SecProbe.io

CORRESP
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filename1.htm

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

March 13,
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 March 9, 2020, respecting post-effective amendment number 143 to the registrant’s
registration statement under the Investment Company Act of 1940, filed on Form N-1A on January 31, 2020 and relating to the Thornburg
Capital Management Fund (the “Fund”).

1.

Principal
Investment Risks. Noting that the registrant has added references to the Fund’s investments in certificates of deposit,
short-term commercial paper, unsecured bank promissory notes, and bankers’ acceptances to the Fund’s principal investment
strategies disclosure, the staff requested that the registrant add attendant risk disclosures regarding those types of securities
to the disclosures of the Fund’s principal investment risks.

Response.
The registrant has considered the staff’s comment and determined that the Fund’s principal investment risk disclosures
adequately describe the risks to which the Fund’s portfolio as a whole is subject and the circumstances reasonably likely
to affect the Fund’s net asset value, yield, and total return, including the principal risks arising from the Fund’s
investments in certificates of deposit, short-term commercial paper, unsecured bank promissory notes, and bankers’ acceptances.
The registrant has reviewed the risks applicable to each of those investments to evaluate whether any of those investments present
unique risks that rise to the level of a principal risk and that are not already referenced in the existing disclosures, and has
determined that the existing disclosure about the Fund’s principal risks is sufficient and fulfills the requirements of
Form N-1A.

2.

Principal
Investment Risks. The staff reiterated its previous request that the registrant re-order the principal risks in order of significance
to the Fund. The staff referred the registrant to the transcript of a speech delivered by Dalia Blass, Director of the SEC Division
of Investment Management, at the ICI Securities Law Developments Conference on October 25, 2018.

    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

Ms. Kimberly Browning

March 13, 2020

Page 2

Response.
The registrant again respectfully declines to make the requested change. The registrant is not aware of any requirement in
Form N-1A that a fund’s principal risks be set forth in any particular order, and believes that the current risk
disclosure is presented in a manner that clearly identifies the Fund’s key risks to the Fund’s investors and
potential investors. The registrant also notes that the significance of a particular risk is fluid and will necessarily vary
over time, and at times may vary from day to day, in response to changes in the composition of the Fund’s portfolio and
developments affecting particular issuers or the overall market. As a result, the registrant believes that ordering the risk
disclosure in the manner suggested may at any given point in time misrepresent the significance of a particular risk, which
may confuse or mislead shareholders, who may not otherwise understand that the significance of the Fund’s risks is
fluid and likely to change over time.

3.

Principal
Investment Risks. The staff observed that the “Market and Economic Risk” disclosure in the Fund’s principal
investment risks indicates that a significant portion of the Fund’s assets may be invested in issuers that are economically
exposed to one country, state, territory, or region, such as a particular U.S. territory or possession. The staff requested that
the registrant confirm supplementally that the Fund is not principally invested in a particular country, state, territory, or
region; and to the extent that the Fund is currently invested principally in a particular country, state, territory, or region,
that disclosure regarding those countries, states, territories or regions be added to the Fund’s principal investment strategies
and that the Fund modify the disclosures relating to the Fund’s principal investment risks to identify any specific principal
risks attendant to investments in those countries or regions.

Response.
The registrant confirms that the Fund is not currently principally invested in a particular country, state, territory, or region.

4.

Pricing
of Fund Shares. The staff asked the registrant to confirm whether the Fund is currently investing in securities that are primarily
listed on foreign exchanges that trade on weekends or other days when the Fund does not price its shares.

Response.
The registrant confirms that there have been no changes and the Fund’s investments in foreign bank obligations, obligations
of foreign governments and their agencies and instrumentalities, and obligations of foreign companies does not result in the Fund
currently being invested in securities that are primarily listed on foreign exchanges that trade on weekends or other days when
the Fund does not price its shares.

Other
Matters

Please
contact me or Meg Koehler with any questions. We appreciate the staff’s time and attention to our filings.

    Sincerely,

    /s/ Daniel April

    Daniel April

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