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Eversheds Sutherland (US) LLP 700 Sixth Street, NW, Suite 700 Washington, DC 20001-3980
D: +1 202.383.0176 F: +1 202.637.3593
stevenboehm@ eversheds-sutherland.com |
March 14, 2018
Via EDGAR
Sumeera Younis
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Solar Capital Ltd. |
| Registration Statement on Form N-2 Filed March 14, 2018 |
Dear Ms. Younis:
On behalf of Solar Capital Ltd. (the “Company”), we hereby respectfully request that the staff of the Securities and Exchange Commission (the “Commission”) afford the Company’s registration statement on Form N-2, filed with the Commission on March 14, 2018 (the “Registration Statement”), a selective review in accordance with Securities Act Release No. 6510 (February 15, 1984).
The disclosure contained in the Registration Statement contains no material changes from the disclosure included in Post-Effective Amendment No. 4 to the Company’s registration statement on Form N-2 (File No. 333-194870) (“Amendment No. 4”), filed with the Commission on April 28, 2017 and declared effective on May 2, 2017, except for (i) revisions reflecting the material developments relating to the Company since the effective date of Amendment No. 4 and (ii) the inclusion of annual audited financial statements and related financial data for the year ended December 31, 2017, together with disclosure relating thereto.
If you have any questions or additional comments concerning the foregoing, please contact Vlad M. Bulkin at (202) 383-0815, or the undersigned at (202) 383-0176.
| Sincerely, |
| /s/ Steven B. Boehm |
| Steven B. Boehm |
| cc: | Vlad M. Bulkin |
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