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

 PHILIP T. HINKLE

 philip.hinkle@dechert.com
 +1 202 261 3460 Direct
 +1 202 261 3050 Fax

 August 11, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Investment Management

 Disclosure Review and Accounting Office

 100 Pearl Street, Suite 20-100

 New York, NY 10004

 Attn:
 Mr. Raymond Be

 Re:
 Sound Point Meridian Capital, Inc. Registration Statement on Form N-2 File Nos. 333-288330 and 811-23881

 Dear Mr. Be:

 On behalf of Sound Point Meridian Capital, Inc. (the "Company"), this letter responds to the comments issued by the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "SEC") in a call on July 25, 2025, between Raymond Be of the Staff and Theresa Hyatte of Dechert LLP, relating to the Company's registration statement on Form N-2 filed with the SEC on June 26, 2025 (the "Registration Statement"). The Company has considered your comments and has authorized us to make the responses and changes discussed below on its behalf.

 For your convenience, the Staff's comments are included in this letter and are followed by the responses of the Company. Capitalized terms used in this letter and not otherwise defined herein shall have the meanings specified in the Registration Statement.

 1.

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

 Response : The Company respectfully acknowledges the Staff's comment.

 August 11, 2025 Page 2

 2.

 Comment : Supplementally advise how the Company anticipates attaining the 35% level of leverage, including relative portions attributable to borrowings versus preferred securities. Revise the disclosure to make clear that, if true, the reference to 35% will be the total leverage including the leverage effects of the preferred shares.

 Response : The Company supplementally confirms that it anticipates incurring leverage in an amount up to approximately 35% of its total assets through borrowings and through the issuance of preferred stock or debt securities. The relative portion of leverage attributable to borrowings is anticipated to be 16.7%, and the relative portion attributable to preferred stock is anticipated to be 18.3%. The Company has complied, and anticipates continuing to comply, with the applicable limitations on leverage set forth in Section 18 of the Investment Company Act of 1940. The Company has revised the disclosure in Amendment No. 1 to the Registration Statement, filed herewith, on pages 5-6 under the section "PROSPECTUS SUMMARY-Financing and Hedging Strategy" and on pages 58-59 under the section "BUSINESS-Certain Investment Techniques- Leverage ".

 * * *

 The Company believes that the foregoing has been responsive to the Staff's comment. Please call the undersigned at 202.261.3460 if you wish to discuss this correspondence further.

 Sincerely,

 /s/ Philip T. Hinkle

 Philip T. Hinkle

 cc:
 Philip T. Hinkle, Dechert LLP

 Raymond Be, Securities and Exchange Commission

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

 July 2, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Investment Management

 Disclosure Review and Accounting Office

 100 Pearl Street, Suite 20-100

 New York, NY 10004

 Attn:
 Mr. Raymond Be

 Re:
 Sound Point Meridian Capital, Inc.
 Amendment No. 2 to Registration Statement on Form N-2
File Nos. 333-286054 and 811-23881

 Dear Mr. Be:

 On behalf of Sound Point Meridian Capital, Inc. (the “Company”), this letter responds to the comment issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) in a call on July 2, 2025, between Raymond Be of the Staff and Theresa Hyatte of Dechert LLP, relating to the Company’s Amendment No. 2 to the registration statement on Form N-2 filed with the SEC on June 25, 2025 (the “Second Amended Registration Statement”). The Company has considered your comment and has authorized us to make the response and changes discussed below on its behalf.

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

 1.
 Comment : Supplementally advise how the Company anticipates attaining the 35% level of leverage, including relative portions attributable to borrowings versus preferred securities. Revise the disclosure to make clear that, if true, the reference to 35% will be the total leverage including the leverage effects of the preferred shares. To the extent that the Company intends to make such clarification in a prospectus supplement, please provide the proposed language in a response letter.

 Response : The Company supplementally confirms that it anticipates incurring leverage in an amount up to approximately 35% of its total assets through borrowings and through the issuance of preferred stock or debt securities. The relative portion of leverage attributable to borrowings is anticipated to be 16.7%, and the relative portion attributable to preferred stock is anticipated to be 18.3%. The Company has complied, and anticipates continuing to comply, with the applicable limitations on leverage set forth in Section 18 of the Investment Company Act of 1940. The Company intends to revise the disclosure in a prospectus supplement as follows (new disclosure underlined; deleted disclosure struck through). These edits will be incorporated in disclosure on pages 5-6 under the section “PROSPECTUS SUMMARY—Financing and Hedging Strategy” and on pages 56-57 under the section “BUSINESS—Certain Investment Techniques— Leverage ”.

 July 2, 2025 Page 2

 We
currently anticipate incurring leverage in an amount up to approximately 35% of our total assets (as determined immediately after the
leverage is incurred) through borrowings under the CIBC Credit Facility described below, and through the issuance of preferred stock
or debt securities .

 by virtue of our entering We have entered into a Credit Agreement (the “ CIBC Credit Facility ”) with the lenders from time to time party thereto and Canadian Imperial Bank of Commerce (“ CIBC ”), as administrative agent, on July 8, 2024 , and potentially other credit facilities, or through the issuance of preferred stock, including our Series A Preferred Shares and our Series B Preferred Shares, or debt securities . We entered into the CIBC Credit Facility, and may enter into other revolving facilities, in order to allow us to draw capital in the case that current cash available to pay dividends is lower than our anticipated run-rate cash dividend, or in the case that asset values in the CLO market fall in a way as to make new investments attractive, in which case we may incur leverage (including the issuance of preferred stock or debt securities) in excess of approximately 35% of our total assets. The Adviser will decide whether or not it is beneficial to us to use leverage at any given time. Such facilities would be committed, but subject to certain restrictions that may not allow us to draw capital even if the Adviser deems it favorable to do so. Such facilities, if drawn, would become senior in priority to our common stock. The facilities would also earn an undrawn commitment fee that we would pay on an ongoing basis, regardless of whether we draw on the facilities or not.

 Instruments that create leverage are generally considered to be senior securities under the 1940 Act. With respect to senior securities representing indebtedness (i.e., borrowings or deemed borrowings , including the CIBC Credit Facility) , other than temporary borrowings, as defined under the 1940 Act, we are required under current law to have an asset coverage of at least 300%, as measured at the time of borrowing and calculated as the ratio of our total assets (less all liabilities and indebtedness not represented by senior securities) over the aggregate amount of our outstanding senior securities representing indebtedness. With respect to senior securities that are equity (i.e., shares of preferred stock, including the Series A Preferred Shares and the Series B Preferred Shares), we are required under current law to have an asset coverage of at least 200%, as measured at the time of the issuance of any such shares of preferred stock and calculated as the ratio of our total assets (less all liabilities and indebtedness not represented by senior securities) over the aggregate amount of our outstanding senior securities representing indebtedness plus the aggregate liquidation preference of any outstanding shares of preferred stock.

 *       *      *

 The Company believes that the foregoing has been responsive to the Staff’s comment. Please call the undersigned at 202.261.3460 if you wish to discuss this correspondence further.

 Sincerely,

 DECHERT DRAFT

 /s/ Philip T. Hinkle

 Philip T. Hinkle

 cc:
 Philip T. Hinkle, Dechert LLP

 Steven B. Boehm, Eversheds Sutherland (US) LLP

 Payam Siadatpour, Eversheds Sutherland (US) LLP

 Raymond Be, Securities and Exchange Commission

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 25, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Investment Management

 Disclosure Review and Accounting Office

 100 Pearl Street, Suite 20-100

 New York, NY 10004

 Attn:
 Ms. Mindy Rotter

 Mr. Raymond Be

 Re:
 Sound Point Meridian Capital, Inc. Amendment No. 1 to Registration Statement on Form N-2 File Nos. 333-286054 and 811-23881

 Dear Ms. Rotter and Mr. Be:

 On behalf of Sound Point Meridian Capital, Inc. (the "Company"), this letter responds to the comments issued by the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "SEC") in a call on June 12, 2025, between Mindy Rotter of the Staff, and Nicholas Chionchio and Theresa Hyatte of Dechert LLP, counsel to the Company, and a call on June 20, 2025, between Raymond Be of the Staff, and Philip Hinkle and Theresa Hyatte of Dechert LLP, relating to the Company's Amendment No. 1 to the registration statement on Form N-2 filed with the SEC on June 11, 2025 (the "Amended Registration Statement"). The Company has considered your comments and has authorized us to make the responses and changes discussed below on its behalf.

 For your convenience, the Staff's comments are included in this letter, and each comment is followed by the response of the Company. Capitalized terms used in this letter and not otherwise defined herein shall have the meanings specified in the Amendment No. 2 to the Amended Registration Statement filed by the Company on the date hereof (such registration statement being referred to herein as the "Second Amended Registration Statement."

 1.
 Comment : Please explain why the Financial Highlights are labeled "unaudited", and how this presentation complies with Form N-2, Item 4, Instructions 2 and 8. In addition, please confirm in correspondence that the financial highlights section will be updated in a pre-effective amendment and provide an updated consent as well.

 Response : The Company
respectfully acknowledges the Staff's comment and has removed the Financial Highlights from the Second Amended Registration
Statement and added information regarding its incorporation by reference to the Company's amended Form N-CSR filed with the SEC on June 24, 2025. As discussed in
response to comment 2 below, the Company has revised the Second Amended Registration Statement to incorporate by reference the
audited financial statements for the fiscal year ended March 31, 2025 and the notes thereto, which includes the audited
Financial Highlights table from the amended Form N-CSR.

 June 25, 2025 Page 2

 2.
 Comment : Please provide the supporting documentation to the asset coverage per unit disclosed in the senior securities table. As part of the response, please explain why the asset coverage per unit is the same for both the Preferred Shares and the Revolving Credit Facility.

 Response : The Company
respectfully acknowledges the Staff's comment and has updated the senior securities table to conform to the specific
calculation methodology prescribed by the instructions to Form N-2 in an amendment to the Company's annual report on Form
N-CSR filed with the SEC on June 24, 2025. Because the audited financial statements will be incorporated by reference to the amended Form N-CSR, the Company has added an updated link to that report in the Second Amended Registration Statement.

 3.
 Comment : With regard to the Purchase Agreement discussed at the bottom of page 6, please add disclosure where the material terms of the Purchase Agreement, including how pricing is set, can be found in the Company's SEC filings.

 Response : The Company respectfully
acknowledges the Staff's comment and has revised the disclosure at the bottom of page 6 accordingly and added the Purchase Agreement
to the Exhibit Index in the Second Amended Registration Statement.

 * * *

 The Company believes that the foregoing has been responsive to the Staff's comments. Please call the undersigned at 202.261.3460 if you wish to discuss this correspondence further.

 Sincerely,

 /s/ Philip T. Hinkle

 Philip T. Hinkle

 cc:
 Philip T. Hinkle, Dechert LLP

 Nicholas Chionchio, Dechert LLP

 Steven B. Boehm, Eversheds Sutherland (US) LLP

 Payam Siadatpour, Eversheds Sutherland (US) LLP

 Mindy Rotter, Securities and Exchange Commission

 Jaime Catalina, Securities and Exchange Commission

 Raymond Be, Securities and Exchange Commission

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 7532 Fax

 June 4, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Investment Management

 1900 K Street, NW

 Washington, D.C. 20006-1110

 Attn: Kieran Brown

 Re:
 Sound Point Meridian Fund LP, et al.; File No. 812-15593

 Dear Mr. Brown:

 On
behalf of Sound Point Meridian Capital, Inc. and the other applicants, (the " Applicants "), this letter responds to
the comments raised by the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ")
issued in an email on June 3, 2025 to the Applicants relating to the Applicants' Fourth Amendment and Restated application on Form
40-APP filed with the Commission on May 13, 2025 (the " Application ").

 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 Amendment No. 5 to the Application (" Amendment No. 5 "), which reflects
the responses below.

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

 1. On the cover page, please revise "Sound Point CLO C-MOA, LLC" to insert a "-" immediately after "CLO" or revise the name of the fund on the signature pages, verification pages, and on Schedule A to the application to match the name on the cover page.

 Response:

 The
requested changes have been made.

 2. In Section I, in the third bullet point, beginning "Sound Point Alternative Income Fund …", if Skypoint Trust is registered under the Act as a closed-end fund, please describe it as such. Please make a similar change to Section II.B. In this regard, we note that the fund previously filed a different application under expedited review stating that the fund "is registered under the 1940 Act as a non-diversified, closed-end management investment company" (that other application has already been ordered). See Sound Point Alternative Income Fund, et al. (File No. 812-15615).

 Response:

 The
requested changes have been made.

 Kieran Brown June 4, 2025 Page 2

 3. In Section I, in the fifth bullet point, beginning "Sound Point Capital Management, LP …", please also note that SPC Adviser will act as sub-adviser to Skypoint Trust.

 Response:

 The
requested change has been made.

 4. In Section II.D., in the first paragraph, beginning "SPM Adviser, SPC Adviser and Sound Point C-MOA Adviser serve …":

 a.
Immediately after "and Sound Point C-MOA Adviser serve as the investment adviser", please insert "(or will serve as
the sub-adviser)". This change will reflect SPC Adviser's service as sub-adviser (rather than adviser) to Skypoint Trust.

 b.
Immediately after "either they or another Adviser will serve as the investment adviser", please insert "or sub-adviser".
This change will make the statement consistent with the definition of Future Regulated Fund.

 Response:

 The
requested changes have been made.

 5. In footnote 10, beginning "Skypoint Adviser is not (i) …", please change "of SPC Adviser" to "of any Adviser" each time it appears.

 Response:

 The
requested changes have been made.

 6. In Section II.D., in the second paragraph, beginning "SPM Adviser serves as the investment adviser …", please also state that SPC Adviser will serve as sub-adviser to Skypoint Trust.

 Response:

 The
requested change has been made.

 7. In Section II.D., please revise the last paragraph, beginning "[u]nder the terms of an investment advisory agreement with each Existing Regulated Fund …", to reflect that SPC Adviser will enter into a contract with Skypoint Adviser to act as sub-adviser to Skypoint Trust.

 Response:

 The
requested change has been made.

 * * * * * * * * *

 Kieran Brown June 4, 2025 Page 3

 If
you have any questions, please feel free to contact Harry Pangas by telephone at 202.261.3466 or by email at harry.pangas@dechert.com
or Philip T. Hinkle 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

 cc: Wendy
Ruberti, General Counsel, Sound Point Capital Management, LP

CORRESP
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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

October 24, 2024

Via EDGAR

David P. Mathews
 U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549

    Re:
    Sound Point Meridian Capital, Inc.
 Registration Statement on Form N-2
 File Nos. 333-282187 and 811-23881

Dear Mr. Mathews:

This letter responds to comments that you conveyed via a letter dated October 18, 2024 with respect to the registration statement on Form N-2 (the “Registration Statement”) under the Securities Act of 1933, as amended (“Securities Act”) and the Investment Company Act of 1940, as amended (the “1940 Act”), filed with the U.S. Securities and Exchange Commission (the “SEC”) on September 18, 2024 on behalf of Sound Point Meridian Capital, Inc. (the “Company”). The Company has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement on its behalf. Capitalized terms have the meanings attributed to such terms in the Registration Statement.

The Company undertakes to file a pre-effective amendment to the Registration Statement (the “Pre-Effective Amendment”), which will reflect the disclosure changes discussed below.

On behalf of the Company, set forth below are the comments of the SEC staff (“Staff”) along with our responses to or any supplemental explanations of such comments, as requested.

General Comments

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

Response: The Company acknowledges the Staff’s comment.

    2.
    Comment: Where a comment is made with regard to disclosure in one location, it is applicable to all similar disclosure appearing elsewhere in the Registration Statement. Please make all conforming changes.

Response: The Company acknowledges the Staff’s comment and so confirms.

       David P. Mathews
 October 24, 2024

Page 2

    3.
    Comment: In correspondence, confirm whether FINRA has approved the underwriting terms of the Company’s offering of Series A Preferred Shares, or if exempt from FINRA’s corporate financing rule, please identify the exemption being relied upon.

Response:
The Company supplementally advises the Staff that FINRA has approved the underwriting terms of the Company’s offering of Series
A Preferred Shares, and has issued a “No Objections” letter to the same effect.

    4.
    Comment: The prospectus for the Company’s common share offering suggested that you anticipated paying stable distributions to common shareholders even if it necessitated a return of capital and that, at least initially, the distribution would equal approximately 12% annualized of the initial offering price per share. In correspondence, please explain how the proposed offering of Series A Preferred Shares is expected to impact the outstanding common shareholders and, if material, where and how you have or will disclose the impact.

Response: The Company supplementally advises the Staff that the Company expects the proposed offering of the Series A Preferred Shares to impact the outstanding common shareholders in the same manner as increasing the Company’s leverage would impact such shareholders. As the Company’s leverage increases, the Company expects that returns to its common shareholders will increase, although the risk of loss will increase as well. The Company respectfully refers the Staff to its risk factor titled “[w]e may leverage our portfolio, which would magnify the potential for gain or loss on amounts invested and will increase the risk of investing in us,” in which the Company discloses the risks associated with increasing the Company’s leverage, including through the issuance of preferred shares.

Prospectus

Cover Page

    5.
    Comment: Include a brief description of how the public offering price will be determined, either as a footnote to the Offering Table or in the “Underwriting” section of the Prospectus. Also include, if applicable, any difference in price available to individuals as compared to groups of individuals, the underwriter, or Company affiliates.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment. The Company supplementally confirms that there will be no differences in price available as between individuals and groups of individuals.

       David P. Mathews
 October 24, 2024

Page 3

Prospectus Summary

Portfolio Composition (page 5)

    6.
    Comment: Please update details in respect of the Company’s portfolio and its operations here, and throughout the Registration Statement, as of the most current available date (e.g., as of September 30, 2024) in the pre-effective amendment.

Response: The Company notes that, to the extent that more recent information is available, disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

Recent Developments (page 7)

    7.
    Comment: Please disclose the loan-to-value ratio restriction under your Credit Agreement and, to the extent you have borrowings outstanding, disclose the total amount of borrowings and loan-to-value ratio as of a recent date. In addition, please clarify the reference to “capital contributions received from [y]our investors.”

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

Summary Risk Factors (page 8)

    8.
    Comment: Regarding the “Limited Prior Offering History” risk, please also note the recent date upon which the Company commenced its operations, in addition to its date of formation.

Response: The Company notes that disclosure in the “Limited Prior Operating History” summary risk factor, as well as the corresponding disclosure in the “We have a limited prior operating history as a closed-end investment company” risk factor, have been revised in the Pre-Effective Amendment in response to the Staff’s comment.

    9.
    Comment: Please revise and update your Summary Risk Factors to address material risks associated with an investment in the Company’s Series A Preferred Shares (e.g., duration risk).

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

Risk Factors

Risks Relating to an Investment in Series A Preferred Shares (pages 35-36)

    10.
    Comment: To aid investors’ understanding, please expand the disclosure regarding the impact of increases in market yields (page 36) to clarify what is meant by market yields, and describe the impact of interest rate fluctuations on market yields and, in turn, on secondary market prices.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

       David P. Mathews
 October 24, 2024

Page 4

Special Note Regarding Forward-Looking Statements

    11.
    Comment:  Please revise the reference to the Registration Statement as a “prospectus supplement” (page 51) as this is an initial registration statement and prospectus in respect of the Series A Preferred Shares offering.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

Use of Proceeds (page 52)

    12.
    Comment: The disclosure states that net proceeds from the sale of Series A Preferred Shares will be invested in accordance with the Company’s investment objective and strategies and for general working capital purposes. In correspondence, please confirm whether any part of the net proceeds from this offering will be used as a return of capital to any of the Company’s shareholders.

Response: The Company supplementally confirms that the net proceeds from this offering are not intended to be used as a return of capital to any of the Company’s shareholders. The use of proceeds from this offering are limited to those uses disclosed in the “Use of Proceeds” section of the Pre-Effective Amendment.

    13.
    Comment: The “Risks Related to the Offering” section (page 37) states that management will have broad discretion as to the use of proceeds of this offering and cannot specify with certainty all of the particular uses of the net proceeds of this offering. Please acknowledge in the “Use of Proceeds” section the potential for other uses of offering proceeds in the discretion of management, and elaborate on what those potential uses of the proceeds might be.

Response: The Company has revised the risk factor titled “[m]anagement will have broad discretion as to the use of proceeds, if any, from this offering and may not use the proceeds effectively” to clarify that management will have broad discretion as to the use of proceeds in accordance with the intended uses as disclosed in the “Use of Proceeds” section. The Company supplementally advises the Staff that it does not intend to use the offering proceeds for uses beyond those that are stated in the “Use of Proceeds” section.

Description of Our Series A Preferred Shares

    14.
    Comment: We note the statement in the first paragraph of page 89 that the summary disclosure is not necessarily complete and is subject, and entirely qualified by, reference to the certificate of incorporation, bylaws, and Series A Certificate of Designations. Please remove this statement or include a new statement indicating that the description describes the material terms of the Series A Preferred Shares preferred stock.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment to state that the summary disclosure describes the material terms of the Series A Preferred Shares.

       David P. Mathews
 October 24, 2024

Page 5

    15.
    Comment: Also in the first paragraph, you state that the Series A Certificate of Designations is attached as Appendix A. However, it does not appear in Appendix A of the Registration Statement, and Part C indicates it will instead be filed pre-effectively as an exhibit to the Registration Statement. Please clarify or correct the disclosure in this regard. Once filed, the [S]taff may have further comments as to the terms of the Certificate and its description in the Registration Statement.

Response: The Company notes that the Series A Certificate of Designations has been attached as Appendix B to the Pre-Effective Amendment and attached as an exhibit to the Pre-Effective Amendment. Where applicable, the Company has updated references in the Pre-Effective Amendment to so indicate.

    16.
    Comment: The disclosure in the “Ranking” sub-section (page 89), and elsewhere throughout the Registration Statement, refers generally to the rights of Series A Preferred Shares holders to receive both dividends and distributions. Please confirm to the [S]taff in correspondence, and clarify in the disclosure, the extent to which there exists potential additional rights to dividends or distributions, other than the preferred dividend and the liquidation distribution.

Response: The Company supplementally confirms to the Staff that no potential additional rights to distributions or dividends exist for the Series A Preferred Shares, other than the preferred dividend and the liquidation distribution.

    17.
    Comment: In the “Ranking” sub-section, please also expand the disclosure to clarify that, subject to the asset coverage requirements of the 1940 Act, the Company may issue indebtedness that is senior in right of payment to the Series A Preferred Shares without the vote or consent of Series A Preferred Shares holders.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

    18.
    Comment: In the “Dividends” / “Dividend Periods” subsection (page 89), please describe how the Company will notify Series A Preferred Shares holders of the applicable record dates for each dividend payment.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

    19.
    Comment: In the “Modification” sub-section (page 96), please clarify that, consistent with other provisions of the Series A Certificate of Designations, no modification made to cure any ambiguity, or correct or supplement any provision, without the consent of Series A Preferred Shares holders, will materially or adversely affect any preference, right or powers of those preferred shareholders.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

       David P. Mathews
 October 24, 2024

Page 6

Underwriting

    20.
    Comment: Please update the disclosure in the “Alternative Settlement Cycle” sub-section (page 99) to reflect recent amendments to Exchange Act Rule 15c6-1 that became effective on May 28, 2024, with regard to required settlement times.

Response: The Company notes that disclosure has been revised in the Pre-Effective Amendment in response to the Staff’s comment.

* * *

We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at 202.261.3460 if you wish to discuss this correspondence further.

    Sincerely,

    /s/ Philip T. Hinkle

    Philip T. Hinkle

    cc:
    Harry S. Pangas, Dechert LLP
 Nicholas Chionchio, Dechert LLP
 Steven B. Boehm, Eversheds Sutherland (US) LLP
 Payam Siadatpour, Eversheds Sutherland (US) LLP
 Christian Sandoe, Securities and Exchange Commission
 Jay Williamson, Securities and Exchange Commission
 Mindy Rotter, Securities and Exchange Commission

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

    PHILIP
    T. HINKLE

        philip.hinkle@dechert.com

        +1 202 261 3460 Direct

        +1 202 261 3050 Fax

June 12, 2024

Via EDGAR

U.S. Securities and Exchange Commission
Division of Investment Management
 Disclosure Review and Accounting Office
100 Pearl Street, Suite 20-100
New York, NY 10004
Attn: Mr. Raymond Be

    Re:
    Sound Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

Dear Mr. Be:

This letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) on June 12, 2024, in connection with your review of the amended registration statement on Form N-2 (the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital, LLC) (the “Fund”) filed with the SEC on June 11, 2024. The Fund has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement on its behalf.

The Fund has filed a Pre-Effective Amendment to its Registration Statement reflecting the disclosure changes discussed below. Capitalized terms have the meanings attributed to such terms in the Registration Statement.

On behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such comments, as requested.

General Comments

1. Comment: The Staff is aware of recent news addressing stresses in collateralized loan obligation (“CLO”) and commercial mortgage-backed securities (“CMBS”) markets, particularly in structures focused on real estate. Given the nature of the portfolio being acquired by the Fund, please confirm in correspondence that the Fund has considered the need for updated summary and risk disclosures addressing the current CLO and CMBS markets and how the risks may impact the Fund and its investors.

 Response: The Fund confirms that it has considered the need for updated summary and risk disclosures addressing current market conditions and how they may impact the Fund and its investors. While the Fund appreciates that there have been recent news articles regarding potential stress in the CMBS and CRE-CLO market, the Fund respectfully notes that its mandate is focused on broadly syndicated loan CLO structures, which are collateralized by corporate loans, not CRE loans.

       June 12, 2024

Page 2

Comments Related to Appendix B

2. Comment: Please include a heading that clearly describes the source of the prior performance and does not suggest that performance is that of the Fund.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

3. Comment: Please disclose that the performance includes all accounts that are substantially similar to the Fund.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

4. Comment: Please supplementally confirm that the presentation includes substantially similar accounts managed by the Adviser, not just accounts managed by the Fund’s portfolio managers. The Staff notes that, if the Adviser and its affiliates have in common virtually all of their investment professionals, then the performance presentation may also include accounts managed by those affiliates.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

5. Comment: Please confirm that the prior performance presentation discloses performance that is either: (i) net of all actual fees and expenses or (ii) adjusted to reflect all of the Fund’s expenses listed in the Fund’s fee table, including sales load. If the Fund presents adjusted performance, please supplementally disclose that the use of adjusted fees and expenses does not result in performance that is higher than the performance that would have been achieved using actual fees and expenses.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

6. Comment: Please disclose that the private accounts were not subject to certain investment limitations, diversification requirements, and other restrictions imposed by the Investment Company Act of 1940 and the Internal Revenue Code, which, if applicable, may have adversely affected the performance result.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

7. Comment: If the standardized SEC calculation method was not used to calculate prior performance, please disclose how the performance was calculated and that the calculation method differs from the standardized SEC calculation method.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

       June 12, 2024

Page 3

8. Comment: Please present the average annual total returns for the 1-, 5- and 10-year periods (or since the date of inception, if less than 10 years).

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

9. Comment: Please supplementally confirm that the Fund has the records necessary to support the calculation of the performance, as required by Rule 204-2(a)(16) under the Investment Advisers Act of 1940.

 Response: The referenced performance information has been removed from the Registration Statement. Accordingly, this comment is no longer applicable.

*       *       *

Should you have any questions or comments, please contact me at 202.261.3460.

    Sincerely,

    /s/ Philip T. Hinkle

    Philip T. Hinkle

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

    PHILIP T. HINKLE

        philip.hinkle@dechert.com

        +1 202 261 3460 Direct

        +1 202 261 3050 Fax

June 11, 2024

Via EDGAR

U.S. Securities and Exchange Commission
 Division of Investment Management

Disclosure Review and Accounting Office
 100 Pearl Street, Suite 20-100
 New York, NY 10004
 Attn: Mr. Raymond Be

    Re:
    Sound Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

Dear Mr. Be:

This letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) on June 10, 2024 and June 11, 2024, in connection with your review of the amended registration statement on Form N-2 (the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital, LLC) (the “Fund”) filed with the SEC on May 29, 2024. The Fund has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement on its behalf.

The Fund will file a Pre-Effective Amendment to its Registration Statement (the “Amended Registration Statement”), which will reflect the disclosure changes discussed below. Capitalized terms have the meanings attributed to such terms in the Registration Statement.

On behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such comments, as requested.

1. Comment: Please include clarifying disclosure on the cover page of the Registration Statement addressing NAV dilution.

Response: The Fund has revised the disclosure as follows (new disclosure underlined; deleted disclosure struck through):

“This is our initial public offering and our common stock has no history of public trading. We are offering 3,750,000 shares of common stock. Assuming an initial public offering price of $20.00 per share of common stock (which wasis above our net asset value, or “NAV,” per share as of the date of this prospectus due to dilution), purchasers in this offering will experience immediate dilution in NAV of approximately $        per share on a pro forma basis after deducting offering expenses payable by us of $300,000. See ‘Capitalization — Pro Forma Dilution.’”

Additionally, the Fund confirms that it will make corresponding changes to the “Capitalization—Pro Forma Dilution” section of the Registration Statement.

       June 11, 2024

Page 2

2. Comment: Please confirm which New York Stock Exchange (“NYSE”) listing qualifications the Fund will meet and how the Fund will meet the listing qualifications.

Response: The Fund intends to comply with the following minimum public float and shareholder requirements applicable to closed-end funds for initial listing on the NYSE:

    1.
    400 round lot stockholders.

    2.
    1,100,000 publicly held shares.

    3.
    $20 million of (i) market value of publicly held shares or (ii) net assets.

    4.
    $4 stock price.1

3. Comment: Please confirm in correspondence that the Fund has received a no-objection letter from the Financial Industry Regulatory Authority, Inc. (“FINRA”).

Response: The underwriters have advised the Fund that they expect to receive FINRA’s no-objection to the underwriting compensation arrangements relating to the initial public offering of shares of the Fund’s common stock shortly and have provided the FINRA examiner with the SEC reviewer’s contact information so that the FINRA examiner can orally notify the SEC reviewer of the same.

4. Comment: Please confirm in correspondence that the free writing prospectus includes all accounts that the Adviser manages using a substantially similar strategy as that of the Fund.

Response: The Fund so confirms.

*     *      *

Should you have any questions or comments, please contact me at 202.261.3460.

    Sincerely,

    /s/ Philip T. Hinkle

    Philip T. Hinkle

    1
    See NYSE Manual Section 102.04 Minimum Numerical Standards - Closed-end Management Investment Companies.

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

    PHILIP T. HINKLE

        philip.hinkle@dechert.com

        +1 202 261 3460 Direct

        +1 202 261 3050 Fax

      June 10, 2024

      Via EDGAR

      U.S. Securities and Exchange Commission
Division
of Investment Management

      Disclosure Review and Accounting Office
100 Pearl Street, Suite 20-100
New York, NY 10004
Attn: Ms. Mindy Rotter

            Re:
            Sound Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

      Dear Ms. Rotter:

      This letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) on June 7, 2024, in connection with your review of (1) the amended registration statement on Form N-2 (the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital, LLC) (the “Fund”) filed with the SEC on May 29, 2024, and (2) the responses and changes discussed in the letter filed on June 6, 2024. The Fund has considered your comments and has authorized us to make the responses
         and changes discussed below to the Registration Statement on its behalf.

      The Fund will file a Pre-Effective Amendment to its Registration Statement (the “Amended Registration Statement”), which will reflect the disclosure changes discussed below and reflected in Appendices A-1 and A-2 hereto. Capitalized terms have the meanings attributed to such terms in the Registration
         Statement.

      On behalf of the Fund, set forth below are the comments of the Staff along with our
         responses to or any supplemental explanations of such comments, as requested.

      1. Comment: Please confirm in correspondence that the bracketed information included in footnote 1 to the fee table will be provided in the Amendment Registration Statement. Please
         provide the revised disclosure in correspondence.

            Response: The Fund confirms that it will update footnote 1 to the fee table in the Amended Registration Statement as indicated in Appendix A-1 hereto. The Fund respectfully notes that the dollar values in footnote 1 will be omitted in reliance on Rule 430A(a) under the Securities Act of 1933.

       June 10, 2024

Page 2

      2. Comment: Please confirm in correspondence that the following disclosure will be removed from the footnote to the expense example: “would either not be payable or would have an insignificant impact on the expense
         amount shown above.”

            Response: The Fund confirms that it will update the footnote to the expense example as indicated in Appendix A-2 hereto.

      *       *       *

      Should you have any questions or comments, please contact me at 202.261.3460.

      Sincerely,

      /s/ Philip T. Hinkle

      Philip T. Hinkle

       June 10, 2024

Page 3

      Appendix A-1

      FEES AND EXPENSES

      The following table is intended to assist you in understanding the costs and expenses
         that an investor in shares of our common stock will bear directly or indirectly. The
         expenses shown in the table under “Annual Expenses” are based on estimated amounts
         for our first full year of operations and assume that we incur leverage in an amount
         up to approximately 27.4% of our total assets (as determined immediately after the
         leverage is incurred) and that we issue 3,750,000 shares of common stock in this offering
         at an assumed public offering price of $20.00 per share (which price is equal to our
         NAV per share of common stock as of the date of this prospectus). If we issue fewer
         shares of common stock, all other things being equal, these expenses would increase
         as a percentage of net assets attributable to our common stock. The following table
         should not be considered a representation of our future expenses. Actual expenses
         may be greater or less than shown.

    Stockholder Transaction Expenses (as a percentage of the offering price):

    Sales load

    0.00
    %(1)

    Offering expenses

    0.140.08
    %(2)

    Dividend reinvestment plan expenses

    0.00
    (3)

    Total stockholder transaction expenses

    0.140.08
    %

    Annual Expenses (as a percentage of net assets attributable to common stock):

    Base management fee

    1.92
    %(4)

    Incentive fee

    3.64
    %(5)

    Interest payments on borrowed funds

    2.812.80
    %(6)

    Other expenses

    0.75
    %(7)

    Total annual expenses

    9.129.11
    %

    (1)
    The Adviser or its affiliates will pay the full amount of the sales load of $[  ]      per share of common stock issued in connection with this public offering (excluding shares sold to our board of directors, the Adviser, its affiliates, employees of the Adviser and its affiliates and certain other persons if agreed with the underwriters) and an additional fee for structuring the syndicate equal to [ ]0.75% of the gross proceeds, which, assumingexcluding proceeds from certain investors and their affiliates, plus (2) 0.50% of the gross proceeds raised from those certain investors and their affiliates, subject to a maximum fee of $250,000 on such gross proceeds. Assuming the issuance of [  ]3,750,000 shares to the relevant investors in connection with this offering, the sales load and the structuring fee may be up to an aggregate amount of $[  ]     . Because the sales load isand the structuring fee are paid solely by the Adviser or its affiliates (and not by us), it isis the sales load and the structuring fee are not reflected in the table above and will not reduce the NAV per share of our common stock. See “Underwriting.”

    (2)
    Amount reflects offering expenses of $550,000300,000. The Adviser has agreed that it or its affiliates will pay any remaining amounts. The Adviser or its affiliates will also pay all of our organizational expenses. The aggregate organizational expenses (excluding the sales load) are estimated to be approximately $580,000. In addition, the Adviser or its affiliates may be responsible for reimbursement of up to $50,000 of the underwriters’ costs and expenses.

    (3)
    The expenses of administering the DRIP are included in “other expenses.” If a participant elects by written notice to the DRIP administrator prior to termination of his or her account to have the DRIP administrator sell part or all of the shares held by the DRIP administrator in the participant’s account and remit the proceeds to the participant, the DRIP administrator is authorized to deduct a $0.03 per share brokerage commission from the proceeds. See “Dividend Reinvestment Plan.”

       June 10, 2024

Page 4

            (4)
            We have agreed to pay the Adviser as compensation under the Investment Advisory Agreement
               a base management fee at an annual rate of 1.75% of our Total Equity Base which is
               calculated and payable quarterly in arrears. “Total Equity Base” means the net asset
               value attributable to the common stock (prior to the application of the base management
               fee or incentive fee) and the paid-in or stated capital of the preferred interests
               in us (howsoever called), if any.

      The figure shown in the table above reflects our assumption that we incur leverage
         in an amount up to approximately 27.4% of our total assets (as determined immediately
         after the leverage is incurred). These base management fees are indirectly borne by
         holders of our common stock and are not borne by the holders of preferred stock, if
         any, or the holders of any other securities that we may issue. See “The Adviser and the Administrator — Investment Advisory Agreement — Base Management
         Fee and Incentive Fee.”

 (5) We have agreed to pay the Adviser as compensation under the
Investment Advisory Agreement a quarterly incentive fee equal to 20% of our Pre-Incentive Fee Net Investment Income for the immediately
preceding calendar quarter, subject to a quarterly preferred return, or hurdle, of 2.00% (8.00% annualized) and a catch-up feature. Pre-Incentive
Fee Net Investment Income includes, in the case of investments with a deferred interest feature (such as original issue discount, payment-in-kind
interest and zero coupon securities), accrued income that we have not yet received in cash. No incentive fee is payable to the Adviser
on capital gains whether realized or unrealized. The incentive fee is paid to the Adviser as follows:

            ●
            no incentive fee in any calendar quarter in which our Pre-Incentive Fee Net Investment
               Income does not exceed 2.00%;

            ●
            100% of our Pre-Incentive Fee Net Investment Income with respect to that portion of
               such Pre-Incentive Fee Net Investment Income, if any, that exceeds the hurdle rate
               but is less than 2.50% in any calendar quarter (10.00% annualized). We refer to this
               portion of our Pre-Incentive Fee Net Investment Income (which exceeds the hurdle but
               is less than 2.50%) as the “catch-up.” The “catch-up” is meant to provide the Adviser
               with 20% of our Pre-Incentive Fee Net Investment Income as if a hurdle did not apply
               if this net investment income meets or exceeds 2.50% in any calendar quarter; and

            ●
            20% of the amount of our Pre-Incentive Fee Net Investment Income, if any, that exceeds
               2.50% in any calendar quarter (10.00% annualized) is payable to the Adviser (that
               is, once the hurdle is reached and the catch-up is achieved, 20% of all Pre-Incentive
               Fee Net Investment Income thereafter is paid to the Adviser).

            ●
            For a more detailed discussion of the calculation of this fee, see “The Adviser and the Administrator — Investment Advisory Agreement — Base Management
               Fee and Incentive Fee.” We estimate annual incentive fees payable to the Adviser during our first year of
               operation to equal 3.64% based on the historical performance of our initial portfolio
               and our estimation of the use of the proceeds of this offering.

 (6) Assumes that we incur borrowings in an amount up to 27.4% of
our total assets (as determined immediately after the borrowing is incurred) with an assumed interest rate of 8.70% per annum, based
on current market rates.

       June 10, 2024

Page 5

            (7)

               Investors will bear indirectly the fees and expenses (including management fees and
                  other operating expenses) of the CLO equity securities in which we invest.

               CLO collateral manager fees are charged on the total assets of a CLO but are assumed
                  to be paid from the residual cash flows after interest payments to the CLO debt tranches.
                  Therefore, these CLO collateral manager fees (which generally range from 0.35% to
                  0.50% of a CLO’s total assets) are effectively much higher when allocated only to the CLO equity
                  tranche.

               Other operating expenses include an estimate of trustee fees and administrative CLO
                  expenses. These amounts can vary but run in the annual range of 0.04% to 0.07% of
                  a CLO’s total assets.

               The indirect expenses described above that are associated with our CLO equity investments
                  are not included in the fee table presentation, but if such expenses were included
                  in the fee table presentation then our total annual expenses would have been 9.61%
                  - 9.79% (assuming investment of all of the proceeds of this offering in CLO equity
                  investments).

               In addition, CLO collateral managers may earn fees based on a percentage of the CLO’s equity cash flows after the CLO equity has earned an internal rate of return above
                  a specified “hurdle” rate. Future CLO fees and expenses indirectly borne by us may
                  be substantially higher because of these fees, which may fluctuate over time.

       June 10, 2024

Page 6

      Appendix A-2

      Example

The following example is furnished
in response to the requirements of the SEC and illustrates the various costs and expenses that you would pay, directly or indirectly,
on a $1,000 investment in shares of our common stock for the time periods indicated, assuming (1) combined offering expenses payable by
us of 0.140.08%,
(2) total annual expenses of 9.129.11%
of net assets attributable to our common stock and (3) a 5% annual return*:

    1 year

    3 years

    5 years

    10 years

    You would pay the following expenses on a $1,000 investment, assuming a 5% annual return

    $
    9392

    $
    264263

    $
    421420

    $
    761760

 * The example should not be considered
a representation of future returns or expenses, and actual returns and expenses may be greater or less than those shown. The estimated
incentive fee of 3.64% under the Investment Advisory Agreement, which, assuming assumes a 5.0% annual return, would either not be payable or would have an insignificant impact on the
expense amount shown above, is included in the example. The example assumes that the estimated “other expenses”
set forth in the Annual Expenses table are accurate, and that all dividends and distributions are reinvested at NAV. Our actual rate
of return may be greater or less than the hypothetical 5% return shown in the example.

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

    PHILIP T. HINKLE

        philip.hinkle@dechert.com

        +1 202 261 3460 Direct

        +1 202 261 3050 Fax

June 6, 2024

Via EDGAR

U.S. Securities and Exchange Commission
 Division of Investment Management

Disclosure Review and Accounting Office
 100 Pearl Street, Suite 20-100
 New York, NY 10004
 Attn: Ms. Mindy Rotter

    Re:
    Sound Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

Dear Ms. Rotter:

This
letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “SEC”) on May 30, 2024, in connection with your review of the amended registration statement on Form N-2
(the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly Sound Point Meridian Capital,
LLC) (the “Fund”) filed with the SEC on May 29, 2024. The Fund has considered your comments and has authorized
us to make the responses and changes discussed below to the Registration Statement on its behalf.

The
Fund will file a Pre-Effective Amendment to its Registration Statement (the “Amended Registration Statement”),
which will reflect the disclosure changes discussed below and reflected in Appendices A-1 and A-2 hereto. Capitalized terms have the
meanings attributed to such terms in the Registration Statement.

On behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such comments, as requested.

1. Comment: Please confirm in correspondence that the reference to footnote 7 to the fee table will be added to the “Other expenses” line item in the Amended Registration Statement prior to requesting acceleration of the Amended Registration Statement’s effectiveness.

Response:
The Fund confirms that it will update the fee table in the Amended Registration Statement to include the reference to footnote 7
in the “Other expenses” line item as indicated in Appendix A-1 hereto.

       June 6, 2024

Page 2

2. Comment: Please confirm in correspondence that the expense example will be rounded to the nearest dollar in accordance with Item 3 of Form N-2 in the Amended Registration Statement.

Response:
The Fund confirms that it will update the expense example as indicated in Appendix A-2 hereto.

3. Comment: Please confirm in correspondence that the expense example in the Amended Registration Statement will be updated to include an example that shows what expenses would be if the Incentive Fee is included. Additionally, please revise the lead in paragraph to the expense example, as necessary.

Response: The Fund confirms that it will update the expense example, and the lead-in paragraph thereto, as indicated in Appendix A-2 hereto.

*   *    *

Should you have any questions or comments, please contact me at 202.261.3460.

    Sincerely,

    /s/ Philip T. Hinkle

    Philip T. Hinkle

       June 6, 2024

Page 3

Appendix A-1

FEES AND EXPENSES

The following table is intended to assist you in understanding the costs and expenses that an investor in shares of our common stock will bear directly or indirectly. The expenses shown in the table under “Annual Expenses” are based on estimated amounts for our first full year of operations and assume that we incur leverage in an amount up to approximately 28.527.4% of our total assets (as determined immediately after the leverage is incurred) and that we issue 3,750,000 shares of common stock in this offering at an assumed public offering price of $20.00 per share (which price is equal to our NAV per share of common stock as of the date of this prospectus). If we issue fewer shares of common stock, all other things being equal, these expenses would increase as a percentage of net assets attributable to our common stock. The following table should not be considered a representation of our future expenses. Actual expenses may be greater or less than shown.

    Stockholder Transaction Expenses (as a percentage of the offering price):

    Sales load

    0.00
    %(1)

    Offering expenses

    0.080.14
    %(2)

    Dividend reinvestment plan expenses

    0.00
    (3)

    Total stockholder transaction expenses

    0.080.14
    %

    Annual Expenses (as a percentage of net assets attributable to common stock):

    Base management fee

    1.931.92
    %(4)

    Incentive fee

    3.693.64
    %(5)

    Interest payments on borrowed funds

    2.81
    %(6)

    Other expenses

    0.75
    %(7)

    Total annual expenses

    9.189.12
    %

    (1)
    The Adviser or its affiliates will pay the full amount of the sales load of $[ ] per share of common stock issued in connection with this offering (excluding shares sold to our board of directors, the Adviser, its affiliates, employees of the Adviser and its affiliates and certain other persons if agreed with the underwriters) and an additional fee for structuring the syndicate equal to [ ]% of the gross proceeds, which, assuming the issuance of [ ] shares to the relevant investors in connection with this offering, may be up to an aggregate amount of $[ ]. Because the sales load is paid solely by the Adviser or its affiliates (and not by us), it is not reflected in the table above and will not reduce the NAV per share of our common stock. See “Underwriting.”

    (2)
    Amount reflects offering
    expenses of $300,000550,000.
    The Adviser or its affiliates will pay all of our organizational expenses. The aggregate organizational expenses (excluding the sales
    load) are estimated to be approximately $580,000. In addition, the Adviser or its affiliates shallmay be responsible for reimbursement of up to $50,000 of the underwriters’ costs and expenses.

    (3)
    The expenses of administering the DRIP are included in “other expenses.” If a participant elects by written notice to the DRIP administrator prior to termination of his or her account to have the DRIP administrator sell part or all of the shares held by the DRIP administrator in the participant’s account and remit the proceeds to the participant, the DRIP administrator is authorized to deduct a $0.03 per share brokerage commission from the proceeds. See “Dividend Reinvestment Plan.”

       June 6, 2024

Page 4

    (4)
    We have agreed to pay the Adviser as compensation under the Investment Advisory Agreement a base management fee at an annual rate of 1.75% of our Total Equity Base which is calculated and payable quarterly in arrears. “Total Equity Base” means the net asset value attributable to the common stock (prior to the application of the base management fee or incentive fee) and the paid-in or stated capital of the preferred interests in us (howsoever called), if any.

The figure shown in the table above reflects our assumption that we incur leverage in an amount up to approximately 28.527.4% of our total assets (as determined immediately after the leverage is incurred). These base management fees are indirectly borne by holders of our common stock and are not borne by the holders of preferred stock, if any, or the holders of any other securities that we may issue. See “The Adviser and the Administrator — Investment Advisory Agreement — Base Management Fee and Incentive Fee.”

    (5)
    We have agreed to pay the Adviser as compensation under the Investment Advisory Agreement a quarterly incentive fee equal to 20% of our Pre-Incentive Fee Net Investment Income for the immediately preceding calendar quarter, subject to a quarterly preferred return, or hurdle, of 2.00% (8.00% annualized) and a catch-up feature. Pre-Incentive Fee Net Investment Income includes, in the case of investments with a deferred interest feature (such as original issue discount, payment-in-kind interest and zero coupon securities), accrued income that we have not yet received in cash. No incentive fee is payable to the Adviser on capital gains whether realized or unrealized. The incentive fee is paid to the Adviser as follows:

    ●
    no incentive fee in any calendar quarter in which our Pre-Incentive Fee Net Investment Income does not exceed 2.00%;

    ●
    100% of our Pre-Incentive Fee Net Investment Income with respect to that portion of such Pre-Incentive Fee Net Investment Income, if any, that exceeds the hurdle rate but is less than 2.50% in any calendar quarter (10.00% annualized). We refer to this portion of our Pre-Incentive Fee Net Investment Income (which exceeds the hurdle but is less than 2.50%) as the “catch-up.” The “catch-up” is meant to provide the Adviser with 20% of our Pre-Incentive Fee Net Investment Income as if a hurdle did not apply if this net investment income meets or exceeds 2.50% in any calendar quarter; and

    ●
    20% of the amount of our Pre-Incentive Fee Net Investment Income, if any, that exceeds 2.50% in any calendar quarter (10.00% annualized) is payable to the Adviser (that is, once the hurdle is reached and the catch-up is achieved, 20% of all Pre-Incentive Fee Net Investment Income thereafter is paid to the Adviser).

    ●
    For a more detailed discussion
    of the calculation of this fee, see “The Adviser and the Administrator — Investment Advisory Agreement —
    Base Management Fee and Incentive Fee.” We estimate annual incentive fees payable to the Adviser during our first year
    of operation to equal [3.693.64]%
    based on the historical performance of our initial portfolio and our estimation of the use of the proceeds of this offering.

    (6)
    Assumes that we incur borrowings in an amount up to 28.527.4% of our total assets (as determined immediately after the borrowing is incurred) with an assumed interest rate of 8.008.70% per annum, based on current market rates.

       June 6, 2024

Page 5

    (7)

        Investors will bear indirectly the fees and expenses (including management fees and other operating expenses) of the CLO equity securities in which we invest.

        CLO collateral manager fees are charged on the total assets of a CLO but are assumed to be paid from the residual cash flows after interest payments to the CLO debt tranches. Therefore, these CLO collateral manager fees (which generally range from 0.35% to 0.50% of a CLO’s total assets) are effectively much higher when allocated only to the CLO equity tranche.

Other operating expenses include an estimate of trustee fees and administrative CLO expenses. These amounts can vary but run in the annual range of 0.04% to 0.07% of a CLO’s total assets.

 The indirect expenses described above that are associated with our CLO equity investments are not included in the fee table presentation, but if such expenses were included in the fee table presentation then our total annual expenses would have been 9.61% - 9.79% (assuming investment of all of the proceeds of this offering in CLO equity investments).

 In addition, CLO collateral managers may earn fees based on a percentage of the CLO’s equity cash flows after the CLO equity has earned an internal rate of return above a specified “hurdle” rate. Future CLO fees and expenses indirectly borne by us may be substantially higher because of these fees, which may fluctuate over time.

       June 6, 2024

Page 6

Appendix A-2

Example

The following example is furnished in response to the requirements of the SEC and illustrates the various costs and expenses that you would pay, directly or indirectly, on a $1,000 investment in shares of our common stock for the time periods indicated, assuming (1) combined offering expenses payable by us of 0.080.14%, (2) total annual expenses of 5.499.12% of net assets attributable to our common stock and (3) a 5% annual return*:

    1 year

    3 years

    5 years

    10 years

    You would pay the following expenses on a $1,000 investment, assuming a 5% annual return

    $
    55.6593

    $
    164.56264

    $
    272.41421

    $
    537.44761

    *
    The example should not be
    considered a representation of future returns or expenses, and actual returns and expenses may be greater or less than those shown.
    The estimated incentive fee of 3.64% under the Investment Advisory
    Agreement, which, assuming a 5.0% annual return, would
    either not be payable or would have an insignificant impact on the expense amount
    shown above, is included in the example. The example assumes that the estimated “other expenses” set forth in the
    Annual Expenses table are accurate, and that all dividends and distributions are reinvested at NAV. In
    addition, because the example assumes a 5% annual return, the example does not reflect the payment of the incentive fee which would
    either not be payable or would have an insignificant impact on the expense amounts
    shown above. Our actual rate of return may
    be greater or less than the hypothetical 5% return shown in the example.

CORRESP
1
filename1.htm

    1900
    K Street, NW

    Washington, DC 20006

    +1
    202 261 3300 Main

    +1
    202 261 3333 Fax

    www.dechert.com

    Philip
T. Hinkle

    philip.hinkle@dechert.com

    +1
    202 261 3460 Direct

    +1
    202 261 3050 Fax

May
22, 2024

Via
EDGAR

U.S.
Securities and Exchange Commission

Division of Investment Management

Disclosure
Review and Accounting Office

100 Pearl Street, Suite 20-100

New York, NY 10004

Attn: Ms. Mindy Rotter

 Re: Sound
                                            Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

Dear
Ms. Rotter:

This
letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “SEC”) on May 21, 2024, in connection with your review of the amended registration statement on Form N-2
(the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital,
LLC) (the “Fund”) filed with the Securities and Exchange Commission (“SEC”) on May 10, 2024. The
Fund has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement
on its behalf.

The
Fund will file a Pre-Effective Amendment to its Registration Statement (the “Amended Registration Statement”),
which will reflect the disclosure changes discussed below. Capitalized terms have the meanings attributed to such terms in the Registration
Statement.

On
behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such
comments, as requested.

1.       Comment:
The Staff notes that the fee table and example in the “FEES AND EXPENSES” section remain incomplete. Please confirm in
correspondence that the tables will be completed in the Amended Registration Statement.

Response:
The Fund so confirms.

2.       Comment:
Regulation S-X 6-04.15 requires a line item for commitments and contingencies. The Staff notes that such disclosure was not provided
on the Statement of Assets and Liabilities of the Fund. Please confirm in correspondence that all commitments and contingencies have
been accounted for in the audited financial statements and please confirm that the required disclosure will be provided as warranted
going forward.

Response:
The Fund so confirms.

  May 22, 2024

  Page 2

3.       Comment:
Please confirm in correspondence that an updated auditor’s consent will be provided for the seed financial statements when
the request for acceleration is filed with respect to the Amended Registration Statement.

Response:
The Fund so confirms.

4.       Comment:
Please confirm in correspondence that an updated auditor’s consent will be provided for the financial statements of the entity
to be acquired when the request for acceleration is filed with respect to the Amended Registration Statement.

Response:
The Fund so confirms.

*
    *     *

Should
you have any questions or comments, please contact me at 202.261.3460.

    Sincerely,

    /s/
    Philip T. Hinkle

    Philip
    T. Hinkle

CORRESP
1
filename1.htm

  1900 K Street,
NW
 Washington, DC 20006

+1 202 261 3300
Main

+1 202 261 3333
Fax

www.dechert.com

  Philip
T. Hinkle

philip.hinkle@dechert.com

+1
202 261 3460 Direct

+1
202 261 3050 Fax

May
1, 2024

Via
EDGAR

U.S.
Securities and Exchange Commission

Division of Investment Management

Disclosure
Review and Accounting Office

100 Pearl Street, Suite 20-100

New York, NY 10004

Attn: Ms. Mindy Rotter

 Re: Sound
                                            Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

Dear
Ms. Rotter:

This
letter responds to oral comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “SEC”) on April 25, 2024, in connection with your review of the amended registration statement on Form
N-2 (the “Registration Statement”) for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital,
LLC) (the “Fund”) filed with the Securities and Exchange Commission (“SEC”) on April 15, 2024.
The Fund has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement
on its behalf.

The
Fund will file Pre-Effective Amendment No. 3 to its Registration Statement (the “Amended Registration Statement”),
which will reflect the disclosure changes discussed below. Capitalized terms have the meanings attributed to such terms in the Registration
Statement.

On
behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such
comments, as requested.

  1.
                                            Comment: The Staff notes that reference was not made to financial highlights in
                                            Pre-Effective Amendment No. 2 to the Registration Statement. Please confirm in correspondence
                                            that a statement regarding the financial highlights (i.e., that the Fund is newly
                                            organized, the Fund does not have any financial history as of the date of this prospectus,
                                            and that the Fund’s financial highlights will be available in the Fund’s annual,
                                            semiannual reports, etc.) will be included in the Amended Registration Statement.

Response:
The Fund will revise the disclosure accordingly in the Amended Registration Statement.

  2.
                                            Comment: The Staff notes that portions of the Registration Statement remain incomplete
                                            and reminds the Fund that a full financial review must be completed before the Amended Registration
                                            Statement can be declared effective. The Staff may have additional comments following a review
                                            of the Amended Registration Statement.

Response:
The Fund respectfully acknowledges the Staff’s comment and confirms that the Amended Registration Statement will contain all
information required for the Staff to complete a full financial review.

*
  *   *

  May 1, 2024

Page 2

Should
you have any questions or comments, please contact me at 202.261.3460.

Sincerely,

/s/
Philip T. Hinkle

Philip
T. Hinkle

CORRESP
1
filename1.htm

        1900 K Street, NW

        Washington, DC 20006

        +1 202 261 3300 Main

        +1 202 261 3333 Fax

        www.dechert.com

    PHILIP T. HINKLE

        philip.hinkle@dechert.com

        +1 202 261 3460 Direct

        +1 202 261 3050 Fax

April 15, 2024

Via EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

Attn: Mr. Raymond A. Be

 Re: Sound Point Meridian Capital, Inc. (File Nos. 333-272541 and 811-23881)

Dear Mr. Be:

This letter responds to oral comments issued by
the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”)
on March 18, 2024, in connection with your review of the amended registration statement on Form N-2 (the “Registration Statement”)
for Sound Point Meridian Capital, Inc. (formerly, Sound Point Meridian Capital, LLC) (the “Fund”) filed with
the Securities and Exchange Commission (“SEC”) on November 1, 2023. The Fund has considered your comments and has authorized
us to make the responses and changes discussed below to the Registration Statement on its behalf.

The Fund has filed Pre-Effective Amendment No.
2 to its Registration Statement (the “Amended Registration Statement”), which reflects the disclosure changes
discussed below. Capitalized terms have the meanings attributed to such terms in the Amended Registration Statement.

On behalf of the Fund, set forth below are the
comments of the Staff along with our responses to or any supplemental explanations of such comments, as requested.

Summary of Offering
– Distributions

1. Comment:
The staff is re-issuing Comment 15 issued by the Staff on July 19, 2023. To the extent the Fund discloses a policy or practice to
maintain distributions, please also disclose the potential source of such distributions and the impact of distributions from such
sources. This disclosure should clarify: (1) that distributions that are not entirely from income and gains would be made even if
the Fund had negative performance, if true, (2) that shareholders who receive a distribution consisting of return of capital may be
under the impression that they are receiving net profits when they are not, and (3) that distributions of return of capital may not
reflect the performance of the Fund.

Response:
The Fund acknowledges the Staff’s comment. The Fund respectfully maintains that disclosing the Fund’s intended distribution
policies is consistent with market practice for registration statements filed on Form N-2 in connection with initial public offerings.
The disclosure will be revised as follows (new text underlined; deleted text struck through). These edits will also be incorporated in
corresponding disclosure on page 72 under the section “Distribution Policy – Regular Distributions.”

    April
        15, 2024

        Page
        2

[We anticipate declaring
a distribution of approximately $[  ] per share of common stock for the month of [  ] (in each case, if continued,
such amount to equal approximately [  ]% annualized of our initial public offering price per share) payable to holders of our
common stock, including investors in this offering.] If our distributions exceed our investment company taxable income in a tax
year, such excess will represent a return of capital to our stockholders, which is in effect a partial return of the
amount a stockholder invested in us. Stockholders who receive the payment of a distribution consisting of a return of capital may be under
the impression that they are receiving net investment income or profit when they are not. Stockholders should not assume that the source
of a distribution from us is net investment income or profit, and our distributions should not be used as a measure of performance or
confused with yield or income. A return of capital will lower a shareholder’s tax basis in his or her shares, which could result
in shareholders having to pay higher taxes in the future when shares are sold, even when shares are sold at a loss from the original investment.
Additionally, in order to maintain a stable level of distributions, we may at times pay out less than all of our investment income or
pay out accumulated undistributed income in addition to current net investment income. No assurance can be given that we will be able
to declare such distributions in future periods, and our ability to declare and pay distributions will be subject to a number of factors,
including our results of operations.

*     *     *

Should you have any questions or comments, please
contact me at 202.261.3460.

Sincerely,

/s/ Philip T. Hinkle

Philip T. Hinkle

CORRESP
1
filename1.htm

    1900
                                            K Street, NW

                                            Washington, DC 20006

    +1
    202 261 3300 Main

    +1
    202 261 3333 Fax

    www.dechert.com

                                                                                         Philip
T. Hinkle

philip.hinkle@dechert.com

+1
202 261 3460 Direct

+1
202 261 3050 Fax

October
5, 2023

Via
EDGAR

U.S.
Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

Attn: Mr. Raymond A. Be

 Re: Sound
                                            Point Meridian Capital, LLC (File Nos. 333-272541 and 811-23881)

Dear
Mr. Be:

This
letter responds to comments issued by the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “SEC”) in a letter dated July 19, 2023, in connection with your review of the registration statement
on Form N-2 (the “Registration Statement”) for Sound Point Meridian Capital, LLC (the “Fund”)
filed with the Securities and Exchange Commission (“SEC”) on June 9, 2023. The Fund has considered your comments and has
authorized us to make the responses and changes discussed below to the Registration Statement on its behalf.

The
Fund intends to file Pre-Effective Amendment No. 1 to its Registration Statement (the “Amended Registration Statement”)
at a future date, which will reflect the disclosure changes discussed below.” Capitalized terms have the meanings attributed to
such terms in the Amended Registration Statement.

On
behalf of the Fund, set forth below are the comments of the Staff along with our responses to or any supplemental explanations of such
comments, as requested.

 General

1. Comment:
                                            We note that portions of the filing, including the Fund’s financial statements,
                                            are incomplete. A full financial review (e.g., seed financial statements, auditor’s
                                            report, consent) must be performed prior to declaring the registration statement effective.
                                            We may have additional comments on such portions when you complete them in a pre-effective
                                            amendment, on disclosures made in response to this letter, on information supplied supplementally,
                                            or on exhibits added in any amendments. Given the substantial amount of missing information,
                                            please plan for additional time for staff review once the relevant disclosures are filed.

Response:
The Fund acknowledges the Staff’s comment.

 October 5, 2023

Page 2

2. Comment:
                                            Please supplementally explain the status of any exemptive relief or no-action request
                                            submitted, or expected to be submitted, in connection with the registration statement, including
                                            with respect to multi-class and co-investment relief. Also, to the extent exemptive relief
                                            has not been obtained, highlight the fact that the Fund will only offer Institutional Shares
                                            until such relief is granted.

Response:
On June 13, 2023, the Fund submitted to the SEC an application for an order pursuant to Section 17(d) of the Investment Company Act
of 1940, as amended (the “1940 Act” or “Investment Company Act”), and Rule 17d-1
thereunder to permit the Fund to engage in certain joint transactions that otherwise would be prohibited by Section 17(d), including
to allow the Fund to participate in the same investment opportunities with other funds through a proposed co-investment program, as described
more fully in the application.

Other
than this application, the Fund has not submitted and does not expect to submit any other applications for exemptive relief or no-action
requests in connection with the Registration Statement, including multi-class relief, and will only offer Institutional Shares until
such relief is granted.

3. Comment:
                                            Please tell us if you have presented any test the waters materials in connection with
                                            this offering. We may have additional comments based on your response.

Response:
The Fund confirms that it has not presented any test the waters materials to potential investors in connection with this offering.

4. Comment:
                                            Please confirm in your response letter that FINRA has reviewed the proposed distribution
                                            arrangements for the offering described in the registration statement and that FINRA has
                                            issued a statement expressing no objections to the arrangements of the offering.

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.

5. Comment:
                                            Section 8(c) of the Securities Act relates to post-effective amendments. Please remove
                                            the check from the box next to “when declared effective pursuant to Section 8(c).”

Response:
The Fund will revise the disclosure on the cover page of the Amended Registration Statement in response to the Staff’s comment.

6. Comment:
                                            In correspondence please advise us of the timing of your Initial Portfolio Transaction
                                            and the implications of the transaction under the federal securities laws. In your response
                                            address,

 ● How
                                            the transaction complies with Section 17 of the Investment Company Act, including any no-action
                                            letters on which you intend to rely;

 ● What
                                            disclosures will be provided to investors about the transaction and portfolio investments
                                            prior to any sales of your securities to investors;

 October 5, 2023

Page 3

 ● The
                                            general background of the portfolio being purchased, including when the investments were
                                            initially purchased and why they were purchased, whether the same investment analyses were
                                            applied to these purchases, and who you are purchasing the investments from; and,

 ● How
                                            the Fund will pay for the purchase of the initial portfolio.

Response:
The Fund anticipates that as soon as possible after the effective date of the Registration Statement and immediately prior to the
completion of the initial public offering of its shares of common stock in the Fund (“Common Stock”), Sound
Point Meridian Master Fund LP, a Cayman Islands exempted limited partnership that currently owns 100% of the interest in the Fund (the
“Sole Member”), will transfer all of its assets and other portfolio securities and liabilities to the Fund
in exchange for interest in the Fund (the “Initial Portfolio Transaction”). No other consideration, payments
or fees will be made in connection with the Initial Portfolio Transaction. The Fund will contemporaneously convert into Sound Point Meridian
Capital, Inc., a Delaware corporation, pursuant to the terms and provisions of a plan of conversion (the “Conversion”).
The interest in the Fund held by the Sole Member will convert by action of law into shares of Common Stock at the time of the Conversion.
The Sole Member will receive a number of shares of the Fund’s Common Stock equal to (1) the Fund’s net asset value as of
the Conversion date divided by (2) the public offering price for Common Stock to be issued in the initial public offering multiplied
by (3) the Sole Member’s proportionate share of units outstanding immediately prior to the Conversion.1 The Sole
Member will distribute on a pro rata basis to the limited partners of the Sole Member all of the Fund shares received in the Initial
Portfolio Transaction in exchange for their partnership interests in the Sole Member in liquidation of the Sole Member contemporaneous
with the Conversion. With respect to compliance with Section 17 of the 1940 Act, the Fund confirms that these transactions will be effected
in a manner substantially consistent with the representations set forth in GuideStone Financial Resources of the Southern Baptist
Convention, SEC No-Action Letter (pub. avail. Dec. 27, 2006) (“Guidestone”). Further, the transactions
are intended to qualify as a nontaxable exchange under Section 351 of the Internal Revenue Code of 1986, as amended (the “Code”),
followed by a nontaxable distribution under Section 731 of the Code.

The
assets and other portfolio securities to be acquired by the Fund in the Initial Portfolio Transaction are comprised of certain equity
and mezzanine tranches of collateralized loan obligations (“CLOs”) and loan accumulation facilities (“LAFs”
or “warehouses”). These CLOs and LAFs were purchased in both the primary and secondary markets beginning in
February 2022, upon inception of the Sole Member. All of the purchased investments to be acquired by the Fund are consistent with the
investment objective, strategies and policies of the Sole Member. The same investment analyses applicable to the Fund were applied to
these purchases because the Fund’s investment objective, strategies and policies, investment adviser and portfolio managers are,
in all material respects, equivalent to those of the Sole Member.

1 With
                                            regard to valuation, the Sole Member and the Fund will follow the conditions of Guidestone.
                                            In this regard, the Sole Member and the Fund will have the same procedures for determining
                                            their net asset values, which procedures will be approved by the board of directors of the
                                            Fund. The Sole Member and the Fund will follow those procedures in determining the number
                                            of shares of Common Stock to be issued to the Sole Member in connection with the Initial
                                            Portfolio Transaction and Conversion. In addition, the procedures will require the preparation
                                            of a report by an independent evaluator to be considered by the Fund’s board of directors
                                            in assessing the fair value of any securities (or other assets) for which market quotations
                                            are not readily available, that sets forth the fair value of each such asset as of the date
                                            of the Initial Portfolio Transaction as identified by the independent evaluator. The independent
                                            evaluator will be a person who meets the definition set forth in Rule 17a-8(b)(3) under the
                                            1940 Act. Also, any Fund fair valuation will be conducted consistent with the requirements
                                            of Rule 2a-5 under the 1940 Act.

 October 5, 2023

Page 4

The
disclosure on pages 3 and 52 of the Prospectus under the heading “Our Structure and Formation Transaction” will be
revised to include a description of the assets and other portfolio securities to be acquired by the Fund in the Initial Portfolio Transaction,
consistent with the above. In addition, financial statements of the Sole Member as of a recent date will be included in a pre-effective
amendment to the Registration Statement to be filed at a later date, which financial statements will include a schedule of investments.
This pre-effective amendment to the Registration Statement will also include the seed financial statements of the Fund.

7. Comment:
                                            We note your disclosure that the interests held by your Sole Member will convert into
                                            shares of your common stock “with the number of shares to be determined by [y]our board
                                            of directors ...taking into account [y]our NAV at or around such time and the public offering
                                            price ...” Disclosure elsewhere indicates that common stock is being reserved for sale
                                            to the Adviser, its employees, and their affiliates “in exchange for an aggregate cash
                                            contribution ...” In correspondence, please explain how these transactions will be
                                            consistent with Section 23 of the Investment Company Act. In responding, please tell us what
                                            consideration, if any, has been given to the principles set out in the Big Apple Capital
                                            Corp. (May 6, 1982) no-action letter.

Response:
The Fund respectfully submits that these transactions are consistent with the Staff’s position and guidance in the no-action
letter dated May 6, 1982 (the “Big Apple Letter”), from Stanley B. Judd, Deputy Chief Counsel of the Staff,
to Big Apple Capital Corp. In the Big Apple Letter, the staff declined to provide no-action relief under Sections 23(a) and 23(b) in
connection with the private sale by Big Apple Capital Corp. of 4.2 million common shares at $0.05 per share to its organizers, some of
whom were characterized in the Big Apple Letter as “passive investors,” which would then be followed by a public offering
of 4.0 million shares at a price of $1.00 per share.

As
discussed in response 6 above, the Common Stock to be received by the Sole Member will be issued at the net asset value per share of
Common Stock, which net asset value per share of Common Stock will be the same as the public offering price for Common Stock to be issued
in the initial public offering. Likewise, the Adviser, its employees and its affiliates will purchase the Common Stock at the public
offering price for Common Stock in the initial public offering. As a result, the Fund respectfully submits that the transactions comport
fully with the requirements of Sections 23(a) and 23(b) of the 1940 Act. Accordingly, the Fund believes that the issues addressed in
the Big Apple Letter are not raised in connection with these transactions.

 October 5, 2023

Page 5

Prospectus

8. Comment:
                                            As a general matter, the prospectus disclosure, including the Fund Summary (15 pages)
                                            and Risk Factors (33 pages), are particularly long and dense. Please revise throughout using
                                            plain English principles to enhance its readability. See Rule 421(d) under the Securities
                                            Act of 1933 (“Securities Act”); Office of Investor Education, A Plain English
                                            Handbook: How to create clear SEC disclosure documents (August 1998) (“Plain English
                                            Handbook”).

Response:
 The Fund will review the prospectus disclosure and shorten or revise this disclosure where
appropriate.

Cover
Page

9. Comment:
                                            Briefly clarify that securities that a

July 19, 2023

VIA E-MAIL

Wendy Ruberti General Counsel Sound Point Capital Management, LP
375 Park Avenue, 33
rd Floor
New York, NY 10152  Re: Sound Point Meridian Capital, LLC
 File Nos. 333-272541, 811-23881  Dear Ms. Ruberti:
On June 9, 2023, you filed an initial registra tion statement on Form N-2 on behalf of
Sound Point Meridian Capital, LLC (the “Fund”).  Our comments are set forth below.  Where a
comment is made with regard to disclosure in one location, it is applicable to all similar disclosure appearing elsewhere in the registrati on statement.  We may have additional comments
after reviewing your responses to the followi ng comments, or any amendment to the filing.
 General  1. We note that portions of the filing, incl uding the Fund’s financial statements, are
incomplete.  A full financial revi ew (e.g., seed financial statemen ts, auditor’s report, consent)
must be performed prior to declaring the re gistration statement effective.  We may have
additional comments on such portions when you comp lete them in a pre-effective amendment,
on disclosures made in response to this lette r, on information supplied supplementally, or on
exhibits added in any amendments.  Given the substantial amount of missing information, please
plan for additional time for staff review once the relevant disclosures are filed.
 2.  Please supplementally explai n the status of any exemptiv e relief or no-action request
submitted, or expected to be s ubmitted, in connection with the re gistration statement, including
with respect to multi-class and co-investment relief.  Also, to the extent exemptive relief has not been obtained, highlight the fact that the Fund will only offer Institutional Shares until such relief
is granted.
3. Please tell us if you have pres ented any test the waters mate rials in connection with this
offering.  We may have additiona l comments based on your response.

Wendy Ruberti
July 19, 2023 Page 2

4. Please confirm in your response letter that FINRA has reviewed the proposed distribution
arrangements for the offering described in the re gistration statement and that FINRA has issued a
statement expressing no objections to the arrangements of the offering.
5. Section 8(c) of the Securities Act relates to post-effective amendments.  Please remove
the check from the box next to “when declared effective pursuant to Section 8(c).”
6.  In correspondence please advise us of the timing of your Initial Port folio Transaction and
the implications of the transaction under the fede ral securities laws.  In your response address,

x How the transaction complies with Section 17 of the Investment Company Act, including
any no-action letters on wh ich you intend to rely;
x What disclosures will be provided to investors about the transaction and portfolio
investments prior to any sales of your secu rities to investors;
x The general background of the portfolio being purchased, including when the investments
were initially purchased and why they were purchased, whether the same investment analyses were applied to these purchases , and who you are purchasing the investments
from; and,
x How the Fund will pay for the purchase of the initial portfolio.
 7.  We note your disclosure that the interests held by your Sole Memb er will convert into
shares of your common stock “with the number of shares to be determined by [y]our board of
directors …taking into account [y]our NAV at or around such time and the public offering price
…”  Disclosure elsewhere indicates that common st ock is being reserved fo r sale to the Adviser,
its employees, and their affiliates “in exchange for an aggregate cash contribution …”  In correspondence, please explain how these transacti ons will be consistent with Section 23 of the
Investment Company Act.  In responding, please te ll us what consideration, if any, has been
given to the principles set out in the Big A pple Capital Corp. (May 6, 1982) no-action letter.
 Prospectus  8. As a general matter, the prospectus disc losure, including the Fund Summary (15 pages)
and Risk Factors (33 pages), ar e particularly long and dense.  Please revise throughout using
plain English principles to enhance its readability.  See Rule 421(d) under th e Securities Act of
1933 (“Securities Act”); Office of Investor Edu cation, A Plain English Handbook: How to create
clear SEC disclosure documents (A ugust 1998) (“Plain English Handbook”).
 Cover Page
 9. Briefly clarify that securities that are “unrated or rated below investment grade” are commonly known as “junk bonds.”

Wendy Ruberti
July 19, 2023 Page 3

Prospectus Summary (page 1)
 10. The disclosure states “Our focus is on th e primary market when the arbitrage between
assets and liabilities is attractive and will switc h to the secondary market during times of market
volatility or when we identify a ttractive opportunistic and idios yncratic trades.”  Use plain
English principles to explain the Fund’s stra tegy.  Avoid excessive jargon.  Please revise
accordingly.  11. Please consider adding one or more graphics explaining what a CLO is, including its assets
and capital structure, payment wa terfalls, and key features that  may disrupt payments to, or
impair the value of, lower tranches.  Clearly indica te the tranches you will invest principally in.
 Fundamental credit analysis (page 3)
 12. Clearly disclose the types of data and analysis that the Advi ser uses to select securities
and construct the Fund’s portfolio.
 Flexible and disciplined approach (page 3)
 13. The disclosure states that the Adviser “aims  to rotate the portfo lio between equity and
mezzanine.”  Briefly explain what this means in plain English.  Portfolio Composition (page 4)
 14. Briefly clarify, if true, that the F und will be targeting equity tranches of CLOs .
Distributions (page 10)  15. The disclosure discusses the anticipated amount  and percentage of future distributions.
Please explain why such disclosure is consiste nt with Rule 156, or remove.  See also the
disclosure on page 72.  We may be subject to risks associated with  any wholly-owned subsidiaries (page 22)

16. In an appropriate location:
x Disclose that a subsidiary includes entities that engage in investment activities in
securities or other assets that ar e primarily controlled by the Fund.
x Disclose that the Fund will comply with th e provisions of the Investment Company Act
governing investment policies (Section 8) on an aggregate basis with any subsidiary.
x Disclose that the Fund will comply with th e provisions of the Investment Company Act
governing capital structure and leverage (Sec tion 18) on an aggregate basis with the
subsidiary so that the Fund will treat a subsidiary’s debt as its own for purposes of Section 18.

Wendy Ruberti
July 19, 2023 Page 4

x Disclose that any investment adviser to a subsidiary will comply with provisions of the
Investment Company Act relating to investment  advisory contracts (Section 15) as if it
were an investment adviser to the Fund und er Section 2(a)(20) of the Investment
Company Act. Any investment advisory agreement between a subsidiary and its
investment adviser is a materi al contract that should be included as an exhibit to the
registration statement. If the same person is the adviser to both the fund and a subsidiary,
then, for purposes of complying with Secti on 15(c), the reviews of the Fund’s and a
subsidiary’s investment advisory  agreements may be combined.
x Disclose that each subsidiary will comply with provisions relating to affiliated
transactions and custody (Section 17). When applicable, identify the custodian of a
subsidiary, if any.
x Disclose any subsidiary’s principal investment strategies or principal risks that constitute
principal investment st rategies or risks of the Fund. Th e principal investment strategies
and principal risk disclosure s of a fund that invests in a subsidiary should reflect
aggregate operations of the fund and the subsidiary.
x Explain in correspondence whether the financ ial statements of a subsidiary will be
consolidated with those of the F und.  If not, please explain why not.
x Confirm in correspondence that a subsidiary and its board of directors will agree to
inspection by the staff of the subsidiary’s books  and records, which will be maintained in
accordance with Section 31 of the Investment  Company Act and the rules thereunder.
x Confirm that if a subsidiary is organized in  a foreign jurisdiction, the Subsidiary and its
board of directors will agree to designate an agent for service of process in the United States.
x Confirm that if wholly-owned, the subs idiary’s management fee (including any
performance fee), if any, will be included in “Management Fees,” and the wholly-owned
subsidiary’s expenses will be included in “Other Expenses” in the fund’s fee table.
We are subject to risks associated with any he dging or Derivative Transaction in which we
participate (page 30)

17. The disclose in this risk factor indicates th at the Fund intends to use derivatives.  To the
extent this is part of the Fund’s principal stra tegy, please discuss in more  detail in the strategy
section.  To the extent it is not now a principa l strategy, but in the future becomes a principal
strategy, supplementally confirm that the Fund will file appr opriate amendments to the
registration statement at that time.    Derivative Investments (page 43)
 18. The disclosure states that “We may change the election [to rely on the limited derivatives
users exception] and comply with the other pr ovisions of Rule 18f-4 related to derivatives
transactions at any time and without notice.”  S upplementally confirm that, to the extent such a
change constitutes a material change to the F und’s strategy, the Fund w ill appropriately amend
its prospectus and registration stat ement to reflect such changes.

Wendy Ruberti
July 19, 2023 Page 5

Nominating Committee (Page 66)
 19. The disclosure states that “the nomina ting committee would favor the re-nomination of
an existing independent director rather than nom inate a new candidate.”  Supplementally explain
how doing so would be consistent with  the directors’ fiduciary duties.
 20. The disclosure states that “if the no minating committee or the board of directors
determines not to include such candidate among the board of directors’ designated nominees, and
the stockholder has satisfied the requirements of Rule 14a-8, the stockholder’s candidate will be
treated as a nominee of the stockholder who originally  nominated the candidate.  In that case, the
candidate will not be named on the proxy card di stributed with our pr oxy statement.”  These
statements are confusing.  Please clarify.  Provisions of the DGCL and Our Certificate of Incorporation and Bylaws (page 89)
21. We understand that Delaware law permits a f und to eliminate or alte r the fiduciary duties
of trustees, shareholders or other persons, and replace them with the standards set forth in the
fund’s governing documents.  Provisions eliminating or altering the fiduciary  duties of a fund’s
directors are inconsistent with federal securities laws and the Commission’s express views on such persons’ fiduciary duties.
Please add a provision to the Fund’s certificate of incorporation, or otherwise modify the
certificate of incorporation, to clarify explicitly that notwithstanding anything to the contrary in the certificate of incorporation, nothing in the cer tificate of incorporati on modifying, restricting
or eliminating the duties or liabilities of direct shall apply to, or in any way limit, the duties (including state law fiduciary duties of loyalty and care) or liabilities of such persons with respect to matters arising under the federal securities laws.
Part C: Other Information
 Item 15. Financial Statements and Exhibits
 22. Please file the finalized exhib its once they are available.
 23. When available, please provide as soon as pr acticable, via correspondence, a final draft of
the Fund’s organizational documents, both for the limited liability company as well as the
Delaware corporation, in order to enable the staff (as early in the process as possible) to review.
 Accounting Comments  24. Please include a statement re garding the financial highlights (i.e., that it is newly
organized, does not have any financial history as of the date of this prospectus, will be available in the Fund's annual, semiannual repor ts, etc.) See Form N-2, Item 4.

Wendy Ruberti
July 19, 2023 Page 6

25. Please provide the name of the fund's inde pendent registered public accounting firm in
correspondence.
*    *    *
Responses to this letter s hould be made in a letter to  me filed on EDGAR. Where no
change will be made in the fili ng in response to a comment, plea se indicate this fact in the
letter to us and briefly stat e the basis for your position.

You should review and comply with all applicable requireme nts of the federal securities
laws in connection with the preparation and distribution of preliminary prospectuses.

Although we have completed our initial review of the regist ration statement, the filing
will be reviewed further after we receive your response. Therefore, we reserve the right to
comment further on the registrati on statement and any amendments .  After we have resolved
all issues, the Fund and its underw riter must request acceleration of  the effective date of the
registration statement.

In closing, we remind you that the Fund and its management are responsible for the
accuracy and adequacy of their disclosures in the registration statement, notwithstanding any review, comments, action, or absence of action by the staff.
  Should you have any questions regarding this letter, please feel fr ee to contact me at
(202) 551-3250 or, with regard to accoun ting comments, Mindy Rotter at 212-336-1096.
                S i n c e r e l y ,                       /s/ Raymond A. Be
               Raymond A. Be               A t t o r n e y - A d v i s e r   cc:  Jay Williamson, Securitie s and Exchange Commission
 John D. Reiss, DLA Piper LLP (US)