March 14, 2018

VIA EDGAR

Mr. James E. O’Connor, Esq.

Senior Counsel – Disclosure Review Office

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Dear Mr. O’Connor:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Saratoga Investment Corp. hereby respectfully requests that the above-captioned registration statement, including all amendments thereto, be ordered effective on March 14, 2018, at 4:00 p.m., or as soon thereafter as practicable.