Cohen & Steers Total Return Realty Fund (RFI)
Filed: 12 Feb 14, 12:00am
February 12, 2014
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn:
| Re: | Cohen & Steers Total Return Realty Fund, Inc. |
Ladies and Gentlemen:
On behalf of Cohen & Steers Total Return Realty Fund, Inc. (“RFI”), filed herewith under the Securities Act of 1933 (the “Securities Act”), as amended, and the Investment Company Act of 1940, as amended, is a comparison of RFI’s Registration Statement on Form N-14, filed with the Securities and Exchange Commission on December 27, 2013 (Accession No. 0001193125-13-486123) and Pre-Effective Amendment No. 1 to RFI’s Registration Statement on Form N-14 under the Securities Act.
If you require additional information or have any questions, please do not hesitate to contact me. I look forward to hearing from you soon.
Sincerely,
/s/ Tina M. Payne
Tina M. Payne
Senior Vice President and Associate General Counsel
Phone: 212 796-9361
Fax: 212 822-1600
e-mail: tpayne@cohenandsteers.com
280 Park Avenue, New York, NY 10017-1216 Tel: 212.832.3232 Fax: 212.832.3622