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ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM |
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Jessica L. Reece T +1 617 235 4636 F +1 617 235 9688 Jessica.Reece@ropesgray.com |
April 26, 2016
BY EDGAR AND E-MAIL
United States Securities & Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Attention: Jason Fox
| Re: | NexPoint Capital, Inc. |
| Registration Statement on Form N-2 |
| 1933 Act File No. 333-196096 |
Dear Mr. Fox:
On behalf of NexPoint Capital, Inc. (the “Company”), a Delaware corporation, please find below the Company’s responses to the comment provided telephonically on April 25, 2016 (the “Comment”) relating to the Fund’s Registration Statement on Form N-2 filed with the Securities and Exchange Commission (the “Commission”) on March 2, 2016 (File No. 333-196096) (the “Registration Statement”).
For the convenience of the Commission’s staff (the “Staff”), the Comment has been summarized below and the Fund’s response follows. Capitalized terms used but not defined herein have the meanings assigned to them in the Registration Statement.
| 1. | Staff Comment: Please discuss how the Company’s modification of its accounting treatment of organization and initial offering costs aligns with Financial Accounting Standards Board Accounting Standards Codification Topic 250 (“ASC 250”), “Accounting Changes and Error Corrections” and related guidance. |
Response: After reviewing the Company’s treatment of organization and offering costs, and after a review of ASC 250 and Staff Accounting Bulletin No. 99, the Company has determined that going forward, the Company will capitalize, then expense initial offering costs up to the amount of the 1.0% cap over a one-year period. The Company analyzed the impact of the change and believes that the change is immaterial and therefore does not require restatement to prior period financials. Management has discussed its conclusion with the Company’s independent registered public accounting firm.
Should members of the Staff have any questions or comments, they should contact the undersigned at (617) 235-4636 or jessica.reece@ropesgray.com.
Very truly yours,
Jessica L. Reece
| cc: | Brian Mitts, Executive Vice President, Principal Financial Officer and Principal Accounting Officer |
| Brian D. McCabe, Ropes & Gray LLP |
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