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Wasatch Funds Trust

 [State Street Logo]

VIA EDGAR

 January 27, 2022

Ms. Kimberly Browning

 Securities and Exchange Commission

Investment Company Division

 100 F. Street, N.E.

Washington, DC 20549

Re:    Wasatch
 Funds Trust (“Registrant”)

File Nos. 033-10451,
811-04920

Dear Ms. Browning:

 This letter responds to
the comments on Post-Effective Amendment No. 118 to the Registrant’s registration statement on Form N-1A (“PEA 118”) on behalf of the Wasatch Core Growth Fund, Wasatch Emerging India Fund,
Wasatch Frontier Emerging Small Countries Fund, Wasatch Global Opportunities Fund, Wasatch International Growth Fund, Wasatch International Opportunities Fund and Wasatch Ultra Growth Fund filed on EDGAR on December 1, 2021 that were provided
to me by telephone initally on January 13, 2022 and supplementally on January 25, 2022 by the staff of the Securities and Exchange Commission (the “Staff”).

Summary Section of Prospectus – Fees and Expenses of the Fund – Core Growth Fund, Emerging India Fund, Frontier Emerging Small Countries
Fund, Global Opportunities Fund, International Growth Fund, International Opportunities Fund and Ultra Growth Fund

1.    Staff Comment (supplemental): A fund may disclose an expense reimbursement or fee waiver arrangement in the fee
table pursuant to Instruction 3(e) of Form N-1A. Please note that several funds have a footnote 1 regarding an expense reimbursement but do not have a line item in the fee table showing the expense
reimbursement. Please remove footnote 1 if the Fund does not have a line item for an expense reimbursement.

 Response: Footnote 1 will be
removed for Core Growth Fund, Emerging India Fund, International Growth Fund and International Opportunities Fund.

 Summary Section of Prospectus
– Principal Strategies – Core Growth Fund

 2.    Staff Comment: The first paragraph of this section
states that “The Fund invests primarily in smaller growing companies at reasonable prices.” Please define and explain in Plain English the term “smaller growing companies”.

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 Response: The term “smaller growing companies” is defined below for the Core Growth Fund
and such term is only used for the Core Growth Fund. Registrant will replace the second paragraph of the summary titled “Principal Strategies” with the following:

Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of
smaller growing companies. We consider these companies to be companies we believe have typically exhibited consistent growth in earnings per share and that are relatively small, with minimum market capitalizations of $100 million and up to a
maximum market capitalization at the time of purchase of $5 billion or the market capitalization of the largest company in the Russell 2000® Index as of its most recent reconstitution
date, whichever is greater. The Russell 2000 Index reconstitution date is typically each year on or around July 1. As of the 2021 reconstitution date, the market capitalization of companies included in the Russell 2000 Index ranged from
$128.1 million to $27.1 billion. The market capitalization of the largest company in the Russell 2000 Index is subject to change at its next reconstitution date.

3.    Staff Comment: The second paragraph of this section states that “Under normal market conditions, we will
invest the Fund’s net assets primarily in the equity securities of smaller growing companies. The companies in which the Fund invests usually have market capitalizations, at the time of purchase, that are less than the larger of $5 billion
or the market capitalization of the largest company in the Russell 2000 Index as of its most recent reconstitution date. As of the 2021 reconstitution date, the market capitalization of the largest company in the Russell 2000 Index was
$27.1 billion. The market capitalization of the Russell 2000 Index is subject to change at its next reconstitution date.”

(a)
 Please specify what type of equity securities the Fund will invest in and revise principal risks accordingly.

(b)
 Please provide a range for the market capitalization for the indices and a range for the market capitalization size
the Fund may invest including the minimum capitalization range the Fund may invest in.

(c)
 Please indicate the date the index is reconstituted or how often the index is reconstituted.

(d)
 The statement “that are less than the larger of $5 billion or the market capitalization of the largest
company in the Russell 2000 Index as of its most recent reconstitution date” is confusing. Please explain and clarify disclosure.

(e)
 Does the Fund invest in micro-cap companies? If yes, please revise disclosure
in principal strategies and principal risks accordingly to reflect investments in micro cap companies.

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 Response: See the response to Comment 2, above. Registrant has modified the disclosure to:

(a)
 clarify that equity securities are typically common stock and the risk disclosure for equity securities includes the
risks for common stock;

(b)
 clarify the market cap range for the index and the minimum and maximum range of potential investments for the Fund
(the minimum market cap is not tied to the index);

(c)
 include the reconstitution date of the index;

(d)
 clarify the maximum market cap test that will be used; and

(e)
 the Fund does not intend to invest a significant portion of its assets in micro cap stocks, so no additional strategy
or risk disclosure related to micro cap stocks is necessary.

 4.    Staff Comment: The third
paragraph of this section states: “The Fund may invest up to 20% of its total assets at the time of purchase in securities issued by foreign companies in developed markets, emerging markets, or frontier markets. Securities issued by companies
incorporated outside the United States whose securities are principally traded in the United States are not defined as foreign companies and are not subject to this limitation.”

The sixth paragraph of this section states: “The Fund may invest a large percentage of its assets in a particular region or market, including
Europe and the United Kingdom.”

 According to the Annual Report filed on Form N-CSR filed by EDGAR on
December 3, 2021, the Core Growth Fund currently invests 92.1% of its assets in United States, 1.8% of its assets in Argentina, 3.0% of its assets in Ireland and 3.1% of its assets in Israel. The Fund invests less than 10% of its assets in
foreign issuers.

(a)
 Based on investments in the latest Annual Report, are investments in foreign companies a principal strategy?

(b)
 Also, are investments in Europe and the United Kingdom (“U.K.”) a principal strategy?

(c)
 If foreign companies is a principal strategy, please define foreign companies including developed markets, emerging
markets, or frontier markets. Please include the types of securities for foreign companies. This disclosure can be included in response to Item 9 of Form N-1A .

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 Response:

(a)
 As we may invest up to 20% of the Fund’s assets in the securities of foreign companies, we consider the
investments in foreign securities to be a principal strategy and such potential exposure to be a principal investment risk associated with the Fund that should be disclosed.

(b)
 Although the Fund may invest in foreign companies of any country, including countries of Europe and the U.K., given
the limited exposure at this time, the reference to Europe and the U.K. has been removed from the summary and disclosure added in response to Item 9 that exposure to Europe and the U.K. is not a principal risk for the Fund at this time.

(c)
 As the Fund is permitted to invest in the securities of companies incorporated in any
non-U.S. country and is not focused on any particular market region (developed, emerging or frontier), we have revised the disclosure to note that the Fund may invest up to 20% of the Fund’s total assets
in the equity securities (typically common stock) of foreign companies (companies that are incorporated in any country outside the United States and whose securities principally trade outside the United States). Securities issued by companies
incorporated outside the United States whose securities are principally traded in the United States are not defined as foreign companies and are not subject to this limitation. The disclosure in response to Item 9 further has been revised to note
that exposure to emerging markets or frontier markets is not a principal risk of the Fund at this time.

 Summary Section of
Prospectus – Fees and Expenses of the Fund – Core Growth Fund, Emerging India Fund, Frontier Emerging Small Countries Fund, Global Opportunities Fund, International Growth Fund, International Opportunities Fund and Ultra Growth Fund

 5.    Staff Comment (applicable to all Funds): Please add disclosure in principal strategies regarding
specific currencies the Fund will invest in and a corresponding currency risk in the principal risks.

 Response: The Registrant understands
that the Staff has requested that a Fund include disclosure regarding a Fund’s use of foreign currency and whether such currency is U.S. dollar denominated or foreign and that the Staff objects to the applicable Fund not including such
disclosure in its principal strategies.

 However, each Fund (Core Growth Fund, Emerging India Fund, Frontier Emerging Small Countries Fund,
Global Opportunities Fund, International Growth Fund, International Opportunities Fund and Ultra Growth Fund) does not have a principal strategy to invest in a particular foreign currency. A Fund will engage in foreign currency
transactions from USD to the local currency or vice-versa to the extent necessary to execute purchase or sale

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transactions. The currency risk disclosure is a general risk associated with investing in foreign securities regardless of the specific currency exchanged for a transaction, and expressly states
that a Fund may invest in foreign currencies to the extent necessary to effect foreign securities transactions and describes the risks associated with that activity. Although the foreign securities risk disclosure already included currency risk, we
have clarified and revised the currency risk to state:

 More specifically, changes in currency exchange rates will affect the value
of non-U.S. securities, the value of dividends and interest earned from such securities and gains and losses realized on the sale of such securities. The value of an investment denominated in a foreign
currency will decline in U.S. dollar terms if that currency weakens against the U.S. dollar. The Fund may be invested in the local currency of a foreign country in connection with executing foreign securities transactions. When the Fund executes the
securities transactions, there is the risk of the value of the foreign currency increasing or decreasing against the value of the U.S. dollar. While the Fund is permitted to hedge currency risks, the Advisor does not anticipate doing so at this
time.

 6.    Staff Comment (applicable to all Funds): Please delete the word “generally” from the
principal strategies.

 Emerging India Fund - The second paragraph of this section states that “We will generally consider qualifying
investments to be in companies that are listed on an Indian exchange, that have at least 50% of their assets in India, or that derive at least 50% of their revenues or profits from goods produced or sold, investments made, or services performed in
India.”

 Frontier Emerging Small Countries Fund – The fifth paragraph of this section states that “We will generally consider
qualifying investments to be in companies that are listed on a securities exchange in a frontier market or small emerging market country, that are legally domiciled in a frontier market or small emerging market country, that have at least 50% of
their assets in a frontier market or small emerging market country, or that derive at least 50% of their revenues or profits from goods produced or sold, investments made, or services provided in a frontier market or small emerging market
country.”

 Response: The Registrant will delete the word “generally” as requested.

Summary Section of Prospectus – Principal Strategies – Emerging India Fund

7.    Staff Comment: The second paragraph of this section states that “We will generally consider qualifying
investments to be in companies that are listed on an Indian exchange, that have at least 50% of their assets in India, or that derive at least 50% of their revenues or profits from goods produced or sold, investments made, or services performed in
India.”

 5

 Please confirm supplementally the economic test used to determine an investment in India. Is it one test or
more than one test?

 Response: Please note that word “generally” has been deleted (see Response 6 above). The Indian holdings in
the Emerging India Fund are usually listed on an Indian exchange. Indian securities listed on an Indian exchange will be considered qualifying for the purposes of compliance with the names rule. However, if there are Indian companies that are not
listed on an Indian exchange (such as those that may be listed on the London exchange), we would consider the other criteria noted above to help analyze whether a security is economically tied to India (with no particular factor controlling)
consistent with the Adopting Release of Rule 35d-1 (see footnotes 24 and 25 and related text).

8.    Staff Comment: The fourth paragraph in the section states: “The Fund may also invest in companies domiciled
in developed, emerging and frontier markets.”

 According to the Annual Report filed on Form N-CSR filed
by EDGAR on December 3, 2021, the Emerging India Fund currently invests 100% of its assets in India.

 Is the fourth paragraph applicable
where 100% of the Fund’s assets are invested in India? What other countries does the Fund invest in? This disclosure could be considered misleading. If not applicable, please revise principal investment strategies and principal risks,
accordingly.

 Response: India is currently considered an emerging market. Although the Emerging India Fund must invest at least 80% of its
net assets in securities tied economically to India, the Fund may invest in countries outside of India with respect to its 20% bucket. Nevertheless, Registrant will eliminate the line in the summary and revise the disclosure in response to Item 9
that the Emerging India Fund may invest in foreign countries other than India but such exposure is not considered a principal risk at this time. Further, the disclosure in Item 9 will note that investments in frontier markets is not a principal risk
for the Fund at this time.

 Summary Section of Prospectus – Principal Strategies – Frontier Emerging Small Countries Fund

9.    Staff Comment: The third paragraph in the section states: ““Frontier markets” include any country
that is outside the Morgan Stanley Capital International (MSCI) All Country World Index, and also any country that is currently included in the Russell Frontier Index, the S&P Frontier Broad Market Index (BMI), the MSCI Frontier Markets Index,
or similar market indexes, or any country that, in our opinion, has similar characteristics regardless of its inclusion in an index.”

(a)
 Please add the Adviser to the third paragraph. The Advisor considers “frontier markets” to include…

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(b)
 The last part of the sentence “, or similar market indexes, or any country that, in our opinion, has similar
characteristics regardless of its inclusion in an index” is overly broad. Please revise for clarity.

 Response:

(a)
 The modification will be made that “We consider “foreign markets” to include….

(b)
 We note that although some countries, currently Argentina, for example, may be considered a frontier market, it is not
presently included in the specified indices and therefore the Fund cannot be reliant only on inclusion in a fronti