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MAINSTAY VP FUNDS TRUST

51 MADISON AVENUE

NEW YORK, NEW YORK 10010

VIA EDGAR CORRESPONDENCE

April 18, 2022

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 (SEC File
Nos. 002-86082 and 811-03833-01) (the “Registrant”) relating to MainStay VP American Century Sustainable
Equity Portfolio (the “Portfolio”)

Dear Mr. Cowan:

This letter responds to comments provided by you on February 28, 2022 with respect
to the Registration Statement. The Registration Statement was filed with the Securities and Exchange
Commission on January 18, 2022 and relates to the Portfolio. 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.

General and Summary Prospectus Comments

Comment 1: Remember to update
the EDGAR series ID from MainStay VP T. Rowe Price Equity Income Portfolio to MainStay VP American Century
Sustainable Equity Portfolio on May 1, 2022.

Response: We will make
the necessary EDGAR updates at the appropriate time.

Comment 2: Since the Portfolio
is re-branding as an ESG-dedicated fund, please supplementally explain how the Portfolio’s existing
portfolio will change. For example, will certain investments be sold?  Will there be types of investments
that the Portfolio has historically made that it will no longer make?

Response:
As described in our supplement dated December 10, 2021, in order to implement the new principal investment
strategies and investment process, the Portfolio is expected to experience a high level of portfolio
turnover. This portfolio transition period may take a significant amount of time and result in the Portfolio
holding large amounts of uninvested cash. Additionally, there may be certain types of investments that
the Portfolio has historically made (or that were eligible for investment) that will no longer fit in
the new principal investment strategies.

Comment 3: In the introductory
paragraph to the Example table, delete the following sentence as no waiver is indicated.

The
Example reflects the contractual fee waiver and/or expense reimbursement arrangement, if applicable,
for the current duration of the arrangement only.

Response: This language
was added based on prior discussions with the staff and is consistent across our Portfolios. We believe
that removing it for certain Portfolios may cause confusion and increase the risk of error. Therefore,
we decline to make the requested edit.

Comment 4: If the Portfolio's
repositioning will result in increasing the portfolio turnover, please add corresponding principal strategy
and risk disclosure (in Item 4 and in Item 9), including any tax consequences to new and existing shareholders
as a result of such portfolio turnover. Please also make sure the disclosure in response to Item 16(e)
discusses the effect of portfolio turnover resulting from the repositioning.

Response:
 We have made the requested edits.

Comment 5: It seems that American Century Investment
Management, Inc. (the “Subadvisor”) runs its proprietary model against all 500 companies within the
S&P 500 Index, which assigns an ESG score to each. An ESG score in the top 75th percentile qualifies
as a sustainable equity security and that ESG score range must be met for 80% of the assets selected
for the portfolio by following the investment process which utilizes a proprietary multi-factor quantitative
model. If so, please clarify the disclosure to better describe how this process works.

Response:
The ESG score is one component derived from the multi-factor model. The same ESG score is separately
used to ensure compliance with the Portfolio’s policy to invest 80% of its assets in sustainable equity
securities. We revised and reordered the disclosure to clarify how the process works.

Comment
6: Is the ESG score applied overall to all three environmental, social and governance
factors? Revise the disclosure to make clear, if true, that as long as the overall score is within the
top three quartiles, the equity security can be selected for investment, even if a score on any particular
factor is not within the top three quartiles. Also, use plain English for the top three quartiles (i.e.,
top 75%). Given that "sustainable" is in the Portfolio's name, is more weight given to an environmental
score?

Response: As indicated by the disclosure, the Portfolio assigns a
comprehensive ESG score to each security, not a score for each component, and no component is more important
than any other. We have made the requested edit regarding using plain English for the top three quartiles.

Comment
7: Please clarify the following sentence to state, if true, that this is a different
model than the model that screens for a sustainable equity security.

The
Portfolio will generally invest in large capitalization companies it believes show sustainable business
improvement using a proprietary multi-factor quantitative model that combines fundamental measures of
a stock’s value and growth potential with ESG metrics.

Response:  We clarified
the disclosure as outlined in Response 5. We also revised the following sentence to clarify how the financial
metrics score and the ESG score are combined as follows:

“The model assigns each security a financial
metrics score and an ESG score that are combined on an equal basis to create an overall
score.”

Comment 8: Delete "generally" from the following sentence or disclose
the exceptions. If the universe of companies from which the Portfolio will select (using the multi-factor
quantitative model) is not limited to those companies within the cap range of the S&P 500, that universe
needs to be defined.

The Portfolio will generally invest in large
capitalization companies it believes show sustainable business improvement using a proprietary multi-factor
quantitative model that combines fundamental measures of a stock’s value and growth potential with
ESG metrics.

Response: We revised the disclosure to add a sentence to the portion
of the Portfolio’s Principal Investment Strategies section that discusses
market capitalization:

“While the Portfolio generally invests
in large capitalization companies, it may invest in companies of any market capitalization.”

Comment
9: Is the ESG score arrived at through the proprietary model used to define a "sustainable
equity security?" If so, please clarify.

Response: The ESG score
is one component derived from the multi-factor model, and the same ESG score is separately used to ensure
compliance with the Portfolio’s 80% test. “Sustainable equity securities” are defined in the revised
Portfolio’s Principal Investment Strategy section as “those that the Subadvisor’s
proprietary model assigns an ESG score that is in the top three quartiles (i.e. top 75%) of the ESG scores
the model assigns to all the securities in the Portfolio’s primary benchmark, the Standard & Poor's
500® Index (‘S&P 500®
Index’), which ranged from $6.3 billion to $2.7 trillion as of February 28, 2022.” Please see also
our Response to Comment 5 for more explanation.

Comment 10: Clarify the principal
investment strategy disclosure relating to the two models. Does the Portfolio start with companies that
fall within top three quartiles for ESG factors and then apply the proprietary multi-factor model to
those?  It is not clear how these two models are used.  If the Portfolio does not start with companies
that fall within the top three quartiles, then we are not sure how this satisfies the names rule policy
as to "sustainable."

Response: No, the Portfolio applies the multi-factor model to any
security considered for investment. The ESG scores derived from the multi-factor model are used to ensure
compliance with the Portfolio’s 80% test. Please see also our Responses to Comments 5 and 9 for more
details.

Comment 11: Please include the capitalization range of the S&P 500
Index.

Response: We have made the requested edit.

Comment 12:
If true, consider clarifying that while the capitalization range is the same as the S&P 500 Index,
this universe of companies that the Portfolio will consider for investment is broader than the universe
of companies within the S&P 500 Index.

Response: We revised the
disclosure as follows:

“While the Portfolio generally invests
in large capitalization companies, it may invest in companies of any market capitalization.”

Comment
13:  Delete the word “Generally” from the following sentence:

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

Response:
We have made the requested edit.

Comment 14:  Does the Portfolio invest in depository
receipts? If so, disclose here and add principal risks.

Response:
Investing in depository receipts is not a principal strategy of the Portfolio and, as such, principal
risk disclosure is inappropriate.

Comment 15: In the disclosure describing the investment
process, please clarify, if true, that the Subadvisor uses value, growth and price momentum as measures
in its proprietary multi-factor quantitative model to assign a financial metrics score.

Response:
We have made the requested edit.

Comment 16: In the disclosure describing investment
process, please clarify, if true, that this ESG score is arrived at by using the model that determines
a "sustainable equity security." It is a little confusing, as we thought the ESG score was arrived at
first.

Response: The ESG score is one component derived by the multi-factor
investment model. The same ESG score is separately used to ensure compliance with the Portfolio’s 80%
test. Please see also our Responses to Comments 5, 9, and 10 for more details.

Comment 17:
In the disclosure describing the investment process, please identify third-party providers or in the
Item 9 disclosure.

Response: Because we may use multiple providers, which can change
over time, we respectfully decline to make the requested edit.

Comment 18:
Please explain how the following sentence can be true given that a company’s ESG score must be within
the top three quartiles:

If information on a specific metric is unavailable,
the security may still be selected for the portfolio if the Subadvisor believes it can evaluate the security
qualitatively or if the financial metrics and remaining ESG scores merit investment.

Response:
As stated in the Principal Investment Strategies section of the Portfolio’s prospectus,

“Under normal circumstances, the Portfolio invests at least 80% of its assets
(net assets plus any borrowing for investment purposes) in sustainable equity securities.”

The
prospectus goes on to define a sustainable equity security as one:

“that the Subadvisor’s proprietary
model assigns an environmental, social, and governance (“ESG”) score that is in the top three quartiles
(i.e. top 75%) of the ESG scores the model assigns to all the securities in the Portfolio’s primary
benchmark, the Standard & Poor's 500® Index ("S&P
500® Index").”

Thus, only 80% of the Portfolio’s securities
must have an ESG score within the top three quartiles of those in the S&P 500®
index. The sentence in question is intended to notify shareholders that the Subadvisor may occasionally
select a security for the Portfolio even though it may not be able to obtain information on a particular
metric.

Comment 19: As the Portfolio needs to be 80% in sustainable equity,
please explain supplementally whether the multi-factor quantitative model ensures that at least 80% of
the final portfolio includes sustainable equity securities (even though that may not necessarily result
in a portfolio that is made up of the highest combined scores).

Response:
The Subadvisor uses the ESG score derived from the multi-factor model to test the Portfolio and ensures
that at least 80% of the final portfolio includes sustainable equity securities. Please see also our
Responses to Comments 5, 9, 10, and 11 for more information.

Comment 20: Please clarify
whether each sector of the S&P 500 Index must be represented by the Portfolio’s securities holdings.

Response:
There is no requirement that every sector must be represented.

Comment 21:
Please revise the following sentence to include the bold and underlined text:

Final scores for
each security are assigned by the Subadvisor’s multi-factor quantitative model and
are evaluated on a sector-specific basis, and the Portfolio seeks to hold securities with the highest
scores in their respective sectors.

Response: We have made the requested edit.

Comment
22: Please clarify the sentence below. What is the additional fundamental analysis
that is performed? Can this result in a different portfolio than selected by the model?

The Subadvisor validates the output of the multi-factor model using additional
fundamental analysis.

Response: We have deleted this disclosure.

Comment 23:
In the Principal Risks section, please also include risks related to reliance on third-party providers.

Response:
We have made the requested edit.

Comment
24: Why are small- and mid-cap companies included in the Market Capitalization Risk
given that the Portfolio primarily invests in large cap companies.

Response:
See our response to Comment 12 above.

Comment 25: Is including “Liquidity and Valuation
Risk” for this Portfolio correct? Please disclose the types of illiquid securities in which the Portfolio
invests as part of its principal investment strategies.

Response: We have deleted
this disclosure.

Comment 26: Revise the first paragraph in the “Past Performance”
section to be more consistent with Item 4(b)(2)(i) of Form N-1A.

Response:
We have made the requested edit.

Comment 27: Please move the description of the primary
index in the “Past Performance” section from the narrative to a footnote in the Average Annual Total
Returns table.

Response: We have made the requested edit.

Comments
to the Statutory Prospectus

Comment 1: In the More About Investment Strategies and Risks section,
revise the disclosure to indicate which strategies, investments and risks apply on a fund-by-fund basis.
 This can be done though a chart which sets forth the strategies, investments and risks and indicates
to which Portfolio(s) the disclosure is applicable.

Response: We have made the
requested edit.

Comment 2: In the More About Investment Strategies and Risks section,
revise the following sentence to state the actual policy:

The Portfolio has a name
that suggests a focus on a particular type of investment. In accordance with Rule 35d-1 under the 1940
Act, the Portfolio has adopted a policy that it will, under normal circumstances, invest at least 80%
of the value of its assets (net assets plus the amount of any borrowings for investment purposes) in
investments of the type suggested by its name, as described in the Portfolio’s Principal Investment
Strategies section and set forth in the Statement of Additional Information (“SAI”).

Response:
The disclosure relating to the Portfolio has been folded into a larger statutory prospectus which covers
many other Portfolios.  We believe that laying out each Portfolio’s 80% test in the More About Investment
Strategies and Risks section (in addition to the instances where this information is already disclosed)
could cause confusion and increase the risk of error. Therefore, we decline to make the requested edit.

Comment
3: In the More About Investment Strategies and Risks section, is the risk relating
to Emerging Markets applicable to the Portfolio?

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

Comment 4: Please explain
the Subadvisor’s ESG screening methodology in detail. As not