SecProbe.io

CORRESP
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Attorneys and Counselors at Law

Daniel H. April

Of
Counsel

Patrick J. Dolan

David
F. Cunningham

John M. Hickey

C.W.N.
Thompson, Jr.

Megan Hadley Koehler *

* Not Admitted in NM

January 23, 2020

Via EDGAR
correspondence and E-Mail

Kimberly Browning

U.S. Securities
and Exchange Commission

Division of
Investment Management, Disclosure Review Office

100 F Street
N.E.

Washington,
D.C. 20549

    Re:
    Thornburg Investment Trust

    Registration Number under the Securities Act of 1933: 33-14905

    Registration Number under the Investment Company Act of 1940: 811-05201

Dear
Ms. Browning:

I
state below the above-referenced registrant’s responses to the comments received from the staff of the U.S. Securities and
Exchange Commission (“SEC”) on January 10, 2020 respecting post-effective amendment number 130 (“PEA 130”)
to the registrant’s Registration Statement on Form N-1A on November 29, 2019.

The
revisions to the registration statement that are described below are expected to be made in substantially the same form
described, in the registrant’s post-effective amendment which is expected to be filed on or about January 28, 2020. In
those instances where we identify disclosure items analogous to the items that were specific subjects of staff comments, and
the registrant responds to those comments by revisions to the disclosures referenced in staff comments, we expect to make
conforming revisions to the analogous disclosures.

Thornburg
Funds Prospectus

1.
Updates
to Information. The staff asked the registrant to confirm that incomplete information or information not available at
the time that PEA 130 was filed will be included in the next post-effective amendment to the registrant’s registration
statement.

Response.
The registrant will include in its next post-effective amendment, which is expected to be filed on or about January 28, 2020,
all required information omitted from PEA 130.

    460
    St. Michael’s Drive
    E-mail:
    dan_april@catchlaw.com
    Tel.:   (505)
    988-2900

    Suite
    1000
    Web
    address:  www.catchlaw.com
    Extension
    103

    Santa
    Fe, New Mexico 87505

    Fax:   (505)
    988-2901

    January 23, 2020
 Page 2

2.

Application of Rule 35d-1 to Investments in Other Investment Companies. The staff noted that portions of the registration
statement refer to the ability of the Funds to invest in other investment companies, including exchange traded funds (“underlying
funds”). The staff expressed the view that, if any Fund that invests in underlying funds has also adopted a policy to invest
at least 80% of its net assets in a particular type of investment in accordance with the requirements of rule 35d-1 under the Investment
Company Act of 1940 (the “Investment Company Act”), then the Fund should look through to the underlying funds’
holdings in assessing the Fund’s compliance with its 80% policy. The staff requested that the registrant disclose in its
registration statement if it follows this practice of looking through to the holdings of underlying funds.

Response. The registrant
is not aware of any legal or regulatory requirement that a fund look through to the holdings of underlying funds in assessing
the fund’s compliance with a policy adopted in accordance with rule 35d-1. The registrant also questions the practicality
of such an approach because, unless an underlying fund is affiliated with the acquiring fund, information about that underlying
fund’s holdings will generally only be available to the acquiring fund (and to other nonaffiliated investors) on a delayed
basis, meaning that the acquiring fund will not have current information to use in evaluating its compliance with a rule 35d-1
policy. In addition, such a practice would be of limited utility to the registrants’ Funds or their shareholders because
the only Funds to have adopted policies in accordance with rule 35d-1 are Thornburg Low Duration Municipal Fund, Thornburg Limited
Term Municipal Fund, Thornburg Intermediate Municipal Fund, Thornburg Strategic Municipal Income Fund, Thornburg California Limited
Term Municipal Fund, Thornburg New Mexico Intermediate Municipal Fund, Thornburg New York Intermediate Municipal Fund, and Thornburg
Limited Term U.S. Government Fund, none of which currently identify investments in underlying funds as a principal investment
strategy. The registrant therefore declines to adopt the practice described by the staff or to make revisions to its disclosures
at this time.

3.

Table of Contents. The staff noted that the reference to Appendix A in the prospectus’s table of contents
does not include the title of that Appendix, which is “Sales Charge Waivers Offered by Financial Intermediaries.” The
staff suggested that we modify the table of contents to include a reference to the title of Appendix A.

Response. The registrant
will add the title of Appendix A to the table of contents.

4.

Investment in Municipal Debt. The staff noted that if the Fund invests in any municipal obligations the principal
and interest of which are derived from a non-governmental entity, the Fund should look through to the industry in which that entity
operates for purposes of measuring the Fund’s compliance with its investment limitation against investing more than 25% of
the Fund’s total assets in the securities of companies whose principal business activities are in the same industry.

	Response. The
registrant acknowledges that, if the Fund invests in any municipal obligation the principal and interest of which is backed only
by the assets or revenues of a non-governmental entity, then the Fund would look through to the industry in which that non-governmental
entity operates to measure the Fund’s compliance with its 25% industry concentration limitation. In that regard, the registrant
notes the following disclosure, which already appears in the registrant’s statement of additional information in the discussion
of investment limitations applicable to the Thornburg Short Duration Municipal Fund and the Thornburg Strategic Municipal Income
Fund:

April,
                                         Dolan & Hickey, P.C.  Attorneys and Counselors at Law

    January 23, 2020
 Page 3

“The Fund currently views
municipal obligations backed by the credit of a governmental entity not to represent industries for purposes of this limitation
if the interest payable on those obligations is exempt from the regular federal income tax. Municipal obligations backed only by
the assets or revenues of non-governmental users are currently viewed by the Fund to be issued by non-governmental users for the
purposes of the limitation, so that the limitation would apply to those obligations. The Fund does not interpret this limitation
to prevent the investment of more than 25% of the Fund’s total assets in any one economic sector such as housing finance,
public housing, utilities, hospital and healthcare facilities or industrial development, or in any one state. The views and interpretations
by the Fund stated in this paragraph may change due to changes in the law or interpretations of the law, including laws pertaining
to municipal obligations and the taxability of interest paid on those obligations, and due to other factors.”

The registrant will add analogous disclosure
to the portions of the statement of additional information that discuss the investment limitations applicable to the registrant’s
other municipal bond Funds.

5.

Thornburg Short Duration Municipal Fund - Duration Example. The staff noted that the principal investment strategies’
disclosure of the Thornburg Short Duration Municipal Fund includes an example of an obligation with a duration of 2 years. The
staff suggested that the example be revised to show an obligation with a duration rate of 3 years, consistent with the outermost
number of years of the Fund’s range of duration.

Response. The registrant
will revise the example as requested.

In light of the staff’s
comment, the registrant has also determined to revise the disclosure about the Short Duration Municipal Fund’s duration to
state that the Fund will seek to maintain a dollar-weighted average duration of normally no more than three years, rather than
stating that the Fund’s dollar-weighted average duration will normally be within the range of zero to three years. The registrant
will make an analogous change to the disclosure for each of the Thornburg Limited Term Municipal Fund, Thornburg Intermediate Municipal
Fund, Thornburg California Limited Term Municipal Fund, Thornburg New Mexico Intermediate Municipal Fund, and Thornburg New York
Intermediate Municipal Fund. The registrant believes that disclosures identifying the upper end of a Fund’s dollar-weighted
average duration will be more helpful to investors than disclosure about a Fund’s duration range, and will also be consistent
with the staff’s suggested revisions to the language about the duration example.

April,
                                         Dolan & Hickey, P.C.  Attorneys and Counselors at Law

    January 23, 2020
 Page 4

6.

Thornburg Short Duration Municipal Fund - Average Duration. The staff noted that, for the Short Duration Municipal
Fund, the principal investment strategies’ disclosure states that “[t]here is no limitation on the duration or maturity
of any specific security the Fund may purchase.” The staff requested that the registrant disclose how the Fund may invest
in securities with no duration limit while maintaining a specific range of duration consistent with the Fund’s investment
strategy.

Response. The statement
referenced by the staff refers to the duration or maturity of individual securities. In contrast, the statements in the prospectus
pertaining to the dollar-weighted average duration or dollar-weighted average maturity of the Fund refer to the average duration
or maturity of the Fund’s portfolio as a whole. The Fund may purchase an individual security whose duration or maturity exceeds
the dollar-weighted average duration or maturity of the portfolio as a whole, provided that the purchase does not cause the dollar-weighted
average duration or maturity of the entire portfolio to exceed the stated level, under normal circumstances. The registrant believes
that the current disclosure on this topic is adequate.

7.

Thornburg Short Duration Municipal Fund. The staff observed that the Short Duration Municipal Fund’s principal
investment strategies stated that it “may invest up to 20% of its assets in taxable securities which would produce income
not exempt from federal income tax” due to market conditions. The staff inquired whether the income may be subject to the
Alternative Minimum Tax (“AMT”) as a principal risk of the Fund and requested that the Fund and other municipal bond
Funds include disclosure in accordance with Items 4 and Item 9 of Form N-1A if AMT is considered a principal risk of investing
in the Fund.

Response. The registrant
has determined that, at the current time, the risk that income from any of the municipal bond Funds’ investments may subject
an investor to AMT is not a principal risk of any such Fund. The registrant therefore does not believe it is necessary or appropriate
to add disclosure of that risk to the portions of the prospectus that are responsive to Items 4 or 9 of Form N-1A.

8.

Investments in Mortgage- and Asset-Backed Securities, Collateralized Mortgage Obligations (“CMOs”), and other
Structured Products. The staff noted that a number of the Funds include disclosure indicating that they may invest in mortgage-
and asset-backed securities, CMOs, and other structured products as a principal investment strategy. As to any such Fund, the staff
requested that the registrant provide the following information about those investments in the registrant’s written response
to the staff:

 • the percentage of each Fund’s net assets that are invested in those securities;

 • whether there are any limitations on the percentage of a Fund’s net assets that could be
invested in those securities or in any sub-set of those securities;

 • whether the Funds’ investments in these securities may include investments in “non-agency”
securities or in securities that are rated as non-investment grade; and

 • management’s assessment of the liquidity of those securities.

April,
                                         Dolan & Hickey, P.C.  Attorneys and Counselors at Law

    January 23, 2020
 Page 5

The staff also requested that the registrant
review the principal investment strategies and principal investment risks disclosures for those Funds that may invest in such securities
as a principal investment strategy, and confirm that those disclosures adequately describe the various types of mortgage- and asset-backed
securities, CMOs, and other structured products in which the Funds may invest, and the risks attendant to such investments.

	Response. In
response to the first part of the staff’s comment, please see Appendix A to this letter. For each Fund that may as
a principal strategy invest in mortgage-backed securities, asset-backed securities, CMOs, or other structured products, Appendix
A shows the percentage of the Fund’s net assets that were invested in those securities at the most recent fiscal year
end.

	With respect to whether
any of the Funds that may invest in mortgage-backed securities, asset-backed securities, CMOs, or other structured products as
a principal investment strategy have limitations on the percentage of a Fund’s net assets that could be invested in those
securities or in any sub-set of those securities, and whether any of those Funds could invest in “non-agency” securities
or in securities that are rated below investment grade, the registrant notes the following:

 • Thornburg Limited Term U.S. Government Fund is required to invest at least 80% of its net assets
in “U.S. Government Securities,” which the prospectus defines as securities backed by the full faith and credit of
the U.S. government and securities issued or guaranteed
by U.S. government agencies, instrumentalities or sponsored enterprises but not backed by the full faith and credit of the U.S.
government, and which may include repurchase agreements secured by those U.S. Government Securities and participations having economic
characteristics similar to those securities. While the remaining 20% of the Fund’s assets could be invested in securities
other than U.S. Government Securities, including potentially non-agency securities or securities that are rated below investment
grade, the Fund has typically not made any significant investment in non-agency securities or securities that are rated below investment
grade at the time of purchase and has no current intention to make any significant investment in those securities.

 • Thornburg Low Duration Income Fund is required to invest 100% of its net assets in obligations
of the U.S. government and its agencies and instrumentalities, and in debt obligations rated at the time of purchase in one of
the four highest ratings categories or, if no credit rating is available, judged to be of comparable quality by the Fund’s
advisor. There is no specific limitation on the percentage of the Fund’s assets that could be invested in non-agency mortgage-backed
securities, but such investments would have to fall within one of the four highest investment categories at the time of purchase,
and would be subject to the Fund’s other investment limitations, including limitations on concentration in any particular
industry or issuer, and a prohibition on purchasing a security if, as a result, more than 15% of the Fund’s net assets would
be invested in illiquid securities. As shown on Appendix A, only 7.7% of the Fund’s net assets were invested in non-agency
mortgage-backed securities at September 30, 2019.

 • Thornburg Limited Term Income Fund is required to invest at least 65% of its net assets in obligations
of the