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MAINSTAY
VP FUNDS TRUST
51 MADISON AVENUE
NEW YORK, NEW YORK 10010

VIA
EDGAR CORRESPONDENCE

April 23, 2021

Mr.
Mark Cowan
Division of Investment Management, Disclosure Review Office
Securities and Exchange
Commission
100 F Street, NE
Washington, DC 20549

RE: Response to Comments on the Registration Statement (the “Registration
Statement”) for MainStay VP Funds Trust (the “Registrant”)
(SEC File Nos. 002-86082 and 811-03833-01) relating
to MainStay VP Candriam Emerging Markets Equity Portfolio, MainStay VP
Wellington Small Cap Portfolio,
MainStay VP Wellington Growth Portfolio, MainStay VP Wellington U.S. Equity Portfolio, MainStay VP
Wellington
Mid Cap Portfolio and MainStay VP Balanced Portfolio (each a “Portfolio” and collectively, the “Portfolios”)

Dear
Mr. Cowan:

This letter responds to comments provided by you on March 22, 2021 with respect to
the Registration Statement.  The Registration Statement was filed with the Securities and Exchange Commission
on February 10, 2021 and relates to the Portfolios.  On behalf of the Registrant, your comments and our
responses thereto are provided below.

All defined terms in this letter have the same meaning as in the
Registration Statement, except as otherwise defined herein.

Prospectus Comments
– Summary Sections

MainStay VP Candriam Emerging Markets Equity Portfolio

Comment 1:    On the front cover of the prospectus, do not delete
information relating to access to paper copies of annual and semiannual reports until next year.  See
Item 1.

Response:
 The Registrant respectfully declines to make any revisions in response to this comment.  The Registrant
notes that the disclosure required by Item 1(a)(5) of Form N-1A (“Required Statement”) is only required
to the extent it is still applicable.  The Registrant further notes that the Required Statement is only
applicable during the transition period set forth in paragraph (i) of Rule 30e-3.  The Fund has met the
conditions set forth in paragraph (i) of Rule 30e-3 to rely on Rule 30e-3 beginning January 1, 2021.
 Accordingly, the Required Statement is no longer applicable and, therefore, no longer required by Item
1(a)(5).

Comment
2:  In the section
entitled “Example”, delete reference to the contractual fee waiver and/or expense reimbursement arrangement
as there is no such arrangement indicated in the fee table.

Response:  The Registrant respectfully submits that this is standard disclosure to
make shareholders aware that any contractual fee waiver would only be reflected for the duration of the
arrangement, whether or not a contractual waiver is in place currently.   This response applies to the
same comment given on the “Example” sections for other Portfolios.

Comment 3:  Confirm that the
Portfolio’s acquired fund fees and expenses (“AFFE”) are not expected to exceed 0.01% or include
a line item in the Fee and Expense Table, as applicable. If the Fund’s AFFE are expected to exceed
0.01% confirm that the AFFE will be included in “Other Expenses.”

Response:  We confirm that the Portfolio’s AFFE (if any) will
be included as a separate line item or included in “Other Expenses” as required.

Comment 4:  The disclosure related to the Subadvisor’s determination
of a country as an emerging market is inconsistent with the economic tie test noted later in the section.
 The determination can't be in the Subadvisor’s discretion, the definition has to be reasonable.

Response:  We do not believe that
this language is inconsistent.  However, we have added additional language to make this disclosure clearer.

Comment
5:    Please
specify which index(es) will be used to make the determination of whether an investment is tied economically
to an emerging market?   Consider including reference to determinations made by third parties such as
the World Bank.

Response:  We have revised the disclosure
in response to this comment.

Comment 6:
 The statement that an investment is tied economically to an emerging market if the issuer’s primary
trading market is in an emerging market seems to be circular.

Response:  We do not believe that the statement is circular.   However, we have made
edits to this section to clarify the disclosure generally.

Comment 7:  In the section entitled Principal Investment Strategies, explain what is meant by a thematic approach.

Response:  We have revised the disclosure
in response to this comment.

Comment 8:
 The discussion regarding investment process should be in plain English.  For example, the stock selection
methodology based on proprietary quantitative screening platform should be explained in plain English
briefly here and in more detail in response to item 9.

Response:  We have revised the disclosure in response to this comment.

Comment 9:   The Portfolio should describe its due diligence practices
in applying its ESG screening criteria to portfolio companies (e.g., does it perform its own independent
analysis of issuers, or does it rely exclusively on third party screens?). Also, explain: (1) whether
the Portfolio’s ESG criteria are applied to every investment it makes, or only to some of its investments;
and (2) whether ESG is the exclusive factor considered, or whether it is one of several factors.

Also,
the Portfolio should more clearly explain its definition of “ESG” and its specific ESG area(s) of
focus (i.e. focus on sustainable, if true).

Response:  We have revised the disclosure in response to this comment based on information
provided by the Subadvisor.

Comment 10:  Explain what is meant by “seeks to limit exposure to industries which
do not satisfy the Subadvisor’s environmental, social and governance (‘ESG”) criteria…”

Response:  We have revised the disclosure
in response to this comment based on information provided by the Subadvisor.

Comment 11:  Please disclose how the Portfolio will approach relevant
ESG proxy issues for their portfolio companies.

Response:  The Subadvisor’s proxy voting policy is set forth in the SAI.

Comment 12:  Explain what is meant by “Sector, currency, regional
and country deviations are kept within predetermined limits relative to the MSCI Emerging Markets Index.”

Response:
 We have revised the disclosure in response to this comment based on information provided by the Subadvisor.

Comment
13:  Explain
what is meant by “The Subadvisor seeks to reduce risk by investing in securities of a large number
of issuers.”  Is there a minimum number of holdings?  This should be quantified in some manner.

Response:  The target number holdings
can vary depending on various conditions.  However, we added clarifying language in response to this
comment.

Comment
14:  Include a separate risk item for ESG Criteria Risk.  Consider
disclosing that because the Portfolio’s ESG criteria may exclude the securities of certain issuers
for nonfinancial reasons, the Portfolio may forgo some market opportunities available to funds that do
not use ESG criteria. Also, ESG considerations maybe linked to long term rather than short term returns.

Response:  We have revised the disclosure
in response to this comment.

Comment 15:  Please also consider risks related to market manipulation concerns, limited
reliable access to capital, limitations on the rights and remedies available to the fund, individually
or in combination with other shareholders with respect to issuers of securities the fund invests in.
  See ADI 2020-11
Registered Funds’ Risk Disclosure Regarding Investments in Emerging Markets.

Response:  We have revised the disclosure in response to this comment.

Comment
16:  Why is
language regarding fixed-income instruments included in Liquidity and Valuation Risk?

Response:  We have removed the language in response to this comment.

Comment 17:  Consider revising Derivatives Risk to include subcategories for the specific
types of derivative (i.e., futures, options, swaps, and forwards).

Response:  We respectfully decline to make any changes to the disclosure
in response to this comment as our risk factor language is consistent across many funds in our complex.

Comment
18:  Please confirm whether the Portfolio currently concentrates
its investments in any single country. If so, please disclose in the Portfolio’s principal investment
strategies and revise the Geographic Focus Risk

Response:  We have revised the disclosure in response to this comment.

Comment 19:  If Debt Securities
Risk is a principal risk of the Portfolio, please add disclosure regarding debt securities to the principal
investment strategy.

Response:  We have removed the risk
factor in response to this comment.

Comment 20:
 Please consider revising the Portfolio’s disclosure in the Past Performance section of the summary prospectus for consistency with information
required by Item 4(b)(2)(i) of Form N-1A.   This comment applies to all Portfolios.

Response:  We respectfully decline to make any updates in response
to this comment as we believe our disclosure and corresponding performance presentation is consistent
with the information required by Item 4(b)(2)(i) of Form N-1A.

Comment 21:  Please remove the description of the Portfolio’s primary benchmark index from
the first paragraph of the Past Performance section of the summary prospectus.

Response:  We respectfully decline to remove the description of
the Portfolio’s primary benchmark index as we believe this disclosure is useful for shareholders and
prospective shareholders.

MainStay VP Wellington Growth Portfolio

Comment 1:  In the section entitled Principal Investment Strategies of the summary prospectus, please disclose
how the Subadvisor defines “large-capitalization companies.”

Response:  We have revised the disclosure in response to this comment.

Comment
2:  In the section
entitled Principal Investment
Strategies of the summary prospectus, please delete the word “Generally” from the below sentence.

Generally, an issuer of a security is considered to be a U.S. issuer based on the issuer's
"country of risk," as determined by a third-party service provider such as Bloomberg.

Response:  We respectfully decline to make any changes in response
to this comment.

Comment
3:  In the Principal Investment Strategies
section of the summary prospectus, please identify examples of ESG criteria that the Subadvisor may consider.

Response:  We have revised the disclosure
in response to this comment based on information provided by the Subadvisor.

Comment 4:  In the Principal Investment Strategies section of the summary prospectus, the Portfolio
discloses that it invests mainly in stocks of large-capitalization U.S. companies.  Accordingly, please
revise the Market Capitalization
Risk to more closely reflect the risks associated with investments in large-capitalization companies.

Response:  We respectfully decline
to make an update in response to this comment. Although the Portfolio invests mainly in large-capitalization
companies, it may invest in securities issued by small-, or mid-cap companies. Therefore, we believe
it is appropriate to describe the risks associated with such investments.

MainStay VP Wellington Mid Cap Portfolio

Comment 1:  In the section entitled Principal Investment Strategies of the summary prospectus,
please revise the disclosure to only present the market capitalization range of one index as the Staff
believes that the Portfolio’s disclosure of the market capitalization ranges of the Russell Midcap® Index and
S&P Mid Cap 400 Index is not appropriate because the ranges of these indices are not consistent.

Response:  We have updated the disclosure
to only present the market capitalization range of the Russell Midcap® Index.

Comment 2:  In the Principal Investment Strategies section of the summary prospectus, please
identify examples of ESG criteria that the Subadvisor may consider.

Response:  We have revised the disclosure in response to this comment
based on information provided by the Subadvisor.

Comment 3:  Please revise the Market Capitalization Risk to more closely reflect the risks associated with
investments in mid-capitalization companies.

Response:  We respectfully decline to make an update in response to this comment. Although
the Portfolio invests mainly in mid-capitalization companies, it may also invest in securities issued
by small-, or large-cap companies. Therefore, we believe it is appropriate to describe the risks associated
with such investments.

MainStay VP Wellington Small Cap Portfolio

Comment 1:  In the section entitled Fees and Expenses of the Portfolio, please update the expiration date of
the Portfolio’s waiver/reimbursement arrangement if such arrangement will be in place until at least
May 1, 2022.  If not, please remove this disclosure from the Portfolio’s fee table.

Response:  We have revised the disclosure in response to this comment.

Comment
2:  In the section
entitled Principal Investment
Strategies of the summary prospectus, please delete the word “generally” from the first sentence
of the section.

Response:  We have revised the disclosure
in response to this comment.

Comment 3:
 In the Principal Investment
Strategies section of the summary prospectus, please identify examples of ESG criteria that the
Subadvisor may consider.

Response:  We have revised the disclosure
in response to this comment.

Comment 4:  Please move the below sentence of Portfolio Management Risk to the Portfolio’s Principal Investment
Strategies section and provide examples of ESG criteria that the Subadvisor may consider.

Response:  We have made the requested
revision to principal investment strategies section in response to this comment.

MainStay VP Wellington U.S.
Equity Portfolio

Comment
1:  In the section
entitled Principal Investment
Strategies of the summary prospectus, please revise the Investment Process paragraph for plain English.

Response:  We have revised the disclosure in response to this comment.

Comment
2:  In the Principal Investment Strategies
section of the summary prospectus, please identify examples of ESG criteria that the Subadvisor may consider.

Response:  We have revised the disclosure
in response to this comment based on information provided by the Subadvisor.

Comment 3:  Please disclose investments in foreign securities in
the Principal Investment Strategies Section or remove Foreign Securities Risk.

Response:  We have removed this risk factor in response to this comment.

MainStay VP Balanced Portfolio

Comment
1:  In the section
entitled Principal Investment
Strategies of the summary prospectus, please revise the second paragraph to explain how the Subadvisors
consider whether a country is stable.

Response:  We have revised the disclosure in response to this comment.

Comment 2:  In the section entitled Principal Investment Strategies of the summary prospectus,
please revise the second paragraph to explain how the Subadvisors consider whether a security to be of
high quality.

Response:  We respectfully decline
to make any updates in response to this comment as we believe the Investment Processes of each Subadvisor
appropriately describes the Subadvisor’s investment selection process.

Comment 3:  Explain why the subadvisor needs discretion in determining
if a country is an emerging markets country.

Response:
 As there is no definitive list of emerging markets countries, the Subadvisor must have the ability to
make a reasonable determination, based on certain criteria, when making investment decisions.

Comment
4:  In the Principal Investment Strategies
section of the summary prospectus, please identify examples of ESG criteria that the Subadvisor may consider.

Response:  We have
revised the disclosure in response to this comment based on information provided by the Subadvisor.

Comment
5:  In the Principal Investment Strategies
section of the summary prospectus, please describe the Subadvisor’s criteria for determining the credit
quality of a fixed income security. Please specify whether this determination