RegAlert2018-02-14
Added · Updated
SEC Division of Investment Management staff letter: Eagle Point Credit Company Inc.
The SEC staff will not recommend enforcement action against Eagle Point Credit Company Inc. if it uses Rule 486(b) to file post-effective amendments to its Form N-2 registration statement that become effective immediately upon filing. This relief applies to filings made solely to update financial statements, update portfolio manager information, or make non-material changes. The Fund must file a separate post-effective amendment pursuant to Section 8(c) prior to any offering of common stock at a price below net asset value. The staff reserves the right to withdraw this assurance if the Fund misuses Rule 486(b).
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Dechert
LLP
1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax www.dechert.com
PHILIP T. HINKLE philip.hinkle@dechert.com
+1 202 261 3460 Direct
+1 202 261 3050 Fax
February 14, 2018
Mr. Douglas J. Scheidt, Esq.
Associate Director and Chief Counsel
United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E.
Washington, DC 20549
Dear Mr. Scheidt:
On behalf of Eagle Point Credit Company Inc. (the “Fund”), we seek assurance that the staff of the Division of Investment Management (the “Staff”) will not recommend enforcement action against the Fund to the Securities and Exchange Commission (the “Commission”) under Section 5(b) or Section 6(a) of the Securities Act of 1933, as amended (the “Securities Act”), if it utilizes Rule 486(b) under the Securities Act to file post-effective amendments to its registration statement in satisfaction of the undertakings contained in its registration statement under the circumstances set forth in this letter.
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