SecProbe.io

CORRESP
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May 8, 2023

Karen Rossotto, Esq.

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: MBC Total Private Markets Access Fund (the “Fund”)

File Nos. 811-23839, 333-269531

Dear Ms. Rossotto:

This letter responds to comments provided on behalf of the Staff
of the Securities and Exchange Commission on February 10, 2023 regarding the registration statement on Form N-2 filed on behalf of the
Fund. The responses follow the same numbering sequence as in the comment letter; and each response summarizes the comment followed by
a response. All capitalized terms not otherwise defined herein have the meaning given to them in the registration statement.

Accompanying this letter is pre-effective amendment no. 1 to the registration
statement. All capitalized terms not otherwise defined herein have the meaning given to them in the registration statement.

General Comments

 1. Comment: Certain portions of the registration statement are incomplete.

Response:  The Fund will complete the information,
including a full financial review, in a subsequent pre-effective amendment filing, and undertakes to address any further comments from
the Staff.

 2. Comment: In addition to the Fund’s current applications for exemptive orders, please advise
if the Fund intends to submit any additional exemptive applications or a no-action request in connection with the registration statement.

Response: The Fund has not applied for or requested,
and does not currently intend to apply for or request, additional exemptive relief or no-action relief, but may determine to request such
relief in the future if the Fund deems it necessary or appropriate. The Fund will update the Staff on the status of its pending exemptive
applications as noteworthy developments occur with respect to such applications.

Please note that in connection with Fund’s Multi-class
application the Commission has issued an  order (IC-34905, May 2, 2023) granting  the application.

 3. Comment: Please confirm that the Fund does not intend to issue debt securities or preferred shares
within a year from the effective date of the registration statement.

Response: The Fund so confirms.

 4. Comment: Please tell us if you have presented or will present any “test the waters”
materials to potential investors in connection with this offering. If so, please provide us with copies of such materials.

Response: The Fund has not presented and will not present
any "test the waters" materials to potential investors in connection with this offering.

 5. Comment: Please provide the name of the Fund's independent registered public accounting firm in
correspondence.

Response: The Fund will identify its independent registered
public accounting firm in a future pre-effective amendment filing once approved by its board. If a subsequent pre-effective filing
is made before an independent registered public accounting firm is approved by the Fund’s Board but after a firm is expected to
be selected, the Fund will provide the firm’s name in correspondence accompanying such filing.

 6. Comment: The disclosure indicates that investors’ money will be held by the custodian pending
monthly closing with interest credited to the Fund. Please clarify: (1) whether investors will be able to withdraw their money from the
custodial account prior to acceptance and, if so, whether they will receive interest; (2) whether the Fund will have control or access
to this money prior to closing; and (3) whether the money will be entirely invested in cash.

Response: Disclosure has been added to
Purchasing Shares to the effect that:

 1) Prior to acceptance, investors will be able to withdraw their money from the custodial account but will not receive interest. Interest
will be credited to the Fund to offset general custodial and administrative fees incurred by the Fund.

 2) After acceptance and prior to closing, the Fund will not have access to funds held in the custodial account.

 3) The money
will be invested entirely in cash and short-term money market instruments.

Prospectus

Prospectus Cover

 7. Comment: On page 2, please uncheck the box indicating “It is proposed that this filing will become effective when declared
effective pursuant to Section 8(c) of the Securities Act.”

Response: The requested change has been
made.

 8. Comment: The table on page 3 suggests that the proceeds to the Fund will be reduced by Sales
Charges; however, the disclosure elsewhere suggests that Class R investors will pay the Sales Charge. Please reconcile throughout for
consistency.

Response: The Fund confirms that Class R investors will
pay the Sales Charge and that proceeds received by the Fund will be net of the Sales Charges. The registration statement has been reconciled
for consistency.

 9. Comment: On page 3, the disclosure states the Fund may gain access to private assets through
“(iv) investments in listed private equity companies, funds (including business development companies (“BDCs”))
or other vehicles [emphasis added].” Please clarify in the disclosure the types of “funds” that are referred
to here and also what “other vehicles” are.

Response: The types of funds and other vehicles
have been clarified in the disclosure.

 10. Comment: Please disclose on the Cover the Fund’s principal strategies
that are speculative (e.g., use of leverage, investment in early stage/distressed companies, high-yield debt) and include a cross-reference
to the disclosure regarding the risks associated with these strategies. See Form N-2, Item 1.1.j. and the Guidelines to Form N-2,
Guide 6.

Response: The Fund’s principal strategies do not
include investment in early stage/distressed companies, high-yield debt and foreign securities, including emerging market securities.
Consequently, such disclosure has not been added.

The Fund may utilize leverage as permitted under the Investment
Company Act. Disclosure of the Fund’s limited use of borrowing over the short term has been added to the Summary, Investment
Objective and Strategies, and Investment Objective and Strategies.

 11. Comment: On page 4, in “(3)”, the disclosure indicates that
the Fund’s offering costs may be borne by the Adviser. If the Adviser may recoup these costs, disclose so here or at an appropriate
place within the registration statement.

Response: Disclosure has been added to (3) that the advanced
offering costs are subject to recoupment by the Adviser. Also, “, whether borne by Seneca Management, LLC (the “Adviser”)
or the Fund,” in the next sentence in (3) has been deleted.

 12. Comment: On page 4, the disclosure states “If you purchase Shares of the Fund, you will
become bound by the terms and conditions of the Agreement and Declaration of Trust”. Please provide a cross-reference here to the
Summary of the Agreement and Declaration of Trust on page 80.

Response: A cross-reference to the
“Summary of the Agreement and Declaration of Trust” has been added.

 13. Comment: With respect to Fund distributions, please disclose the below as additional bolded bullets
on the Cover, as appropriate:

 · The amount of distributions that the Fund may pay, if any, is uncertain.

 · The Fund may pay distributions in significant part from sources that may not be available in the future and that are unrelated to
the Fund’s performance, such as offering proceeds, borrowings, and amounts from the Fund’s affiliates that are subject to
repayment by investors.

 · The Fund’s distributions may be funded from unlimited amounts of offering proceeds or borrowings, which may constitute a return
of capital and reduce the amount of capital available to the Fund for investment. Any capital returned to Shareholders through distributions
will be distributed after payment of fees and expenses.

 · A return of capital to Shareholders is a return of a portion of their original investment in the Fund,
thereby reducing the tax basis of their investment. As a result from such reduction in tax basis, Shareholders may be subject to tax in
connection with the sale of Shares, even if such Shares are sold at a loss relative to the Shareholder’s original investment.

Response:  The Fund does not intend to make distributions
from sources other than income and gains, so disclosure regarding the second and third bullets has not been added. With respect to the
first and fourth bullets, while the body of the prospectus contains disclosure addressing those items, the Fund’s investment objective
is long-term capital appreciation and income generation is not a principal strategy or investment objective of the Fund. Accordingly,
the Fund does not believe these risks are important enough to be included on the Cover.

 14. Comment: Please confirm that the bolded bullets on the Cover will also appear immediately above
the signature line on the account registration form or subscription agreement used by investors to purchase Fund Shares. As you are not
an interval fund, please include a statement here indicating that the Fund is not obligated to repurchase Shares from investors. Later,
when discussing your quarterly share repurchases, affirmatively state that you are not an interval fund and explain the implications for
investors.

Response: The Fund so confirms.

Disclosure regarding that the Fund is not
obligated to repurchase Shares has been added to the prospectus cover, Closed-End Fund; Liquidity Limited to Periodic Repurchases of
Shares, and to Periodic Repurchases, as well as an affirmative statement that the Fund is not an interval fund to Periodic
Repurchases.

Summary

 15. Comment: In several instances the Summary repeats itself or Cover Page information. For example,
information about the Adviser is disclosed on page 8 and again on page 10. Please review to ensure the Summary is concise and avoids unnecessary
duplication.

Response: The disclosure has been made
more concise.

Investment Objective and Strategies (page 8)

 16. Comment: The disclosure in the first paragraph states “The Fund will invest primarily
in an actively managed portfolio of private equity investments [emphasis added].” The disclosure in the first line of
the following paragraph states “The Fund’s investments…will include direct investments in the equity or debt of
a company [emphasis added].” As debt, or Direct Credit Investments, are referred to throughout the registration statement, please
consider if stating the Fund will “primarily” invest in private equity is accurate. If not, please revise.

Response: Disclosure that the Fund’s
investments in debt and Direct Credit Investments, under normal market conditions, will generally be limited to 20% or less of the Fund’s
total assets at time of purchase has been added to Summary, Investment Objective and Strategies and Investment Objective and
Strategies.

 17. Comment: The disclosure in the second paragraph of this section states “Fund Investments
will include secondary purchases of Portfolio Funds and other private assets.” Please explain what “secondary purchases”
are.

Response: An explanation of
secondary purchases has been added to the description of “Secondary Investments” to the Summary, Investment Objective
and Strategies, and to Investment Objective and Strategies, Investment Strategies.

 18. Comment: In the second paragraph, the sentence beginning “As opposed to multiple individual investments, programmatic
investment relationships…” Please break up this sentence to explain in plain English what programmatic investment relationships
are.

Response: The references to programmatic
investment relationship has been deleted.

 19. Comment: In the penultimate sentence of this paragraph, the disclosure
states “The Fund may make investments through wholly-owned Subsidiaries.” Regarding the Fund’s use of wholly- owned
Subsidiaries, we have the following comments:

 a. Disclose that the Fund complies with the provisions of the Investment Company Act governing investment
policies (Section 8) on an aggregate basis with each Subsidiary.

 b. Disclose that the Fund complies with the provisions of the Investment Company Act governing capital structure
and leverage (Section 18) on an aggregate basis with each Subsidiary so that the fund treats the Subsidiary’s debt as its own for
purposes of Section 18.

 c. Disclose that any investment adviser to a Subsidiary complies with provisions of the Investment Company
Act relating to investment advisory contracts (Section 15) as if it were an investment adviser to the Fund under Section 2(a)(20) of the
Investment Company Act. Any investment advisory agreement between a Subsidiary and its investment adviser should be included as an exhibit
to the registration statement.

 d. Disclose that each Subsidiary complies with provisions relating to affiliated transactions and custody
(Section 17). Identify the custodian of each Subsidiary, if any.

 e. Disclose any of a Subsidiary’s principal investment strategies or principal risks that constitute
principal investment strategies or risks of the Fund. The principal investment strategies and principal risk disclosures of a fund that
invests in a subsidiary should reflect aggregate operations of the fund and the subsidiary.

Response: The requested disclosure for Comment 19 a.-e.-has
been added. As to c., any investment advisory agreement with a Subsidiary will be included as an exhibit to the registration statement.
As to d., the Fund will identify the custodian of each Subsidiary at the appropriate time. The Fund acknowledges that the investment strategies
and risk disclosures will reflect the aggregate operations of the Fund and the subsidiary.

 f. Explain in correspondence whether the financial statements of each Subsidiary will be consolidated
with those of the Fund. If not, please explain why not.

Response: The financial statements of each Subsidiary will
be consolidated with those of the Fund.

 g. Confirm in correspondence that each Subsidiary and its board of directors will agree to inspection by
the Staff of the Subsidiary’s books and records.

Response: The Fund so confirms.

 h. Confirm any wholly-owned Subsidiary’s management fee (including any performance fee), if any,
will be included in the line item “Investment Management Fee” and the wholly-owned Subsidiary’s expenses will be included
in “Other Expenses” in the Fund’s fee table.

Response: The Fund so confirms.

 i. Disclose that the Fund does not intend to create or acquire primary control of any entity that primarily
engages in investment activities in securities or other assets, other than entities wholly-owned or majority-owned by the Fund.

Response: The requested disclosure has been added.

 20. Comment: The disclosure in the last sentence on page 9 states that the Fund’s “portfolio construction approach
is designed to maintain a relatively high level of exposure to private assets….” In compliance with rule 35d-1, please disclose
specifically that, under normal circumstances, the Fund intends to invest at least 80% of its net assets (plus the amount of any borrowings
for investment purposes) in private market investments. Your revised disclosure should clarify the circumstances under which investments
listed on the Cover in (i) to (v) would be counted towards the Fund’s policy. Please confirm the Fund will not count unfunded commitments
towards its 80% test.

Response:  References to (v) programmatic
investment relationships has been deleted and replaced with (v) “Other Investments”. The revised disclosure includes the investments
listed on the Cover in (i) to v), which are private assets as that term is understood in the market, will be counted towards the 80% test.

The Fund respectfully acknowledges the
Staff’s comment regarding unfunded commitments. The Fund believes that treating capital commitments as assets for purposes of
the Fund’s 80% test is appropriate. Private equity investments are typically structured as commitments to invest in an asset
(a direct i