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THE MAINSTAY FUNDS

MAINSTAY FUNDS TRUST

51 Madison Avenue

New York, NY 10010

VIA EDGAR CORRESPONDENCE

February 21, 2020

Mr. Mark A. Cowan

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re: Response to Comments on the 485A filings (each a “Registration Statement” and, collectively, the
                                 “Registration Statements”) for The MainStay Funds (SEC File No. 333-214498) and MainStay Funds Trust (SEC File
                                 No. 333-160918) (collectively, the “Registrants”)

Dear Mr. Cowan:

This letter responds to comments provided
by e-mail on January 24, 2020 with respect to the Registration Statements. The Registration Statements were filed with the Securities
and Exchange Commission on December 18, 2019. On behalf of the Registrants, your comments and our responses thereto are provided
below. All defined terms in this letter have the same meaning as in the Registration Statements, except as otherwise defined herein.

Comments applicable to more than
one Fund

Comment 1: Please update
the class identifier on EDGAR to reflect the tickers for Class R6 shares.

Response: We will update
the tickers for Class R6 shares prior to offering such shares to the public.

Comment 2: Please update
the cover page to disclose the former name of a Fund, as applicable.

Response: We respectfully
decline to make this change. To the extent applicable, we have historically included a Fund’s former name on the first page
of its summary section.

Comment 3: In the section
entitled “Fees and Expenses of the Fund”, delete the following sentence:

“The amount may
vary depending on the MainStay Fund in which you invest.”

Response: Although this information
is not fund specific, we believe that it is important for an investor to understand how sales charge discounts work across our
fund complex. Therefore, we decline to make the requested edit.

Comment 4: Please provide
the updated fee and example tables (including footnotes) in this correspondence.

Response: We have included
the current fee and example tables in Appendix A below.

Comment 5: Please confirm
supplementally that if a Fund’s investments in other investment companies are expected to exceed 0.01% of the Fund’s
average net assets, you will add the acquired fund fees and expenses row in the fee table.

Response: We hereby confirm
that the acquired fund fees and expenses row will be included as applicable.

Comment 6: Please explain
supplementally why the “Other Expenses” of Class R6 shares are based on estimated amounts for the current fiscal year
and not based on actual Fund expenses.

Response: The “Other
Expenses” figure will be estimated based on the expenses a Fund’s Class R6 shares are expected to incur for the current
fiscal year because certain expense components are unique to Class R6 shares and therefore could not have not been actual expenses
incurred by the Fund prior to the launch of Class R6 shares. Therefore, we are not basing “Other Expenses” on actual
amounts incurred by a Fund during the prior fiscal year.

Comment 7: In the section
entitled “Example”, please delete the following disclosure for any Fund that does not have a contractual
fee waiver and/or expense reimbursement arrangement in place.

The Example reflects the contractual fee waiver and/or expense
reimbursement arrangement, if applicable, for the current duration of the arrangement only.

Response: We respectfully
decline to make this change as we believe the disclosure clearly notes that such arrangements will only be reflected in the Example
if applicable.

Comment 8: In the section
entitled “Principal Investment Strategies”, please disclose the ratings typically associated with investments
in “high-yield” securities.

Response: We have made the
requested revision.

Comment 9: In the section
entitled “Principal Investment Strategies”, please list the derivatives specifically that would be used
by each Fund. Please review the Barry Miller/Karrie McMillan letter.

Response: Each Fund is mindful
of the Staff’s views on derivatives disclosure, including as set forth in the Barry Miller/Karrie McMillan letter. We continue
to believe that each Fund’s derivatives disclosure is appropriate and that further revision of this section is not necessary.

Comment 10: In the section
entitled “Principal Risks”, please revise the “Debt Securities Risk” to provide additional
detail regarding a debt or fixed income security’s sensitivity to changes in an issuer’s credit rating, which could
decrease the value of such security.

Response: We have made the
requested revision.

Comment 11: In the section
entitled “Past Performance”, please revise the disclosure to specifically reference any share classes
with less than one calendar year of performance.

Response: We respectfully
decline to make this change as we believe this disclosure is consistent with our performance presentation in the “Average
Annual Total Returns” table, which includes the inception date for each share class.

Comment 12:  In the section
entitled “Past Performance”, please update the “Average Annual Total Returns” table to present
the after-tax returns for the share class presented in the bar chart.

Response: We have made the
requested revision.

Comment 13:  In the section
entitled “Past Performance”, please confirm that the rationale for changing the share class presented
in the bar chart is consistent with the requirements in Form N-1A.

Response: We respectfully
decline to make this change as we confirm the rationale for changing the share class as presented is consistent with the requirements
in Form N-1A.

Comment 14: In the section
entitled “More About Investment Strategies and Risk”, please consider including a table or other method
to designate which risks/strategies apply to which Fund and/or Underlying Fund, and which are principal, for example in the derivatives
and market capitalization risks. Alternatively, move the non-principal information into the SAI.

Response: The Registrant
has reviewed and revised the disclosure summarizing a Fund’s and/or Underlying Fund’s principal investment strategies
per Item 9 of the Form N-1A and respectfully submits that the disclosure is reasonable and appropriate both to describe a Fund’s
and/or Underlying Fund’s principal investment strategies and risks and to summarize them, as applicable. The Registrant continuously
monitors and revises the disclosure required by Item 4 and Item 9 to seek to ensure that the disclosure continues to meet Staff
Guidance. The Registrant notes that the strategies and risks disclosed in the first section under
 “More About Investment Strategies and Risks” are principal, and additional non-principal strategies and risks are disclosed
as such in response to prior comments from the Staff.

Comment 15: In the section
entitled “More About Investment Strategies and Risk”, please revise the “Floating Rate Notes and
Variable Rate Demand Obligations Risks” tile if current information technology systems are not available to accommodate new
instruments and rates with features that differ from LIBOR.

Response: We have made the
requested revision.

Comment 16: In the section
entitled “Shareholder Guide – Information on Fees”, please include the small account fee in the
fee table for the relevant Funds.

Response: We respectfully
decline to add this disclosure, as the small account fee only applied to less than 1% of the Fund’s shareholder base during
its last fiscal year.

Comment 17: In the section
entitled “Shareholder Guide – General Policies—Selling Shares”, disclose
that a redemption will be the earlier of when the check proceeds clear or 10 days.

Response: We respectfully
decline to make this change as this disclosure was added in response to previous SEC Staff comments.

Comment 18: In the section
entitled “Shareholder Guide – Operation As a Manager of Managers”, please update any relevant disclosure
consistent with the BNY Mellon Family of Funds SEC No-Action Letter (July 19, 2019).

Response: We have made the
requested revision.

Comment 19: Please revise
the following language since the disclosure in “Appendix A” must be revised each time there is a change
or addition of an intermediary, and not “from time to time.”

  This Appendix will be updated from time to time with
changes to this Appendix or to add additional intermediaries.

Response: We intend to update
the Appendix promptly when informed by an intermediary that a change is necessary, and respectfully note that this disclosure is
intended to notify shareholders that this information may change. Accordingly, we respectfully decline to make this revision.

Comments applicable only to MainStay
Candriam Emerging Markets Debt Fund

Comment 1: In the section
entitled “Principal Investment Strategies”, please include the criteria for determining whether a company
is located or doing business in an emerging market country, including which index the Subadvisor considers to be representative
of emerging markets.

Response: We have made the
requested revision.

Comment 2: In the section
entitled “Principal Investment Strategies”, please disclose the applicable criteria as to maturity or
duration for the Fund’s investments in debt securities.

Response: We have made the
requested revision.

Comment 3: In the section
entitled “Principal Investment Strategies”, please delete “some of” from the following sentence:

Some of the securities
in which the Fund invests may be denominated in foreign currency.

Response: We have made the
requested revision.

Comment 4: In the section
entitled “Principal Investment Strategies”, please disclose the percentage of the Fund’s assets
that may be invested in securities that are rated below investment grade by a NRSRO.

Response: We respectfully
decline to make this change as we believe the disclosure appropriately describes the Fund’s principal investment strategies,
including investments in securities that are rated below investment grade by a NRSRO.

Comment 5: In the section
entitled “Principal Investment Strategies”, please disclose the applicable criteria as to credit quality
for the Fund’s investments in debt securities.

Response: We respectfully
decline to make this change as we believe the disclosure appropriately describes the Fund’s principal investment strategies,
including the credit quality of the Fund’s investments.

Comment 6: In the section
entitled “Principal Investment Strategies”, please delete the following sentence as it is not consistent
with requirements under Rule 35d-1 of the 1940 Act.

In unusual market conditions
or abnormal circumstances, the Fund may invest all or a portion of its assets in fixed income securities of countries with developed
economies.

Response: Although we believe
this disclosure is consistent with the requirements under Rule 35d-1, we have nonetheless made the requested revision.

Comment 7: In the section
entitled “Principal Investment Strategies”, please confirm that floating rate notes are derivatives.
If they are not derivatives, please revise the disclosure accordingly.

Response: We have made the
requested revision.

Comment 8: Please update
the “Principal Risks” section to disclose the risks associated with the Fund’s investments in quasi-sovereign
and corporate Eurobonds.

Response:We believe the Fund’s current principal risks appropriately disclose the risks associated with quasi-sovereign and corporate Eurobonds, including debt securities risk, foreign securities risk, emerging markets risk, and sovereign debt risk.

Comment 9: In the section
entitled “Principal Investment Strategies”, please disclose the applicable ESG criteria that the Subadvisor
uses to make investment determinations, including how and when the Subadvisor takes such criteria into consideration.

Response: We have made the
requested revision.

Comment 10: In the section
entitled “Principal Risks”, please revise the “Debt Securities Risk” tile to specifically
address the interest rate risk associated with the Fund’s investments in fixed income securities of issuers located in emerging
markets.

Response: We have made the
requested revision.

Comment 11: In the section
entitled “Principal Risks”, please consider whether the expected discontinuation of LIBOR is a principal
risk for the Fund. If you believe it is not, please explain to us why supplementally. Please tailor any such principal risk disclosure
to describe how the expected discontinuation of LIBOR could affect the Fund’s investments, including (1) if the Fund will
invest in instruments that pay interest at floating rates based on LIBOR that do not include fallback provisions that address how
interest rates will be determined if LIBOR stops being published, how it will affect the liquidity of these investments, and (2)
how the transition to any successor rate could impact the value of investments that reference LIBOR.

Response: We have made the
requested revision.

Comment 12: In the section
entitled “Principal Risks”, please explain supplementally how the following disclosure in the “Liquidity
and Valuation Risk” tile is consistent with the requirements under Rule 22e-4.

The Fund is subject to the risk that it
could not meet redemption requests within the allowable time period without significant dilution of remaining investors' interests
in the Fund.

Response: This disclosure
indicates that the Fund is subject to liquidity risk. Consistent with Rule 22e-4, the Fund has adopted and implemented a written
liquidity risk management program (“LRMP”) that is reasonably designed to assess and manage the Fund’s liquidity
risk. Consistent with the Fund’s LRMP, the Fund has assessed its liquidity risk and has put in place procedures to manage
such risk. As noted in the adopting release to Rule 22e-4, Rule 22e-4 “requires a fund to assess and manage liquidity
risk and does not require a fund to eliminate all adverse impacts of liquidity risk, which would be incompatible with an investment
product such as a mutual fund or ETF, whose NAV may fluctuate for a variety of reasons, including changing liquidity conditions.”
Accordingly, we do not believe that this disclosure is inconsistent with Rule 22e-4.

Comments applicable only to MainStay
Asset Allocation Funds

Comment 1: Please confirm
the acquired (underlying) fund fees and expenses will be included as a line item in each Fund’s fee table.

Response: Please see the
Fund’s fee table provided below in Appendix A.

Comment 2: Please confirm
that there is no contractual fee waiver and/or expense reimbursement arrangement in place for the MainStay Moderate Allocation
Fund.

Response: Please see the
Fund’s fee table provided below in Appendix A.

Comment 3: In the section
entitled “Principal Risks of the Underlying Funds”, please include the principal risks of each Underlying
Fund.

Response: We respectfully
decline to make any changes in response to this comment. We note that the Fund’s allocations to Underlying Funds will vary
from time to time and submit that identifying every principal risk of every potential Underlying Fund in which the Fund may invest
will likely lead to confusion and potentially stale disclosure over the course of a year. The Fund’s disclosure informs shareholders
and potential shareholders of the types of Underlying Funds and the principal risks associated with such investments. We continuously
monitor and revise the Item 4 and Item 9 disclosure to ensure that the disclosure continues to meet Staff Guidance.

Comment 4: In the section
entitled “Principal Risks of the Underlying Funds” for the MainStay Growth Allocation Fund, please delete
 “Debt Securities Risk” and “High Yield Securities Risk” as principal risks of the Underlying Funds given
the Fund’s target allocation to the equity asset class is 100%.

Response: We respectfully
decline to make this change. We note that the Fund’s pri