CAPITAL SOUTHWEST CORP (CSWC)

Company response: Response : The Company advises the Staff on a supplemental basis that the percentage of its net assets invested in unitranche loans (which is comprised of first out term loans and last out term loans) is 6.31%, comprised of first out term loans of 3.66% and last out term loans of 2.65%. response letter →

Company response: The Company advises the Staff on a supplemental basis that the Company's earnings per share (“ EPS ”) amounts have been computed based on the weighted-average number of shares of common stock outstanding for the period under the two-class method in a ccordance with Accounting Standards Codification (“ ASC ”) 260-10-45-60A. Basic EPS is computed by dividing net increase (decrease) in net assets resulting from operations applicable to common shareholders (adjusted for income allocated to participating securities, which relates to the unvested shares of restricted stock awarded pursuant to the Company’s equity compensation plans) by the weighted average number of shares of common stock… response letter →

Company response: The Company advises the Staff on a supplemental basis that the Company is an internally managed business development company and, as part of management operations, incur fix asset costs. Specifically, during the year ended March 31, 2025, the realized loss on disposal of fixed assets related to the Company’s disposition of certain office equipment, and the acquisition of fixed assets related to the Company’s purchase of office furniture for its office. The realized loss on disposal of fixed assets is included in operating activities as a reconciliation of net income and net cash flow from operating activities in accordance with ASC 230-10-45-28(b). Cash outflows for the acquisition of fixed… response letter →

Company response: The Company advises the Staff on a supplemental basis that the Tranche C Loan to Lift Brands, Inc. and the Third Lien loan to U.S. Telepacific Corp. are non-interest bearing until the occurrence of specific trigger events as set forth in the governing credit agreements, and as of March 31, 2025, both investments were non-interesting bearing. Instruction 4 to Rule 12-12 under Regulation S-X requires registrants to only disclose the “end of period interest rate” and therefore the Company respectfully advises the Staff that no further footnote disclosure with respect to such investments was required as of March 31, 2025. 5. Within the Consolidated Schedule of Investments as of March 31, 2025,… response letter →