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VIA EDGAR [CORRESPONDENCE FILING]
(714) 668-6210
johndellagrotta@paulhastings.com
February 19, 2013
Mr. Edward P. Bartz
Staff Attorney
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Kayne Anderson Energy Total Return Fund, Inc. |
| Registration Statement on Form N-2 (File Nos. 333-172410 and 811-21750) |
Dear Mr. Bartz:
Enclosed for electronic filing via EDGAR pursuant to the Securities Act of 1933, as amended (the“Securities Act”) and the Investment Company Act of 1940, as amended (the“1940 Act”), on behalf of our client, Kayne Anderson Energy Total Return Fund, Inc. (the“Fund”), is Post-Effective Amendment No. 4 (“Post-Effective Amendment No. 4”) to the Fund’s Registration Statement on Form N-2 originally filed with the U.S. Securities and Exchange Commission (the“Commission”) on February 24, 2011, amended by Pre-Effective Amendment No. 1 filed on April 21, 2011 and declared effective on June 9, 2011, further amended by Post-Effective Amendment No. 1 filed on July 18, 2012, Post-Effective Amendment No. 2 filed on September 5, 2012 and Post-Effective Amendment No. 3 filed on September 25, 2012, and last declared effective on September 11, 2012 (the“Initial Registration Statement”).
Post-Effective Amendment No. 4 updates the financial statement disclosure contained in the Initial Registration Statement primarily by incorporating by reference the Fund’s financial statements, financial highlights, the accompanying notes thereto, and the report of the Fund’s independent registered public accountants contained in the Fund’s Annual Report to Stockholders on Form
N-CSR for the fiscal year ended November 30, 2012, filed by it with the Commission on February 5, 2013. Post-Effective Amendment No. 4 also updates (i) market and net asset value data and as much other information as was practicable to a more recent date; (ii) the tax disclosures; and (iii) certain risk factors relating to the Fund’s investments.
In light of the similarities between the disclosures made in the Initial Registration Statement and using the principles stated in Release 33-6510 and Release No. IC - 13768, we respectfully request that the Staff consider a cursory or no review position with respect to Post-Effective Amendment No. 4.
The Fund respectfully requests the Staff’s assistance in completing its review of Post-Effective Amendment No. 4 as soon as possible. Please advise us if we can provide any further information or assistance to facilitate your review. Please direct any comments or questions to the undersigned at (714) 668-6210 or David A. Hearth at (415) 856-7007.
Very truly yours,
/s/ JOHN F. DELLA GROTTA
John F. Della Grotta of
PAUL HASTINGS LLP
| cc: | Kevin S. McCarthy, Kayne Anderson (w/enclosures) |
| David S. Shladovsky, Esq., Kayne Anderson (w/ enclosures) |
| David A. Hearth, Esq., Paul Hastings (w/enclosures) |
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