<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>RFI_NSAR.txt
<TEXT>






Report of Independent Registered Public Accounting Firm

To the Board of Directors and Shareholders
of Cohen & Steers Total Return Realty Fund, Inc.

In planning and performing our audit of the financial
statements of Cohen & Steers Total Return Realty
Fund, Inc. ("the Fund") as of and for the year ended
December 31, 2016, in accordance with the
standards of the Public Company Accounting Oversight
Board (United States), we considered the Fund's
internal control over financial reporting, including
controls over safeguarding securities, as a basis for
designing our auditing procedures for the purpose of
expressing our opinion on the financial statements
and to comply with the requirements of Form N-SAR,
but not for the purpose of expressing an opinion on
the effectiveness of the Fund's internal control
over financial reporting.  Accordingly, we do not
express an opinion on the effectiveness of the
Fund's internal control over financial reporting.

The management of the Fund is responsible for
establishing and maintaining effective internal
control over financial reporting.  In fulfilling
this responsibility, estimates and judgments by
management are required to assess the expected
benefits and related costs of controls.  A fund's
internal control over financial reporting is a
process designed 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.  A fund's internal
control over financial reporting includes those
policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions
and dispositions of the assets of the fund;
(2) provide reasonable assurance that transactions
are recorded as necessary to permit preparation of
financial statements in accordance with generally
accepted accounting principles, and that receipts
and expenditures of the fund are being made only
in accordance with authorizations of management and
directors of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection
of unauthorized acquisition, use or disposition of
a fund's assets that could have a material effect
on the financial statements.

Because of its inherent limitations, internal
control over financial reporting may not prevent
or detect misstatements.  Also, projections of any
evaluation of effectiveness to future periods are
subject to the risk that controls may become
inadequate because of changes in conditions, or
that the degree of compliance with the policies
or procedures may deteriorate.

A deficiency in internal control over financial
reporting exists when the design or operation of
a control does not allow management or employees,
in the normal course of performing their assigned
functions, to prevent or detect misstatements on a
timely basis.  A material weakness is a deficiency,
or a combination of deficiencies, in internal control
over financial reporting, such that there is a
reasonable possibility that a material misstatement
of the Fund's annual or interim financial statements
will not be prevented or detected on a timely basis.

Our consideration of the Fund's internal control
over financial reporting was for the limited
purpose described in the first paragraph and
would not necessarily disclose all deficiencies
in internal control over financial reporting
that might be material weaknesses under standards
established by the Public Company Accounting
Oversight Board (United States).  However, we
noted no deficiencies in the Fund's internal
control over financial reporting and its
operation, including controls over safeguarding
securities, that we consider to be material
weaknesses as defined above as of
December 31, 2016.

This report is intended solely for the information
and use of management and the Board of Directors
of Cohen & Steers Total Return Realty Fund, Inc.
and the Securities and Exchange Commission and
is not intended to be and should not be used by
anyone other than these specified parties.



/s/ PricewaterhouseCoopers LLP
New York, New York
February 27, 2017







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