|
|
SUTHERLAND ASBILL & BRENNAN LLP |
HARRY S. PANGAS
DIRECT LINE: 202.383.0805
E-mail: harry.pangas@sutherland.com
July 16, 2015
U.S. Securities and Exchange Commission
Division of Investment Management
Attention: Mr. James E. O’Connor, Senior Counsel
Ms. Sheila Stout, Senior Accountant
100 F Street, NE
Washington, DC 20549
Re: Main Street Capital Corporation
Registration Statement on Form N-2 (File Number: 333-203147)
Dear Mr. O’Connor and Ms. Stout:
On behalf of Main Street Capital Corporation (the “Company”), set forth below is the Company’s response to an oral comment received from the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission on July 16, 2015 relating to the above-referenced Form N-2 registration statement. The Staff requested that the Company represent to the Staff that based on its preliminary estimates of its financial information as of June 30, 2015 the Company would be in compliance with the asset coverage requirement set forth in Section 18 of the Investment Company Act of 1940, as amended, as modified by Section 61, (the “Asset Coverage Requirement”) if the Company were to treat its unfunded commitments as “senior securities” for the purposes of Sections 18 and Section 61, consistent with the methodology previously approved by the Staff.
The Company hereby confirms that based on its preliminary estimates of its financial information as of June 30, 2015 the Company would currently be in compliance with the Asset Coverage Requirement if the Company were to treat its unfunded commitments as “senior securities” for the purposes of Sections 18 and 61.
* * * * *
If you have any questions or additional comments concerning the foregoing, please contact the undersigned at (202) 383-0805 or Steven B. Boehm at (202) 383-0176.
|
|
Sincerely, |
|
|
|
|
|
/s/ Harry S. Pangas |
|
|
Harry S. Pangas |