CORPORATE CAPITAL TRUST, INC.
450 S. Orange Avenue
Orlando, Florida 32801
April 1, 2011
VIA EDGAR TRANSMISSION
James E. O’Connor, Esq.
Attorney/Advisor
Division of Investment Management
100 F Street, N.E.
United States Securities and Exchange Commission
Washington, D.C. 20549
| Re: | Registration Statement on Form N-2 |
File Nos. 333-167730 and 814-00827
Dear Mr. O’Connor:
Corporate Capital Trust, Inc. (the “Company”) hereby requests acceleration of the effective date of the above referenced registration statement to 10:00 a.m. (EDT) on Monday, April 4, 2011, or as soon thereafter as practicable.
The Company confirms that it is aware of its responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of securities specified in the above referenced registration statement. Further, in connection with this acceleration request, the Company hereby acknowledges that:
| • | should the Securities and Exchange Commission (the “Commission”) or the Staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
James E. O’Connor, Esq.
April 1, 2011
Page 2
Please call Darren Skinner at (202) 942-5636, or, in his absence, Richard E. Baltz at (202) 942-5124, both of Arnold & Porter LLP, if you have any questions regarding the above.
| Sincerely, |
| /s/ Paul S. Saint-Pierre |
| Paul S. Saint-Pierre |
| Chief Financial Officer, Treasurer and Secretary |