What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-04-17 compared with 2025-04-10 · 30 added, 36 removed, 20 unchanged (77% 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.

We face significant cybersecurity

threats, which are continuously increasing in sophistication, including computer viruses, internal and external security breaches, and

other cyber-attacks.

These threats could disrupt our operations, lead to the loss of confidential information, and hinder our ability

to accurately report our financial results in a timely manner.

We have adopted a Cybersecurity Policy to create effective administrative,

technical, electronic, and physical protections to safeguard the personal information of Company personnel, confidential information concerning

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

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 threats, which are continuously increasing in sophistication, including computer viruses, internal and external security

breaches, and other cyber-attacks.

These threats could disrupt our operations, lead to the loss of confidential information, and hinder

our ability to accurately report our financial results in a timely manner.

We have adopted a Cybersecurity Policy to create effective

administrative, technical, electronic, and physical protections to safeguard the personal information of Company personnel, confidential

information concerning 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

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;

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.

Among 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 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

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.

5 unchanged sentences

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

Material Impact of Cybersecurity Threats

Material Impact of Cybersecurity

While we have yet to experience

6 unchanged sentences

Board of Directors Oversight

Our Board of Directors oversees risks

related to cybersecurity, including the security of our corporate, financial, and portfolio investment information and the steps management

is taking to monitor and control these risks.

Our Chief Compliance Officer conducts regular meetings with our independent directors to

discuss various compliance matters, including any cybersecurity issues, and also delivers a comprehensive Annual Compliance Report to

the Board, which report also addresses cybersecurity matters.

TableOfContents

Our Board of Directors oversees

risks related to cybersecurity, including the security of our corporate, financial, and portfolio investment information and the steps

management is taking to monitor and control these risks.

Our Chief Compliance Officer conducts regular meetings with our independent directors

to discuss various compliance matters, including any cybersecurity issues, and also delivers a comprehensive Annual Compliance Report

to the Board, which report also addresses cybersecurity matters.

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