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One International Place, 40th Floor +1 617 728 7100 Main +1 617 426 6567 Fax www.dechert.com
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Thomas Friedmann
thomas.friedmann@dechert.com +1 617 728 7120 Direct +1 617 275 8389 Fax |
June 2, 2017
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Attn: John Ganley and Kenneth Ellington
| Re: | WhiteHorse Finance, Inc. Registration Statement on Form N-2 File Numbers 333-217093 and 814-00967 |
Ladies and Gentlemen:
On behalf of WhiteHorse Finance, Inc., a Delaware corporation (the “Company”), we hereby respond to the comment raised by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a phone call between Mr. John Ganley of the Staff and Thomas Friedmann of Dechert LLP, outside counsel to the Company, on June 1, 2017. For your convenience, a transcription of the Staff’s comment is included in this letter (in italics) followed by the response. Capitalized terms used in this letter and not otherwise defined shall have the meanings specified in the Registration Statement.
| 1. | In the section entitled “Fees and Expenses,” in future filings please round all dollar figures to the nearest dollar and all percentages to the nearest hundredth of one percent as required by General Instruction 3 to Item 3 of Form N-2. |
The Company hereby undertakes in future filings to round all dollar figures to the nearest dollar and all percentages to the nearest hundredth of one percent.
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United States Securities and June 2, 2017 Page 2 |
If you have any questions, please feel free to contact the undersigned by telephone at 617.728.7120 (or by e-mail at thomas.friedmann@dechert.com). Thank you for your cooperation and attention to this matter.
Sincerely,
/s/ Thomas J. Friedmann
Thomas J. Friedmann
| cc: | Stuart Aronson, WhiteHorse Finance, Inc. |
Edward J. Giordano, WhiteHorse Finance, Inc.