(203) 352-4057                                       marina_belaya@ustrust.com




                                January 24, 2007

VIA EDGAR

U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

      Re: EXCELSIOR ABSOLUTE RETURN FUND OF FUNDS, LLC, FILE NO. 811-21396

Ladies and Gentlemen:

          On  behalf  of  Excelsior  Absolute  Return  Fund of  Funds,  LLC (the
"Fund"), filed herewith pursuant to Section 14(a) of the Securities Exchange Act
of 1934, as amended,  is the preliminary proxy statement for the special meeting
(the "Meeting") of members of the Fund ("Members") to be held on March 15, 2007.
At the Meeting, Members will be asked to vote on the following proposals: (i) to
approve a new Investment  Advisory  Agreement between Excelsior  Absolute Return
Fund of Funds Master Fund,  LLC (the  "Master  Fund") and U.S.  Trust Hedge Fund
Management,  Inc. to become  effective upon completion of the sale of U.S. Trust
Corporation  to the Bank of America  Corporation;  (ii) to elect four persons to
serve as members of the Board of Managers of the Fund and to serve as members of
the Board of  Managers  of the  Master  Fund;  and (iii) to  transact  any other
business that may properly come before the Meeting.

          Consistent with Peter Tsirigotis' (the Fund's Chief Legal Counsel) and
Richard Pfordte's conversation, we have incorporated the Staff's comments on the
Excelsior Funds' (mutual funds)  preliminary proxy statement filed on January 9,
2007 (File No.  811-04088),  and  accordingly  request  expedited  review of the
Fund's filing.

          Please contact the  undersigned at the above number with any questions
or comments you may have or for any further information you may desire.

                                          Very truly yours,


                                          /s/ Marina Belaya
                                          ----------------------------
                                          Marina Belaya


Enclosure