SEC Company Response from CORNERSTONE TOTAL RETURN FUND INC (CRF) (CIK 0000033934) (CRF) — Jun 9, 2017
CORNERSTONE TOTAL RETURN FUND INC (CRF) (CIK 0000033934)
Date: June 9, 2017 · CIK: 0000033934 · Accession: 0001398344-17-007516
AI Filing Summary & Sentiment
File numbers found in text: 811-02363
Letter
Phone:
(212)885-5234
Fax:
(917)898-1392
Email:
cschrenko@blankrome.com
June 9, 2017
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re:
Cornerstone Total Return Fund, Inc. (File Number: 811-02363)
Registration Statement on Form N-2
Request for Selective Review
To Whom It May Concern:
The above-referenced filing (the “Registration Statement”) of our client, Cornerstone Total Return Fund, Inc. (the “Fund”), being filed on June 9, 2017, is based on and is substantially similar to the registration statement on Form N-2 of the Fund which was reviewed and declared effective by the Staff on September 16, 2016. Please accept this letter as a request under the selective review procedures discussed below with respect to the Staff’s review of the Registration Statement.
In this regard, the Staff follows certain selective review procedures for registration statements, set forth in Securities Act Release No. 6510 (Feb. 15, 1984), which are applicable to all management investment company registration statements. The Staff may determine not to review a registration statement (or portions of a registration statement) based on similarity to prior filings that have been reviewed by the Staff. Based on these procedures, a registrant may identify portions of prior filings similar or identical to, and intended to serve as precedent for, a current filing.
The Registration Statement represents a “rights offering” of the Fund’s shares, the terms and conditions of which are substantially similar to those contained in the registration statement of the Fund referenced above.
Please contact me at (212) 885-5234 or Thomas R. Westle at (212) 885-5239 with any questions you may have or for any further information you may desire.
Securities and Exchange Commission
June 9, 2017
Page 2
Very truly yours,
/s/ Courtney B. Schrenko
Show Raw Text
CORRESP 1 filename1.htm Phone: (212)885-5234 Fax: (917)898-1392 Email: cschrenko@blankrome.com June 9, 2017 VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Cornerstone Total Return Fund, Inc. (File Number: 811-02363) Registration Statement on Form N-2 Request for Selective Review To Whom It May Concern: The above-referenced filing (the “Registration Statement”) of our client, Cornerstone Total Return Fund, Inc. (the “Fund”), being filed on June 9, 2017, is based on and is substantially similar to the registration statement on Form N-2 of the Fund which was reviewed and declared effective by the Staff on September 16, 2016. Please accept this letter as a request under the selective review procedures discussed below with respect to the Staff’s review of the Registration Statement. In this regard, the Staff follows certain selective review procedures for registration statements, set forth in Securities Act Release No. 6510 (Feb. 15, 1984), which are applicable to all management investment company registration statements. The Staff may determine not to review a registration statement (or portions of a registration statement) based on similarity to prior filings that have been reviewed by the Staff. Based on these procedures, a registrant may identify portions of prior filings similar or identical to, and intended to serve as precedent for, a current filing. The Registration Statement represents a “rights offering” of the Fund’s shares, the terms and conditions of which are substantially similar to those contained in the registration statement of the Fund referenced above. Please contact me at (212) 885-5234 or Thomas R. Westle at (212) 885-5239 with any questions you may have or for any further information you may desire. Securities and Exchange Commission June 9, 2017 Page 2 Very truly yours, /s/ Courtney B. Schrenko Courtney B. Schrenko