0001193125-12-016867.txt : 20120329 0001193125-12-016867.hdr.sgml : 20120329 20120119145456 ACCESSION NUMBER: 0001193125-12-016867 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120119 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HELIOS TOTAL RETURN FUND INC CENTRAL INDEX KEY: 0000851169 IRS NUMBER: 132529369 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THREE WORLD FINANCIAL CENTER STREET 2: 200 VESEY STREET, 10TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10281-1010 BUSINESS PHONE: 212-549-8328 MAIL ADDRESS: STREET 1: THREE WORLD FINANCIAL CENTER STREET 2: 200 VESEY STREET, 10TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10281-1010 FORMER COMPANY: FORMER CONFORMED NAME: HYPERION BROOKFIELD TOTAL RETURN FUND INC DATE OF NAME CHANGE: 20070620 FORMER COMPANY: FORMER CONFORMED NAME: HYPERION TOTAL RETURN FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: HYPERION TOTAL RETURN & INCOME FUND INC DATE OF NAME CHANGE: 19890727 CORRESP 1 filename1.htm Helios Total Return Fund, Inc.

[Letterhead of Helios Total Return Fund, Inc.]

 

January 19, 2012

Brion R. Thompson

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

 

Re: Helios Total Return Fund, Inc. (the “Fund”)

Registration Statement on Form N-14 (the “Registration Statement”)

File Nos. 333-178129 and 811-05820

Dear Mr. Thompson:

On November 22, 2011, January 9, 2012 and January 19, 2012, the Fund filed its Registration Statement on Form N-14, Pre-Effective Amendment No. 1 to such Registration Statement and Pre-Effective Amendment No. 2 to such Registration Statement relating to the proposed reorganization of the Helios Strategic Mortgage Income Fund, Inc. into the Helios Total Return Fund, Inc.

Pursuant to Rule 461 under the Securities Act of 1933, the Fund hereby requests acceleration of the effective date of the Registration Statement so that such Registration Statement may be declared effective on Tuesday, January 24, 2012, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone call to Rachael Schwartz of Paul Hastings LLP at (212) 318-6275, and that such effectiveness also be confirmed in writing.

Very truly yours,

Helios Total Return Fund, Inc.

 

By:  

/s/ Kim G. Redding

  Name:     Kim G. Redding
  Title:     President