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Monica J. Shilling, P.C. To Call Writer Directly: +1 310 552 4355 monica.shilling@kirkland.com | 2029 Century Park East Suite 1400N Los Angeles, CA 90067 United States
+1 310 552 4200
www.kirkland.com | Facsimile: +1 310 552 5900 | ||
October 3, 2019
VIA EDGAR SUBMISSION
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attention: Vince Di Stefano, Esq.
Dear Mr. Di Stefano:
We write on behalf of Crescent Capital BDC, Inc. (“Crescent Capital BDC”) and Alcentra Capital Corporation (“Alcentra Capital”) to inform the staff (the “Staff”) of the Division of Investment Management of the U.S. Securities and Exchange Commission (the “SEC”) that today each of Crescent Capital BDC and Alcentra Capital have filed a preliminary merger proxy statement on PREM14A in respect of the registration statement on Form N-14 (File No. 333-233995) filed by Crescent Reincorporation Sub, Inc., a wholly owned subsidiary of Crescent Capital BDC (“Crescent Capital Maryland BDC”), on September 30, 2019 (the “Registration Statement”). The Registration Statement relates to the previously announced merger transaction involving Crescent Capital BDC and Alcentra Capital. The Registration Statement contains preliminary proxy statements of each of Crescent Capital BDC and Alcentra Capital for their anticipated special stockholder meetings in connection with the proposed transactions.
Crescent Capital BDC and Alcentra Capital filed the preliminary proxy statements solely to make it easier for their respective stockholders to access the preliminary proxy statements contained in the Registration Statement during the pendency of the Staff’s review. They also will not file with the SEC or mail to their respective stockholders a definitive merger proxy statement relating to the above-referenced transaction until the Registration Statement has been declared effective by the Staff and understand that the SEC’s time goals for registration statements (and not proxy statements) will apply thereto.
If you have any questions, do not hesitate to contact me at (310) 552-4355 or via email monica.shilling@kirkland.com.
Sincerely,
/s/ Monica Shilling
| Cc: | Jason A. Breaux, Crescent Capital BDC |
Suhail A. Shaikh, Alcentra Capital
Harry Pangas, Dechert LLP
Gregory Schernecke, Dechert LLP
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