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  ROPES
                                            & GRAY LLP

PRUDENTIAL
TOWER

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BOYLSTON STREET

BOSTON,
MA 02199-3600

WWW.ROPESGRAY.COM

February 25, 2026 Jonathan
                                            S. Upchurch

  T
                                            +1 617-235-4730

  jonathan.upchurch@ropesgray.com

VIA EMAIL

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review Office

100 F Street, NE

Washington, DC 20549

Attn: Tara Varghese

 Re: Eaton Vance Mutual Funds Trust (File No. 811-04015) (the “Registrant”)

Dear Ms. Varghese:

This letter responds to comments provided on February 13, 2026, by
the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) with respect to Post-Effective
Amendment No. 370 (the “Amendment”) to the Registrant’s registration statement on Form N-1A (the “Registration
Statement”) relating to Eaton Vance Diversified Currency Income Fund, a series of the Registrant (the “Fund”). The Amendment
was filed with the SEC, via the EDGAR system, pursuant to Rule 485(a) under the Securities Act of 1933, as amended, on December 30, 2025
for the purpose of updating the Fund’s disclosure in compliance with annual updating requirements.

The Staff’s comments are summarized below, followed by the
Registrant’s response. Capitalized terms not otherwise defined herein have the meanings set forth in the Amendment.

*  *  *

 1. Comment: Please confirm that the expense reimbursement agreement referenced in footnote 2 to the “Annual Fund Operating
Expenses Table” will be in place for at least one year from the effective date of the Registration Statement and that the presentation
of any Acquired Fund Fees and Expenses, as applicable, will comply with the requirements of Form N-1A.

Response: The Registrant confirms that
the expense reimbursement agreement will be in place for at least one year from the effective date of the Registration Statement and has
included the expiration date in the referenced footnote. Furthermore, the Registrant confirms that no line item for Acquired Fund Fees
and Expenses is currently required for the Fund. Consistent with Form N-1A, the expense table for the Fund reflects the aggregate expenses
of the Fund and International Income Portfolio, the master fund in which the Fund invests.

    - 2 -
  February 25, 2026

 2. Comment: The Staff notes that the final two sentences of the Fund’s principal investment strategy states that “[t]he
Fund invests substantially all of its assets in the Portfolio, a separate registered investment company. References to the Fund’s
investments include investments held indirectly through the Portfolio in which the Fund invests.” Please consider disclosing this
information in a more prominent position within the Fund’s principal investment strategy.

Response: The Registrant confirms the
requested change has been made.

 3. Comment: The Staff notes that the Fund’s 80% policy states that “[u]nder normal market conditions, the Fund invests
at least 80% of its net assets (plus any borrowings for investment purposes) in (i) securities denominated in foreign currencies; (ii)
fixed income instruments issued by foreign entities or sovereign nations; and/or (iii) derivative instruments denominated in or based
on the currencies, interest rates, or issues of foreign entities or sovereign nations.”

Please supplementally confirm that any investments
counted towards the Fund’s 80% policy will be denominated in foreign currencies. If not, please supplementally explain why the existing
80% policy complies with requirements of Rule 35d-1 (the “Amended Names Rule”) under the Investment Company Act of 1940 (the
“1940 Act”).

Response: The Registrant submits that
investments that are denominated in both foreign currencies and U.S. dollars may count toward the Fund’s 80% policy if such investments
are otherwise consistent with the policy. The second and third prongs of the Fund’s 80% policy are not limited to securities denominated
in foreign currencies. For example, prong (ii) of the 80% policy would permit fixed income instruments issued by foreign entities but
denominated in U.S. dollars to count toward the test, and prong (iii) of the 80% policy would permit U.S. dollar denominated non-deliverable
forwards on foreign currencies to count toward the test.

The Registrant believes that the Fund’s
name and associated 80% policy comply with the requirements of the Amended Names Rule. The Fund’s name suggests diversified currency
exposure (not a fund whose exposure is limited to foreign currencies), and the Fund’s portfolio investments are expected to be denominated
in, and provide economic exposure to, a number of different currencies.

 4. Comment: Please supplementally explain how the policy to invest 40% of the Fund’s net assets in foreign investments (the
“40% policy”) interacts with the Fund’s 80% policy. Specifically, please supplementally explain if there may be certain
investments counted toward the Fund’s 80% policy that are not considered foreign investments for purposes of the Fund’s 40%
policy?

    - 3 -
  February 25, 2026

Response: The Fund’s 40% policy
and 80% policy are separate but overlapping policies. For purposes of the Fund’s 40% policy, foreign investments are those primarily
traded outside the U.S. or issued by an issuer that is domiciled, or derives a significant portion of its revenue, outside the U.S. While
many of the investments that count toward prongs (i) and (ii) of the 80% policy would qualify as foreign investments for purposes of the
40% policy, there may be certain investments that would count toward the 80% policy that would not be considered foreign investments for
purposes of the Fund’s 40% policy. Examples of such securities could include, among others, (i) securities issued by domestic issuers
denominated in foreign currencies; or (ii) derivative instruments based on foreign currencies that trade primarily in the U.S.

 5. Comment: The Staff notes that the Fund’s fact sheet for the fourth quarter of 2025 states that the Fund seeks to provide
“non-U.S. dollar currency exposure” and that the Fund “has the potential to benefit from a decline in the value of the
U.S. dollar while producing an income stream from international markets.” Please consider clarifying the Fund’s principal
investment strategy disclosure to more directly address the topics of non-U.S. dollar currency exposure, and the potential impact of a
declining U.S. dollar, as stated in the existing Fund fact sheet.

Response: The Registrant believes that
its principal investment strategies disclosure, including its 80% policy, makes it clear that the Fund will provide non-U.S. dollar currency
exposure. The Registrant further notes that its currency risk disclosure, which is included among the Fund’s principal risks, states
that “[i]f the U.S. dollar rises in value relative to a foreign currency, a security denominated in that foreign currency will be
worth less in U.S. dollars. If the U.S. dollar decreases in value relative to a foreign currency, a security denominated in that foreign
currency will be worth more in U.S. dollars.”

 6. Comment: Please review the principal risk factors to ensure they are applicable to this Fund. To the extent investments such
as mortgage-backed securities, asset-backed securities, municipal securities, loans, commodities-related investments are deemed to be
principal risks, please ensure that the Fund’s principal investment strategy disclosure expressly address each such investment.

Response: The Registrant confirms that
the principal risks disclosed in the Fund Summary are applicable to the Fund and related to the principal investment strategies. As disclosed
in the principal investment strategies section of the Fund Summary, the Fund’s investments “may include foreign and domestic
securities and other instruments, including sovereign debt (including U.S. Treasuries), mortgage-backed securities (“MBS”)
and asset-backed securities, stripped securities, loans, bank instruments, municipal securities, corporate debt, other fixed-income securities
and commodities-related investments.”

    - 4 -
  February 25, 2026

 7. Comment: The Staff notes that an index that pertains to the equity or fixed-income market of a group of countries or a group
of countries with shared characteristics such as emerging markets can serve as a Fund’s broad-based securities market index, provided
that the index represents the overall applicable international equity or debt market relative to the Fund’s investments. Please
supplementally explain how an emerging market index such as the J.P. Morgan Government Bond Index: Emerging Markets (JPM GBI-EM) Global
Diversified (Unhedged) (the “Index”) can be an appropriate broad-based index for a fund that invests in both developed and
emerging markets.

Response: The Registrant believes that
the Index is an appropriate “broad-based securities market index” for the Fund because it represents the overall applicable
market relative to the Fund’s investments. Although the Fund’s principal investment strategies allow it to invest in both
developed and emerging markets, the Fund “frequently has significant exposure to emerging markets investments.” Given the
Fund’s expected exposure to emerging markets and its related currency risk profile, the Fund’s adviser has deemed the Index
to be the most representative, among the available options, of the Fund’s portfolio.

*  *  *

We hope the foregoing response adequately addresses
the Staff’s comment. Should you have any further questions or comments, please do not hesitate to contact me at (617) 235-4730.

  Sincerely,

  /s/ Jonathan Upchurch

 cc: Jordan Beksha, Morgan Stanley Investment Management

Sarah Clinton, Ropes & Gray LLP