November 9, 2016
Via Edgar
Dominic Minore, Esq.
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
| Re: | Sierra Total Return Fund Registration Statement on Form N-2, File Nos. 333-209496; 811-23137 (the “Registration Statement”) |
Dear Mr. Minore:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, ALPS Distributors, Inc., the principal underwriter in connection with the proposed offering of the shares of beneficial interest of Sierra Total Return Fund, hereby respectfully requests that the above-captioned Registration Statement, including all amendments thereto, to be ordered effective on November 9, 2016 at 3:00 pm, or as soon thereafter as practicable.
By:/s/ Steven B. Price
Steven B. Price
SVP, Director of Distribution Services
