SEC Division of Investment Management staff letter: Carlyle Global Credit Investment Management, L.L.C.

Simpson Thacher & Bartlett LLP
900 G S T RE E T, N W
W A S H I N G TO N, D.C. 20001
T E LE P H O NE: +1-202-636-5500
F A CS I M I L E: +1-202-636-5502
Direct Dial Number
+1-202-636-5543
E-mail Address rajib.chanda@stblaw.com
N E W Y O R K B E I J I N G B R U S S E L S H O N G K O N G H O U S T O N L O N D O N L O S A N G E L E S P A L O A L T O S Ã O P A U L O T O K Y O BY E-MAIL July 14, 2023 Re: Carlyle Global Credit Investment Management, L.L.C:
Request for No-Action
Kaitlin Bottock
Co-Chief Counsel
Division of Investment Management
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Dear Ms. Bottock:
Carlyle Credit Income Fund, Inc. (f/k/a Vertical Capital Income Fund, Inc. (the “Fund”)) is an externally managed, closed-end management investment company, registered under the Investment Company Act of 1940, as amended (the “1940 Act”). The Fund is a statutory trust organized under the laws of the State of Delaware. Shares of the Fund are listed and trade on the New York Stock Exchange under the ticker symbol VCIF. Oakline Advisors, LLC (“Oakline”), a Delaware limited liability company registered under the Investment Advisers Act of 1940 (the “Advisers Act”), served as investment adviser to the Fund until July 14, 2023. On January 12, 2023, the Fund entered into a Transaction Agreement (the “Transaction Agreement”) with Carlyle Global Credit Investment Management, L.L.C. (“CGCIM”), a Delaware limited liability company registered under the Advisers Act. Pursuant to the Transaction Agreement, among others things, CGCIM would become the investment adviser to the Fund (the “Transaction”). We are writing on behalf of our client, CGCIM, in coordination with the Fund and counsel to the Fund and its Board of Trustees (the “Board”), to confirm the oral no-action position communicated to CGCIM and the Fund by the staff of the Division of Investment Management (the “Staff”) on May 25, 2023, prior to closing the Transaction, that the Staff would not recommend enforcement action under Section 17(d) of the 1940 Act and Rule 17d-1 thereunder, if the series of actions contemplated under the Transaction Agreement, as described herein, are consummated in