| Phone: | (212)885-5205 |
| Fax: | (917)332-3033 |
| Email: | ajanell@blankrome.com |
July 15, 2015
FILED VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. Eric McNealy
| Re: | Cornerstone Total Return Fund, Inc. |
Registration Statement on Form N-2/A
(File Numbers: 811-02363 and 333-198846)
Dear Mr. McNealy:
Enclosed for filing herewith is Pre-Effective Amendment No. 2 to the above referenced filing (the “Registration Statement”) of our client, Cornerstone Total Return Fund, Inc. (the “Fund”), initially filed on September 19, 2014. Pre-Effective Amendment No. 2 to the Registration Statement was initially filed on July 10, 2015 under the incorrect filing number. We would like to request that Pre-Effective Amendment No. 2 to the Registration Statement filed today, July 15, 2015, be back dated to July 10, 2015.
Please contact me at (212) 885-5205 or Thomas R. Westle at (212) 885-5239 with any questions you may have or for any further information you may desire.
Very truly yours, | |
/s/ Allison H. Janell | |
| Allison H. Janell |
