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SEC Company Response from CORNERSTONE TOTAL RETURN FUND INC (CRF) (CIK 0000033934) (CRF) — Jul 6, 2015

CORNERSTONE TOTAL RETURN FUND INC (CRF) (CIK 0000033934)
Date: July 6, 2015 · CIK: 0000033934 · Accession: 0001398344-15-004227

AI Filing Summary & Sentiment

File numbers found in text: 333-191119, 811-02363

Date
July 6, 2015
Author
/s/ Allison H. Janell
Form
CORRESP
Company
CORNERSTONE TOTAL RETURN FUND INC (CRF) (CIK 0000033934)

Letter

Securities and Exchange Commission Division of Investment Management Attention: Asen Parachkevov Re: Cornerstone Total Return Fund, Inc. (File Numbers: 811-02363 and 333-191119) Registration Statement on Form N-2

Dear Mr. Parachkevov:

Enclosed for filing herewith is Pre-Effective Amendment No. 1 to the above-referenced filing (the “Registration Statement”) of our client, Cornerstone Total Return Fund, Inc. (the “Fund”), initially filed on September 19, 2014. This is being filed to respond to the Staff’s comments received on October 17, 2014. Please note we are also filing a request for acceleration such that the Registration Statement will be declared effective on Friday, July 10, 2015 or as soon thereafter as practicable.

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

Show Raw Text
CORRESP
1
filename1.htm

Phone:

(212)885-5205

Fax:

(917)332-3033

Email:

ajanell@blankrome.com

July 6, 2015

FILED VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

 Washington, D.C. 20549

Attention: Asen Parachkevov

Re:
Cornerstone Total Return Fund, Inc.

(File Numbers: 811-02363 and 333-191119)

Registration Statement on Form N-2

Dear Mr. Parachkevov:

Enclosed for filing herewith is Pre-Effective Amendment No. 1 to the above-referenced filing (the “Registration Statement”) of our client, Cornerstone Total Return Fund, Inc. (the “Fund”), initially filed on September 19, 2014. This is being filed to respond to the Staff’s comments received on October 17, 2014. Please note we are also filing a request for acceleration such that the Registration Statement will be declared effective on Friday, July 10, 2015 or as soon thereafter as practicable.

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