December 9, 2016

VIA EDGAR

Trace W. Rakestraw, Esq.

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

RE: CM Finance Inc

Registration Statement on Form N-2

(File No. 333-201432)

Dear Mr. Rakestraw:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, CM Finance Inc hereby respectfully requests that the above-captioned registration statement, including all amendments thereto, be ordered effective on December 12, 2016, at 4:00 p.m. EST, or as soon thereafter as practicable.

CM Finance Inc
By:	/s/ Michael C. Mauer
Michael C. Mauer
Chief Executive Officer and
Chairman of the Board