 | Eversheds Sutherland (US) LLP 700 Sixth Street, NW, Suite 700
D: +1 202.383.0845
stephanihildebrandt@ eversheds-sutherland.com |
March 28, 2018
Via Edgar
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: | CM Finance Inc –Registration Statement on Form N-2 |
Dear Sir or Madam:
On behalf of CM Finance Inc (the “Company”), we are transmitting herewith for filing under the Securities Act of 1933, as amended (the “Securities Act”), the Company’s registration statement on Form N-2 (the “Registration Statement”). The Registration Statement relates to the shelf offering of the Company’s securities under Rule 415 of the Securities Act.
The Company respectfully asks that the staff of the Securities and Exchange Commission afford the Registration Statement selective review in accordance with Securities Act Release No. 6510 (February 15, 1984). The disclosure contained in the Registration Statement is substantially similar to the disclosure contained in the Company’s prior registration statement on Form N-2 (File No. 333-201432) as declared effective on October 19, 2017, except for the updating of financial information and certain other data.
Please let us know if you would like a courtesy copy of the Registration Statement. If you have any questions or comments regarding the Registration Statement, please do not hesitate to contact the undersigned at (202) 383-0845 or Steven B. Boehm at (202) 383-0176.
| Sincerely, |
/s/ Stephani M. Hildebrandt |
cc: | Michael C. Mauer Steven B. Boehm |
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