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Attorneys and Counselors at Law

    Daniel H. April

    Of Counsel

    Patrick J. Dolan

    David F. Cunningham

    Megan H. Koehler

March 24, 2023

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 1, 2023 respecting post-effective amendment number 147 (“PEA 147”) to the registrant’s Form N-1A registration
statement (the “Registration Statement”) applicable to the Thornburg Emerging Markets Managed Account Fund (the “Emerging
Markets Managed Account Fund”) and Thornburg Municipal Managed Account Fund (the “Municipal Managed Account Fund”) (each,
a “Fund,” and together, the “Funds”), filed via EDGAR on January 13, 2023 (Accession No. 0001387131-23-000305).

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 March 31, 2023 (hereinafter, the “485B Filing”). 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.

General Comments

1.    The staff asked the registrant to acknowledge the staff’s pronouncement on October 5, 2016,
that the registrant and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or absence of action by the staff.

Response: The registrant
and its management acknowledge their responsibilities related to the Registration Statement disclosure.

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

    Suite 603
    Website: www.catchlaw.com
    Extension 103

    Santa Fe, New Mexico 87505

    Fax: (505) 988-2901

March 24, 2023

Page 2

2.    The staff asked the registrant to confirm that incomplete information or information not available
at the time PEA 147 was filed will be included in the next post-effective amendment to the Registration Statement.

Response: The registrant
will include in the 485B Filing all required information omitted from PEA 147.

Prospectus Comments

3.    The staff asked the registrant to explain whether the example amounts listed under Form N-1A Item
3 for the Funds for years 1 and 3 will reflect the waiver, payment or expense reimbursement agreement described in footnote 3 of each
Fund’s fee table. The staff also asked the registrant to clarify in the preamble to that expense example that the example does not
reflect any charges imposed by the applicable separately managed accounts (“SMAs”) through which the Funds are sold, and that
if such charges were reflected, the amounts shown in the example would be higher.

Response: The registrant
confirms that the fee waiver, payment or expense reimbursement arrangement between Thornburg Investment Management, Inc. (the “Advisor”),
Thornburg Securities Corporations and the registrant will apply during all years of the Funds’ existence, and the registrant will
revise the preamble language in the examples to remove the reference to the fee waivers and expense reimbursements being effective only
“in the first year.” The registrant will also revise the preamble language to disclose that the examples do not reflect any
charges that are imposed by the applicable SMAs and that, if those charges were reflected, the amounts shown in the example would be higher.

4.    The staff noted the Emerging Markets Managed Account Fund may seek to invest in companies’
equity securities through initial public offerings (“IPOs”) as part of its Item 9 of Form N-1A disclosure; however, the Fund
does not include correlating summary disclosure of the Fund’s investments in IPOs as part of its Form N-1A Item 4 principal investment
strategy disclosure. The staff requested that if investments in IPOs are a principal strategy of the Fund, disclosure be added to that
effect in the discussion of the Fund’s principal investment strategies. Alternatively, the staff noted that if investments in IPOs
are not a principal strategy of the Fund, then the registrant should consider moving the description of such investments from Item 9 to
the Fund’s statement of additional information (“SAI”) in accordance with Item 16(b) of Form N-1A.

Response: The registrant
respectfully submits that the current disclosure is appropriate and in compliance with the requirements of Form N-1A. The registrant notes
that investments in equity securities are part of the principal investment strategies of the Fund, but while IPOs are one type of equity
security, IPO investments are not expected to be a principal investment strategy of the Fund when it commences investment operations,
and the registrant believes it would be misleading to suggest to the Fund’s potential investors that the Fund pursues a strategy
which focuses on investing principally in IPOs.

5.    The staff noted the Emerging Markets Managed Account Fund’s Form N-1A Item 9 disclosure under
the sub-section “Investing in Stocks and Other Equity Securities” lists various types of equity securities in which the Fund
may invest, including common stocks, preferred stocks, convertible securities, warrants, sponsored or unsponsored American Depositary
Receipts, European Depositary Receipts, and Global Depositary Receipts, partnership interests (including interests in master limited partnerships,
private equity firms, and other public and private issuers organized as partnerships), shares in exchange traded funds and other investment
companies, and publicly traded real estate investment trusts. The staff noted that if investments in any of those types of equity securities
are not expected to be a principal investment strategy of the Fund, the registrant should consider moving the description of such investments
from Item 9 to the SAI into the Statement of Additional Information in accordance with Item 16(b) of Form N-1A. The staff also asked the
registrant to confirm supplementally whether the Fund expects to allocate more than 15% of its net assets to the types of partnership
interests mentioned in the referenced disclosure.

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

March 24, 2023

Page 3

Response: The registrant
respectfully submits that the current disclosure is appropriate and in compliance with the requirements of Form N-1A. The registrant notes
that investments in equity securities are part of the principal investment strategies of the Fund, and while the various types of equity
securities listed in the referenced disclosure are each one type of equity security in which the Fund may invest, such investments are
not individually expected to be a principal investment strategy of the Fund when it commences investment operations, and the registrant
believes it would be misleading to suggest to the Fund’s potential investors that the Fund pursues a strategy which focuses on investing
principally in each particular type of equity security. In addition, the registrant confirms the Fund does not expect to allocate more
than 15% of its net assets to the types of partnership interests described and has deleted the reference to such investments from the
Item 9 disclosure.

6.    The staff observed that the Funds’ names include the term “Managed Account” and
asked the registrant to consider adding language defining the meaning of “Managed Account” to the Funds’ Form N-1A Item
4 disclosure.

Response: The registrant
notes that the disclosure in response to Item 6 of Form N-1A, under the heading “Purchase and Sale of Fund Shares,” already
references the fact that the Funds’ shares are available exclusively within separately managed accounts, and that similar disclosure
appears in the disclosures that are responsive to Items 11(b) and (c) of Form N-1A. Given the existence of those other disclosures, because
the term “Managed Account” does not relate to any particular type of investments to be made by the Funds, and because shares
of the Funds will only be held by investors who have already executed agreements to open separately managed accounts through which the
Funds will be offered, the registrant does not feel that it is necessary to add a definition of the term “Managed Account”
within the Item 4 disclosure, and therefore respectfully declines the staff’s comment..

7.    The staff requested that the registrant add to the Emerging Markets Managed Account Fund’s
Form N-1A Item 4 principal investment strategies disclosure regarding any specific allocation strategy that the Fund may have toward particular
countries, as well as attendant risk disclosure to the Fund’s principal investment risks.

Response: The registrant
confirms that the Fund does not have any specific allocation strategy for any particular countries.

8.    The staff noted that in the Emerging Markets Managed Account Fund’s Form N-1A Item 4 principal
investment strategies disclosure, the Advisor identifies what it considers to be emerging markets based upon its own analysis of measures
of industrialization, economic growth, population growth and other factors. The staff stated its view that the terms “population
growth” and “other factors” are overly broad and vague and asked the registrant to clarify and revise the noted disclosure.

Response: The registrant
has determined to remove the sentence in which the referenced disclosure appears. Instead, the disclosure respecting what constitutes
an emerging market country will be simplified to read substantially as follows:

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

March 24, 2023

Page 4

“Currently, Thornburg considers
emerging market countries to include most Central and South American, African, Asian (including the Middle
and Near East and the Indian subcontinent) and Central and Eastern European nations.”

9.    The staff noted that when identifying what it considers to be emerging markets, the Advisor may also
consider classifications by independent financial services firms that maintain indices of emerging markets. The staff asked that the registrant
please provide an example of such a firm in the Emerging Markets Managed Account Fund’s Form N-1A Item 4 principal investment strategies
disclosure.

Response: As noted in the
prior response, the registrant has determined to remove the sentence referenced by the staff, and accordingly the disclosure no longer
refers to the Advisor’s consideration of whether independent financial service firms classify a particular country as an emerging
market.

10.    The staff noted that the disclosure in the Emerging Markets Managed Account Fund’s principal
investment strategies regarding whether an investment is tied economically to one or more emerging markets appears to be an economic tie
test, and that the factors listed in the disclosure are overly broad and vague; and asked the registrant to revise the disclosure in plain
English to comport with the guidance issued by the Staff regarding methods of determining whether an issuer has an economic tie to a given
emerging market country. The Staff specifically noted in this regard footnote 24 to the Adopting Release for Rule 35d-1 under the Investment
Company Act of 1940, as amended (the “1940 Act”). The staff also asked the registrant to state supplementally whether the
Fund has adopted a policy of investing in a minimum number of countries and whether the Fund may meet the requirements of its 80% policy
by investing in the securities economically tied to a single emerging market country. The staff further asked if the Fund may be invested
in a single emerging market country to please explain why the Fund’s name using the plural term “markets” is not misleading.
Furthermore, the staff asked the registrant to change the phrase “a variety of different countries” in the fourth paragraph
of the Fund’s principal investment strategies disclosure to refer to different “emerging market” countries.”

Response: The registrant
has determined to replace the referenced disclosure with disclosure that reads substantially as follows:

“The material
factors that Thornburg considers when determining whether an issuer has substantial economic ties to an emerging market country include
whether the issuer:

 · is included in the MSCI Emerging Markets Index;

 · is organized or headquartered in an emerging market
country, or maintains most of its assets in one or more such countries;

 · has a primary listing for its securities on a stock
exchange of an emerging market country; or

 · derives a majority of its profits, revenues, sales,
or income from one or more emerging market countries.”

The registrant believes that this
disclosure is clearer and addresses the staff’s concern that the previous disclosure was overly broad and vague, and also comports
more closely to prior guidance from the staff.

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

March 24, 2023

Page 5

Regarding the staff’s question
about whether the Fund has adopted a policy of investing in a minimum number of countries or may invest in securities that are tied to
a single emerging market country, the registrant notes that the term “Emerging Markets” as used in the Fund’s name in
plural form as it is intended to refer to the Fund’s principal investment strategy of investing, under normal market conditions,
at least 80% of its assets in equity securities of issuers from multiple emerging market countries. Finally, the registrant notes that
it will change the phrase “a variety of different countries” to refer to “a variety of different emerging market countries,”
per the staff’s comment.

11.    The staff noted that the Emerging Markets Managed Account Fund’s Form N-1A Item 4 principal
investment strategies disclosure refers to the Fund investing in “Basic Value,” “Consistent Earner,” and “Emerging
Franchise” equity securities that are initially described using the phrase “types of issuers” but then subsequently
described as “categories,” and asked the registrant to revise the disclosure to clarify in plain English that the foregoing
are each a category determined by the Advisor.

Response: The registrant
will revise the referenced disclosure to read substantially as follows:

“Thornburg typically
categorizes the Fund’s equity investments in one of the following three categories:”

12.    The staff asked the registrant to enhance the Emerging Markets Managed Account Fund’s Form
N-1A Item 9 disclosure by adding language by explaining in plain English the meaning of the term “economic sensitivity” and
by defining what the Advisor considers to be “mature” and “cyclical” industries, as summarized in the Item 4 disclosure
regarding the “Basic Value” equity securities category. The staff noted that these enhancements could be disclosed in the
portion of the prospectus responsive to Form N-1A Item 9. The staff also asked the registrant to disclose in the Form N-1A Item 9 disclosure
any specific “mature or cyclical” industries in which the Fund will invest as a principal investment strategy, along with
attendant risk disclosure.

Response: The registrant
will add disclosure substantially as follows within the Form N-1A Item 9 disclosure, under the heading “Investing in Stocks and
Other Equity Securities”:

“The issuers of securities categorized
by Thornburg