Simpson Thacher & BartlettLLP
900 G STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE: +1-202-636-5500
FACSIMILE: +1-202-636-5502
July 17, 2020
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.W.
Washington, D.C. 20549
Attn: Christina DiAngelo Fettig and Raymond Be
| Re: | Apollo Investment Corporation |
Pre-Effective Amendment No. 2 on Form N-2, File No. 333-238518
Annual Report on Form 10-K, File No. 814-00646
Dear Ms. Fettig:
On behalf of Apollo Investment Corporation (the “Registrant”), we are providing the following responses to comments received by telephone from you on July, 2020 relating to the Registrant’s pre-effective amendment filed with the Securities and Exchange Commission on Form N-2 on July 14, 2020 (the “Registration Statement”). All capitalized terms used but not defined in this letter have the meanings given to them in the Registration Statement.
| 1. | In the expense example, assuming a 5% annual return completely in the form of net realized capital gains on investments under the Fees and Expense table, please confirm the calculation of the 1, 3, 5 and 10-year expenses. |
The Registrant has recalculated the 1, 3, 5 and 10-year expenses assuming a 5% annual return completely in the form of net realized capital gains on investments and will update the table as disclosed below in a filing pursuant to Rule 424 or 497:
| 1 year | 3 years | 5 years | 10 years | |||||||||||||
You would pay the following expenses on a $1,000 investment, assuming a 5% annual return (all of which is subject to a capital gains incentive fee) | $ | 114 | $ | 320 | $ | 499 | $ | 849 | ||||||||
| 2. | In future prospectus filings pursuant to Rule 424 or 497, please include a heading “Selected Financial and Other Information” and include appropriate incorporation by reference disclosure. |
The Registrant will make the requested change in future filings.
| 3. | In future prospectus filings pursuant to Rule 424 or 497, please include footnote (3) beside the Carbonfree Chemicals SA LLC (“Carbonfree”) investment because the Registrant does not control Carbonfree. |
The Registrant will make the requested change in future filings.
Please call me (202-636-5592) with any questions you may have regarding this filing or if you wish to discuss the above responses.
| Very truly yours, |
| /s/ STEVEN GRIGORIOU |
| cc: | David Blass |
Joseph Glatt
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