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Published on July 2, 2012
The Tower at Peabody Place
100 Peabody Place, Suite 900
Memphis, TN 38103-3672
(901) 543-5900
July 2, 2012
CONFIDENTIAL
VIA EDGAR
Kevin Rupert
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-4041
| Re: | Triangle Capital Corporation Post-Effective Amendment No. 3 to Registration Statement on Form N-2, File No. 333-175160 (the Registration Statement) |
Dear Mr. Rupert
On behalf of Triangle Capital Corporation (the Company), set forth below is the Companys response to the comment of the staff of the Division of Investment Management (the Staff) of the Securities and Exchange Commission (the Commission) that you provided to us via phone on June 28, 2012 regarding the Registration Statement. The Staffs comment is set forth below and is followed by the Companys response.
Comment: In future filings of the prospectus, include on the cover page of the prospectus, language in boldface type regarding the credit quality of the types of investments that the Company makes, including disclosure regarding the fact that such investments may be below investment grade.
Response: In response to the Staffs comment, the Company undertakes to include language similar to the language below on the cover page of future prospectus filings.
We generally invest in securities that would be rated below investment grade if they were rated. Below investment grade securities, which are often referred to as high yield or junk, have speculative characteristics with respect to the issuers capacity to pay interest and repay principal.
If you have any questions concerning the foregoing, please contact me via phone at (901) 543-5918 or via email at hwbrown@bassberry.com.
| Sincerely, |
| /s/ Helen W. Brown |
bassberry.com