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ALTERNATIVE
INVESTMENT PARTNERS ABSOLUTE RETURN FUND STS

100 Front Street, Suite 400

West Conshohocken, Pennsylvania 19428

VIA EDGAR

April 29, 2020

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

Attn: 	Ryan Sutcliffe

 Re: Alternative Investment Partners Absolute Return Fund STS

Post-Effective Amendment No. 6 to the
Registration Statement on Form N-2

SEC File Nos. 333-223061; 811-21831

Dear Mr. Sutcliffe:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, Alternative Investment Partners Absolute Return Fund STS (the “Registrant”) hereby requests that
the effective date of Post-Effective Amendment No. 6 to the Registration Statement on Form N-2 (the “Registration Statement”)
be accelerated so that the Registration Statement may become effective at 2:00 p.m., Eastern Time, on April 30, 2020, or as soon
as practicable thereafter.

In connection with this request, the Registrant
hereby acknowledges that (i) should the U.S. Securities and Exchange Commission (“Commission”) or its staff, acting
pursuant to delegated authority, declare the Registration Statement effective, such action will not foreclose the Commission from
taking any action with respect to the Registration Statement; (ii) the action of the Commission or its staff, acting pursuant to
delegated authority, in declaring the Registration Statement effective, will not relieve the Registrant from its full responsibility
for the adequacy and accuracy of the disclosure in the Registration Statement; and (iii) the Registrant may not assert such action
as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States.

The Registrant requests that notification of
such effectiveness be made by telephone call to Jonathan Gaines of Dechert LLP, legal counsel to the Registrant, at 212-641-5600.

Very truly yours,

Alternative investment
partners Absolute return fund STS

    By:
    /s/ Allan Fajardo

    Name:
    Allan Fajardo

    Title:
    Assistant Secretary

Morgan
Stanley Distribution, Inc.

522 Fifth Avenue

New York, New York 10036

VIA EDGAR

April 29, 2020

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

Attn: 	Ryan Sutcliffe

 Re: Alternative Investment Partners Absolute Return Fund STS

Post-Effective Amendment No. 6 to the
Registration Statement on Form N-2

SEC File Nos. 333-223061; 811-21831

Dear Mr. Sutcliffe:

Pursuant to Rule 461 under the Securities Act of 1933, as
amended (the “1933 Act”), Morgan Stanley Distribution, Inc., in its capacity as distributor of Alternative Investment
Partners Absolute Return Fund STS (the “Fund”), hereby joins in the request of the Fund for acceleration of the effective
date of Post-Effective Amendment No. 6 to the Registration Statement on Form N-2 (the “Registration Statement”) so
that such Registration Statement may be declared effective at 2:00 p.m., Eastern Time, on April 30, 2020, or as soon as practicable
thereafter.

The undersigned, in making this request for acceleration, hereby
states that it is aware of its obligations under Rule 461 and the other applicable provisions of the 1933 Act.

Very truly yours,

Morgan Stanley
Distribution, Inc.

    By:
    /s/ Matthew Graver

    Name:
    Matthew Graver

    Title:
    Managing Director