<DOCUMENT>
<TYPE>EX-99.CERT
<SEQUENCE>2
<FILENAME>ex3a.txt
<DESCRIPTION>EXHIBIT 3(A)
<TEXT>

<PAGE>

                                  EXHIBIT 3(a)
                          RULE 30a-2(a) CERTIFICATIONS

         I, Robert H. Steers, certify that:

         1.       I have reviewed this report on Form N-Q of Cohen & Steers
                  Total Return Realty Fund, Inc.;

         2.       Based on my knowledge, this report does not contain any untrue
                  statement of a material fact or omit to state a material fact
                  necessary to make the statements made, in light of the
                  circumstances under which such statements were made, not
                  misleading with respect to the period covered by this report;

         3.       Based on my knowledge, the schedules of investments included
                  in this report fairly present in all material respects the
                  investments of the registrant as of the end of the fiscal
                  quarter for which the report is filed;

         4.       The registrant's other certifying officer(s) and I are
                  responsible for establishing and maintaining disclosure
                  controls and procedures (as defined in Rule 30a-3(c) under the
                  Investment Company Act of 1940) and internal control over
                  financial reporting (as defined in Rule 30-a-3(d) under the
                  Investment Company Act of 1940) for the registrant and have:

                  (a) designed such disclosure controls and procedures, or
                      caused such disclosure controls and procedures to be
                      designed under our supervision, to ensure that material
                      information relating to the registrant, including its
                      consolidated subsidiaries, is made known to us by others
                      within those entities, particularly during the period in
                      which this report is being prepared;

                  (b) designed such internal control over financial reporting,
                      or caused such internal control over financial reporting
                      to be designed under our supervision, to provide
                      reasonable assurance regarding the reliability of
                      financial reporting and the preparation of financial
                      statements for external purposes in accordance with
                      generally accepted accounting principles;

                  (c) evaluated the effectiveness of the registrant's disclosure
                      controls and procedures and presented in this report our
                      conclusions about the effectiveness of the disclosure
                      controls and procedures, as of a date within 90 days prior
                      to the filing date of this report based on such
                      evaluation; and

                  (d) disclosed in this report any change in the registrant's
                      internal control over financial reporting that occurred
                      during the registrant's most







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                      recent fiscal quarter that has materially affected, or is
                      reasonably likely to materially affect, the registrant's
                      internal control over financial reporting; and

         5.       The registrant's other certifying officer(s) and I have
                  disclosed to the registrant's auditors and the audit committee
                  of the registrant's board of directors (or persons performing
                  the equivalent functions):

                  (a) all significant deficiencies and material weaknesses in
                      the design or operation of internal control over financial
                      reporting which are reasonably likely to adversely affect
                      the registrant's ability to record, process, summarize,
                      and report financial information; and

                  (b) any fraud, whether or not material, that involves
                      management or other employees who have a significant role
                      in the registrant's internal control over financial
                      reporting.




                  Date: May 27, 2005

                                            /s/ Robert H. Steers
                                            --------------------
                                            Robert H. Steers
                                            Chairman, Secretary and
                                            principal executive officer






<PAGE>


                                  EXHIBIT 3(a)
                          RULE 30a-2(a) CERTIFICATIONS



         I, Martin Cohen, certify that:

         1.       I have reviewed this report on Form N-Q of Cohen & Steers
                  Total Return Realty Fund, Inc.;

         2.       Based on my knowledge, this report does not contain any untrue
                  statement of a material fact or omit to state a material fact
                  necessary to make the statements made, in light of the
                  circumstances under which such statements were made, not
                  misleading with respect to the period covered by this report;

         3.       Based on my knowledge, the schedules of investments included
                  in this report fairly present in all material respects the
                  investments of the registrant as of the end of the fiscal
                  quarter for which the report is filed;

         4.       The registrant's other certifying officer(s) and I are
                  responsible for establishing and maintaining disclosure
                  controls and procedures (as defined in Rule 30a-3(c) under the
                  Investment Company Act of 1940) and internal control over
                  financial reporting (as defined in Rule 30-a-3(d) under the
                  Investment Company Act of 1940) for the registrant and have:

                  (a) designed such disclosure controls and procedures, or
                      caused such disclosure controls and procedures to be
                      designed under our supervision, to ensure that material
                      information relating to the registrant, including its
                      consolidated subsidiaries, is made known to us by others
                      within those entities, particularly during the period in
                      which this report is being prepared;

                  (b) designed such internal control over financial reporting,
                      or caused such internal control over financial reporting
                      to be designed under our supervision, to provide
                      reasonable assurance regarding the reliability of
                      financial reporting and the preparation of financial
                      statements for external purposes in accordance with
                      generally accepted accounting principles;

                  (c) evaluated the effectiveness of the registrant's disclosure
                      controls and procedures and presented in this report our
                      conclusions about the effectiveness of the disclosure
                      controls and procedures, as of a date within 90 days prior
                      to the filing date of this report based on such
                      evaluation; and







<PAGE>

                  (d) disclosed in this report any change in the registrant's
                      internal control over financial reporting that occurred
                      during the registrant's most recent fiscal quarter that
                      has materially affected, or is reasonably likely to
                      materially affect, the registrant's internal control over
                      financial reporting; and

         5.       The registrant's other certifying officer(s) and I have
                  disclosed to the registrant's auditors and the audit committee
                  of the registrant's board of directors (or persons performing
                  the equivalent functions):

                  (a) all significant deficiencies and material weaknesses in
                      the design or operation of internal control over financial
                      reporting which are reasonably likely to adversely affect
                      the registrant's ability to record, process, summarize,
                      and report financial information; and

                  (b) any fraud, whether or not material, that involves
                      management or other employees who have a significant role
                      in the registrant's internal control over financial
                      reporting.


                  Date: May 27, 2005


                                            /s/ Martin Cohen
                                            ----------------
                                            Martin Cohen
                                            President, Treasurer and
                                            principal financial officer



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