December 28, 2016

VIA EDGAR

Lisa Larkin

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re: Registration Statement (File No. 333-205660) of

Apollo Investment Corporation (the “Company”)

Dear Ms. Larkin:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the Company hereby requests acceleration of the effective date of the Company’s Post-Effective Amendment No. 2 to the Registration Statement on Form N-2 (File No. 333-205660) so that it may become effective at 3:00 PM (Eastern Time) on December 30, 2016, or as soon as practicable thereafter.

The Company hereby requests that you notify Richard Prins (212-735-2790) or Steven Grigoriou (416-777-4727) of Skadden, Arps, Slate, Meagher & Flom LLP by telephone once the Registration Statement has been declared effective.

Very truly yours,

Apollo Investment Corporation

/s/ Joseph D. Glatt

Name: Joseph D. Glatt

Title: Chief Legal Officer, Secretary

and Vice President