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CORRESP

 One International Place, 40th Floor

 100 Oliver
Street

 Boston, MA 02110-2605

 +1 617 728 7100 Main

+1 617 426 6567 Fax

 www.dechert.com

EDWIN BATISTA

edwin.batista@dechert.com

 +1 617 728 7165 Direct

+1 617 275 8364 Fax

 February 21, 2023

 VIA
ELECTRONIC TRANSMISSION

 Securities and Exchange Commission

100 F Street, NE

 Washington, DC 20549

Re:
 Harbor Funds (the “Registrant”)

Post-Effective Amendment No. 170

(File Nos. 333-5852 and 811-4676)

Ladies and Gentlemen:

 This correspondence is
being filed for the purpose of responding to comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided by Ms. Kimberly Browning of the Division of Investment Management with
respect to Post-Effective Amendment (“PEA”) No. 170 to the Registrant’s registration statement on Form N-1A. PEA No. 170 was filed in connection with certain changes being made to Harbor
Convertible Securities Fund (the “Fund”).

 Set forth below are the Staff’s verbal comments together with the
Registrant’s responses. Terms used but not defined herein have the same meaning as in PEA No. 170.

COMMENT 1:

 (Prospectus and SAI)

The Staff reminds the Registrant that it and its management are responsible for the accuracy and adequacy of the Registrant’s disclosures, notwithstanding
any review, comments, action or absence of action by the Staff.

Response:

The Registrant acknowledges this statement.

 February 21, 2023

 Page 2

COMMENT 2:

 (Prospectus and SAI)

The Staff notes that the comments apply to similar disclosures throughout, as applicable.

Response:

The Registrant acknowledges this statement and has responded accordingly.

COMMENT 3:

 (Prospectus and SAI)

Please confirm that the Registrant’s Rule 485(b) filing will be complete (i.e., all bracketed/blank information will be completed).

Response:

The Registrant confirms that its Rule 485(b) filing will be complete.

COMMENT 4:

 (Prospectus and SAI)

If the Registrant determines to decline a comment, please explain why in a response letter and include well-reasoned and detailed legal analysis in support of
the Registrant’s views.

Response:

The Registrant acknowledges this request and has responded accordingly.

COMMENT 5:

 (Prospectus and SAI)

The Staff notes that the Registrant is making material changes to the Fund, including changes to its principal investment strategy, risks and subadviser. With
respect to the changes in the Fund’s, strategy, risks and subadviser, please supplementally explain why the Board of Trustees (“Board” or “Trustees”) believes these changes are consistent with its fiduciary duty and in the
best interest of shareholders who did not vote for these changes. Describe the information the Board considered and how it weighed the information in arriving at its position.

Response:

The Registrant notes that a meeting of the Board was held on November 13-14, 2022, at which the Board considered the proposed changes to the Fund’s investment strategy, risks and
subadviser. In considering the approval of these matters, the Trustees evaluated a number of factors relevant to their determination. They did not identify any single factor as all-important or controlling,
and individual Trustees did not necessarily attribute the same weight or importance to each factor.

 February 21, 2023

 Page 3

 The Board considered that, given the lack of a reasonable, viable commercial growth path for the Fund due to underperformance of the Fund
relative to its peers and benchmark index over the long-term, Harbor Capital determined that a change in subadviser would better enable the Fund to fulfill Harbor Capital’s goal of offering a vibrant, competitively priced, actively managed Fund
that could serve shareholders over the long term and gain additional traction in the marketplace. The Board further considered that Harbor Capital believes that the hiring of BlueCove Limited (“BlueCove”) offers the Fund and its
shareholders the opportunity for attractive risk-adjusted returns over the long term. The Board further considered that Harbor Capital believes that BlueCove’s record as a strong partner to Harbor Capital would place the Fund in a better
position to continue to grow and remain viable for shareholders over the long term.

The Trustees considered that, in considering potential replacement subadvisers, Harbor Capital conducted research on asset managers across the fixed income
universe and also relied on knowledge built from its ongoing monitoring of BlueCove, as an existing Harbor Funds subadviser, and other comparable managers. That research led to the identification of BlueCove as a firm in which Harbor Capital has a
high degree of investment conviction. Harbor Capital believes that BlueCove will provide the investment approach needed to help the Fund become both sustainable and vibrant over the long term. At a meeting held on November 13-14, 2022, the Trustees received presentations by (i) Harbor Capital regarding its recommendation, and (ii) BlueCove regarding the firm’s experience, investment philosophy and process, operational
and trading capabilities, and BlueCove’s proposed approach to managing the Fund’s assets, among other things.

The Trustees considered that, in connection with the changes, the contractual rate of the advisory fee payable by the Fund to the Adviser would be reduced from
0.65% to 0.50% annually as a percentage of the Fund’s average daily net assets.

As a result of their deliberations, the Board determined to approve the proposed changes. The Board believes these changes are consistent with its fiduciary
duty and in the best interest of shareholders because the changes are designed to lower fees for shareholders while continuing to provide investors with a convertible securities strategy in which the Adviser has a high degree of investment
conviction.

 February 21, 2023

 Page 4

The Board also noted that shareholders would be provided with approximately three months of notice before the transition of the Fund would take place. The Board noted that this notice period would afford shareholders a substantial
opportunity to carefully evaluate the proposed new direction of the Fund before making a decision as to whether to redeem or remain in the Fund prior to the Fund actually converting to its new approach.

COMMENT 6:

 (Prospectus and SAI)

Please supplementally explain why the Adviser believes these changes are consistent with its fiduciary duty.

Response:

The Adviser believes these changes are consistent with its fiduciary duty for the same reasons discussed above with respect to the Board.

COMMENT 7:

 (Prospectus and SAI)

The Staff notes supplements to the Fund’s summary prospectus, prospectus and statement of additional information were filed via EDGAR on December 1,
2022. Please supplementally confirm if these supplements were mailed to shareholders. Please further describe if there was another form of notice of these changes provided to shareholders.

Response:

The summary prospectus supplement was distributed to shareholders on December 1, 2022, via mail or electronically, depending on how each particular shareholder typically receives fund documents consistent with relevant
Commission guidance. In addition to the foregoing, the Registrant distributed an information statement to shareholders on December 10, 2022, electronically, and on December 16, 2022, via mail, containing information about the new
subadvisory agreement and the factors considered by the Board in approving the agreements.

 February 21, 2023

 Page 5

COMMENT 8:

 (Prospectus and SAI)

Please explain what percentage of the Fund’s portfolio will be repositioned as a result of these changes.

Response:

Approximately 75% of the Fund’s portfolio will be repositioned in connection with the subadviser change.

COMMENT 9:

 (Prospectus and SAI)

Please confirm whether any shareholders have contacted the Registrant or any intermediaries regarding the changes. Please describe the nature of
communications, including whether anyone has expressed displeasure or disagreement with the planned changes or threatened legal action.

Response:

The Registrant confirms that as of the date of this letter, no shareholders have contacted the Registrant regarding the proposed changes. The Registrant is not aware of shareholders contacting intermediaries about the
change.

COMMENT 10:

 (Prospectus – Fund Summary – Principal Investment Strategy)

 The “Principal Investment Strategy” section for Harbor Capital Appreciation
Fund states that “[a]s part of its investment process, the Subadviser considers environmental, social and governance (“ESG”) factors that it believes may have a material impact on an issuer and the value of its securities. As a
result, the key ESG considerations may vary depending on the industry, sector, geographic region or other factors and the core business of each issuer.” Please explain if this disclosure is meant to apply to all investments made by Harbor
Capital Appreciation Fund. If so, please disclose that an investment could be made in a company by Harbor Capital Appreciation Fund that scores poorly on ESG criteria if it scores well on other criteria.

Response:

The Registrant has added risk disclosure to address this comment as set forth in Comment 11 below.

COMMENT 11:

 (Prospectus – Fund Summary – Principal Risks)

Please consider adding attendant Item 4 risk disclosure pertaining to ESG investing for Harbor Capital Appreciation Fund or explain to the Staff why such
disclosure is not necessary.

 February 21, 2023

 Page 6

Response:

 The Registrant has incorporated this comment by adding the following disclosure to the “Principal Risks” section for Harbor Capital
Appreciation Fund:

 ESG Factors Risk: The consideration of ESG factors by the
Subadvisor and/or Advisor, as applicable, could cause the Fund to perform differently than other funds. ESG factors are not the only consideration used by the Subadvisor and/or Advisor, as applicable, in making investment decisions for the Fund and
the Fund may invest in a company that scores poorly on ESG factors if it scores well on other criteria. ESG factors may not be considered for every investment decision.

COMMENT 12:

 (Prospectus – Fund Summary – Principal Investment Strategy)

 The “Principal Investment Strategy” section for the Fund states that
“convertible securities include corporate bonds, preferred stocks and other types of securities that are convertible into common stock or its equivalent value.” Please delete the phrase “other types of securities,” and any
similar vague terms, from the principal investment strategy description for the Fund and confirm that the Fund is in compliance with Item 4(a) of Form N-1A.

Response:

 The Registrant has incorporated this comment by revising the disclosure as follows:

 “These convertible securities include corporate bonds,
and preferred stocks and other types of securities that are convertible into common stock or its equivalent value.”

 Additionally, the Registrant confirms that the Fund is in compliance with Item 4(a) of
Form N-1A.

COMMENT 13:

 (Prospectus – Fund Summary – Principal Investment Strategy)

 The Staff feels that the disclosure describing the Subadviser’s investment approach
for the Fund is jargon-laden and vague. Please revise this disclosure to describe the Subadviser’s investment approach in plain English.

Response:

The Registrant has incorporated this comment by revising the disclosure as set forth in the screenshot below:

 February 21, 2023

 Page 7

 Principal Investment Strategy

Under normal market conditions, the Fund invests at least 80% of its net assets, plus borrowings for investment purposes, in a diversified portfolio of
convertible securities.

 Convertible securities are “hybrid” securities
that possess both fixed income and equity characteristics. These convertible securities include corporate bonds,; and preferred stocks and other types
of securities that are convertible into common stock or its equivalent value. A convertible security generally performs more like a common stock when the
price of the underlying stock is closer to or above the conversion price because it is more likely that the convertible security will be converted into stock. A convertible security generally performs more like a bond when the price of the
underlying stock is well below the conversion price because it is more likely that the convertible security will mature without being converted. While the Fund has broad discretion to invest in all types of convertible securities, the Fund
focuses primarily on investmentsprimarily invests in convertible bonds, which may be unrated, or may have ratings assigned by credit rating agencies, including below investment-grade ratings (known as
“junk bonds”). To assess the quality of unrated securities, the Subadviser evaluates an issuer’s probability of default using a proprietary default probability model that considers multiple variables, including capital
structure of the firm, asset volatility, and annual cash outflows of interest and dividend payments. The Fund invests primarily in U.S. dollar denominated securities, including those of foreign issuers; however, the Fund may invest in securities
denominated in other currencies.

 The Subadvisor follows a structured investment
process based on the testing of investment hypotheses using historical data. The Subadvisor’s investment process utilizes proprietary quantitative models to produce investment recommendations. The Subadvisor’s portfolio management team
retains discretion with respect to all investment decisions. The Subadvisor generates proprietary insights based on its experience and reasoned intuition to form an investment hypothesis. Insights are a means to express isolated drivers of returns
that the Subadvisor believes are likely to generate excess returns over time.

The Subadvisor follows a
structured investment process based on the testing of investment hypotheses using historical data. The
Subadvisor’s investment process utilizes proprietary quantitative models to produce investment
recommendations. The Subadviser’s portfolio management team retains discretion with respect to all investment decisions. The Subadviser generates properietary insights based on its experience and reasoned
intuition to form an investment hypothesis. Using historical market data, the SubadviserSubadvisor back-tests each investment hypothesis to determine whether actual observations
appear consistent with the hypothesis over time. The Subadviser’s back testing process involves the development of research parameters, internal peer review, and consideration of a wide range of analyses.
Insights are weighted in the SubadviscrSubadvisor’s models according to their deemed strength in predicting returns, as determined by the
SubadviserSubadvisor through this testing process. In managing the Fund, the SubadviserSubadvisor will rely on insights that seek to target
idiosyneratic company and security specific risk, which form the basis of security selection decisions and assess metrics such as company strength, company outlook, and valuation.
The SubadviserSubadvisor’s models consider data from multiple sources, including issuer specific information such as company cash flow, default risk, earnings expectations, and price volatility.

 The
SubadviserSubadvisor expects that the majority of the Fund’s total returns will be generated from security selection of convertible securities.
Positions are sized based on an optimization which aims to effectively translate the
insights gleaned from the Subadviser’s
proprietary models into portfolio positions. The SubadviserSubadvisor’s optimization process
seeks to maximize total returns while minimizing expected risk and transaction costs. The SubadviserSubadvisor measures risk at the portfolio level and on each instrument. Fur