What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2025-04-10 compared with 2024-04-02 · 31 added, 28 removed, 25 unchanged (70% of the section changed)

1 unchanged sentence

Cybersecurity

Our operations and other aspects of our

business rely heavily on various information technology systems which are largely managed by third parties.

Our operations and other aspects of

our business rely heavily on various information technology systems which are largely managed by third parties.

We face significant cybersecurity

6 unchanged sentences

our portfolio investments and the integrity of the Company’s information systems.

We have created an Information Security

Team, consisting of our Chief Financial Officer and our Chief Compliance Officer, to implement and administer our Cybersecurity Policy.

Among the duties and responsibility of our Information Security Team are the following:

· Ensuring that all Equus personnel are aware of the Cybersecurity

Policy and agree to adhere to its requirements;

· Establishing that information concerning the Fund is stored

on encrypted cloud-based servers accessible only by authorized Equus personnel;

· Providing that all of the Company’s information systems

are backed up daily, with offline copies available in the event that a major security issue arises;

· Testing and evaluating cybersecurity safeguards via the

use of third-party information technology service providers;

We have created an Information

Security Team, consisting of our Chief Financial Officer and our Chief Compliance Officer, to implement and administer our Cybersecurity

Our Chief Financial Officer and Chief Compliance Officer have each served in senior management

positions for a number of years, have received cybersecurity training from time to time in connection with their professional certifications,

and have overseen and supervised the activities of external information technology personnel of the Fund during this period.

the duties and responsibilities of our Information Security Team are the following:

· Ensuring that all Equus personnel are aware of the Cybersecurity Policy

and agree to adhere to its requirements;

· Establishing that information concerning the Fund is stored on encrypted

cloud-based servers accessible only by authorized Equus personnel;

· Providing that all of the Company’s information systems are backed

up daily, with offline copies available in the event that a major security issue arises;

· Testing and evaluating cybersecurity safeguards via the use of third-party

information technology service providers;

· Reviewing the security measures in the Company’s Cybersecurity

Policy annually or when there is a change in applicable laws or regulations or in business activities of Equus;

· Conducting training as necessary for all Equus

· Reporting cybersecurity matters to our Board of

Directors who provide oversight of our Information Security Team.

We utilize third-party services and tools

for identifying, protecting against, and detecting cyber incidents, and also partner with external vendors to augment our internal security

capabilities.

Additionally, we engage third-parties to conduct independent assessments of our cybersecurity infrastructure to evaluate

the efficiency and effectiveness of our detection capabilities, along with our response mechanisms, and overall risk management.

· Conducting training as necessary for all Equus personnel;

· Reporting cybersecurity matters to our Board of Directors who provide

oversight of our Information Security Team.

We utilize third-party services and

tools for identifying, protecting against, and detecting cyber incidents, and also partner with external vendors to augment our internal

security capabilities.

Additionally, we engage third-parties to conduct independent assessments of our cybersecurity infrastructure to

evaluate the efficiency and effectiveness of our detection capabilities, along with our response mechanisms, and overall risk management.

Our approach to managing cybersecurity

risks is part of a continuous improvement process, both in the context of cybersecurity and broader operational

risk management.

This ongoing process, which includes personnel training, is aimed at routinely reviewing and, as necessary, improving,

our oversight processes and tools to ensure they remain effective and resilient in their management of cybersecurity risk.

risks is part of a continuous improvement process, both in the context of cybersecurity and broader operational risk management.

ongoing process, which includes personnel training, is aimed at routinely reviewing and, as necessary, improving, our oversight processes

and tools to ensure they remain effective and resilient in their management of cybersecurity risk.

Material Impact of Cybersecurity Threats

While we have yet to experience a material

cybersecurity event, we acknowledge the persistent and evolving nature of these threats, which have the potential to materially impact

our business strategy, operations, and financial results adversely.

While we have yet to experience

a material cybersecurity event, we acknowledge the persistent and evolving nature of these threats, which have the potential to materially

impact our business strategy, operations, and financial results adversely.

We maintain robust policies and procedures focused on cybersecurity

9 unchanged sentences

the Board, which report also addresses cybersecurity matters.

TableOfContents

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments