the Registration Statement the Fund believes is appropriate given the overall composition of the Fund’s investment portfolio.
Notwithstanding the revision to the Registration Statement, and in response to the Staff’s request, the Fund supplementally notes
that “fee rebates,” which may take various forms and have differing terms, typically function as a waiver or reduction of
the underlying collateral management fees borne by a primary market investor in the subordinated notes issued by a CLO. The amounts of
these waivers or reductions differ based on the negotiated arrangement with the applicable CLO and depend on the relevant facts and circumstances;
for example, a CLO issuer may find it appropriate to offer reduced collateral management fees in order to price and close a primary CLO
transaction in an otherwise challenging market environment for new CLO issuance. In general, it is market practice in the CLO market for
a CLO issuer to disclose in its offering memorandum the fact that certain investors are or may be party to an arrangement with the CLO
issuer or collateral manager pursuant to which the terms of their investment vary from those applicable to other investors; however, market
practice varies as to the specificity of such disclosure. To the extent that the Fund invests alongside other funds and accounts managed
by Eagle Point Credit Management LLC or an affiliate, such fee waivers or reductions would be allocated pro rata among the investing
accounts in accordance with the Fund’s co-investment exemptive order.

 4. Please supplementally explain whether the synthetic investments referenced in the Registration Statement
are derivatives transactions under Rule 18f-4 under the 1940 Act.

Response:

The synthetic investments referenced in the description
of the Fund’s investment strategies (such as significant risk transfer securities and credit risk transfer securities issued by
banks or other financial institutions) are not derivatives under Rule 18f-4 under the 1940 Act because they do not create any future payment
or delivery obligations for the Fund.

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
4

 5. Please delete the following language in the “Names Rule” Policy section of the Registration
Statement as this language is repetitive of the preceding disclosure: “This policy is not a fundamental policy of ours and may be
changed our board of directors without prior approval of our stockholders.”

Response:

The Fund has updated the “Names Rule”
Policy section of the Registration Statement in accordance with this comment.

 6. Please consider adding Synthetic Investments Risk to the Summary Risk Factors and Risk Factors sections
of the Registration Statement or explain why such addition is not necessary.

Response:

The Fund has added the following disclosure to
the Summary Risk Factors and Risk Factors sections of the Registration Statement:

“Synthetic Investments Risk. We
may invest in synthetic investments, such as significant risk transfer securities and credit risk transfer securities issued by banks
or other financial institutions, or acquire interests in lease agreements that have the general characteristics of loans and are treated
as loans for withholding tax purposes. In addition to the credit risks associated with the applicable reference assets, we will usually
have a contractual relationship only with the counterparty of such synthetic investment, and not with the reference obligor of the reference
asset. Accordingly, we generally will have no right to directly enforce compliance by the reference obligor with the terms of the reference
asset nor will it have any rights of setoff against the reference obligor or rights with respect to the reference asset. We will not directly
benefit from the collateral supporting the reference asset and will not have the benefit of the remedies that would normally be available
to a holder of such reference asset. In addition, in the event of the insolvency of the counterparty, we may be treated as a general creditor
of such counterparty, and will not have any claim with respect to the reference asset.

Our synthetic strategy involves
certain additional risks.

We may invest in synthetic
investments, such as significant risk transfer securities and credit risk transfer securities issued by banks or other financial
institutions, or acquire interests in lease agreements that have the general characteristics of loans and are treated as loans for
withholding tax purposes. In addition to the credit risks associated with the applicable reference assets, we will usually have a
contractual relationship only with the counterparty of such synthetic investment, and not with the reference obligor of the
reference asset. Accordingly, we generally will have no right to directly enforce compliance by the reference obligor with the terms
of the reference asset nor will it have any rights of setoff against the reference obligor or rights with respect to the reference
asset. We will not directly benefit from the collateral supporting the reference asset and will not have the benefit of the remedies
that would normally be available to a holder of such reference asset. In addition, in the event of the insolvency of the
counterparty, we may be treated as a general creditor of such counterparty, and will not have any claim with respect to the
reference asset.”

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
5

 7. Please explain the purpose of the Additional Investments and Techniques section of the Registration
Statement. Please also confirm whether Loan Accumulation Facilities should be included in this section.

Response:

The purpose of the Additional Investments and
Techniques section of the Registration Statement is to disclose certain Fund investment strategies and instruments that are generally
expected to involve a non-material portion of the Fund’s assets (i.e., “secondary investment strategies”). The
Fund has revised the Registration Statement to more clearly distinguish these secondary investments strategies from the Fund’s primary
investment strategies, which are described on the cover page and in the summary section of the Fund’s prospectus.

 8. Please supplementally explain whether the Fund has any unresolved Staff comments. If none, please consider
including a statement to that effect in the Incorporation by Reference section of the Registration Statement.

Response:

The Fund confirms that there were no unresolved
staff comments as of the date of its most recently filed annual report on Form N-CSR. The Fund has added the following disclosure to the
Incorporation by Reference section of the Registration Statement:

“Unresolved Staff
Comments: Not Applicable.”

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
6

 9. Please add language to the Incorporation
                                            by Reference section of the Registration Statement that explains that all relevant filings
                                            made between the date on which the Registration Statement was filed, and the date of the
                                            Registration Statement’s effectiveness are incorporated by reference into the Registration
                                            Statement.

Response:

The Fund has added the following disclosure to
the Incorporation by Reference section of the Registration Statement:

“All filings
filed by the Company pursuant to the Exchange Act or pursuant to Rule 30b2-1 under the 1940 Act after the date of this registration statement
and prior to effectiveness of the registration statement shall be deemed to be incorporated by reference into this prospectus.”

Accounting Comments – Megan Miller

 10. Please update the information provided in the Senior Securities section of the Registration Statement
to be as of the date of the most recent balance sheet.

Response:

The Fund has updated the information included
in the Senior Securities section of the Registration Statement through the incorporation by reference of its annual report for the fiscal
year ended December 31, 2022, which was filed on February 22, 2023 (and subsequently amended February 24, 2023).

 11. Please supplementally explain how the Fund met the requirements of General Instruction 3 to Item 4.1
of Form N-2, which requires that 10 years of financial highlights be included in the Registration Statement.

Response:

To satisfy the requirements of General Instruction
3 to Item 4.1 of Form N-2, the Fund has incorporated by reference into the Registration Statement its annual report for the fiscal year
ended December 31, 2022, which includes consolidated financial highlights for each of the years in the eight-year period then ended and
the period from October 6, 2014 (commencement of operations) to December 31, 2014.

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
7

 12. The Staff notes that the Fund classified its 6.75% Series D Preferred Stock as temporary equity in
the Consolidated Statement of Assets and Liabilities table in its annual report for the fiscal year ended December 31, 2021 (the “Annual
Report”). Please supplementally confirm that the Fees
and Expenses table includes the distributions on such temporary equity. Please see Dear CFO Letter 1997-06.

Response:

The Fund confirms that the Fees and Expenses table
includes the distributions on such temporary equity.

 13. Please consider marking that the Fees and Expenses table is unaudited in future annual reports.

Response:

The Fund confirms that it has marked the Fees
and Expenses table as unaudited in its annual report for the fiscal year ended December 31, 2022 and will do so in future annual reports.

 14. Footnote 5 to the Fees and Expenses Table in the Annual Report states that the Fund has agreed to pay
Eagle Point Credit Management LLC (the “Adviser”) as compensation under the Investment Advisory Agreement a quarterly
incentive fee equal to 20% of the Fund’s pre-incentive fee net investment income for the immediately preceding quarter, subject
to a hurdle of 2.00% of the Fund’s net asset value and a catch-up feature. In future annual reports, please consider including disclosure
that the hurdle rate is equal to 8% of the Fund’s net asset value on an annualized basis.

Response:

The Fund will add the requested disclosure for
future annual reports.

    Lisa Larkin

    Megan Miller

    May 26, 2023

    Page
8

* * * * * * * * *

If you have any questions, please feel free to
contact the undersigned by telephone at 202.261.3460 or by email at philip.hinkle@dechert.com. Thank you for your cooperation and attention
to this matter.

Sincerely,

  /s/ Philip T. Hinkle

Philip T. Hinkle

cc:          Thomas P. Majewski, Chief Executive Officer,
Eagle Point Credit Company Inc.

Nauman S. Malik, Chief Compliance
Officer, Eagle Point Credit Company Inc.

Alexander C. Karampatsos,
Dechert LLP

CORRESP
1
filename1.htm

    1900 K Street, NW

    Washington, DC 20006-1110

    +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

February 10, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Lisa Larkin and Megan Miller

 Re: Eagle Point Credit Company Inc.

Registration Statement on
Form N-2

File Numbers: 333-269139 and
811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company Inc.,
a Delaware corporation (the “Fund”), we hereby respond to four comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in telephonic conversations on January 25, 2023 between
Megan Miller of the Staff and Alexander Karampatsos and Kathleen Hyer of Dechert LLP and on February 1, 2023 between Lisa Larkin of the
Staff and Alexander Karampatsos and Kathleen Hyer of Dechert LLP, each relating to the Fund’s registration statement on Form N-2
filed with the Commission on January 6, 2023 (the “Registration Statement”). We note that the Fund will file separately
responses to certain comments not addressed herein as correspondence on the Commission’s EDGAR database.

For your convenience, the Staff’s comments
are summarized in this letter, followed by the responses (“Responses”). The Fund intends to file Pre-Effective Amendment
No. 1 to the Registration Statement (“Pre-Effective Amendment No. 1”) at a future date.

Capitalized terms used in this letter and not
otherwise defined herein shall have the meanings specified in the Registration Statement.

     Lisa Larkin
 Megan Miller
 February 10, 2023
 Page 2

 1. Please amend the Fund’s two most recent Form N-CSR filings to include a consent of the Fund’s
independent registered public accounting firm. Please supplementally confirm whether the Fund previously obtained manually signed copies
of these consents.

Response:

The Fund confirms that it has filed amendments
to its Form N-CSR filing for each of the fiscal years ended December 31, 2020 and December 31, 2021 for the sole purpose of adding the
consent of KPMG LLP, the Fund’s independent registered public accounting firm (the “Auditor”), to incorporate
by reference the Auditor’s audit report into the Fund’s existing registration statement on Form N-2 (File No. 333-237586)
(the “2020 Registration Statement”). The Fund obtained manually signed copies of the Auditor’s consents on February
10, 2023, prior to making the amended filings.

The Fund did not obtain the Auditor’s signed
consents when the Fund’s 2020 and 2021 annual reports were initially filed. As discussed further in the Response to Comment #2,
this oversight was due to a misapplication of the amended securities offering rules and disclosure requirements applicable to closed-end
funds that took effect in August 2020 (the “CEF Offering Reforms”). Notwithstanding this failure to obtain a formal
consent, consistent with the primary purpose of Rule 439 under the Securities Act, the Auditor has previously, and contemporaneously,
confirmed to the Fund that it had full knowledge of, and had no objection to, its report being used in the 2020 Registration Statement
and the Fund’s other disclosure documents. Specifically, in connection with the Fund’s “at-the-market” offering
program (“ATM Program”), the Auditor issued comfort letters in each of March 2021 and March 2022 to the Fund’s
placement agents (“Comfort Letters”) in which it explicitly acknowledged that the Fund’s annual reports on Form
N-CSR for the fiscal years ended December 31, 2020 and December 31, 2021 (which contained the Auditor’s report regarding the Fund’s
consolidated financial statements and financial highlights) were incorporated by reference into the 2020 Registration Statement. More
recently, the Auditor’s ready willingness to provide its consents for the 2020 and 2021 annual reports, which are now on file, is
further indication that the firm understands and is comfortable with how its audit reports have been used.

     Lisa Larkin
 Megan Miller
 February 10, 2023
 Page 3

 2. Please provide us with your analysis as to what impact, if any, the failure to file the consent has
had on the ability to keep the 2020 Registration Statement current. In doing so, please explain whether any offers or sales were made
pursuant to the prospectuses in the 2020 Registration Statement since the Fund filed its annual reports for 2020 and 2021 fiscal years.
Please refer to Section 10(a)(3) of the Securities Act of 1933, as amended (the “Securities Act”), as well as rules
436 and 439 thereunder.

Response:

The Fund acknowledges that, following the CEF
Offering Reforms, it was required to obtain and file an auditor’s consent because the Fund had an effective registration statement
that incorporated an auditor’s report via forward incorporation by reference. However, we believe that, when applying the new requirements
of the CEF Offering Reforms, the Fund’s inadvertent failure to obtain and file the Auditor’s consent as an exhibit to the
Fund’s Form N-CSR filings for the fiscal years ended December 31, 2020 (the “2020 Form N-CSR Filing”) and December
31, 2021 (the “2021 Form N-CSR Filing” and, together with the 2020 Form N-CSR Filing, the “Form N-CSR Filings”)
did not render the 2020 Registration Statement non-current or ineffective under Section 10(a)(3) of the Securities Act. The Fund confirms
that, during the period of February 23, 2021 through February 1, 2023 (the “Period”), the Fund offered and sold securities
under the 2020 Registration Statement.

Omitted
Consent had no Bearing on Automatic Incorporation by Reference

The 2020 Registration Statement remained “current”
during the Period as a result of the normal operation of forward incorporation by reference. In this context, we intend “current”
to mean that the 2020 Registration Statement did not make any untrue statement of a material fact, and did not omit to state a material
fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading.

The 2020 Registration Statement states that
all filings made by the Fund on or after August 1, 2020 pursuant to Sections 13(a), 13(c), 14 or 15(d) of the Securities Exchange
Act of 1934, as amended (the “Exchange Act”), or pursuant to Rule 30b-2 under the Investment Company Act of 1940,
as amended (the “1940 Act”) (collectively, the “Incorporable Documents”), prior to the
termination of the relevant offering, will be deemed to be incorporated by reference into the prospectus, as required by General
Instruction F of Form N-2. As a result of this operative language, the Form N-CSR Filings and all other Incorporable Documents filed
during the Period were automatically incorporated by reference into the 2020 Registration Statement upon the filing of the Form
N-CSR Filings and the other Incorporable Documents, respectively. This incorporation by reference maintained the currency of the
2020 Registration Statement during the Period.

     Lisa Larkin
 Megan Miller
 February 10, 2023
 Page 4

This understanding is expressly acknowledged
in Rule 439 under the Securities Act, which states (in relevant part and with emphasis added):

If the [Securities]
Act or the rules and regulations of the Commission require the filing of a written consent to the use of any material in connection with
the registration statement, such consent shall be filed as an exhibit to the registration statement even though the material
is incorporated therein by reference.

If the operation of incorporation
by reference was dependent upon compliance with the consent filing requirements, the phrase of Rule 439 emphasized above would need to
state, in substance, “in order for the material to be incorporated therein by reference.”
The actual phrasing of Rule 439 – “even though the material is incorporated therein
by reference” – makes clear that incorporation by reference functions separately from the consent filing requirements and
compliance therewith.

We are unaware of any statute, regulation, or
Commission guidance providing that an inadvertent failure to file an auditor’s consent, which the Fund has subsequently filed, would
prevent, limit, or affect forward incorporation by reference into the 2020 Registration Statement.

The Form N-CSR Filings were Timely Filed

The Fund filed the Form
N-CSR Filings within the applicable timeframe required by Section 30(e) of the 1940 Act and Rule 30e-1 thereunder. Respectfully, the Fund
does not believe that the inadvertent omission of the Auditor’s consent from the Form N-CSR Filings, as originally filed, renders
the Form N-CSR Filings unfiled or untimely filed and, as a result, unavailable for forward incorporation by reference into the 2020 Registration
Statement during the Period. As discussed below, the primary purpose of the auditor consent filing requirement is to assure that the auditor
is aware that its report is being incorporated by reference into a registration statement and the context in which it is being used.

     Lisa Larkin
 Megan Miller
 February 10, 2023
 Page 5

The Fund also
respectfully believes that the absence of the Auditor’s consent from the Form N-CSR Filings is most relevant to Section 7
of and Rule 401 under the Securities Act, rather than the reporting requirements pursuant to Sections 13 and 15(d) of the Exchange
Act, because the substantive necessity for, and purpose of, an auditor’s consent arise under the Securities Act, not the
reporting requirements of Sections 13 and 15(d) of the Exchange Act. While an annual report on Form N-CSR may serve as the
procedural mechanism by which a registrant satisfies its substantive obligation to file an auditor’s consent as an exhibit to
its registration statement, an annual report on Form N-CSR will never, in and of itself, require the filing of an auditor's consent
(which, in part, explains why the Fund failed to identify the consent requirement in its disclosure review process; see
Complexity of CEF Offering Reforms, below). The necessity of filing an auditor’s consent with a Form N-CSR will never
arise in the absence of effective registration statements under the Securities Act because the necessity of such filing is,
fundamentally, a vehicle for compliance with principles governed by the Securities Act.

Given the foregoing,
we respectfully submit that the inadvertent failure to file a copy of the Auditor’s consent as an exhibit to an annual report on
Form N-CSR, where the Auditor’s was aware of the incorporation by reference of its audit report into the 2020 Registration Statement
at the time of filings, does not nullify the entire annual report and does not render the annual report unfiled or otherwise unavailable
to be incorporated by reference into the 2020 Registration Statement.

The Fund respectfully
notes that publicly available correspondence filings appear to indicate that the Staff has previously reached a similar conclusion. In
its review of correspondence in which issuers received Staff comments indicating that the issuer neglected to file an auditor’s
consent (or filed an auditor’s consent that lacked a signature or included an incorrect date), the Fund was unable to find any instances
where the Staff did not accept the subsequent re-filing by the issuer of the auditor’s consent as a means of resolving the comment.

The Purpose of Obtaining the Auditor’s
Consent Was Satisfied

As the legislative history
makes clear, the primary purpose of requiring registrants to obtain an auditor’s consent in connection with inclusion of an auditor’s
report in a registration statement is to assure that the auditor is aware of the use of its audit report in connection with a registered
securities offering (see H.R. Conf. Rep. No. 73-152, at 26 (1933), stating that the purpose of the consent requirement
was to “to protect an unauthorized use of the expert’s name”) The Staff has similarly characterized the consent requirement
(see Section 4810.1 of the Division of Corporation Finance Financial Reporting Manual of the Staff, updated as of December
31, 2022, stating that “[t]he primary purpose of obtaining a consent or acknowledgement letter is to assure that the auditor is
aware of the use of its report and the context in which it is used”).

     Lisa Larkin
 Megan Miller
 February 10, 2023
 Page 6

As noted above, the
Auditor was demonstrably aware of the use of its report and the context in which it was used, as the Auditor was familiar with the
Fund’s ATM Program and issued related Comfort Letters (in each case within one or two weeks of the applicable Form N-CSR
filing) in which the Auditor explicitly stated that it was aware that each Form N-CSR Filing was “incorporated by reference in
the registration statement (File Nos. 333-237586 and 811-22974) on Form N-2.” The Auditor further participated in due
diligence calls with the Fund and its placement agents and reviewed other disclosures by the Fund which indicated that the
Fund’s periodic reports were automatically incorporated by reference into the 2020 Registration Statement. Furthermore, as
described above in the Response to Comment #1, the Auditor has now more formally consented to the incorporation by reference of its
audit reports for the Fund’s 2020 and 2021 annual reports into the 2020 Registration Statement and the Fund has filed those
consents in amended Form N-CSR filings on EDGAR (providing further indication that the Fund’s previous failure to obtain and
file the consents was merely inadvertent and not a result of any objection by the auditor). Given this, we believe the
 “primary purpose” of the consent requirement was fully satisfied notwithstanding the Fund’s inadvertent failure to
obtain and file the Auditor’s consent with its Form N-CSR Filings.

Complexity of CEF
Offering Reforms

The CEF Offering Reforms
fundamentally changed the manner in which closed-end funds register and sell their securities to the public, through a series of highly
technical rule and form amendments. The Fund expended significant resources to facilitate compliance with the new regulatory and disclosure
regime to which it is now subject. Since the CEF Offering Reforms were adopted, with the assistance of external legal counsel, the Fund
has made wholesale changes to its offering documents and periodic reports and related internal procedures. While not an excuse, the Fund
regards the missed auditor consent requirement as a technical misstep – with no practical harm to investors, the Auditor, or any
other relevant party – in light of the sweeping nature of the regulatory reforms. In this regard, the Fund believes that other closed-end
funds registered under the 1940 Act have made similar technical failures in connection with the CEF Offering Reforms transition. For example,
based on a cursory review of public filings, the Fund has identified over 10 other registered closed-end fund complexes that, subsequent
to the CEF Offering Reforms, appear to have failed to timely file an auditor’s consent with their Form N-CSR filings while the funds
had effective registration statements that incorporated such auditor’s audit report via forward incorporation by reference.

Steps Taken by the
Fund

Notwithstanding the
foregoing, the Fund acknowledges that compliance with the Commission’s rules and regulations is of utmost importance and in the
future it will strive to minimize the risk of any similar filing error or omission. In order to ensure that an error of this nature does
not occur again, the Fund made enhancements to its SEC filing checklists (including an item specifically relating to auditor and other
expert consents, as required by Rule 436 and Rule 439 under the Securities Act) and disclosure review procedures (including an enhanced
layer of review by th

CORRESP
1
filename1.htm

    1900 K Street, NW

        Washington, DC 20006-1110

        +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 28, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Ken Ellington and Christopher Bellacicco

 Re: Eagle Point Credit Company Inc.

Registration Statement
on Form N-2

File Numbers: 333-237586;
811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in telephonic conversations on May 21, 2020
between Ken Ellington of the Staff and Philip T. Hinkle of Dechert LLP and on May 22, 2020 between Lisa Larkin and Christopher
Bellacicco of the Staff and Philip T. Hinkle and Cynthia C. Bien of Dechert LLP, relating to the Fund’s responses, dated
May 20, 2020, to the Staff’s initial comments regarding the registration statement on Form N-2 filed with the Commission
on April 6, 2020 (the “Registration Statement”).

For your convenience, the Staff’s
comments are summarized in this letter, and each comment is followed by the applicable response. The Fund intends to file Pre-Effective
Amendment No. 1 to the Registration Statement (“Pre-Effective Amendment No. 1”) at a future date, which will
reflect the responses below.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

 1. Please expand the disclosure to address how the expected potential impact of the general market
conditions related to the COVID-19 pandemic on the CLO market might affect future Fund distributions (e.g., if payments are not
made to the CLO equity or CLO debt securities that the Fund holds, the Fund may increase the proportion of Fund distributions representing
a return of capital or reduce the distributions in the future).

    Ken Ellington

Christopher Bellacicco

May 28, 2020

Page 2

Response:

The Fund has revised the risk disclosure
relating to COVID-19 under “Terrorist actions, natural disasters, outbreaks or pandemics may disrupt the market and impact
our operations” as follows:

“In late 2019, an initial
outbreak of COVID-19 was reported in Hubei, China. Since then, a large and growing number of cases has been confirmed around the
world, which has resulted in numerous deaths and the imposition of both local and more widespread “work from home”
and other quarantine measures, border closures and other travel restrictions, causing social unrest and commercial disruption on
a global scale. In March 2020, the World Health Organization declared the COVID-19 outbreak a pandemic.

Global economies and financial
markets are becoming increasingly interconnected, and conditions and events in one country, region or financial market may adversely
impact issuers in a different country, region or financial market. The ongoing COVID-19 pandemic has magnified these risks and
has had, and will continue to have, a material adverse impact on local economies in the affected jurisdictions and also on the
global economy, as cross border commercial activity and market sentiment are increasingly impacted by the outbreak and government
and other measures seeking to contain its spread. The effects of the COVID-19 pandemic have contributed to increased volatility
in global financial markets and likely will affect countries, regions, companies, industries and market sectors more dramatically
than others. The COVID-19 pandemic has had, and any other outbreak of an infectious disease or serious environmental or public
health concern could have, a significant negative impact on economic and market conditions, could exacerbate pre-existing political,
social and economic risks in certain countries or regions and could trigger a prolonged period of global economic slowdown, which
may impact us and our underlying investments. It is not known how long the impact of the COVID-19 pandemic will, or future impacts
of other significant events would, last or the severity thereof. Federal, state and local governments, as well as foreign governments,
have taken aggressive steps to address problems being experienced by the markets and by businesses and the economy in general;
however, there can be no assurance that these measures will be adequate.

To the extent the Company’s
underlying investments are overweight in certain countries, regions, companies, industries or market sectors, such positions will
increase the risk of loss from adverse developments affecting those countries, regions, companies, industries or sectors. The COVID-19
pandemic and related government-imposed restrictions have imposed severe financial harm on certain industries to which the Fund
is exposed indirectly through its CLO investments’ underlying loan assets. For example, the airline and hotel industries
have experienced sharp declines in revenue due to restrictions on travel, hospitals and other healthcare companies have experienced
financial losses as a result of increased expenses and declining revenue as patients elect to delay elective or routine procedures,
and many casino operators have been forced to completely halt operations due to the imposition of mandatory business closures and
to address social distancing guidelines.

    Ken Ellington

Christopher Bellacicco

May 28, 2020

Page 3

To date, certain of the CLOs
in which we invest have experienced increased defaults by underlying borrowers. Obligor defaults and rating agency downgrades have
caused, and may continue to cause, payments that would have otherwise been made to the CLO equity or CLO debt securities that the
Fund holds to instead be diverted to buy additional loans within a given CLO or paid to senior CLO debt holders as an early amortization
payment. In addition, defaults and downgrades of underlying obligors have caused, and may continue to cause, a decline in the value
of CLO securities generally. If CLO cash flows or income decreases as a result of the pandemic, the portion of our distribution
comprised of a return of capital could increase or distributions could be reduced.”

 2. Please consider referring to the Commission’s final rule on incorporation by reference
as opposed to the Economic Growth, Regulatory Relief, and Consumer Protection Act in the Registration Statement.

Response:

The Fund will refer to the Commission’s
final rule and form amendments adopted on April 8, 2020 in addition to the Economic Growth, Regulatory Relief, and Consumer Protection
Act in the Registration Statement.

 3. Please let us know supplementally how and when the Fund intends to implement backward incorporation
by reference.

Response:

The Registration Statement includes the
Fund’s financial statements for the fiscal year ended December 31, 2019. Pre-Effective Amendment No. 1 will include the Fund’s
financial statements for the period ended March 31, 2020. The Fund will not need to backward incorporate by reference. Beginning
August 1, 2020, the Fund will forward incorporate by reference any filings it will make with the SEC under Sections 13(a), 13(c),
14, or 15(d) of the Exchange Act of 1934, as amended (the “Exchange Act”), or pursuant to Rule 30b2-1 under the Investment
Company Act of 1940, as amended (the “1940 Act”). As a result, the Fund will forward incorporate the financial statements
for the period ended June 30, 2020 filed with the Fund’s semi-annual report.

    Ken Ellington

Christopher Bellacicco

May 28, 2020

Page 4

 4. Please supplementally explain why the Fund is eligible to use the short-form registration statement
on Form N-2 and forward incorporate by reference.

Response:

The Fund believes it will be eligible to
use the short-form registration statement on Form N-2 because it will satisfy the conditions to General Instruction A.2 to the
Amended Form N-2 in that (i) it meets the registrant and transaction requirements of Form S-3 and (ii) it has been registered under
the 1940 Act for at least 12 calendar months immediately preceding the filing of the registration statement and has timely filed
all reports required to be filed under Section 30 of the 1940 Act.

The Fund meets all of the registrant requirements
in General Instruction I.A of Form S-3. The Fund will meet the transaction requirement in General Instruction I.B.1 of Form S-3
because the aggregate market value of the voting and non-voting common equity held by non-affiliates of the Fund is $75 million
or more.

Because the Fund is eligible to use the
short-form registration statement on Form N-2, the Fund will be able to also rely on the new General Instruction F.3.b of the Amended
Form N-2 to incorporate by reference to subsequently filed Exchange Act reports.

    Ken Ellington

Christopher Bellacicco

May 28, 2020

Page 5

* * * * * * * * *

If you have any questions, please feel
free to contact the undersigned by telephone at 202.261.3460 or by email at philip.hinkle@dechert.com. Thank you for your cooperation
and attention to this matter.

Sincerely,

/s/ Philip T. Hinkle

Philip T. Hinkle

 cc: Thomas P. Majewski, Chief Executive Officer, Eagle Point
Credit Company Inc.

Nauman S. Malik, Chief
Compliance Officer, Eagle Point Credit Company Inc.

CORRESP
1
filename1.htm

    1900 K Street, NW

        Washington, DC 20006-1110

        +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 20, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Ken Ellington and Christopher Bellacicco

 Re: Eagle Point Credit Company Inc.

Registration Statement
on Form N-2

File Numbers: 333-237586;
811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in telephonic conversations on April 14, 2020
between Ken Ellington of the Staff and Philip T. Hinkle of Dechert LLP and May 4, 2020 between Christopher Bellacicco of the Staff
and Philip T. Hinkle and Cynthia C. Bien of Dechert LLP, relating to the Fund’s registration statement on Form N-2 filed
with the Commission on April 6, 2020 (the “Registration Statement”).

For your convenience, the Staff’s
comments are summarized in this letter, and each comment is followed by the applicable response. The Fund intends to file Pre-Effective
Amendment No. 1 to the Registration Statement (“Pre-Effective Amendment No. 1”) at a future date, which will
reflect the responses below.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

 1. Please confirm that the Fund has received or will receive a FINRA no objections letter.

Response:

The Fund confirms it will use its reasonable
best efforts to obtain a FINRA no objections letter. The Fund will address and resolve any FINRA comments prior to effectiveness
of the Registration Statement.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 2

 2. The Staff notes the name of the Fund includes the word “Credit.” Please include
an investment policy with respect to the name “Credit” in accordance with Rule 35d-1 under the Investment Company Act
of 1940, as amended (the “1940 Act”).

Response:

While the Fund believes the term “credit”
does not necessarily implicate the requirements of Rule 35d-1 under the 1940 Act, it will add the following 80% policy to the description
of its principal investment strategy in accordance with Rule 35d-1.

“Under normal circumstances,
the Fund invests at least 80% of the aggregate of its net assets and borrowings for investment purposes in credit and credit related
instruments. For purposes of this policy, the Fund considers credit and credit related instruments to include, without limitation:
(i) equity and debt tranches of collateralized loan obligations, or “CLOs,” loan accumulation facilities and securities
issued by other securitization vehicles, such as credit-linked notes and collateralized bond obligations or “CBOs”;
(ii) secured and unsecured floating rate and fixed rate loans; (iii) investments in corporate debt obligations, including bonds,
notes, debentures, commercial paper and other obligations of corporations to pay interest and repay principal; (iv) debt issued
by governments, their agencies, instrumentalities, and central banks; (v) commercial paper and short-term notes; (vi) preferred
stock; (vii) convertible debt securities; (viii) certificates of deposit, bankers’ acceptances and time deposits; and (ix)
other credit-related instruments. The Fund’s investments in derivatives, other investment companies, and other instruments
designed to obtain indirect exposure to credit and credit related instruments are counted towards the Fund’s 80% investment
policy to the extent such instruments have similar economic characteristics to the investments included within that policy.”

In addition, the Fund will add the following
explanatory disclosure elsewhere in the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“The Fund’s 80% policy
with respect to investments in credit and credit related instruments is not fundamental and may be changed by our board of directors
without stockholder approval. Stockholders will be provided with sixty (60) days’ notice in the manner prescribed by the
SEC before making any change to this policy. The Fund’s investments in derivatives, other investment companies, and other
instruments designed to obtain indirect exposure to credit and credit related instruments are counted towards the Fund’s
80% investment policy to the extent such instruments have similar economic characteristics to the investments included within that
policy.”

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 3

 3. Please discuss in correspondence how the Fund’s portfolio, liquidity and creditworthiness
has changed since early March 2020. Please confirm whether any of the securities and underlying collateralized loan obligations
(“CLOs”) have been downgraded or are in default. If there have not been downgrades or defaults, please explain if that
is attributable to government support and, if so, please describe the Fund’s plans for the expiration of such support.

Response:

The Fund has not substantially repositioned
its portfolio in response to the COVID-19 pandemic or related government actions. As disclosed in the Registration Statement, the
Fund’s portfolio investments are generally less liquid than high yield bonds in normal market conditions. Since March 2020,
we have observed a modest decline in liquidity, which has primarily affected distressed assets.

During the first quarter, essentially all
of the Fund’s CLO investments experienced a decrease in the value of their underlying corporate loan portfolios. Indeed,
the S&P/LSTA Leveraged Loan Index had one of its worst months ever in March 2020. In essentially all cases, however, the value
of the corporate loan portfolios has increased since April 1, 2020, though typically not to levels from the beginning of the year.

None of the securities held by the Fund
have defaulted. This is attributable, in part, to the fact that the Fund’s CLO investments do not have liquidation triggers
based on the market value of non-defaulted corporate loans. Certain CLO debt investments held by the Fund have been placed on “negative
watch” by Moody’s or S&P, indicating that such rating agency is currently reviewing these assets for potential
future downgrade. However, only one CLO debt investment has been downgraded between March 1, 2020 and May 1, 2020. The Fund’s
investments in CLO equity, which comprise the majority of the Fund’s portfolio, are not rated. We do not believe any of our
CLO investments have received government support though certain obligors of the loans underlying our CLO investments may participate
in recent government programs. Based on our limited knowledge of the extent of underlying obligors’ reliance on COVID-19
government support measures, we do not believe the expiration of those measures would result in a material increase in defaults
on the Fund’s CLO investments or their underlying collateral.

 4. Please confirm that the Fund does not plan on issuing preferred stock within the next year.

The Fund has no current plans to issue
preferred stock within the next 12 months. However, as noted in the Registration Statement, the Fund may issue preferred stock
or otherwise incur leverage in accordance with the 1940 Act at any time.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 4

 5. Please update the December 31, 2019 or February 29, 2020 information to March 31, 2020, as applicable,
throughout the Registration Statement for disclosure relating to closing price, net asset value (“NAV”), portfolio
composition (including industries affected by the COVID-19 pandemic), credit facility compliance, effective leverage, price range
of common stock, senior securities, and the lagging 12-month default rate by principal amount.

The Fund will update the relevant December
31, 2019 and February 29, 2020 disclosure (including the items noted in this comment 5) in the Registration Statement prior to
filing Pre-Effective Amendment No. 1.

 6. In the “Efficient vehicle for gaining exposure to CLO securities” bullet point under
the Competitive Advantages section, please explain what a CLO reset transaction is in plain English.

Response:

The Fund will add the following disclosure
in the applicable section of the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“In a CLO reset, the CLO’s
indenture, which sets forth the terms governing the CLO, is “re-opened” (e.g., the terms of the indenture and the various
tranches of the CLO can be re-negotiated). Among other potential benefits, resetting a CLO renews the reinvestment period on the
CLO.”

 7. In the Financing and Hedging Strategy section of the Registration Statement, please disclose
if the Fund has failed to meet its asset coverage ratio requirements. Please prominently disclose the risk of a failure to meet
the asset coverage ratio requirements, such as an inability to pay certain dividends or make additional borrowings.

Response:

The Fund notes that it had satisfied applicable
asset coverage requirements as of March 31, 2020. The Fund will include the following disclosure in the Financing and Hedging Strategy
section of the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“As of March 31, 2020, the
Company’s asset coverage ratios in respect of (i) senior securities representing indebtedness and (ii) our outstanding preferred
stock, each as calculated pursuant to Section 18 of the 1940 Act, were 330% and 220%, respectively. In the event we fail to meet
our applicable asset coverage ratio requirements, we may not be able to incur additional debt and/or issue preferred stock, and
could be required by law or otherwise to sell a portion of our investments to repay some debt or redeem shares of preferred stock
(if any) when it is disadvantageous to do so, which could have a material adverse effect on our operations, and we may not be able
to make certain distributions or pay dividends of an amount necessary to continue to qualify as a RIC for U.S. federal income tax
purposes.”

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 5

 8. Please include a COVID-19 risk factor in the Risk Factor Summary section.

Response:

The Fund will add the following disclosure
in the Risk Factor Summary section of the Registration Statement prior to filing Pre-Effective Amendment No. 1:

“COVID-19
Pandemic Risk. The emergence of the global outbreak of the COVID-19 pandemic has created economic and financial disruptions
and contributed to increased volatility in global financial markets and likely will affect countries, regions, companies, industries
and market sectors more dramatically than others. It is not known how long the impact of the COVID-19 pandemic will last or the
severity thereof.”

 9. In the Fees and Expenses table, the management fee is based on actual amounts incurred during
the three months ended December 31, 2019, annualized for a full year, and reflects the pro forma effect of the issuance of 1,107,612
shares of the Fund’s common stock from January 1, 2020 through April 2, 2020 in the Fund’s “at-the-market”
offering, yielding net proceeds of approximately $16.3 million, as if such shares were issued at the start of such period. Please
discuss in correspondence whether the disclosure would change materially if the management fee was based on managed assets as of
a more recent date.

Response:

The management fee line item in the Fees
and Expenses table will be updated to reflect amounts actually incurred during the three months ended March 31, 2020 prior to filing
Pre-Effective Amendment No. 1.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 6

 10. Please include a discussion in the Risk Factors section of the Fund’s exposure to industries
that have been impacted by recent market events, if applicable.

Response:

The Fund will enhance the risk disclosure
in the Registration Statement in accordance with this comment, as reflected in its response to comment 22, below.

 11. Please revise the “Low Interest Rate Environment” paragraph in the Risk Factors
section in light of current developments.

Response:

The Fund will replace the “Low Interest
Rate Environment” paragraph prior to filing Pre-Effective Amendment No. 1 with the following:

“As of the date of this
prospectus, interest rates in the United States are at historic lows due to the U.S. Federal Reserve’s recent lowering of
certain interest rates as part of its efforts to ease the economic effects of the COVID-19 pandemic. With the historically low
interest rates, there is a risk that interest rates will rise once the COVID-19 pandemic abates.”

 12. The Staff references the Risk Factor “[w]e are subject to risks associated with defaults
on an underlying asset held by a CLO.” Please discuss in correspondence whether such defaults have been occurring and if
so, please explain the circumstances.

Response:

Owing to the large number of corporate
loans underlying our CLOs, even in benign markets, we expect a certain amount of loan defaults each year. Due to the unexpected
decrease in revenue at companies due to COVID-19 related shut-downs and other business disruptions, defaults of assets underlying
CLOs have begun to increase. For example, we note that in April 2020, 11 constituents out of the over 1400 loans in the S&P/LSTA
Leveraged Loan Index experienced a default. We have observed that defaults have been concentrated in the retail, telecommunications,
healthcare and travel sectors. Year to date, the energy sector has had among the highest default rates compared to other industries
due to decreased demand caused by COVID-19 related travel restrictions and a price war among major oil producing nations; however,
the CLOs comprising the Fund’s investment portfolio generally have minimal exposure to energy obligors.

From March 1, 2020 to April 30, 2020, underlying
loans held by the Fund’s CLO investments which were in default increased by approximately 31 basis points, from 1.03% to
1.34%. Despite this increase, the current overall default rate on the Fund’s underlying investments remains below the historical
default rate for senior secured loans according to data provided by S&P Leveraged Commentary & Data. The Fund is monitoring
activity in the underlying loan market, including defaults, carefully.

        Ken Ellington

        Christopher Bellaciccio

        May 20, 2020

        Page 7

 13. The Staff references the Risk Factor “[a]ny unrealized losses we experience on our portfolio
may be an indication of future realized losses, which could reduce our income available for distribution or to make payments on
our other obligations.” Please describe supplementally any expected impact on the Fund’s ability to pay distributions
and any expectations of higher percentages of returns of capital than distributed in previous fiscal periods in making such distributions.

Response:

This Risk Factor is intended to highlight
the general inverse correlation between a decline in a CLO’s market value and an increase in the perceived risk of loan defaults
and/or lower recoveries from defaulted loans. Market prices of a CLO’s loans reflect market participants’ views of
each loan’s value on any given day. However, CLOs are not required to sell assets due to price movements of performing loans.
In addition, CLO liabilities typically have maturity dates beyond those of the CLO’s loan assets, thereby mitigating risk
associated with a loan’s price volatility prior to repayment. Thus, while unrealized losses o

CORRESP
1
filename1.htm

    1900 K Street, NW

        Washington, DC 20006-1110

        +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

November 4, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Kenneth Ellington

 Re: Eagle Point Credit Company Inc. (File No. 811-22974)

Dear Mr. Ellington:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in a telephonic conversation on September
10, 2019 between Kenneth Ellington of the Staff and Thomas J. Friedmann, Philip T. Hinkle and Cynthia C. Bien of Dechert LLP and
a telephonic conversation on October 31, 2019 between Kenneth Ellington and Philip T. Hinkle, with respect to your review pursuant
to the Sarbanes-Oxley Act of 2002 of certain annual reports and other filings of the Fund.

For your convenience, the Staff’s
comments are summarized in this letter, and each comment is followed by the applicable response.

 1. The disclosure in footnote 2 of the Fund’s Consolidated Schedule of Investments discloses
that the investments are restricted investments. Please ensure in future filings that all the disclosure related to restricted
securities required by footnote 8 of Rule 12-12 of Regulation S-X are included in future financial statements, including acquisition
date.

Response:

The Fund will ensure that all disclosure
related to restricted securities required by footnote 8 of Rule 12-1 of Regulation S-X are included in future financial statements,
including the initial acquisition date of each restricted security listed on the Consolidated Schedule of Investments.

Kenneth
Ellington

November
4, 2019

Page
2

 2. In Note 1 “Organization” to the financial statements, please disclose in future
filings the percentage of the Fund invested in each subsidiary.

Response:

The Fund will disclose the percentage of the Fund’s net
assets invested in each subsidiary in Note 1 “Organization” to the consolidated financial statements in future financial
statements.

 3. With respect to Note 2 “Summary of Significant Accounting Principles” to the financial
statements, please discuss in correspondence the accounting for interest income from loan accumulation facilities, including citations
to applicable U.S. GAAP. Please also state the amount of income that was attributable to such interest income.

Response:

Interest income from loan accumulation
facilities (each a “LAF”, and collectively “LAFs”) is recorded according to the guidance noted in ASC 325-40-35-1,
which states that the holder of a beneficial interest in securitized financial assets shall determine interest income over the
life of the beneficial interest in accordance with the effective yield method, provided such amounts are expected to be collected.
FASB ASC 325-40-20 further defines “beneficial interests”, among other things, as “rights to receive all or portions
of specified cash inflows received by a trust or other entity.”

FASB ASC 325-40-15-7 also states that for
income recognition purposes, beneficial interests in securitized financial assets (such as those in LAFs) are within the scope
of ASC 325-40 because it is customary for certain industries, such as investment companies, to report interest income as a separate
item in their income statements even though the investments are accounted for at fair value.

The amounts of interest income from loan
accumulation facilities recorded for the year ended December 31, 2018 and for the six month period ended June 30, 2019 were approximately
$5.8 million and $2.8 million, respectively.

The Fund will include the relevant information
and U.S. GAAP references noted above in Note 2 “Summary of Significant Accounting Principles” to the consolidated financial
statements in future financial statements.

Kenneth
Ellington

November
4, 2019

Page
3

 4. The disclosure in Note 3 “Investments” to the financial statements discusses situations
when the fair value of the loan accumulation facilities is based on the market value of the underlying loans plus accrued interest
and realized gains (losses) reported by the Trustee. Please explain in correspondence how this valuation policy is in accordance
with U.S. GAAP and specifically ASC 820.

Response:

ASC 820 defines “fair value”
as the price that would be received to sell an asset or that would be paid to transfer a liability in an orderly transaction between
market participants at the particular measurement date.

The Fund determines the fair value of LAFs
consistent with the “income approach” noted in ASC 820-10-55-3F, which states the fair value measurement should reflect
current market expectations about the receipt of future amounts (i.e., the Fund’s estimated exit price).

LAFs are typically short to medium term
in nature and formed to acquire loans on an interim basis that are expected to form part of a specific CLO transaction. Pursuant
to a typical LAF’s governing documents, loans acquired by the LAF are typically required to be transferred to the contemplated
CLO transaction at the original cost. In such a situation, because the LAF will receive its full cost basis in the underlying loan
assets and the accrued interest thereon upon the consummation of the CLO transaction, the Fund fair values its investment in the
LAF as follows: (A) the cost of the Fund’s investment (i.e., the principal amount invested) and (B) to the extent
the LAF has realized gains (losses) on its underlying loan assets which are reported by the Trustee during the applicable reporting
period, its attributable portion of such realized gains (losses). For clarification, the LAF’s attributable portion of such
realized gains (losses) are recorded as a change in unrealized appreciation (depreciation) on the Fund’s Consolidated Statement
of Operations, which becomes a realized gain (loss) at the time the LAF converts into a specific CLO transaction.

Kenneth
Ellington

November
4, 2019

Page
4

ASC 820-10-35-25 states valuation techniques
used to measure fair value should be applied consistently. However, the pronouncement further states a change in valuation technique
or application may be appropriate if the change results in a measurement that is equal or more representative of fair value under
certain circumstances, such as a change in market conditions or new information becoming available. In such circumstances, Eagle
Point Credit Management LLC (the “Adviser”), the Fund’s investment adviser, may determine that, despite the initial
expectation that a CLO transaction would result from a LAF at the time of the Fund’s investment therein, such a transaction
is in fact unlikely to occur and, accordingly, it is unlikely the loans held by the LAF will be transferred at cost. Rather, the
loans held by the LAF will most likely be sold at market value. In such situations, the Fund will continue to fair value the LAF
consistent with the income approach noted in ASC 820-10-55-3F, but modify the fair value measurement to reflect the change in exit
strategy of the LAF to incorporate current market expectations of the receipt of future amounts (i.e., the Fund’s estimated
exit price). As such, the fair value of the Fund’s investment in the LAF is most appropriately determined by reference to
the market value of the LAF’s underlying loans, which is reflective of the price at which the LAF could sell its loan assets
in an orderly transaction between market participants. As such, in these situations, the Fund fair values its investment in the
LAF as follows: (A) the cost of the Fund’s investment (i.e., the principal amount invested), and (B) the Fund’s
attributable portion of the unrealized gain (loss) on the LAF’s underlying loan assets, and (C) to the extent the
LAF has realized gains (losses) on its underlying loan assets which are reported by the Trustee during the applicable reporting
period, its attributable portion of such realized gains (losses). The Fund’s measure of its attributable portion of the unrealized
gain (loss) on the LAF’s underlying loan assets takes into account the Fund’s current market expectations of its receipt
of future amounts on such assets, which may be impacted by various factors including any applicable change in market conditions
or new information.

Additionally, as noted in comment 3’s
response, the Fund also records the LAF’s attributable portion of interest income in its Consolidated Statement of Operations
in the period such interest is earned.

In future financial statements, the Fund
will update the Valuation of Loan Accumulation Facilities discussion in Note 3 “Investments” to the consolidated
financial statements to include the relevant information and U.S. GAAP references noted above.

 5. The disclosure in Note 4 “Related Party Transactions” to the financial statements
states that the Adviser has voluntarily waived a portion of its incentive fee. Please disclose in correspondence whether the incentive
fees are subject to recoupment. If the incentive fees are subject to recoupment, then please confirm whether the recoupment period
is limited to three (3) years from the date the fees were waived. Please disclose in future filings the amounts subject to recoupment
by year and the terms of recoupment in the notes to the financial statements. Any recapture provision should be limited to the
lesser of (i) the expense cap in effect at the time of waiver and (ii) the expense cap in effect at the time of recapture. See
2009 Investment Companies Industry Developments Audit Risk Alert ARA-INV.73.

Response:

The waived portion of the incentive fee
is not subject to recoupment. The Fund will include additional disclosures stating such in future filings as applicable.

 6. The Staff notes that the Fund has significant return of capital distributions during the fiscal
year. The Staff also notes that the distribution amounts in the distribution history section of the Fund’s website only discloses
the total amount of each distribution. Please clearly identify on the Fund’s website the portion of each distribution that
is a return of capital.

Response:

The Fund will (A) update its website to
include a clear hyperlink from the “Distribution History” section of the website to the “Tax Characteristics”
section of the website and (B) enhance the “Tax Characteristics” section of the website to include a table that discloses,
for each distribution associated with each of the Fund’s fiscal years (including the estimated cumulative current fiscal
year-to-date), the percentage of each distribution sourced from each of (i) net investment income, (ii) short-term capital gain,
(iii) long-term capital gain, and (iv) return of capital.

For completed fiscal years, when such information
becomes available, the source percentage of each distribution will be determined from the Fund’s 1099-Div statement as reported
to the Fund’s shareholders. For the current period, the source percentage of each distribution will be as estimated consistent
with the year-to-date percentage noted in the Fund’s most recent Section 19 Notice.

Kenneth
Ellington

November
4, 2019

Page
5

 7. The Summary Tax Characteristics of Dividends and Distributions document found on the Fund’s
website for the tax year ended December 31, 2018 appears to identify return of capital as a non-taxable dividend. Please refrain
from using the term “dividend” to describe distributions that contain a return of capital as that term has a connotation
of income.

Response:

The Fund will refrain from using the term
 “dividend” in the Summary Tax Characteristics of Dividends and Distributions document to describe distributions that
contain a return of capital.

 8. Item 4(e)(2) of the Fund’s Form N-CSR discloses that 100% of the independent accountant’s
expenses were pre-approved by the Fund’s audit committee and does not include separate responses for sub-items (b), (c) and
(d). Item 4(e)(2) of Form N-CSR requires disclosure of situations where the pre-approval requirement was waived in accordance with
paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, not when pre-approval was obtained. Please confirm this disclosure is accurate
and provide separate responses for sub-items (b), (c) and (d) in future flings.

Response:

The Fund intended the disclosure to be
0% to reflect that each of the services provided by the independent accountant and listed in sub-items (b), (c) and (d) were pre-approved
by the Fund’s audit committee, and no pre-approvals were waived. The Fund confirms it will update this disclosure in the
future to more closely track the requirements of paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.

Kenneth
Ellington

November
4, 2019

Page
6

 9. Please confirm that the Fund has adopted and is applying the provisions of Accounting Standards
Update No. 2017-08, which is called the Premium Amortization on Purchased Callable Debt Securities.

Response:

The Fund confirms it applies the provisions
of Accounting Standards Update No. 2017-08 (“ASU 2017-08”) in calculating amortization of premium for CLO debt securities.
Additionally, in future filings the Fund will update Note 2 “Significant Accounting Policies” to the consolidated financial
statements stating adherence to ASU 2017-08.

 10. The Fund’s semi-annual report filed on Form N-CSRS on August 15, 2019 discloses the quarterly
distribution for each of the quarters ended March 31, 2019 and June 30, 2019 was lower partially due to the accounting treatment
of a CLO that undertook a “call and roll” transaction. Please explain in correspondence the transaction, discuss the
accounting for it and the impact to the financial statements.

Response:

The “call and roll” transaction
noted in the Fund’s semi-annual report for the period ending June 30, 2019 relates to an effective “reset” of
the applicable CLO investment. Generally, in such a transaction, an existing CLO investment is called (the “Called CLO”),
resulting in a full repayment of all of its outstanding rated debt securities, and the majority of the assets of the called CLO
are transferred to a new special purpose vehicle managed by the same collateral manager as the Called CLO (the “New CLO”)
which issues new debt securities and new subordinated notes pursuant to an indenture whose terms typically differ from those of
the Called CLO. The Fund, which was a holder of the subordinated notes in the Called CLO, utilized the proceeds from the call of
the Called CLO to subsequently acquire subordinated notes in the New CLO. The subordinated notes issued by the New CLO have a new
maturity date and have a different CUSIP than those issued by the Called CLO given that the New CLO is a distinct legal entity
from the Called CLO.

Because the Called CLO investment was unwound,
this triggered a realization of an unrealized loss that was previously carried by the Fund in connection with its investment in
the Called CLO (which unrealized loss was reflected in the Fund’s Net Asset Value as applicable over the holding period of
the investment). The impact to the Fund’s financial statements for the quarter ending June 30, 2019 was primarily a geographical
shift of an unrealized loss previously recorded in the quarter ended March 31, 2019 to a realized loss and the impact to the Fund’s
Net Asset Value resulting from this transaction was minimal.

Kenneth
Ellington

November
4, 2019

Page
7

 11. The accountant’s report on internal control included in the Fund’s Form N-CEN filed
on March 15, 2019 is missing the city and state of the accounting firm. Please confirm the Fund maintains a copy of the report
that contains this information and ensure the city and state are in

CORRESP
1
filename1.htm

    1900
K Street, NW

Washington, DC 20006-1110

+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

June 13, 2017

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Jeffrey Foor

 Re: Eagle Point Credit Company Inc.

Registration Statement on Form N-2

File Numbers: 333-218611; 811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in a telephone call between Jeffrey Foor of
the Staff and Philip T. Hinkle and Owen T. Williams of Dechert LLP, outside counsel to the Fund, on June 13, 2017.

For your convenience, the Staff’s
comments are summarized in this letter, and each comment is followed by the applicable response. Capitalized terms used in this
letter and not otherwise defined herein shall have the meanings specified in the Company’s registration statement on Form
N-2 (File Nos. 333-218611; 811-22974) (the “Registration Statement”).

 1. Please undertake to submit to the Financial Industry Regulatory Authority, Inc. (“FINRA”)
any underwritten offering for approval of the underwriting terms thereof.

Response:

The Fund undertakes to submit, or to cause
the underwriters to submit, as applicable, to FINRA any underwritten offering for approval of the underwriting terms thereof.

    Jeffrey Foor

June 13, 2017

Page 2

 2. Please undertake to (i) include in any prospectus supplement a description of the terms of any
agreement entered into with an underwriter or its affiliates in connection with an underwritten offering of the Fund’s securities
and (ii) to file all such agreements in a post-effective amendment to the Registration Statement.

Response:

The Fund undertakes to (i) include in any
prospectus supplement a description of the terms of any agreement entered into with an underwriter or its affiliates in connection
with an underwritten offering of the Fund’s securities and (ii) to file all such agreements in a post-effective amendment
to the Registration Statement.

 3. In connection with each offering of the Fund’s securities, please undertake to file in
a post-effective amendment to the Registration Statement an unqualified legality opinion and related consent of the Fund’s
counsel consistent with Staff Legal Bulletin No. 19.

Response:

The Fund undertakes to file in a post-effective
amendment to the Registration Statement an unqualified legality opinion and related consent of the Fund’s counsel consistent
with Staff Legal Bulletin No. 19 in connection with each offering of the Fund’s securities.

* * * * * * * * *

If you have any questions, please feel
free to contact the undersigned by telephone at 202.261.3460 or by email at philip.hinkle@dechert.com or Thomas J. Friedmann by
telephone at 617.728.7120 or by email at thomas.friedmann@dechert.com. Thank you for your cooperation and attention to this matter.

Sincerely,

/s/ Philip T. Hinkle

Philip T. Hinkle

    cc:
    Thomas P. Majewski, Chief Executive Officer, Eagle Point Credit Company Inc.

    Nauman S. Malik, General Counsel, Eagle Point Credit Management LLC

    Thomas J. Friedmann, Dechert LLP

CORRESP
1
filename1.htm

EAGLE
POINT CREDIT COMPANY INC.

20 Horseneck Lane

Greenwich, Connecticut 06830

June 13, 2017

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Jeffrey Foor and Chad Eskildsen

    Re:
    Eagle Point Credit Company Inc.

    Registration Statement on Form N-2

    File Numbers: 333-218611; 811-22974

Dear Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
Eagle Point Credit Company Inc., a Delaware corporation (the “Company”), respectfully requests acceleration
of the effective date of its Registration Statement on Form N-2 (File Nos. 333-218611; 811-22974) (the “Registration Statement”)
so that such Registration Statement may be declared effective on Tuesday, June 13, 2017, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone
call to Philip T. Hinkle of Dechert LLP at (202) 261-3460, and that such effectiveness also be confirmed in writing.

    Very truly yours,

    Eagle Point Credit Company Inc.

    By:
    /s/
    Kenneth P. Onorio

    Name:
    Kenneth P. Onorio

    Title:
    Chief  Financial Officer

CORRESP
1
filename1.htm

    1900 K Street, NW
 Washington, DC  20006-1110
+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

April 10, 2017

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Dominic Minore

 Re: Eagle Point Credit Company Inc.

Preliminary Proxy Statement on Schedule
14A

File Number: 811-22974

Dear Mr. Minore:

On March 28, 2017, Eagle Point Credit Company
Inc., a Delaware corporation (the “Company”), filed with the Securities and Exchange Commission (the “Commission”)
a preliminary proxy statement on Schedule 14A for the Company’s 2017 annual meeting of stockholders (the “Meeting”).
On behalf of the Company, we hereby respond to the comments raised by the staff (the “Staff”) of the Commission
in phone calls between Dominic Minore of the Staff and Philip T. Hinkle and Erin M. Lett of Dechert LLP, outside counsel to the
Company, on April 6, 2017. For your convenience, summaries of the Staff’s comments are included in this letter, and each
comment is followed by the applicable response. Capitalized terms used in this letter and not otherwise defined herein shall have
the meanings specified in the preliminary proxy statement.

 1. Please confirm that all information required to be disclosed by Item 22(b)(11) of Schedule 14A
has been disclosed in the proxy statement.

Response:	The Company confirms
that all information required to be disclosed by Item 22(b)(11) of Schedule 14A was disclosed in the preliminary proxy statement
and is disclosed in the definitive proxy statement.

   U.S. Securities and
Exchange Commission

        April 10, 2017

Page 2

 2. Given the interplay between the hurdle and catch-up features of the incentive fee, include disclosure
regarding whether, under the advisory agreement, there is (a) any accumulation of amounts on the hurdle rate from quarter
to quarter, (b) any clawback of amounts previously paid under the advisory agreement if Pre-Incentive Fee Net Investment Income
falls below the hurdle rate in subsequent quarters or (c) any delayed payments to the Adviser if Pre-Incentive Fee Net Investment
Income was below the hurdle rate in prior quarters. Please also consider whether, if including new disclosure, there are any necessary
adjustments to the examples of the incentive fee calculation.

Response:	The Company hereby
confirms that, under both the Current Advisory Agreement and the New Advisory Agreement, there is no (1) accumulation of amounts
on the hurdle rate from quarter to quarter, (2) clawback of amounts previously paid under either agreement if Pre-Incentive Fee
Net Investment Income falls below the hurdle rate in subsequent quarters or (3) delay of payment if Pre-Incentive Fee Net
Investment Income was below the hurdle rate in prior quarters. The Company has included disclosure to this effect in the definitive
proxy statement. Based on the above confirmations and clarifying disclosure, the Company believes that no adjustments are necessary
to the examples of the incentive fee calculation.

 3. If none of (a) through (c) in Comment 3 applies to the New Advisory Agreement, please remove
the supplemental presentation of the annualized percentages for the hurdle and catch up features as these annualized percentages
may be confusing to investors if the Company does not exceed hurdle and catch up levels in all quarters.

Response:	As requested, the Company
has removed the supplemental presentation of the annualized percentages for the hurdle and catch-up levels in the definitive proxy
statement.

 4. Confirm that there is no circumstance in which amounts payable under the New Advisory Agreement
would differ from the amounts that would be payable under the Current Advisory Agreement. If amounts payable under the New Advisory
Agreement could differ from amounts payable under the Current Advisory Agreement, include in the proxy statement either (1) a calculation
of the total amounts payable under both agreements or (2) a comparative table setting forth total amounts payable under both agreements.

Response:	The Company notes that
the additional language regarding the calculation of base management fees in Article IV of the New Advisory Agreement simply provides
additional detail regarding how base management fees have historically been calculated under the Current Advisory Agreement. As
such, the Company hereby confirms that that there is no circumstance in which amounts payable under the New Advisory Agreement
would differ from the amounts that would be payable under the Current Advisory Agreement.

   U.S. Securities and
Exchange Commission

        April 10, 2017

Page 3

 5. Reference is made to Article VII, Section 5 of the New Advisory Agreement. In your response,
please describe amendments to the New Advisory Agreement (aside from a reduction in fees payable under the agreement) that would
not require stockholder approval. If applicable, please include a description of the categories of material amendments that would
not require stockholder approval in the proxy statement.

Response: 	The Company respectfully
submits that any amendment to the New Advisory Agreement that does not result in a change of control of the Adviser or adversely
affect the rights of the Company or its stockholders does not require stockholder approval. As there are no amendments that would
materially affect the rights of stockholders that would not require stockholder approval, additional disclosure has not been added
to the definitive proxy statement.

* * * * * * * * *

If you have any questions, please feel
free to contact the undersigned by telephone at 202.261.3460 or by email at philip.hinkle@dechert.com or Thomas J. Friedmann at
617.728.7120 or by email at thomas.friedmann@dechert.com. Thank you for your cooperation and attention to this matter.

Sincerely,

/s/ Philip T. Hinkle

Philip T. Hinkle

cc:    Nauman S. Malik, General Counsel, Eagle Point Credit
Management LLC

Thomas J. Friedmann, Dechert LLP

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006-1110

        +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

September 6, 2016

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov and Megan Miller

 Re: Eagle Point Credit Company Inc.

   Registration Statement on Form N-2

   File Numbers: 333-205540; 811-22974

Ladies and Gentlemen:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in telephone calls between Megan Miller of
the Staff and Thomas J. Friedmann of Dechert LLP, outside counsel to the Fund, on July 28, 2016 and between Asen Parachkevov of
the Staff and Philip T. Hinkle and Erin M. Lett of Dechert LLP on August 5, 2016.

For your convenience, the Staff’s
comments are summarized in this letter, and each comment is followed by the applicable response. Concurrently, the Fund is filing
post-effective amendment no. 6 (“Amendment No. 6”) to its registration statement on Form N-2 (the “Registration
Statement”) via EDGAR. We will also provide under separate cover courtesy copies of Amendment No. 6, as submitted and
marked to show the changes from post-effective amendment no. 4 to the Registration Statement.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

Asen Parachkevov and Megan Miller

September 6, 2016

Page 2

Post-Effective Amendment No. 4 to
the Registration Statement

 1. Please consider whether it is necessary to continue including disclosure on the front cover
relating to the aggregate market value of the Fund’s common stock held by selling stockholders.

Response:

The Fund believes that it is common practice
in the industry to include on the front cover the aggregate market value of securities being registered pursuant to a registration
statement that are held by the selling stockholders. The Fund believes that potential investors may view the information as material
and will expect to see the information disclosed in such a manner.

 2. Please confirm whether any of the collateralized loan obligation (“CLO”)
collateral managers referenced in the prospectus are affiliated persons of Stone Point Capital LLC or the Trident V Funds.

Response:

The Fund confirms that none of the CLO
collateral managers referenced in the prospectus are affiliated persons (as defined in Section 2(a)(3) of the Investment Company
Act of 1940, as amended (“1940 Act”)) of either Stone Point Capital LLC or the Trident V Funds.

 3. In the table presenting a description of the Fund’s portfolio investments, please clarify
that the aggregate exposure to senior secured loans is obtained indirectly through investments in CLOs.

Response:

The Fund has revised the table and added
a footnote clarifying that the Fund obtains exposure to underlying senior secured loans through its investments in CLOs.

 4. In the section entitled “Our Competitive Advantage,” the bullet with the
heading “Alignment of Interests” describes the application of the “hurdle rate.” Please add disclosure
explaining how the Fund’s obligation to pay monthly dividends on its preferred stock is not dependent upon meeting the hurdle
rate.

Asen Parachkevov and Megan Miller

September 6, 2016

Page 3

Response:

The Fund has added disclosure to the section
entitled “The Adviser and the Administrator – Investment Advisory Agreement – Management Fee and Incentive
Fee” that clarifies that the payment of monthly dividends on its preferred stock (including any preferred stock that
may be held by officers or other affiliates of the Adviser) is not subject to meeting the hurdle rate.

 5. Please explain in your response to the Staff why the assumption of the Fund’s adjusted
total assets in the Fees and Expenses Table decreased from $427.0 million in pre-effective amendment no. 5 to the Registration
Statement, which was filed on November 25, 2015, to $341.8 million in post-effective amendment no. 4 to the Registration Statement.

Response:

The Fund notes that the change in the assumption
regarding adjusted total assets is principally driven by (1) a decrease in the Fund’s net asset value, from $257.2 million
as of June 30, 2015 to $180.0 million as of March 31, 2016, and (2) an increase in the assumed rate at which the Fund incurs leverage,
from approximately 31% of total assets to 35% of total assets. The Fund notes that it has revised such assumption in Amendment
No. 6 in connection with the publication of the Fund’s unaudited consolidated financial statements as of and for the period
ended June 30, 2016, with the assumption being based on the Fund’s total assets as of June 30, 2016.

 6. If the assumptions used by the Fund in preparing the Fees and Expenses Table change while the
Registration Statement, or any amendment thereto, is still effective, please undertake to file a prospectus supplement with the
Commission reflecting such updated assumptions.

Response:

The Fund hereby undertakes to file a prospectus
supplement with the Commission that reflects any updates in the assumptions used in preparing the Fees and Expenses Table prior
to using the Registration Statement to offer common stock.

Asen Parachkevov and Megan Miller

September 6, 2016

Page 4

 7. Please provide the calculations supporting the amount listed in the Fees and Expenses Table
for the line “Interest payments on borrowed funds.” The Staff was unable to duplicate this result based upon the information
provided in the footnotes to the table.

Response:

As requested, attached as Annex A
to this letter are the calculations supporting the amount listed for the line “Interest payments on borrowed funds”
in the Fees and Expenses Table. The Fund notes that such amounts have been updated to reflect the updated figure included in Amendment
No. 6 for this line item.

 8. With respect to Footnote 3 to the Fees and Expenses Table, please explain to the Staff why expenses
related to the Fund’s dividend reinvestment plan are included in the calculation of “Other expenses.” See
General Instruction 4 in Item 3 of the Form N-2.

Response:

The Fund respectfully notes that the instructions
to the “Fees and Expenses” table require that fees that are charged to participating shareholder accounts be disclosed
as a separate line item under “Stockholder Transaction Expenses”. However, stockholders will bear the expenses incurred
by the Fund in connection with administering the Fund’s dividend reinvestment plan regardless of whether they actually participate
in that plan. The Fund, therefore, believes that it is more appropriate to treat such expenses as ongoing annual expenses of the
Fund for purposes of the presentation set forth in the “Fees and Expenses” table rather than as stockholder transaction
expenses specific to an offering pursuant to the Registration Statement.

 9. With respect to the Fund’s wholly-owned Cayman subsidiary (the “Cayman Subsidiary”):

 (i) Please confirm that the financial statements of the Cayman Subsidiary are consolidated with
those of the Fund.

Response:

The Fund confirms that the financial statements
of the Cayman Subsidiary are consolidated with those of the Fund.

Asen Parachkevov and Megan Miller

September 6, 2016

Page 5

 (ii) Please disclose that the Fund complies with the provisions of the 1940 Act governing investment
policies (Section 8) and capital structure and leverage (Section 18) on an aggregate basis with the Cayman Subsidiary.

Response:

The Fund confirms that the Fund aggregates
its direct investments with the Cayman Subsidiary’s investments when testing for compliance with Section 8 and Section 18.

 (iii) Please disclose that the Cayman Subsidiary complies with provisions relating to affiliated transactions
and custody (Section 17) and identify the custodian of the Cayman Subsidiary.

Response:

The Fund confirms that the Cayman Subsidiary complies with,
and will continue to comply with, the provisions relating to affiliated transactions under Section 17 of the 1940 Act and the rules
thereunder, and complies with, and will continue to comply with, the custody provisions of Section 17(f). Additionally, each of
the Fund and the Cayman Subsidiary utilizes the same custodian (Wells Fargo Bank, National Association).

 (iv) Disclose any of the Cayman Subsidiary’s principal investment strategies or principal risks
that constitute principal investment strategies or risks of the Fund.

Response:

The Fund confirms that, to the extent any
principal investment strategies and principal risks of the Cayman Subsidiary are deemed principal investment strategies and principal
risks of the Fund on an aggregate basis, such principal investment strategies and principal risks are disclosed as such in the
Fund’s prospectus.

 (v) Confirm that the Cayman Subsidiary is not subject
to a management fee.

Response:

The Fund confirms that the Cayman Subsidiary
is not subject to a management fee.

Asen Parachkevov and Megan Miller

September 6, 2016

Page 6

 (vi) Confirm that, in connection with its review of the Fund’s investment advisory agreement
under Section 15(c) of the 1940 Act, the Fund’s board of directors reviews the Fund and the Cayman Subsidiary on a consolidated
basis.

Response:

The Fund confirms that, in connection with
its review of the Fund’s investment advisory agreement under Section 15(c) of the 1940 Act, the Fund’s board of directors
considers the performance and expense data of the Fund and its subsidiaries (including the Cayman Subsidiary) on a consolidated
basis and may also consider the activities of the Cayman Subsidiary and the related nature and quality of the services provided
with respect to the Cayman Subsidiary together with its consideration of such factors in respect of the Fund. However, the Fund
respectfully notes that the Cayman Subsidiary is not a registered investment company under the 1940 Act and therefore is not subject
to the requirements of Section 15.

 (vii) Confirm that (1) the Cayman Subsidiary and its board of directors have designated an agent for
service of process in the United States; and (2) the Cayman Subsidiary and its board of directors will agree to inspection by the
Staff of the Cayman Subsidiary’s books and records, which will be maintained in accordance with Section 31 of the 1940 Act
and the rules thereunder.

Response:

The Fund hereby confirms that the Cayman
Subsidiary and its board of directors will designate a domestic (U.S.) agent for service of process, although
not required by applicable law. In addition, the Fund hereby confirms that the Cayman Subsidiary and its board of directors will
agree to examination of the Cayman Subsidiary’s books and records by the SEC. The books and records of the Cayman Subsidiary
are maintained in accordance with Section 31 of the 1940 Act and the rules thereunder together with the books and records of the
Fund.

 10. The section entitled “Prospectus Summary – Financing and Hedging Strategy –
Leverage by the Company” states that the Fund generally expects to operate with leverage within a range of 25% to 35%
of total assets. Please explain in your correspondence to the Staff how the Fund is permitted to incur leverage of over 33% of
total assets (less current liabilities).

Asen Parachkevov and Megan Miller

September 6, 2016

Page 7

Response:

The leverage range disclosed in the Registration
Statement and noted by the Staff is for a combined leverage ratio that includes both securities representing indebtedness and preferred
stock.  The Fund respectfully notes that the asset coverage restrictions under Section 18 of the 1940 Act for registered
closed-end companies such as the Fund apply separately to classes of senior securities that represent indebtedness and those that
represent stock. As Section 18(a)(2) only requires asset coverage of at least 200% with respect to preferred stock, to the extent
the Fund has preferred stock outstanding, its leverage ratio may exceed 33% of total assets (which would be the maximum leverage
permitted if such leverage represented only indebtedness).

 11. Please review the principal strategy and principal risk
disclosures related to derivatives and tailor the disclosures to the actual operations of the fund and related risks.

Response:

In drafting the disclosure relating to
derivatives, the Fund took into consideration the guidance set forth in the July 30, 2010 letter from Barry Miller to the Investment
Company Institute. The disclosure concerning derivatives reflects how such investments were expected to be utilized by the Fund
when it commenced operations. In response to the Staff’s request, and based on the Fund’s experience since it commenced
operations, the Fund has reviewed and further tailored the disclosures to reflect the Fund’s current expectations relating
to the Fund’s potential use of derivatives.

 12. Please disclose in the section entitled “Use of Proceeds” whether proceeds
could be used to make a return of capital.

Response:

The Fund has added disclosure to the section
entitled “Use of Proceeds” stating that proceeds of offerings may be used to pay distributions to stockholders
which may include a return of capital. The Fund supplementally notes that it has disclosed in each applicable prospectus supplement
if proceeds of an offering could be used to pay a distribution to the Fund’s stockholders.

Asen Parachkevov and Megan Miller

September 6, 2016

Page 8

 13. The Staff notes that the section entitled “Determination of Net Asset Value”
refers to a review of “information compiled by the Adviser.” Please disclose in more detail the information the Adviser
uses to estimate fair value and whether such information includes a discounted cash flow analysis (or explain in correspondence
where such disclosure is presented). The Staff requests that the Fund provide as much detail on the Adviser’s valuation process
as possible.

Response:

The Fund notes that Notes 2 and 3 to the
Fund’s consolidated financial statements as of and for the period ended March 31, 2016, and Notes 2 and 3 to the Fund’s
consolidated financial statements as of and for the period ended June 30, 2016, each describe the valuation techniques and inputs
used in the Adviser’s fair valuation process for the Fund’s investments. The Fund also notes that both the narrative
disclosure and the table summarizing the quantitative inputs and assumptions used for investments categorized in Level III of the
fair value hierarchy in Note 3 describe the use of discounted cash flow techniques. The Fund has added additional detail consistent
with such notes to the prospectus in response to the Staff comment.

Periodic Review of the Fund’s
Public Filings Pursuant to the Sarbanes-Oxley Act of 2002

 14. Please explain why the Fund filed an amended Form NSAR-B on March 2, 2015. Going forward, please
also undertake to provide a cover letter to the Staff in connection with any future amended filings explaining the reason for such
filing.

Response:

Due to administrative oversight, the initial
filing of the Fund’s NSAR-B for the fiscal year ended December 31, 2014 did not include the required exhibits. Less than
three hours later, upon discovering the error, the Fund filed an amended NSAR-B to include such exhibits. The Fund hereby undertakes
to provide a cover letter to the Staff in connection with any future amended filings explaining the reason for such filing.

 15. The Staff notes that neither the Fund’s audited Consolidated Statement of Assets and Liabilities
as of December 31, 2015, as included in the Form N-CSR filed with the

CORRESP
1
filename1.htm

EAGLE
POINT CREDIT COMPANY INC.

20 Horseneck Lane

Greenwich, Connecticut 06830

November 24, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

Attention: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

Registration Statement on Form N-2

File Numbers: 333-205540; 811-22974

Dear Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
Eagle Point Credit Company Inc., a Delaware corporation (the “Company”), respectfully requests acceleration
of the effective date of pre-effective amendment no. 5 to its Registration Statement on Form N-2 (File Nos. 333-205540; 811-22974)
(the “Registration Statement”) so that such Registration Statement may be declared effective on Wednesday,
November 25, 2015, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone
call to Thomas J. Friedmann of Dechert LLP at (617) 728-7120, and that such effectiveness also be confirmed in writing.

The Company hereby acknowledges that (i) should the Securities
and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”),
acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action
with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure
in the filing; and (iii) the Company may not assert this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very truly yours,

    Eagle Point Credit Company Inc.

    By:
    /s/ Thomas P. Majewski

    Name:
    Thomas P. Majewski

    Title:
    Chief Executive Officer

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006-1110

        +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

November 23, 2015

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

Registration Statement on Form N-2

File Numbers: 333-205540; 811-22974

Dear Mr. Parachkevov:

On behalf of Eagle Point Credit
Company Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) in
phone calls between Asen Parachkevov of the Staff and Philip T. Hinkle and Erin M. Lett of Dechert LLP, outside counsel
to the Fund, on November 20, 2015 and between Mr. Parachkevov and Ms. Lett on November 23, 2015.

For your convenience, the Staff’s
comments are summarized in this letter, and each summarized comment is followed by the applicable response. Concurrently, the Fund
is filing pre-effective amendment no. 5 (“Amendment No. 5”) to its registration statement on Form N-2 (the “Registration
Statement”) via EDGAR. We will also provide under separate cover courtesy copies of Amendment No. 5, as submitted and
marked to show the changes from pre-effective amendment no. 4 to the Registration Statement.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

 1. Please provide the status of review by the Financial Industry Regulatory Authority (“FINRA”)
of the Registration Statement.

Response:	The Fund hereby confirms
that the Registration Statement has been reviewed and cleared by FINRA.

        Asen Parachkevov

        November 23, 2015

        Page 2

 2. Please confirm that the Fund will submit any underwritten offering pursuant to the Registration
Statement to FINRA for its prior approval of the underwriting terms.

Response:	The Fund hereby confirms
that it will submit any underwritten offering pursuant to the Registration Statement to FINRA for its prior approval of the underwriting
terms.

 3. Please confirm that all material terms (other than pricing terms), including the senior or subordinated
status, of any securities that may be offered pursuant to the Registration Statement are reflected in the relevant form of prospectus
supplement filed as an exhibit to the Registration Statement. Please undertake that the Fund will file and have declared effective
a post-effective amendment to the Registration Statement prior to any offering of securities for which the material terms differ
from those in the form of prospectus supplement.

Response:	The Fund hereby confirms
that all material terms (other than pricing terms) of any securities that may be offered pursuant to the Registration Statement
are reflected in the relevant form of prospectus supplement filed as an exhibit to the Registration Statement. The Fund also notes
that, as a registered closed-end fund, the Fund can only issue a single class of senior securities representing indebtedness and,
therefore, all debt securities issued pursuant to the Registration Statement will have the same ranking.

In addition, the Fund undertakes to file
and have declared effective a post-effective amendment to the Registration Statement prior to any offering of securities for which
the material terms differ from those in the relevant form of prospectus supplement.

 4. Please confirm that the offering document for any offering pursuant to the Registration Statement
for the account of a stockholder will comply with the requirements of Item 6 of Form N-2.

Response:	The Fund
hereby confirms that the offering document for any offering pursuant to the Registration Statement for the account of a
stockholder will comply with the requirements of Item 6 of Form N-2. The Fund supplementally notes that the disclosure in
Amendment No.5 complies with the requirements of Item 6 as of November 23, 2015 and that such disclosure will be included and
updated in the prospectus supplement for any offering in which a selling stockholder participates.

 5. Please confirm that any selling stockholder that is
an affiliate of the Fund will bear its own expenses in connection with any offering.

Response: The Fund hereby
confirms that any selling stockholder who is an affiliate of the Fund at the time of the applicable offering will bear its
own expenses, including any incremental printing, legal, filing or similar expenses incurred as a result of the
selling stockholder’s participation in the offering, and has revised its disclosure consistent with this comment. The
Fund supplementally notes that each of the identified selling stockholders is currently an affiliate of the Fund.

 6. Revise the Fee Table to include an assumption regarding leverage that the Fund will incur in
the next 12 months.

Response:	As requested, the Fund
has revised the Fee Table in this Registration Statement to reflect an assumption regarding leverage to be incurred by the Fund
in the next 12 months. Consistent with this comment, for this Registration Statement, the Fund has also revised the Effects of
Leverage table to reflect such assumption regarding leverage.

        Asen Parachkevov

        November 23, 2015

        Page 3

* * * * * * * * *

The Fund hereby acknowledges that (i) it
is responsible for the adequacy and accuracy of the disclosure in its filings with the Commission, (ii) the action of the Commission
or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not foreclose the Commission from
taking any action with respect to any filing, (iii) the action of the Commission or the Staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Fund from full responsibility for the adequacy and accuracy of disclosure
in its filings and (iv) the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

* * * * * * * * *

If you have any questions, please feel
free to contact the undersigned by telephone at 202.261.3460 or by email at philip.hinkle@dechert.com or Thomas J. Friedmann at
617.728.7120 or by email at thomas.friedmann@dechert.com. Thank you for your cooperation and attention to this matter.

Sincerely,

/s/ Philip T. Hinkle

Philip T. Hinkle

 cc: Thomas P. Majewski, Chief Executive Officer, Eagle Point
Credit Company Inc.

Nauman S. Malik, General Counsel, Eagle
Point Credit Management LLC

Thomas J. Friedmann, Dechert LLP

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006-1110

        +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

September 11, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

  Registration Statement on Form N-2

  File Numbers: 333-205540; 811-22974

Dear Mr. Parachkevov:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comment raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in a phone call between Asen Parachkevov of
the Staff and Philip T. Hinkle and Erin M. Lett of Dechert LLP, outside counsel to the Fund, on September 1, 2015.

For your convenience, the Staff’s
comment is repeated in this letter, followed by the applicable response. Concurrently, the Fund is filing pre-effective amendment
no. 3 (“Amendment No. 3”) to its registration statement on Form N-2 (the “Registration Statement,”
and the prospectus contained therein, the “Prospectus”) via EDGAR. We will also provide under separate cover
courtesy copies of Amendment No. 3, as submitted and marked to show the changes from pre-effective amendment no. 2 to the Registration
Statement.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

 1. Please provide a brief description of loan accumulation facilities on the front cover of the
Prospectus.

Response:	The Fund
has revised its disclosure consistent with this comment.

        September 11, 2015

        Page 2

The Fund hereby acknowledges that (i) it
is responsible for the adequacy and accuracy of the disclosure in its filings with the Commission, (ii) the action of the Commission
or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not foreclose the Commission from
taking any action with respect to any filing, (iii) the action of the Commission or the Staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Fund from full responsibility for the adequacy and accuracy of disclosure
in its filings and (iv) the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

* * * * * * * * *

If you have any questions, please feel
free to contact the undersigned by telephone at 202.261.3460 or by email at philip.hinkle@dechert.com or Thomas J. Friedmann at
617.728.7120 or by email at thomas.friedmann@dechert.com. Thank you for your cooperation and attention to this matter.

Sincerely,

/s/ Philip T. Hinkle

Philip T. Hinkle

 cc: Thomas P. Majewski, Chief Executive Officer, Eagle Point
Credit Company Inc.

   Nauman S. Malik, General Counsel, Eagle Point Credit
Management LLC

   Anna T. Pinedo, Morrison & Foerster LLP

CORRESP
1
filename1.htm

August 11, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

  Registration Statement on Form N-2

  File Numbers: 333-205540; 811-22974

Dear Mr. Parachkevov:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in the letter dated August 6, 2015 from Asen
Parachkevov of the Staff to Thomas Friedmann of Dechert LLP, outside counsel to the Fund.

For your convenience, the Staff’s
comments are repeated in this letter, and each comment is followed by the applicable response. Concurrently, the Fund is filing
pre-effective amendment no. 2 (“Amendment No. 2”) to its registration statement on Form N-2 (the “Registration
Statement,” and the prospectus contained therein, the “Prospectus”) via EDGAR. We will also provide
under separate cover courtesy copies of Amendment No. 2, as submitted and marked to show the changes from pre-effective amendment
no. 1 to the Registration Statement.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

General

 1. 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 pre-effective amendments.

Response:	The Fund acknowledges
the Staff’s comment.

        August 11, 2015

        Page 2

 2. Please advise us if you have submitted any exemptive application(s) or no-action request(s)
in connection with your Registration Statement.

Response:	Although no exemptive
or no-action relief has been, or is expected to be, requested with respect to the Registration Statement, the Fund received an
order from the Commission on March 17, 2015 that granted the Fund an exemption from section 17(d) of the Investment Company Act
of 1940, as amended (the “1940 Act”), and rule 17d-1 under the 1940 Act permitting the Fund to participate in
certain negotiated co-investments alongside other accounts managed by Eagle Point Credit Management LLC, the Fund’s investment
adviser (the “Adviser”), subject to certain conditions.

 3. Please state in your response letter whether FINRA has reviewed or will review the proposed
underwriting terms and arrangements of the transaction involved in the Registration Statement.

Response:	The Fund hereby confirms
that the Registration Statement has been filed with FINRA and that the FINRA examiner has notified the Staff verbally that no objections
have been issued by FINRA with respect to the underwriting terms and arrangements.

 4. Please advise the Staff whether the Fund intends to supplement its registration statement pursuant
to which its common and preferred shares are currently offered, in order to reflect the issuance of preferred stock. We may have
additional comments.

Response:	The Fund respectfully
submits that the public offerings of the Fund’s common stock and preferred stock closed in October 2014 and May 2015, respectively,
and the Fund is not currently offering shares of either its common stock or its preferred stock. The Fund undertakes to reflect
outstanding preferred stock, if any, in future registration statements.

 5. Please explain in your response whether the CLO vehicles in which the Fund invests would be
deemed to be investment companies under the 1940 Act but for the exceptions set forth in Section 3(c)(1) or 3(c)(7). Please explain
to us why the Fund should not be subject to the same limits regarding investor qualifications (e.g. accredited investors and investment
minimums) as registered funds of hedge funds and registered funds of private equity funds. In your explanation, please explain
how the CLO vehicles are similar to, and different from, private funds, such as hedge funds and private equity funds. As part of
your explanation, please also discuss: (1) the amount of leverage in the Fund’s CLO investments, including the average leverage
of the Fund’s CLO investments that has the highest leverage (e.g. 10 times leverage); (2) whether the Fund has any limits
on investment in a CLO investments that exceeds a certain amount of leverage, and (3) whether the managers of the CLO are generally
entitled to performance fees, and what those performance fees are based on (e.g. limited to income, or also include performance
fees on capital gains).

        August 11, 2015

        Page 3

Response: 	Although we expect
that substantially all of the CLOs whose securities the Fund may acquire would be deemed to be investment companies under the 1940
Act but for the exception set forth in Section 3(c)(7) of the 1940 Act,1
the Fund notes that it invests in securities issued in capital market transactions and not hedge fund or private equity fund interests.
As noted by the Staff, the Fund acknowledges that registered funds of private investment funds2
(each a “Registered FOPF”) have historically adhered to certain investor eligibility standards and investment
minimums and, as such, have historically not listed their shares on a national securities exchange.3
However, the Fund respectfully notes that not all issuers that rely on Section 3(c)(7) of the 1940 Act are private investment funds
and many issuers that rely on Section 3(c)(7) do not present the same risks or considerations as private investment funds.4
In many cases, issuers choose to rely on Section 3(c)(7) because doing so is simple, convenient and well-understood. Such issuers
may not have considered whether another exception would be available.

 1 In our experience, some issuers that appear to be relying on Section
3(c)(7) based on their disclosures and offering practices could also potentially rely on other exceptions such as Section 3(c)(5)
or Rule 3a-7.

 2 For ease of reference, hedge funds and private equity funds are referred to collectively in this
letter as “private investment funds”.

 3 See Implications of the Growth of Hedge Funds, Staff
Report to the United States Securities and Exchange Commission (Sep. 29, 2003) at nn. 237 and 250 (and accompanying text)
(“2003 Hedge Fund Report”). The Fund notes that the Staff expressly stated that certain of these investor qualifications
are not required by law. Id. at n. 239 (and accompanying text) (“[r]egistered [funds of hedge funds], however, may
lower or eliminate the investment minimum at any time because this investment qualification is not required by law.”)
(emphasis added).

 4 Many issuers that are not private investment funds rely on Section 3(c)(7) as a default matter
as it is a relatively simpler exception to meet from investment company regulation than the other available exceptions and exemptions
under the 1940 Act, which require detailed analysis of an issuer’s characteristics. For an issuer to rely on Section 3(c)(7),
all of the outstanding securities of the issuer must be owned by persons who are “qualified purchasers” at the time
of acquisition of the securities. In this respect, an issuer’s reliance on Section 3(c)(7) to issue its securities can be
seen as being similar to an issuer’s reliance on Rule 144A under the Securities Act of 1933, as amended, to issue unregistered
securities to “qualified institutional buyers.” As the Staff is aware, open-end and closed-end registered investment
companies routinely invest in Rule 144A securities that a retail investor could not otherwise directly acquire.

        August 11, 2015

        Page 4

The Fund respectfully submits that: (i) the
Fund is fundamentally different from a Registered FOPF; and (ii) the CLOs themselves are clearly distinguishable from the private
investment funds in which a typical Registered FOPF invests. As detailed further below, CLOs possess certain attributes that distinguish
them from a typical private investment fund, including the following: (i) CLOs pursue narrowly defined long-only investment
mandates, (ii) CLOs provide complete transparency to their investors, (iii) the management and performance fee structure of CLOs
is not based on unrealized gains from underlying investments and (iv) CLO securities are issued with CUSIPs and are actively traded
on a secondary market.

Accordingly, the Fund believes that restricting
the ability of investors to invest in the Fund (whether by imposing certain eligibility criteria or by requiring higher investment
minimums) is neither necessary nor desirable for the protection of retail investors in the Fund. The Fund respectfully submits
that any such restriction could adversely impact the Fund’s stockholders by impairing the ability of the Fund to raise capital
and the ability of the Fund’s stockholders to freely liquidate their shares, among other adverse effects.5

 · A CLO’s investment strategy is more straightforward than that of a typical private
investment fund. CLOs, like nearly all forms of securitization, are long only vehicles that may only invest in a narrowly
defined set of assets (e.g., secured corporate loans).6
CLOs are subject to numerous portfolio compliance tests that must be adhered to and that are detailed in a CLO’s indenture.
Compliance with these tests is monitored by each CLO’s trustee. These tests are discussed in more detail in the Prospectus.
In addition, CLOs have contractual limitations on levels of trading activity. CLOs also do not hedge or leverage their positions
through the use of derivatives (with a limited exception for hedging of interest rate risk for corporate loans). As a result, a
CLO’s return is principally derived from the interest income received from its loan portfolio rather than from capital gains
on that portfolio. Given these attributes, a CLO’s investment strategy (and the Fund’s strategy of investing in securities
issued by CLOs) is relatively straightforward to understand as compared to a typical private investment fund’s investment
strategy. Further, a CLO’s investment program is contractually required to remain consistent over time.

 5 The Fund’s common stock and preferred stock are listed on the New York Stock Exchange. Accordingly,
in response to information reported by the Fund or for any other reason, the Fund’s current stockholders may freely sell
their shares on the open market. As of August 10, 2015, the Fund’s common stock traded at an approximate 9% premium to its
estimated net asset value as of June 30, 2015. We believe the Fund’s transparency into the underlying loan portfolios of
its CLO investments (as discussed below) is a significant reason why investors may be willing to pay a premium to NAV for the Fund’s
common stock.

 6 By contrast, and as discussed below, most hedge funds are permitted to invest in nearly any kind
of investment. Although some have investment objectives and restrictions that serve as practical limits on the types of investments
that can be made, very few, if any, hedge funds are as restricted in their investment activities.

        August 11, 2015

        Page 5

By contrast, many hedge funds
reserve the ability to engage in complex and varied trading strategies and may utilize hedging techniques to either increase returns
or modify portfolio risk profiles. Such private investment funds typically may engage in significantly higher levels of trading
activity than CLOs. In addition, unlike a CLO which generates its returns primarily from interest income received from its loan
portfolio, typical private equity funds, and many hedge funds, primarily generate a significant portion of returns from capital
gains on underlying portfolio investments.

Because of their simpler and
more consistent investment strategy and approach, the Fund respectfully submits that CLOs do not raise issues regarding the ability
of a retail investor to understand a CLO’s core investment strategy in the same way that a typical private investment fund
does.7

 · On a monthly basis, the Fund has complete transparency into the underlying loan portfolios
and loan portfolio transactions of the CLOs whose securities the Fund holds. By contrast, transparency for private investment funds
is dependent upon the reporting provided by the private investment fund’s sponsor or the contents of the annual audit report.
The Fund receives a monthly report from each CLO’s trustee that lists all of the loans held in that CLO’s portfolio
as well as all portfolio transactions that occurred in the portfolio during the month.8
The trustee that provides this report is an independent third party unrelated to the CLO’s collateral manager. This information
allows the Fund to report summary underlying portfolio characteristics, including the Fund’s top 10 overall loan obligor
and industry exposures. The Fund has begun to report this information on a monthly basis from May 2015. The ability of Fund investors
to have access to such information, and the ability of the Fund to report such information on a regular basis, significantly distinguishes
the Fund from typical Registered FOPFs that invest predominantly in hedge funds.

 7 As noted in the 2003 Hedge Fund Report, Registered FOPFs “typically disclose the various
investment strategies that the underlying hedge funds may employ, including, in some cases, the impact of style shifts in underlying
hedge funds on the [Registered FOPF’s] ability to achieve its stated investment objective.” 2003 Hedge Fund Report
at 72. As described above, each CLO has the same (or substantially similar) investment strategy and the need to explain multiple
investment strategies and issues relating to style shift are not applicable to CLOs.

 8 The Fund notes that this level of transparency exceeds even that which registered investment companies
are required to make available both in terms of frequency and level of information as these reports are produced monthly and provide
not only a snapshot of portfolio positions, but also information regarding each portfolio transaction during the reporting period.

        August 11, 2015

        Page 6

Registered FOPFs typically do
not have this level of information regarding the portfolio holdings and characteristics of the underlying private investment funds
(and to the extent any such information is provided to a Registered FOPF, such information would likely be provided by a private
investment fund’s manager or sponsor rather than a third party).9
As a result, such Registered FOPFs would be unable to provide reporting that may be important to retail investors or that otherwise
provides insight on the private investment fund’s overall risk profile.

 · The SEC specifically distinguished CLOs (which are nearly always “securitized
asset funds”) from “hedge funds” and “private equity funds” through definitions of these terms in
Form ADV and Form PF. In requiring issuers that rely on Section 3(c)(7) under the 1940 Act to be classified on Form ADV
and Form PF, the Commission has expressly recognized that not all Section 3(c)(7) issuers are alike. Form ADV and Form PF identify
several categories of such issuers, including “hedge fund,” “private equity fund” and “securitized
asset fund.” A “securitized asset fund” is defined as any private fund whose primary purpose is to issue asset
backed securities and whose investors are primarily debt-holders.10
In practice, based on our understanding of how CLOs are operated, all CLOs should be classified as “securitized asset funds”
and, as a result, no CLO will be classified as a hedge fund or private equity fund for purposes of Form ADV and Form PF. The Commission’s
definitions for purposes of classifying private funds make clear that the Commission recognizes a meaningful distinction between
issuers such as

1

August 6 , 2015

Thomas Friedman n
Dechert LLP
1900 K Street, NW
Washington, DC 20006 -1110

Re:  Eagle Point Credit Company Inc.
Registration Statement on Form N -2
File Number s: 333 -205540 ; 811 -22974

Dear M r. Friedman n:

Eagle Point Credit Compan y Inc.  (the “Fund”) filed a  registration statement on July 7 , 201 5,
which was subsequently amended on July 22, 2015  (the “Registration Statement ”).  The filing s
were  made for the purpose of  registering notes  of the Fund.  Based on our review of the
Registr ation Statement, we have the following comments.  The captions used below correspond
to the captions the Fund uses in its Registration S tatement.  Please note, however, that the
comments we give in one section are applicable to other sections of the Regist ration S tatement
that contain similar disclos ure, unless otherwise indicated.

General

1. We note that portions of t he R egistration Statement are incomplete .  We may have
additional comments on such portions when you complete them in a pre -effective
amendmen t, on disclosures made in response to this letter, on information supplied
supplementally, or on exhibits added in any pre -effective amendments.

2. Please adv ise us if you have submitted any exemptive application (s) or no -action
request (s) in connection wit h your Registration S tatement.

3. Please state in your response letter whether FINRA has reviewed or will review the
proposed underwriting terms and arrangements of the transaction involv ed in the
Registration Statement .

4. Please advise the Staff whether the Fund intends to supplement its registration statement
pursuant to which its common  and preferred  shares are currently offered, in order to
reflect the issuance of preferred stock . We may have additional comments.

2
 5. Please explain in your response whether th e CLO vehicles in which the Fund invests
would be deemed to be investment companies under the 1940 Act but for the exceptions
set forth in Section 3(c)(1) or 3(c)(7).  Please explain to us why the Fund  should not be
subject to the same limits regarding inv estor qualifications (e.g. accredited investors and
investment minimums) as registered funds of hedge funds and registered funds of private
equity funds.  In your explanation, please explain how the CLO vehicles are similar to,
and different from, private funds, such as hedge funds and private equity funds.  As part
of your explanation, please also discuss: (1) the amount of leverage in the Fund’s CLO
investments, including the average leverage of the Fund’s CLO investments that has the
highest leverage (e. g. 10 times leverage); (2) whether the Fund has any limits on
investment in a CLO investments that exceeds a certain amount of leverage, and (3)
whether the managers of the CLO are generally entitled to performance fees, and what
those performance fees are  based on (e.g. limited to income, or also include performance
fees on capital gains).

Cover Page

6. It is disclosed that the Fund  does not intend to list the Notes on an exchange. Please
include the following additional disclosure:  “ Thus, an investment in  the Notes  may not
be suitable for investors who may need the money they invest in a specified timeframe .”

Prospe ctus

Prospectus Summary  – Eagle Point Credit Company

Page 1

7. Please provide additional details regarding the structure and operation of loa n
accumulation facilities. In your response, please address the concerns raised by Comment
5 above.

Prospectus Summary – Portfolio

Page 2

8. In your response, please explain to the Staff how the Fund is able to compile  the
information regarding loan  and b orrower characteristics underling the CLOs in which the
Fund invests? Have the CLO vehicles provided the Fund with portfolio information as of
March 31, 2015?

Prospectus Summary – Initial Public Offering

Page 3

9. It is stated that the Fund has made three  quarterly distributions on its common stock,
representing a 12% annualized rate of distribution . The disclosure states that  45% and

3
 32%, respectively, of the two first two distributions represen t return of capital. Please
explain briefly the tax consequen ces for shareholders of receiving distributions that may
be characterized as return of capital.

Prospectus Summary – Summary Risk Factors – First Loss Risk of CLO Equity and Subordi nate
Securities

Page 9

10. Please include additional disclosure that CLO vehicles are highly leveraged and provide
the average leverage of the CLO vehicles in which the Fund invests (see Comment 5
above), which subjects  the Fund’s investments, i.e. CLO equity and debt tranches , to
higher ris k of total loss. Please also include the disc losure on the Cover Page .

The Offering  – Use of Proceeds

Page 14

11. Please disclose whether proceeds from the notes offering may be used to maintain the
Fund’s distribution rate.  We may have additional comments.

Business – Overview of Seni or Secured Loans

Page 49

12. The graph illustrating the lagging 12 -month default rate of the S&P/LSTA Leveraged
Loan Index appears to be missing years 2004, 2008 and 2012 on the x -axis. Please
explain in your response.

Business  – Temporary Defensive Positi on

Page 57

13. The disclosure states that the Fund  may take temporary defensive positions and invest in
cash equivalents, government securities or short -term fixed income securities. Please
explain that taking a defensive position may not be possible given t he illiquid nature of
the Fund ’s investments.

*     *     *     *     *     *

You are reminded that the burden of full and fair disclosure rests with each registrant, its
counsel, and others eng aged in the preparation of the Registration S tatement. As a matter of law,
this burden cannot be shifted to the Commission or its staff.

4
  Notwithstanding our comments, please furnish a letter with respect to the Fund
acknowledging that:

 the Fund is responsible for the adequacy and accuracy of the disclosure in it s
filings;

 should the Commission or the staff, acting pursuant to delegated authority, declare
the filing effective, it does not foreclose the Commission from taking any action
with respect to the filing;

 the action of the Commission or the staff, acting  pursuant to delegated authority, in
declaring the filing effective, does not relieve the Fund from full responsibility for
the adequacy and accuracy of the disclosure in the filings;

 the Fund may not assert this action as a defense in any proceeding init iated by the
Commission or any person under the Federal securities laws of the United States.

        In addition, please be advised that the Division of Enforcement has access to all
information you provide the staff of the Division of Investment Managem ent in connection with
our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the registration
statements as confirmation that those requesting acceleration are  aware of their respective
responsibilities.

Please respond to this letter in the form of a pre -effective amendment for the Fund.
Please respond to all comment letters in a letter filed in the form of EDGAR correspondence.
Where no changes will be made in response to a comment, please so state in your letter and
explain the basis for your position.  The staff may have further comments after reviewing your
responses.

 Should you have any questions regarding this letter, please contact me at (202) 551 -
6908.

Sincerely,

         /s/ Asen Parachkevov
Attorney Adviser

CORRESP
1
filename1.htm

EAGLE
POINT CREDIT COMPANY INC.

20 Horseneck Lane

Greenwich, Connecticut 06032

May 11, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

Attention: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

Registration Statement on Form N-2

File Numbers: 333-202914; 811-22974

Dear Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
Eagle Point Credit Company Inc., a Delaware corporation (the “Company”), respectfully requests acceleration
of the effective date of pre-effective amendment no. 2 to its Registration Statement on Form N-2 (File No. 333-202914; 811-22974)
(the “Registration Statement”) so that such Registration Statement may be declared effective at 2:00 p.m. on
Tuesday, May 12, 2015, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone
call to Thomas J. Friedmann of Dechert LLP at (202) 261-3313, and that such effectiveness also be confirmed in writing.

The Company hereby acknowledges that (i) should the Securities
and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”),
acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action
with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure
in the filing; and (iii) the Company may not assert this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very truly yours,

    Eagle Point Credit Company Inc.

    By:
    /s/ Thomas P. Majewski

    Name:
    Thomas P. Majewski

    Title:
    Chief Executive Officer

CORRESP
1
filename1.htm

May 11, 2015

Mr. Asen Parachkevov

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.
20549-0504

Eagle
Point Credit Company Inc.

Registration
Statement on Form N-2

File
Nos. 333-202914 and 811-22974

Dear Mr. Parachkevov:

Pursuant to Rule 460 of the General
Rules and Regulations under the Securities Act of 1933, as amended, we, on behalf of the several underwriters, wish to advise
you that distribution of the Registration Statement on Form N-2 as filed on March 20, 2015 and the Preliminary Prospectus
dated May 11, 2015, began on May 11, 2015 and is expected to conclude at approximately 5:00 p.m., Eastern Time, on May
12, 2014, with anticipated distribution results as follows: a limited number of Registration Statements have or will be sent
to underwriters and approximately 1,800 copies of the Preliminary Prospectus have or will be sent to underwriters, dealers
and institutions.

In accordance with Rule 461 of the
General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, on behalf of the underwriters of
the offering of Series A Term Preferred Stock of Eagle Point Credit Company Inc. (the “Fund”), hereby joins in
the request of the Fund for acceleration of the effective date of the above-named Registration Statement so that it becomes
effective at 2:00 p.m., Eastern Time, on May 12, 2015 or as soon thereafter as practicable.

[Signature page follows]

Sincerely,

Deutsche Bank Securities Inc. and Keefe, Bruyette &
Woods, Inc.

On behalf of the Several Underwriters

By: Deutsche Bank Securities Inc.

By:
 /s/ Anguel Zaprianov

Name:  Anguel Zaprianov

Title:    Managing Director

By:
 /s/ Adam Raucher

Name:   Adam Raucher

Title:     Director

By: Keefe, Bruyette & Woods, Inc.

By:
 /s/ Justin P. Bowman

Name:  Justin
P. Bowman

Title:    Managing Director

[Signature
Page to Underwriters’ Acceleration Request]

CORRESP
1
filename1.htm

April 29, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company Inc.

  Registration Statement on Form N-2

  File Numbers: 333-202914; 811-22974

Dear Mr. Parachkevov:

On behalf of Eagle Point Credit Company
Inc., a Delaware corporation (the “Fund”), we hereby respond to the comments raised by the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in the letter dated April 17, 2015 from Asen
Parachkevov, Attorney Adviser, to Thomas Friedmann, outside counsel to the Fund.

For your convenience, the Staff’s
comments are repeated in this letter, and each comment is followed by the applicable response. Concurrently, the Fund is filing
pre-effective amendment no. 1 (“Amendment No. 1”) to its registration statement on Form N-2 (the “Registration
Statement” and the prospectus contained therein, the “Prospectus”) via EDGAR. We will also provide
under separate cover courtesy copies of Amendment No.1, as submitted and marked to show the changes from the initial filing of
the Registration Statement.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

April 29, 2015

Page 2

General

 1. 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 pre-effective amendments.

Response:	The Fund acknowledges
the Staff’s comment.

 2. Please advise us if you have submitted any exemptive application(s) or no-action request(s)
in connection with your Registration Statement.

Response:	Although no
exemptive or no-action relief has been, or is expected to be, requested with respect to the Registration Statement, the Fund
received an order from the Commission on March 17, 2015 that granted the Fund an exemption from section 17(d) of the
Investment Company Act of 1940, as amended (the “1940 Act”), and rule 17d-1 under the 1940 Act permitting
the Fund to participate in certain negotiated co-investments alongside other accounts
managed by Eagle Point Credit Management LLC, the Fund’s investment adviser (the “Adviser”), subject to
certain conditions.

 3. Please state in your response letter whether FINRA has reviewed or will review the proposed
underwriting terms and arrangements of the transaction involved in the Registration Statement.

Response:	The Fund hereby confirms
that the Registration Statement has been filed with FINRA. The Fund or underwriters’ counsel will address and resolve any
FINRA comments prior to effectiveness of the Registration Statement, and underwriters’ counsel will ask the FINRA examiner
to notify the Staff once verbal no objections have been issued by FINRA with respect to the underwriting terms and arrangements.

 4. Please advise the Staff whether the Fund intends to supplement its registration statement pursuant
to which its common shares are currently offered, in order to reflect the issuance of preferred stock. We may have additional comments.

Response:	The Fund respectfully
submits that the initial public offering of the Fund’s common stock closed on October 17, 2014 and the Fund is not currently
offering shares of its common stock. The Fund undertakes to reflect outstanding preferred stock, if any, in future registration
statements pursuant to which common stock is offered.

April 29, 2015

Page 3

Cover Page

 5. It is disclosed that the CLOs in which the Fund seeks to invest are collateralized by a diverse
portfolio consisting primarily of below investment grade U.S. senior loans. Since the Fund is classified as “non-diversified”
as the term is defined in Section 5(b)(2) of the 1940 Act, please use alternative language to avoid confusion. Please make this
change throughout the Registration Statement. With respect to references to unrated or below investment grade securities, please
define such securities as “junk.”

Response: The Fund has revised its
disclosure consistent with this comment.

 6. It is disclosed that the Fund “may” also invest in other securities and instruments,
to the extent such investments are consistent with the Fund’s objectives, including senior debt tranches of CLOs and loan
accumulation facilities. To what extent does the Adviser expect to make such investments? Do investments in loan accumulation facilities
and other direct investments constitute part of the Fund’s principal strategy? We may have additional comments.

Response: As noted in
the Prospectus, the Fund seeks to achieve its investment objectives by primarily investing in CLO equity and junior
debt tranches. However, the Fund may invest in other securities and instruments to the extent such investments are consistent
with the Fund’s objectives. The Fund’s total investment in these other securities and instruments as a percentage
of its total assets may vary from time to time depending on the Adviser’s assessment of prevailing market conditions
and available investment opportunities. In certain circumstances, such investments could comprise a material percentage of
the Fund’s investment portfolio. As of December 31, 2014, for example, investments in loan accumulation
facilities comprised 14% of the Fund’s portfolio by value, although the Fund only held one such position. As such, the
Prospectus includes a discussion of risks associated with those CLO-related securities and instruments that the Adviser
expects could, from time to time, constitute a material percentage of the Fund’s investment portfolio (see
“Risk Factors—Risks Related to Our Investments — We are subject to risks associated with loan accumulation
facilities.”). The Fund notes that it has revised its disclosure consistent with this response to clarify its
investment in such other securities and instruments.

 7. The disclosure states that the Fund intends to pay monthly dividends on its Series A Term Preferred
Stock at a specified rate. Please include a clarification that the payment of such dividend may be suspended by the Board indefinitely,
subject to the requirements of the 1940 Act.

April 29, 2015

Page 4

Response: The Fund has revised its
disclosure under the heading “The Offering—Dividends” to note that the Fund’s board of directors may determine
not to declare a dividend for any given month. However, the Fund supplementally notes that, as stated elsewhere in the disclosure,
any unpaid dividends (whether or not declared) must be paid upon the redemption of the Series A Term Preferred Stock, that the
Fund may not pay cash distributions to its common stockholders until all dividends on the Series A Term Preferred Stock for past
dividend periods have been declared and paid and that failure by the Fund to pay dividends equal to two full years will result
in the holders of the Series A Term Preferred Stock obtaining the right to elect a majority of the Funds’ board of directors.

 8. It is disclosed that the Series A Term Preferred Stock “will rank senior in right of payment
to our common stock and will rank equally in right of payment with any shares of preferred stock that we may issue.” Please
disclose that the Series A Term Preferred Stock is subordinated to the rights of any senior indebtedness and state the extent to
which such indebtedness is currently outstanding.

Response: The Fund has revised its
disclosure consistent with this comment.

Prospectus

Prospectus Summary—Eagle Point Credit Company

Page 2

 9. It is stated that the Adviser may exercise certain protective rights associated with holding
a majority position in a CLO equity tranche. How frequently has the Adviser exercised such rights in the past? Please remove the
statement if such rights are exercised only infrequently.

Response:  The Adviser has exercised
protective rights on behalf of the Fund in one instance since the Fund’s inception and members of the Senior Investment Team
have exercised protective rights on behalf of other persons previously over the course of their careers. While these protective
rights are expected to be exercised a minority of the time, the Fund believes that these rights confer meaningful protective value
to the Fund if and when they are exercised. Accordingly, securing certain protective rights is an important aspect of the Fund’s
investment strategy. Given such importance, the Fund respectfully submits that disclosure regarding protective rights is appropriate
to include in the Prospectus. However, the Fund has revised its disclosure to clarify that, under normal market conditions, such
rights would be expected to be exercised only a minority of the time.

 10. The disclosure states that the Fund seeks to “construct a portfolio of CLO securities
that is diverse across a number of key categories.” Please revise the disclosure in accordance with Comment [5].

Response: The Fund has revised its
disclosure consistent with this comment.

April 29, 2015

Page 5

 11. Under the “Initial Public Offering” subsection, it is stated that the Fund has declared
two quarterly distributions on shares of the Fund’s common stock at a 12% annualized rate based on the price of the common
stock in the initial public offering. Please disclose the extent to which such quarterly distributions included any return of capital.

Response: The Fund has revised its
disclosure consistent with this comment.

Prospectus Summary—Eagle Point Credit Company

Page 3

 12. In discussing the Senior Investment Team’s qualifications, it is stated that members of
the team have “collectively” been involved in the CLO market in various roles. In your response, please explain the
use of the term “collectively”: please indicate which team member held each of the positions that are listed. We may
have additional comments.

Response: The Fund notes that the
term “collectively” as used in the context noted in the Staff’s comment is intended to provide an overall description
of the aggregate experience of the members of the Senior Investment Team in the CLO market rather than to itemize each member’s
individual involvement in the CLO market (which information is described in each Senior Investment Team member’s biography
included on pages 60 and 61 of the Prospectus).

Please see below a table setting forth
the members of the Senior Investment Team that have held each of the positions noted in the disclosure:

    Position

        Senior Investment Team Member

    Head of the CLO business at various investment banks

        Thomas P. Majewski (U.S. Head of CLO Banking at RBS Securities,
        Inc.; Head of CLO Banking at Merrill Lynch Pierce Fenner & Smith Inc.)

        Lead CLO structurer and collateralized debt obligation workout
        specialist at an investment bank

        Daniel W. Ko (Vice President of the CLO structuring group at
        Bank of America Merrill Lynch)

    CLO equity and debt investor

        Thomas P. Majewski (U.S. country head at AE Capital Advisers
        (US) LLC)

    Principal investor in CLO collateral management firms

        Daniel M. Spinner (Co-Founder and President of Structured Capital
        Partners, Inc.)

        Lender and merger and acquisitions adviser to CLO collateral
        management firms

    Daniel M. Spinner (Managing Director, Bear, Stearns & Co.)

April 29, 2015

Page 6

Prospectus Summary—CLO Overview

Page 4

 13. The disclosure states that “in the current market environment, we expect investment opportunities
in CLO equity to present more attractive risk adjusted returns than CLO debt.” Please explain what aspects of the “current
market environment” form the basis for the statement. Furthermore, it is stated that the Fund expects CLO equity to “provide
potential protection against rising interest rates after LIBOR has increased above the average LIBOR floor on a CLO’s assets.”
Would a rising interest rate environment result in higher credit risk and default rates for a CLO’s asset portfolio because
it is comprised of “junk” bonds? If so, would more senior tranches of the CLO require additional collateralization
and thus reduce cash flows, and thereby impair the value of, the equity tranches of a CLO? We may have additional comments.

Response: In Amendment No. 1, the
Fund has removed the disclosure regarding the Fund’s expectation that CLO equity will present more attractive risk adjusted
returns than CLO debt in the current market environment.

The Fund has revised its disclosure
under the heading “Prospectus Summary—CLO Overview” to provide cross references to “Risk
Factors—Risks Related to Our Investments—We and our investments are subject to interest rate risk” and
“Business—CLO Overview” which respectively (i) discuss the risk that defaults in the loans underlying the
Fund’s CLO investments may increase in a rising interest rate environment and (ii) explain that if losses from defaults
were significant enough to cause a CLO to breach its overcollateralization test, excess cash flow that would
otherwise be available for distribution to the CLO equity tranche investors is diverted to prepay CLO debt investors in order
of seniority until such time as the covenant breach is cured.

April 29, 2015

Page 7

Prospectus Summary—Our Structure

Page 6

 14. The structure chart indicates that the Fund invests in two wholly-owned subsidiaries. Please
include a description of such subsidiaries and the reason for structuring investments through the subsidiaries. What percent of
its total assets is the Fund permitted to invest in each subsidiary and on a combined basis? We may have additional comments.

Response: The Fund has revised its
disclosure consistent with this comment. While there is no express limit on the percentage of the Fund’s assets that may
be invested in any of the wholly-owned subsidiaries noted in the structure chart (or on a combined basis between the two subsidiaries),
the Fund does not currently expect to invest more than 45% of its total assets in any single subsidiary. As of December 31, 2014,
1.5% of the Fund’s total assets were invested in Eagle Point Credit Company Sub LLC. To date, the Fund has not invested in
Eagle Point Credit Company Sub (Cayman) Ltd. Because each subsidiary noted on the structure chart is wholly-owned by the Fund and
would likely be, but for Section 3(c)(7) of the 1940 Act, an investment company, the Fund will consolidate the subsidiaries on
its financial statements and for purposes of complying with the limitations of the 1940 Act.

The Offering—Ranking

 15. Please include an additional bullet to state that the Series A Term Preferred Stock is subordinated
to the rights of any senior indebtedness. See Comment [8].

Response: The Fund has revised its
disclosure consistent with this comment.

Risk
Factors

Page 31

 16. The subsection titled “Historically Low Interest Rate Environment” should be revised
to reflect risks associated with a rising interest rate environment. Please see IM Guidance Update No. 2014-1.

Response: The Fund has revised its
disclosure consistent with this comment.

April 29, 2015

Page 8

Business—CLO Market Opportunity

Page 52

 17. The disclosure states that “based on the Adviser’s analysis of market data, the
Adviser believes that only approximately 4% of U.S. cash flow CLOs issued between 2002 and 2011 will have a negative internal rate
of return, or “IRR,” whereas nearly half of such CLOs are projected to have IRRs over 15%.” To what extent does
the Fund invest in CLOs issued in the applicable period? What sources/market data form the basis for the Adviser’s belief?

Response: The Fund does not currently
hold any interests in CLOs issued during the 2002 to 2011 period. However, the Fund is invested in U.S. cash flow CLOs i

1

     April 17, 2015  Thomas Friedmann Dechert LLP 1900 K Street, NW Washington, DC 20006-1110   Re:  Eagle Point Credit Company Inc.
Registration Statement on Form N-2  File Numbers: 333-202914; 811-22974
Dear Mr. Friedmann:   Eagle Point Credit Company Inc. (the “Fund”) filed a registration statement on March 20, 2015
(the “Registration Statement”).  The filing wa s made for the purpose of registering Series A
Term Preferred Stock of the Fund.  Based on our re view of the Registration Statement, we have
the following comments.  The captions used belo w correspond to the captions the Fund uses in
its Registration Statement.  Please note, however, that the comments we gi ve in one section are
applicable to other sections of the Registration Statement that contain similar disclosure, unless
otherwise indicated.

General

1. 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 pre-effective amendments.

2. Please advise us if you have submitted any exemptive application(s) or no-action
request(s) in connection with your Registration Statement.

3. Please state in your response letter whethe r FINRA has reviewed or will review the
proposed underwriting terms and arrangements of the tr ansaction involved in the
Registration Statement.

4. Please advise the Staff whether the Fund inte nds to supplement its registration statement
pursuant to which its common shares are currentl y offered, in order to reflect the issuance
of preferred stock. We may have additional comments.

2
 Cover Page

1. It is disclosed that the CLOs in which th e Fund seeks to invest are collateralized by a
diverse portfolio consisting prim arily of below investment grade U.S. senior loans. Since
the Fund is classified as “non-diversified” as th e term is defined in Section 5(b) (2) of the
1940 Act, please use alternative language to avoid confusion.  Pleas e make this change
throughout the Registration Statement. With re spect to references to unrated or below
investment grade securities, please define such securities as “junk.”

2. It is disclosed that the Fund “may” also invest  in other securities a nd instruments, to the
extent such investments are consistent with  the Fund’s objectives, including senior debt
tranches of CLOs and loan accumulation fac ilities.  To what extent does the Adviser
expect to make such investments? Do inve stments in loan accumulation facilities and
other direct investment s constitute part of the Fund’s pr incipal strategy?  We may have
additional comments.

3. The disclosure states that the Fund intends to  pay monthly dividends on its Series A Term
Preferred Stock at a specified rate.  Please incl ude a clarification that the payment of such
dividend may be suspended by the Board indefin itely, subject to the requirements of the
1940 Act.

4. It is disclosed that the Series A Term Preferred Stock “will rank senior in right of
payment to our common stock and will rank equally in right of payment with any shares of preferred stock that we may issue.” Please disclose that the Series A Term Preferred
Stock is subordinated to the rights of any se nior indebtedness and state the extent to
which such indebtedness is  currently outstanding.

Prospectus

Prospectus Summary – Ea gle Point Credit Company

Page 2
5. It is stated that the Adviser may exercise cer tain protective rights associated with holding
a majority position in a CLO equity tranche.  How frequently has the Adviser exercised such rights in the past? Please remove the statement if such rights are exercised only
infrequently.
6. The disclosure states that the Fund seeks to “construct a portfolio of  CLO securities that
is diverse across a number of key categories.” Please revise the disclosure in accordance
with Comment 1.
7. Under the “Initial Public Offe ring” subsection, it is stated th at the Fund has declared two
quarterly distributions on shares of the F und’s common stock at a 12% annualized rate
based on the price of the common stock in th e initial public offering. Please disclose the
extent to which such quarterly distribu tions included any return of capital.

3

Prospectus Summary – Eagl e Point Credit Management

Page 3
5. In discussing the Senior Investment Team’s qua lifications, it is stated that members of the
team have “collectively” been involved in the CLO market in various roles.  In your
response, please explain the use of the term  “collectively”: please indicate which team
member held each of the positions that ar e listed. We may have additional comments.

Prospectus Summar y – CLO Overview

Page 4

6. The disclosure states that “in the current market environment, we expect investment
opportunities in CLO equity to present more attractive risk adjusted returns than CLO
debt.” Please explain what aspects of the “cu rrent market environment” form the basis for
the statement. Furthermore, it is stated th at the Fund expects CLO equity to “provide
potential protection against ri sing interest rates after LI BOR has increased above the
average LIBOR floor on a CLO’s assets.” Would a rising interest rate environment result
in higher credit risk and default rates for a CLO’s asset portfolio because it is comprised of “junk” bonds? If so, would more senior tranches of the CLO require additional
collateralization and thus redu ce cash flows, and thereby impa ir the value of, the equity
tranches of a CLO?  We may have additional comments.
 Prospectus Summar y – Our Structure

Page 6
7. The structure chart indicates that the Fund in vests in two wholly-owned subsidiaries.
Please include a description of such subs idiaries and the reason for structuring
investments through the subsidiaries.  What percent of its total assets is the Fund
permitted to invest in each subsidiary and on a combined basis? We may have additional comments.
 The Offering – Ranking

8. Please include an additional bullet to state th at the Series A Term Preferred Stock is
subordinated to the rights  of any senior indebtedness.  See Comment 4.

4
 Risk Factors

Page 31
9. The subsection titled “Historically  Low Interest Rate Environment” should be revised to
reflect risks associated with a rising interest rate environment. Please see IM Guidance
Update No. 2014-1 .

Business – CLO Market Opportunity

Page 52
10. The disclosure states that “based on the A dviser’s analysis of market data, the Adviser
believes that only approximately 4% of U.S.  cash flow CLOs issued between 2002 and
2011 will have a negative internal  rate of return, or “IRR,” wh ereas nearly half of such
CLOs are projected to have IRRs over 15%.”  To what extent does the Fund invest in
CLOs issued in the applicable period? What sources/market data form the basis for the Adviser’s belief?
Page 57
11. In the sub-section titled “Leverage Effects” , please confirm that the assumption amounts
borrowed is representative of the Fund’s expected use of leverage.
 Page 58
12. In the “Co-Investment with Affiliates” subs ection, please include a brief summary of the
conditions set forth in the SEC order to whic h the Fund and its affilia tes are subject when
making co-investments.

Exhibit N: Consent of Independent Registered Public Accounting Firm

13. Please state the city and state where the consent was issued.

Financial Statements filed on Form N-CSR:

Letter to Shareholders:

14. The Fund discloses the following in the shar eholder letter regardi ng the dividend paid:

“On October 15, 2014, the Company declared an initial dividend of $0.55 per common
share for Q4 2014.  This represents an appr oximate 12% yield based on the IPO price of
$20 per share.  The Company expects to contin ue a base quarterly dividend of 12% of the
IPO price, or $0.60 per common share per quarte r, for the foreseeable future given its
current portfolio positions, though actual divide nd payments are subject to variation from
time to time.”

5
  In future reports and on the website, pl ease remove the term yield, as 45% of the
distribution is expected to  be return of capital.

Statement of Assets and Liabilities:

15. Please add a Commitments and Contingencies lin e item to the Statement of Assets and
Liabilities, with a parenthetical refere nce to the note th at discloses unfunded
commitments and other commitments and/or co ntingencies.  See Re gulation S-X, Article
6-04.15.
 Schedule of Investments:

16. Please confirm the $63,734,284 of cash is not in a money market fund or other
investment that should be reported on the schedule of investments.
 Notes to Financial Statements:

17. Disclose whether or not the Fund had any tr ansfers between Level 1, Level 2 and Level 3
securities during the period.
18. Please disclose the following related to new accounting standards that have been issued
but not yet adopted:
a. A brief description of the new standard, th e date that adoption is required, and the
date that the registrant pl ans to adopt, if earlier.

b. A discussion of the methods of adopti on allowed by the standard and the method
expected to be utilized by th e registrant, if determined.

c. A discussion of the impact that adoption of  the standard is expected to have on the
financial statements of the Fund, unless not known or reason ably estimable. In
that case, a statement to that effect ma y be made. If applicable, companies are
encouraged to disclose that a standard has been issued and that its adoption will
not have a material effect on its financ ial position or results of operations.

d. Disclosure of the potential impact of other significant matters that the Fund
believes might result from the adoption of the standard (such as technical
violations of debt covenant agreements , planned or intended changes in business
practices, etc.) is encouraged.

*     *     *     *     *     *

You are reminded that the burden of full and fair disclosure re sts with each registrant, its
counsel, and others engaged in th e preparation of the Registration Statement. As a matter of law,
this burden cannot be shifted to  the Commission or its staff.

6

 Notwithstanding our comments, please furn ish a letter with respect to the Fund
acknowledging that:

 the Fund is responsible for the adequacy and accuracy of the disclosure in its
filings;

 should the Commission or the staff, acting pursuant to delegate d authority, declare
the filing effective, it does not forecl ose the Commission from taking any action
with respect to the filing;

 the action of the Commission or the staff, acting pursuant to dele gated authority, in
declaring the filing effective,  does not relieve the Fund fr om full responsibility for
the adequacy and accuracy of the disclosure in the filings;

 the Fund may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the Federal securities laws of  the United States.
         In addition, please be advised th at the Division of Enforcement has access to all
information you provide the staff of  the Division of Investment Management in connection with
our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the registration
statements as confirmation that those request ing acceleration are aware of their respective
responsibilities.
 Please respond to this letter in the form of  a pre-effective amen dment for the Fund.
Please respond to all comment letters in a letter  filed in the form of EDGAR correspondence.
Where no changes will be made in response to a comment, please so state in your letter and
explain the basis for your posi tion.  The staff may have furthe r comments after reviewing your
responses.

 Should you have any questions regarding this  letter, please contac t me at (202) 551-
6908.
Sincerely,
         / s /  A s e n  P a r a c h k e v o v
Attorney Adviser

CORRESP
1
filename1.htm

October 3, 2014

Mr. Asen Parachkevov

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-0504

Eagle Point Credit Company LLC

Registration Statement on Form N-2

File Nos. 333-196590 and 811-22974

Dear Mr. Parachkevov:

Pursuant to Rule 460 of
the General Rules and Regulations under the Securities Act of 1933, as amended, we, on behalf of the several underwriters, wish
to advise you that distribution of the Registration Statement on Form N-2 as filed on June 6, 2014 and the Preliminary Prospectus
dated September 30, 2014, began on September 30, 2014 and is expected to conclude at approximately 5:00 p.m., Eastern Time, on
October 7, 2014, with anticipated distribution results as follows: a limited number of Registration Statements have or will be
sent to underwriters and approximately 67 copies of the Preliminary Prospectus have or will be sent to underwriters, dealers and
institutions.

In accordance with Rule
461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, on behalf of the underwriters
of the offering of common shares of Eagle Point Credit Company LLC (the "Fund"), hereby joins in the request of the
Fund for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 1:00 p.m.,
Eastern Time, on October 7, 2014 or as soon thereafter as practicable.

    Sincerely,

    DEUTSCHE BANK SECURITIES INC.

    On behalf of the Several Underwriters

    By: DEUTSCHE BANK SECURITIES INC.

    By:
    /s/Mark Schwartz

    Name: Mark Schwartz

    Title: Managing Director

    By:
    /s/Francis Windels

    Name: Francis Windels

    Title: Managing Director

CORRESP
1
filename1.htm

EAGLE
POINT CREDIT COMPANY LLC

20
HORSENECK LANE

GREENWICH, CONNECTICUT 06830

October 3, 2014

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attention: Asen Parachkevov

 Re: Eagle Point Credit Company LLC

  Registration Statement on Form N-2

  File Numbers: 333-196590; 811-22974

Dear Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, as
amended, Eagle Point Credit Company LLC, a Delaware limited liability company (the “Company”),
respectfully requests acceleration of the effective date of its Registration Statement on Form N-2 (File Nos. 333-196590;
811-22974) (the “Registration Statement”) so that such Registration Statement may be declared effective at
1:00 p.m., Eastern Time, on Tuesday, October 7, 2014, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone
call to Thomas J. Friedmann of Dechert LLP at (202) 261-3313, and that such effectiveness also be confirmed in writing.

The Company hereby acknowledges that (i) should the Securities
and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”),
acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action
with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure
in the filing; and (iii) the Company may not assert this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very truly yours,

    Eagle Point Credit Company LLC

    By:
     /s/ Kenneth P. Onorio

    Name:
    Kenneth P. Onorio

    Title:
    Chief Financial Officer

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006-1110

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

        Nauman Malik

        nauman.malik@dechert.com

        +1 202 261 3456 Direct

        +1 202 261 3062 Fax

July 15, 2014

VIA EDGAR

Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company LLC

                                                                                Registration Statement on Form N-2

                                                                                File Numbers: 333-196590; 811-22974

Dear Mr. Parachkevov:

Pursuant to our correspondence on July
10, 2014, on behalf of Eagle Point Credit Company LLC, a Delaware limited liability company (the “Registrant”),
enclosed please find pages from the Registrant’s registration statement on Form N-2, which update the valuations of the Registrant’s
portfolio investments to June 30, 2014.

Please direct any questions concerning
the enclosed to the undersigned at (202) 261-3456 or Thomas J. Friedmann at (202) 261-3313.

Very truly yours,

/s/ Nauman S. Malik

CORRESP
1
filename1.htm

    1900 K Street, NW

Washington, DC 20006-1110

+1 202 261 3300 Main

+1 202 261 3333 Fax

www.dechert.com

    Nauman Malik

nauman.malik@dechert.com

+1 202 261 3456 Direct

+1 202 261 3062 Fax

July 10, 2014

VIA EDGAR

Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company LLC

Registration Statement on Form N-2

File Numbers: 333-196590; 811-22974

Dear Mr. Parachkevov:

On behalf of Eagle Point Credit Company
LLC, a Delaware limited liability company (the “Registrant”), enclosed please find pages from the Registrant’s
registration statement on Form N-2 (the “Registration Statement”) which reflect the investment portfolio held
by the Registrant as of June 30, 2014. The enclosed pages also reflect the value of the listed investments upon their contribution
to the Registrant by Eagle Point Credit Partners Sub Ltd., the Registrant’s parent company, on June 6, 2014. The Registrant
will update the valuations included in the enclosed changed pages once valuations for the period ended June 30, 2014 are available.

Please direct any questions concerning
the enclosed to the undersigned at (202) 261-3456 or Thomas J. Friedmann at (202) 261-3313.

Very truly yours,

/s/ Nauman S. Malik

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006-1110

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

        Thomas Friedmann

        thomas.friedmann@dechert.com

        +1 202 261 3313 Direct

        +1 202 261 3016 Fax

July 7, 2014

VIA EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Asen Parachkevov

 Re: Eagle Point Credit Company LLC

Registration Statement on Form N-2

File Numbers: 333-196500; 811-22974

Dear Mr. Parachkevov:

On behalf of Eagle Point Credit Company
LLC, a Delaware limited liability company (the “Fund”), we hereby respond to the comments raised by the staff
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) in the letter
dated June 30, 2014 from Asen Parachkevov, Attorney Adviser, to Thomas Friedmann, outside counsel to the Fund.

For your convenience, the Staff’s
comments are repeated in this letter, and each comment is followed by the applicable response. Concurrently, the Fund is filing
pre-effective amendment no. 1 (“Amendment No. 1”) to its registration statement on Form N-2 (the “Registration
Statement” and the prospectus contained therein, the “Prospectus”) via EDGAR. We will also provide
under separate cover courtesy copies of Amendment No.1, as submitted and marked to show the changes from the original filing of
the Registration Statement.

Capitalized terms used in this letter and
not otherwise defined herein shall have the meanings specified in the Registration Statement.

General

 1. 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 pre-effective amendments.

        July 7, 2014

        Page 2

Response: The Fund acknowledges
the Staff’s comment.

 2. Please advise us if you have submitted any exemptive application(s) or no-action request(s)
in connection with your Registration Statement.

Response: Although no exemptive
or no-action request has yet been submitted with respect to the Registration Statement, the Fund intends to submit an exemptive
application to the Commission seeking an order under Section 17(d) of the Investment Company Act of 1940, as amended (the “1940
Act”), and Rule 17d-1 thereunder permitting certain co-investment transactions.

 3. Please state in your response letter whether FINRA has reviewed the proposed underwriting terms
and arrangements of the transaction involved in the Registration Statement.

Response: The Fund hereby confirms
that the Registration Statement was filed with FINRA on June 9, 2014. The Fund will address and resolve any FINRA comments prior
to effectiveness of the Registration Statement and underwriters’ counsel will ask the FINRA examiner to notify the Staff
once verbal no objections have been issued by FINRA with respect to the underwriting terms and arrangements.

 4. In various places in the Registration Statement, it is disclosed that the Fund may
                                                                 purchase and sell a variety of derivatives instruments. In these sections and in the sections discussing the Fund’s
                                                                 investment strategy, please specifically describe the Fund’s use of derivatives in a manner customized to proposed Fund
                                                                 operations. Please list all types of derivative instruments that are expected to be used as opposed to providing a laundry
                                                                 list of investment instruments. Please describe the risks applicable to the derivative instruments expected to be used. The
                                                                 Division of Investment Management has made a number of observations about derivative related disclosure by investment
                                                                 companies in a letter from Barry D. Miller, Associate Director, Office of Legal and Disclosure, to Karrie McMillan, General
                                                                 Counsel, Investment Company Institute dated July 30, 2010.1 Please
                                                                 review the observations set forth in that letter and revise your disclosure concerning the use and risks
                                                                 of derivatives.

1 	See
http://www.sec.gov/divisions/investment/guidance/ici073010.pdf.

        July 7, 2014

        Page 3

Response: As requested, the Fund
has made revisions to the disclosure regarding its expected use of derivative instruments. The Fund has also revised the
related risk disclosure accordingly. The Fund notes that its disclosure regarding possible future uses of derivative instruments
is speculative and, consequently, the degree of specificity that it can include in this disclosure is limited.

 5. Please confirm that the Fund does not intend to issue preferred stock or debt securities in
the next 12 months.

Response: While the Fund
has no current plans to issue preferred stock, the Fund may issue preferred stock or otherwise incur leverage in the next
twelve months. The Fund has revised its disclosure accordingly. Such revisions reflect the possibility that the Fund incurs
leverage during the  12-month period following the completion of the proposed offering.

Cover Page

 6. Please clarify that both the equity and junior debt tranches of CLOs in which the Fund will
primarily seek to invest, as well as the collateral underlying such CLOs, could be considered “junk”. Please include
a similar clarification in each section of the Prospectus where “high yield” or “below investment grade”
securities are mentioned for the first time.

Response: The Fund has revised its
disclosure consistent with this comment.

 7. Please include a statement that closed-end funds that are listed on an exchange frequently trade
at a discount to net asset value.

Response: The Fund has revised its
existing disclosure in the seventh paragraph of the cover page to the Prospectus to specifically reference exchange-listed, closed-end
funds.

 8. Please include a separate line item for the amount of estimated organization and offering expenses
to be paid by the Fund. Please clarify that such expenses will be borne indirectly by the Shareholders.

Response: The Fund has revised its
disclosure consistent with this comment. The Fund notes that Eagle Point Credit Management LLC (the “Adviser”)
has agreed to pay directly, without any possibility of reimbursement by the Fund, a portion of the expenses of the offering, including
all organization costs of the Fund.

        July 7, 2014

        Page 4

Prospectus

Prospectus Summary

Page 5

 9. Please confirm that the initial portfolio of the Fund is going to be a pro rata portion of the
investments held by the Private Fund as of the date of contribution. If not pro-rata, please explain which investments were selected
for contribution. We may have additional comments.

Response:  The Fund hereby confirms
that the portfolio contributed by Eagle Point Credit Sub Ltd. (the “Parent Company”) to the Fund on June 6,
2014 comprises a pro rata portion of the investments held directly and indirectly by the Private Fund as of such date. The Fund
has clarified its disclosure relating to the pro rata contribution.

Page 10

 10. Under the heading “Financing and Hedging Strategy – Leverage by the Company,”
the Prospectus states that the Fund may use “different types or combinations of leveraging instruments.” Please describe
with specificity.

Response: The Fund has revised its disclosure consistent
with this comment.

Summary of Offering

Page 14

 11. With respect to payments of administration expenses, please disclose the methodology used to
allocate costs and expenses under the administration agreement and that the board exercises oversight with respect to the allocation
of such expenses.

Response: The Fund respectfully
submits that the cost of compensation-related expenses are allocated based on the portion of time spent by the relevant officer
and his or her staff working on the Fund’s matters. The Administrator tracks such amounts and allocations in the ordinary
course. Rent-based expenses are allocated based on the cost of space occupied by those individuals who work on the Fund’s
matters and on the time spent by such persons on the Fund’s matters. All other expenses, such as travel and other overhead
expenses, are allocated based on the expenses actually incurred on behalf of the Fund. The board of directors of the Fund intends
to review the allocation methodology to be used by the Fund and the Administrator and intends to closely monitor such expense allocations
on a regular basis going forward. Further, the Fund believes that the Prospectus provides sufficient information regarding the
methodology used to allocate costs and expenses under the administration agreement. Finally, the Fund supplementally notes that
in accordance with Staff no-action letters regarding service arrangements with affiliated entities in light of the prohibitions
of Section 17(d) of the 1940 Act and Rule 17d-1 thereunder, a majority of the Fund’s non-interested directors have approved
the administration agreement between the Fund and the Administrator and will exercise oversight of the services provided by the
Administrator and the expenses incurred on behalf of the Fund on an ongoing basis.

        July 7, 2014

        Page 5

Summary of Expenses

 12. Footnote 5 to the Summary of Expenses table discloses that the incentive fee percentage listed
is an estimate for the first year of operations. Please describe the assumptions on which the estimate is based on and explain
to the staff why such assumptions are appropriate.

Response: The Fund has revised
its disclosure to state that the estimated incentive fee for the first year of operations is based on the historical and
expected future performance of the portfolio contributed to the Fund by the Parent Company, as such portfolio is expected to
be impacted by the proceeds of the offering. Based on the Fund’s current business plan and pipeline of
potential investments, the Fund expects to invest substantially all of the net proceeds of the offering within three to six
months following completion of the offering. The actual pace of such investments will depend upon prevailing market
conditions and the availability of investment opportunities that are consistent with the Fund’s investment objectives.
Pending such investments, the Fund intends to invest the proceeds of the offering in temporary investments, such as cash,
cash equivalents, U.S. government securities and other high-quality debt investments that mature in one year or less. This
portion of the Fund’s portfolio is therefore expected to have returns substantially lower than the returns that the
Fund anticipates earning from its initial portfolio during the same period. The Fund respectfully notes that it is not aware
of any factors that would alter the income it expects to earn on the initial portfolio investments, nor is it able to
estimate its returns on uninvested offering proceeds other than by applying the investment returns that such temporary
investments are earning at this time. Therefore, the Fund respectfully submits that its assumptions are both appropriate and
reasonable.

Risk Factors

Page 34

 13. The sub-section titled “Synthetic Securities Risks” discusses loan assignments and
participations and only the last paragraph applies to synthetic securities. Please review the disclosure and revise. Further, please
include a discussion of these instruments in the sections describing the Fund’s principal investment strategies, to the extent
applicable.

        July 7, 2014

        Page 6

Response:  The Fund has revised
its disclosure under the heading “Synthetic Securities Risks” to focus on the risks associated with synthetic securities
and has separately captioned disclosure regarding possible loan assignments and participations. The Fund respectfully submits
that synthetic securities are not part of the Fund’s principal investment strategies and it has moved disclosure relating
to such securities to the section of the Prospectus titled “Additional Investments and Techniques.”

Page 36

 14. Please clarify if the Fund will seek to invest in CLOs whose underlying collateral will consist
of synthetic securities. Please include additional discussion in the sections describing the Fund’s principal investment
strategies, to the extent applicable.

Response: The Fund respectfully
submits that it does not currently hold, and does not anticipate holding in the future, any CLOs whose underlying collateral consists
of material amounts of synthetic securities.

Page 37

 15. Please revise the disclosures in the sub-section titled “Hedging Risks; Derivative Transactions
Risk” to tailor to specific derivative instruments to be used by the Fund. Please identify such instruments with specificity
and disclose applicable risks associated with the use of such instruments. See Comment 4 above.

Response: See response to Comment
4.

Page 40

 16. If the Fund will invest 10% or more of its assets in foreign securities that are not publicly
traded in the U.S., ensure that the risk factors include those described in the Guidelines for Form N-2, Guide 9.

Response: The Fund has revised its
disclosure to include the risk factors described in Guide 9 of the Guidelines for Form N-2.

        July 7, 2014

        Page 7

Page
41

 17. The Prospectus discloses that the Fund may make use of one or more tax blocker entities for
U.S. federal income tax purposes. To the extent such entities will be used by the Fund, please confirm that the Fund’s financials
will reflect taxes on unrealized gains on the investments with respect to the blockers.

Response: From time to time the
Fund may utilize tax blocker entities, primarily because the character of income from some of the Fund’s investments may
include operating income that would not be appropriate for a regulated investment company under Subchapter M under the Code. As
prescribed by U.S. generally accepted accounting principles, the Fund’s financials will reflect taxes on unrealized gains
on the investments with respect to the blockers.

Business

Page 50

 18. The sub-sections titled “CLO Overview” and “CLO Market Opportunity”
contain various data regarding the state of the U.S. CLO market. Please disclose the applicable source(s) of such data in all instances.

Response:
The Fund has revised its disclosure consistent with this comment.

Page 59

 19. With respect to the historical performance of the Adviser that is presented in the Prospectus,
we have the following comments:

 a. Please confirm that the Fund’s portfolio management team has been responsible for managing
the Private Fund since its inception.

Response: The Fund
hereby confirms that Mr. Majewski, the Fund’s Chief Executive Officer and the Adviser’s Managing Partner, has
been responsible for managing the Private Fund since its organization in November 2012. Mr. Ko joined the Private
Fund’s portfolio management team in December 2012 and Mr. Spinner joined the Private Fund’s portfolio management
team in February 2013, and they have been involved in managing the Private Fund since December 2012 and February 2013,
respectively.

 b. Please confirm that the Private Fund was created for purposes entirely unrelated to the establishment
of a performance record.

        July 7, 2014

        Page 8

Response: The Fund hereby confirms
the Private Fund was created for purposes