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CORRESP
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CORRESP

 Transamerica Asset
Management

 1801 California St, Suite
5200

 Denver, CO 80202

 October 9, 2024

VIA EDGAR CORRESPONDENCE

 Ms. Lauren Hamilton

United States Securities and Exchange Commission

 Division of
Investment Management

 100 F Street, NE

 Washington, DC
20549-0102

Re:
 Transamerica Funds (File Nos. 033-02659; 811-04556) (the “Registrant”, and each series thereof a “Fund” and together, the “Funds”)

Comments Pursuant to Review of the Registrant’s Financial Statements for the Fiscal Years Ended October 31, 2023,
and December 31, 2023, each filed on Form N-CSR (each a “Filing” and together, the “Filings”)

Dear Ms. Hamilton:

On behalf of the Registrant, we are filing this letter to respond in writing to the Staff’s comments on the Filings,
which were submitted via EDGAR to the Securities and Exchange Commission (the “SEC”) on January 3, 2024 (SEC Accession No. 0001193125-24-001436) and
March 4, 2024 (SEC Accession No. 0001193125-24-057731). The Staff’s comments were conveyed to the Registrant by telephone on July 17, 2024. The Staff
noted that the comments generally apply to each Filing unless specifically noted.

 Below are the Staff’s comments on
the Filings and the Registrant’s responses thereto.

1.
 Comment: The Staff notes that the Registrant’s Registration Statement dated March 1, 2024
was filed with the SEC on February 29, 2024, (Post-Effective Amendment No. 316, Accession No.0001193125-24-052681, the “Post-Effective Amendment”)
which is 121 days after the fiscal year end of the Funds. Please discuss the reasons for this tardy filing and address whether the Funds sold off a prospectus including stale financial statements. The Staff reminds the Registrant of the requirement
of Rule 8b-16(a) of the 1940 Act.

 Response: The
Registrant filed the Post-Effective Amendment on February 29, 2024. The Registrant based its filing calendar on the filing calendar from the prior year which had the Registrant filing its Rule 485(b) filing on the last business day of February.
Due to leap year, the last business day of February 2024 was 121 days after the close of the Funds’ October 31, 2023 fiscal year end. The Registrant and certain of its service providers have made enhancements to their policies and
procedures to prevent a recurrence of this kind.

 The Registrant notes that the Funds did not sell shares off prospectuses
containing stale financial statements. The Funds complied with the requirements of Section 10(a)(3) of the Securities Act of 1933, as amended, which provides that “when a prospectus is used more than nine months after the effective date of
the registration statement, the information contained therein shall be as of a date not more than sixteen months prior to such use, so far as such information is known to the user of such prospectus or can be furnished by such user without
unreasonable effort or expense.” The Registrant’s prospectuses used on February 29, 2024 included financial statements as of October 31, 2022, which were not stale under Section 10(a)(3) as they were not more than sixteen
months old. The Post-Effective Amendment was stated to, and did become, effective on March 1, 2024.

 While filing the
Post-Effective Amendment on February 28, 2024 would have complied with Rule 8b-16 under the 1940 Act, filing on that date would not have affected the prospectuses used for sales on February 29, 2024,
which, as noted above, did not contain stale financial statements. The Funds’ March 1, 2024 prospectuses included updated financial statements as of October 31, 2023.

The Registrant acknowledges the Staff’s comment and confirms that it will timely file its registration statements.

2.
 Comment: The Staff notes that there was an issue with the operation of a link to the prospectus for
Class I2 of Transamerica Long Credit. Please confirm the links to this prospectus are operating properly.

Response: The Registrant has fixed the link in question and confirms that all links to the noted prospectus are
operating properly.

3.
 Comment: The Staff notes that Item 11(b) of Form N-CSR
requires that the Registrant disclose the relevant information that occurred during the period covered by the report. Please use the correct language going forward and confirm that there has been no change in the Registrant’s internal controls
over financial reporting during the applicable period.

 Response: The Registrant will make
changes consistent with the Staff’s comment going forward. The Registrant confirms that there were no changes to the Registrant’s internal controls over financial reporting that occurred during the applicable period covered by the Filings
that materially affected, or are reasonably likely to materially affect, the Registrant’s internal controls over financial reporting.

4.
 Comment: The Staff notes that Item 4(d) of the certifications required by Item 19(a)(2) of Form N-CSR requires that the Registrant’s certifying officer(s) certify that the Registrant has disclosed in the relevant report any change in the registrant’s internal control over financial reporting that
occurred during the period covered by the report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting. Please file an amended Form
N-CSR with respect to the Registrant’s financial statements for the fiscal year ended October 31, 2023 with the corrected certifications addressing the full period of that report and include an
explanatory note for the amendment.

 Response: The Registrant will make a Form N-CSR/A filing to amend the certifications consistent with the Staff’s comment, including a related explanatory note.

5.
 Comment: The Staff notes that Item 27(b)(6) of Form N-1A
requires that the annual report to shareholders include a statement that the Statement of Additional Information (“SAI”) includes additional information about fund directors and is available, without charge, upon request, and a toll-free
(or collect) telephone number for shareholders to call to request the SAI. Please include such information in future filings.

Response: The Registrant will make changes consistent with the Staff’s comment going forward.

6.
 Comment: With respect to Transamerica High Yield ESG, Transamerica Sustainable Bond and Transamerica
Sustainable Equity Income, please include an 80% investment policy with regard to the use of the words “sustainable” and “ESG” as applicable in the name of these funds.

Response: The Registrant believes the terms “sustainable” and “ESG,” as used in the names of the
noted Funds, connote an investment strategy and therefore do not require the Funds to include a related 80% investment policy under the current Rule 35d-1 under the 1940 Act. The Registrant acknowledges that
each of these Funds will need to adopt a related 80% policy in advance of the December 10, 2025 compliance date for the amendments to Rule 35d-1.

7.
 Comment: With respect to Transamerica Sustainable Equity Income, the Staff notes that the Fund’s
prospectus states “The sub-adviser applies its sustainability assessment framework in evaluating each company considered for the fund. The sub-adviser maintains an
exclusion list containing companies involved in a range of activities that the sub-adviser believes have a negative impact on the environment and/or social factors.” The Staff notes that the exclusion
criteria include fossil fuels. The Staff further notes that the strategy review included in the Fund’s Annual Report to Shareholders indicates that the utility company, AES Corp., detracted from the Fund’s performance, “partly caused
by the higher interest rate environment and partly by management nudging down guidance due to some project delays and complications of exiting its coal assets”. Please explain how this investment is in line with the Fund’s exclusionary
screening process disclosed in the prospectus.

 Response: The Registrant notes that the
exclusionary screen with respect to fossil fuels disclosed in the prospectus for Transamerica Sustainable Equity Income is defined as “engagement in the extraction of coal and oil.” AES Corp. (“AES”) passes this and all other
exclusionary screens of the Fund. More specifically, AES passes the fossil fuels criteria because the company is not engaged in the extraction of coal or oil. The reference noted in the strategy review included in the Fund’s Annual Report to
Shareholders refers to coal powered generation by AES, and coal powered generation is not one of the exclusionary criteria for the Fund, only coal extraction.

8.
 Comment: With respect to certain series of the Registrant, please supplementally explain why the
investment management fees payable in the Statement of Assets and Liabilities are relatively high when compared to the investment management fee expenses shown in the Fund’s Statement of Operations (for example, the Transamerica ClearTrack
2015). In addition, please explain supplementally whether the Notes to the Financial Statements include all related-party disclosures such as “terms of settlement” in connection with advisory and
sub-advisory arrangements. The Staff advises the Registrant to disclose significant elements of advisory and sub-advisory arrangements in the Notes to the Financial
Statements going forward, and in particular, that the sub-adviser is compensated by the investment adviser and not the Funds. See ASC 850-10-50-1 and January 21, 2020 AICPA Expert Panel Meeting Minutes.

 Response: The Registrant notes that the investment management fee expenses
shown in the Statement of Operations represent the gross management fees accrued throughout the respective Fund’s fiscal year, and do not reflect any waivers, reimbursements or recaptures by Transamerica Asset Management, Inc.
(“TAM”), the Funds’ investment manager. The investment management fees payable in the Statement of Assets and Liabilities for a Fund represents the fees payable by the Fund to TAM, net of any expenses waived and/or reimbursed by
TAM and including any amounts recaptured by TAM of previously waived and/or reimbursed expenses as allowed by the Fund’s expense limitation agreement. Investment management fees are computed daily and paid monthly. The amounts shown as
investment management fees payable in the Statement of Assets and Liabilities for a Fund were accrued during the final month of the Fund’s fiscal year and paid out of the Fund on the first business day of the subsequent fiscal year. In the case
of Transamerica ClearTrack 2015, the investment management fees payable shown in the Statement of Assets and Liabilities reflects the investment management fees as well as certain recaptures and smaller waivers by TAM that were accrued in October
2023.

 The Registrant believes the Notes to the Financial Statements include all required related-party disclosures with
respect to advisory and sub-advisory arrangements. Further, the Registrant notes that the “Organization” note contained in the Notes to the Financial Statements includes the following disclosure
related to the payment of sub-advisory fees, “TAM, not the Fund, is responsible for paying the sub-adviser(s) for their services, and
sub-advisory fees are TAM’s expense.”

9.
 Comment: The Staff notes that certain Funds invest significant amounts of their net assets in other
Funds. Please disclose how investors may obtain a copy of the financial statements of such underlying Funds. See IM-DCFO 1997-02.

Response: The Staff’s comment has been noted. Going forward, the Registrant will include disclosure within the
financial statements of applicable Funds regarding how investors may obtain a copy of an underlying Fund’s financial statements when a Fund invests a significant amount in one or more underlying Fund.

10.
 Comment: With respect to the tax reclaim amounts reported on the Statements of Asset and Liabilities
for Transamerica International Equity and Transamerica International Focus, please provide the country or countries that the tax reclaims pertain to, as well as an explanation of the Funds’ processes for monitoring the tax reclaims.

 Response: The Registrant notes that the tax reclaim amounts reported on the Statement of Asset
and Liabilities for Transamerica International Equity pertain to the following countries: Belgium, Switzerland, Germany, Denmark, Finland, France, United Kingdom, Japan, and Korea. The Registrant notes that the tax reclaim amounts reported on the
Statement of Asset and Liabilities for Transamerica International Focus pertain to the following countries: Austria, Switzerland, Germany, Denmark, Finland, France, United Kingdom, Italy, Japan, Korea, and Taiwan. TAM engages the Funds’
custodian, State Street Bank and Trust Company (“State Street”), to monitor and assist with the submission and processing of treaty-based reclaims, which includes providing required documentation and managing the process through State
Street’s automated proprietary Tax Reclaim System (“TRS”). TRS tracks the progress of all tax reclaim filings, monitors filed receivables, and provides reconciliations between State Street’s custody and accounting systems to
ensure the accuracy of reclaim accruals. TAM has also solicited the assistance of WTax to monitor and submit for European Court of Justice tax reclaims. TAM oversees and monitors the tax reclaim process in its entirety, including the review of
regular reporting from State Street and WTax.

11.
 Comment: The Staff notes that disclosure in the Note to the Financial Statements indicates that any
income recognized for European Court of Justice tax reclaims is reflected in “Other Income” in the Statement of Operations for certain Funds. Please confirm if such income is above 5% for any Fund, and if so, please disclose separately.
See Reg S-X 6-07-1.

Response: The Registrant notes that the amounts of income recognized for European Court of Justice tax reclaims during
the period covered by the report were $56,168 for Transamerica International Small Cap Value, $1,330,473 for Transamerica International Equity, and $62,515 for Transamerica International Growth. Such income was below 5% of total fund income for
each of these Funds.

12.
 Comment: With respect to Transamerica Emerging Markets Debt, please explain supplementally the reason
for the large due to custodian balance and cash overdraft amounts disclosed in the Financial Statements and discuss any related controls. Please include additional disclosure in the Financial Statements when a Fund has incurred overdraft expenses,
such as the average balance, the average number of days and the average interest rate incurred of the overdrafts.

Response: The large due to custodian balance reflected in the Financial Statements for Transamerica Emerging Markets
Debt was the result of certain cash transactions (two cash collateral transactions and two trade settlements) with a contractual settlement date prior to the period end date which had not been physically received in the Fund’s custody account
as of the period end date. On a daily basis, the Fund invests its available cash in an overnight repo. The overnight repo amount is determined from the cash balance in the accounting records which is normally based off of the contractual
settlement date of transactions. Due to the aforementioned cash transactions not physically settling into the custody account prior to the period end date, the amount invested in the overnight repo was more than the actual cash balance in the
custody account, resulting in the due to custodian balance and cash overdraft. As

a result of the Registrant’s oversight processes and discussions with State Street Bank and Trust Company, the Fund’s custodian, and the Fund’s
sub-adviser, the Fund did not bear overdraft fees as a result of this timing issue. The Registrant and the sub-adviser monitor cash availability and balances daily, as
well as potential impacts of any