Form RW Virtus Total Return Fund

William Renahan

[email protected]

September 28, 2016

VIA EDGAR

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Ladies and Gentlemen:

Pursuant to Rule 477 of the Securities Act of 1933, the Registrant hereby respectfully applies for the withdrawal of the above-referenced registration statement on Form N-14 8C filed with the Securities and Exchange Commission (“SEC”) on September 7, 2016 (Accession No: 0001571049-16-018091) (the “Registration Statement”).

The Registration Statement was filed with respect to a proposed reorganization of The Zweig Fund, Inc. into the Registrant. The Registrant has determined not to proceed with the reorganization and wishes to withdraw the Registration Statement. There were no securities sold or issued pursuant to the Registration Statement. The Registrant submits that withdrawal of the Registration Statement is consistent with the public interest and the protection of investors.

We appreciate your assistance in this matter. If you have any questions regarding this matter, please contact the undersigned at (860) 263-4799, or Arie Heijkoop of Sullivan &Worcester LLP, counsel to the Registrant, at (202) 775-1227.

You May Also Be Interested In

• Forcura Launches Referral Summary for Post-Acute Care Market
• Particle Dynamics Appoints New CFO as it Advances its Strategic Growth Plans
• XiFin to Highlight Impact of FDA Regulations, Other Disruptive Forces Facing Hospitals, Independent Labs, and Pathology Practices at 29th Annual Executive War College