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Eversheds Sutherland (US) LLP
700 Sixth Street, NW, Suite 700
Washington, DC 20001-3980
D:+1 202.383.0815 F:+1 202.637.3593
vladbulkin@
eversheds-sutherland.com |
August 21, 2020
VIA EDGAR
Karen Rossotto, Esq.
Division of Investment Management,
Disclosure Review Office
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
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Re: |
Solar Senior Capital Ltd. |
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Preliminary Proxy Statement on Schedule 14A |
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Filed on August 4, 2020 (File
No. 814-00849) |
Dear Ms. Rossotto:
On behalf of Solar Senior Capital Ltd. (the Company), set forth below are the Companys responses to
the oral comments provided by the staff of the Division of Investment Management (the Staff) of the Securities and Exchange Commission (the
Commission) to the Company on August 14, 2020 with respect to the Companys preliminary proxy statement on Schedule 14A (File
No. 814-00849), filed with the Commission on August 4, 2020 (the Proxy Statement). The Staffs comments are set forth below and are followed
by the Companys responses.
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1. |
Comment: Please confirm supplementally to the Staff that holding a
virtual stockholder meeting is consistent with the Companys governing documents and the laws of the state of incorporation of the Company. |
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Response: The Company confirms to the Staff that holding a virtual
stockholder meeting is consistent with the Companys governing documents and with Maryland law, the state of the Companys incorporation. |
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2. |
Comment: In the Notice of Annual Meeting of Stockholders, please add
disclosure indicating that further information on how stockholders can attend the virtual meeting can be found on the proxy card. |
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Response: The Company has added the above-referenced disclosure to the Notice of Annual
Meeting of Stockholders in response to the Staffs comment. |
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3. |
Comment: In the last sentence of the first paragraph of the Notice of Annual Meeting of
Stockholders, please add disclosure indicating that the stockholders control number can be found on the proxy card. |
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Response: The Company has added the above-referenced disclosure to the Notice of Annual
Meeting of Stockholders in response to the Staffs comment. |
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4. |
Comment: In Proposal 1: Election of Directors, please add disclosure that makes clear
that stockholders are permitted to vote on one director nominee and abstain from voting or withhold a vote for the other director nominee. |
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Response: The Company has added the above-referenced disclosure on page 6 of the Proxy
Statement in response to the Staffs comment. |
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