DCA Total Return Fund
518 17th Street, Suite 1200
Denver, CO 80202
October 6, 2011
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: DCA Total Return Fund
File No. 811-21680
Preliminary Proxy Statement on Schedule 14A
To Whom It May Concern:
On behalf of the DCA Total Return Fund (the Fund), attached hereto for filing pursuant to Rule 14a-6 under the Securities Exchange Act of 1934, as amended (the 1934 Act) are the preliminary proxy statement, form of proxy and other soliciting materials (the Proxy Materials) relating to an annual meeting of the shareholders of the Fund to be held on December 6, 2011. The Fund estimates that copies of the definitive Proxy Materials will be released to shareholders of the Fund on or around October 17, 2011.
The SEC Staff is requested to address any comments on this filing to Mr. Peter H. Schwartz, Esq., Davis Graham & Stubbs LLP, at (303) 892-7381.
|Jeffrey W. Taylor|
|cc:||Peter H. Schwartz, Esq., Davis Graham & Stubbs LLP|