[Willkie Farr & Gallagher LLP letterhead]



VIA EDGAR

February 24, 2009

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

Re:   FLAHERTY & CRUMRINE PREFERRED INCOME FUND INCORPORATED
      INVESTMENT COMPANY ACT FILE NUMBER 811-06179
      FLAHERTY & CRUMRINE PREFERRED INCOME OPPORTUNITY FUND INCORPORATED
      INVESTMENT COMPANY ACT FILE NUMBER 811-06495
      FLAHERTY & CRUMRINE/CLAYMORE PREFERRED SECURITIES INCOME FUND INCORPORATED
      INVESTMENT COMPANY ACT FILE NUMBER 811-21129
      FLAHERTY & CRUMRINE/CLAYMORE TOTAL RETURN FUND INCORPORATED
      INVESTMENT COMPANY ACT FILE NUMBER 811-21380

Ladies and Gentlemen:

         On behalf of the above referenced investment companies, each a Maryland
corporation  (together,  the "Funds"),  I hereby transmit for filing pursuant to
the  Securities  Exchange  Act of 1934,  as amended  (the "1934  Act"),  and the
Investment  Company  Act  of  1940,  as  amended,  the  definitive  joint  proxy
statement,  notice of annual  meetings of  shareholders  and forms of proxy card
(together,  the  "Proxy  Materials")  relating  to the  annual  meetings  of the
shareholders of the Funds.

         We are also  responding in this letter to comments of the  Commission's
staff (the "Staff") on the Funds'  preliminary  proxy  statement  filed with the
Securities  and Exchange  Commission  on February 11, 2009 that were provided by
Houghton  R.  Hallock  of  the  Staff  in  a  telephone  conversation  with  the
undersigned.  For the convenience of the Staff,  the substance of those comments
has been set forth below. The Fund's  responses to a particular  comment are set
out immediately under the restated comment.

         1. COMMENT:  Will the financial services sector preferred securities to
be  purchased by  Preferred  Securities  Income  Opportunity  Fund  Incorporated
("PFO") be lower in  preference  relative to the preferred  securities  recently
purchased,  and being  purchased,  by the U.S.  government  from issuers in that
sector? If so, consider whether any additional risk disclosure may be warranted.

            RESPONSE:  PFO invests in a variety of preferred  securities ranging
from preferred stock to hybrid preferred  securities to capital  securities.  To
date, the preferred  securities  purchased by the U.S. government from financial
services  issuers  have been in the form of  preferred  stock that is pari passu
with  outstanding  preferred  stock,  and junior to all other types of preferred
securities that PFO may invest in. As a result,  PFO's  investments  would be on
par with, and potentially senior to, the U.S. government's.  Nonetheless, as PFO
notes in the proxy  statement  on page 15, the risks  associated  with the U.S.
government's preferred stock purchases remain largely unknown.


         2. COMMENT: Please advise supplementally whether the proposed change in
concentration  policy  is  being  considered  for  any of the  other  registered
closed-end funds managed by Flaherty & Crumrine Incorporated (the "F&C Funds").

            RESPONSE:  Each of the  other F&C  Funds  currently  has a policy to
invests  at least 25% of its assets in  securities  issued by  companies  in the
banking industry;  thus none of the F&C Funds needs to consider a change in this
policy.

         3. COMMENT:  Please advise  supplementally  whether, to your knowledge,
other closed-end funds which invest primarily in preferred stocks are soliciting
shareholders to approve a change in  concentration  policy to permit the fund to
invest 25% of its assets in the financial services or banking industry.

            RESPONSE:  Although we have not independently  investigated,  we are
not aware of any  other  closed-end  funds  which  are  soliciting  shareholders
currently in this manner.  It is our  understanding  that many of the closed-end
funds  which  invest  primarily  in  preferred  stocks  already  have a  similar
concentration policy.

         Please be advised, in accordance with the requirements of Rule 14a-6(d)
under  the  1934  Act,  that  the  Funds  plan to mail the  Proxy  Materials  to
shareholders of the Funds beginning on or about February 27, 2009.

         Should  members of the staff have any  questions or comments  regarding
the  enclosed  Proxy  Materials,  they  should  call  the  undersigned  at (212)
728-8178.


         Very truly yours,

         /s/ Mary C. Carty

         Mary C. Carty

Enclosures

cc:      Donald Crumrine
         Rose F. DiMartino
         Chad Conwell




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