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NEW
YORK LIFE INVESTMENTS VP FUNDS TRUST
51 MADISON AVENUE
NEW YORK, NEW YORK 10010

VIA
EDGAR CORRESPONDENCE

April 9, 2025

Ms. Eileen M. Smiley
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 New York Life Investments
VP Funds Trust (SEC File Nos. 002-86082 and 811-03833-01) (the “Registrant”)
relating to NYLI VP Dimensional U.S. Equity Portfolio and NYLI VP Schroders Mid Cap Opportunities Portfolio
(each a “Portfolio and together, the “Portfolios”)

Dear Ms. Smiley:

This letter responds to comments provided by you telephonically on March 24, 2025
with respect to the Registration Statement. The Registration Statement was filed with the Securities
and Exchange Commission on February 10, 2025.  We intend to file a post-effective amendment to the Registration
Statement on or about April 16, 2025.

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.

Comments
related to all Portfolios

Comment 1:  Please bold the second and third sentences
in the section entitled “Fees and Expenses of the Portfolio.”

Response:
  We have made the requested edit.

Comment 2:  Please update all bracketed
and missing information prior to making the 485(b) filing.

Response:
 We have made the requested edit.

Comment 3:  Please provide completed
fee tables 5 calendar days prior to effectiveness.

Response:
 We agree to provide these as requested.

Comment 4:

Confirm
supplementally why the Registrant did not make a 485(a) filing prior to the changes taking effect in
August 2024.

Response:  The changes to the Portfolios’ disclosures reflected in
the Rule 485(a) filing were made in connection with changes to the Portfolios’ respective Subadvisors,
which were disclosed in Rule 497 supplement filings prior to their effectiveness.  Further, each Portfolio
filed an Information Statement on Schedule 14C, which contained detailed information regarding the changes
to the Portfolios.

Rule 485(a) addresses when post-effective amendments to registration statements
become effective rather than when they are required.  The SEC and its Staff have issued limited guidance
setting forth the circumstances under which an off-cycle Rule 485(a) post-effective amendment must be
filed as opposed to a Rule 497 supplement with a Rule 485(a) post-effective amendment to follow in connection
with the fund’s next annual update. Determining whether a Rule 485(a) filing is required for investment
strategy or other changes involves judgment based on the particular facts and circumstances, and there
is no clear, absolute standard.

Moreover, the Portfolios made the changes
to their respective disclosures reflected in the Rule 485(a) filing in connection with changes in Subadvisors
pursuant to the Portfolios’ “Manager of Managers” exemptive relief (the “Order”).  The Order
is designed, in part, to allow for changes in Subadvisors without unnecessary delays, to the benefit
of the Portfolios and their shareholders.  Consistent with this theme, the application seeking the Order
specifically discussed implementing disclosure changes related to a Subadvisor change through a Rule
497 supplement rather than a registration statement amendment: “[i]f a new Subadviser is retained or
a Subadvisory Agreement is materially amended, a Subadvised Fund’s prospectus and statement of additional
information will be supplemented promptly pursuant to Rule 497(e) under the Securities Act.”  The
Registrant believes that it acted appropriately and consistent with applicable law and the Order by issuing
a prompt Rule 497 supplement, followed by a Rule 485(a) filing in connection with its annual update.

Comment
5:
  Please
confirm supplementally whether the Registrant filed an Information Statement to shareholders related
to each Portfolio’s Subadvisor change.  If not, please explain the rationale for delivering an Information
Statement to shareholders.

Response:  The Registrant confirms
that Information Statements regarding these changes were filed with the SEC on March 20, 2024 (SEC Accession No. 0001193125-24-072031
and SEC Accession No. 0001193125-24-072032) and subsequently delivered to shareholders.

Comment
6:
 Please
confirm that each Portfolio will generally rely on an issuer’s “country of risk” (or similar designation)
as determined by Bloomberg (or another similar third party) when categorizing securities as either U.S.
or foreign-based.  Additionally, include an explanation of the criteria used for when a Portfolio may
override such a designation in the section entitled More About Investment Strategies and Risks.

Response:

We confirm that that each Portfolio will generally rely on an issuer’s “country of risk” (or similar
designation) as determined by Bloomberg (or another similar third party) when categorizing securities
both as U.S. or foreign-based.  We have also added disclosure explaining when a Portfolio may override
such a designation in the section entitled More About Investment Strategies and Risks.

Comments
related to NYLI VP DFA U.S. Equity Portfolio

Comment 1:  In the section entitled
“Principal Investment Strategies,” please consider leading with the Portfolio’s 80% policy and
other principal investment strategies followed by the Subadvisor’s investment approach.

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

Comment 2:  In the section entitled
“Principal Investment Strategies,” please confirm whether the Portfolio will invest in small- and
mid-cap issuers as part of its principal investment strategies. If so, please include corresponding disclosure
in the principal investment strategies.

Response:   We have revised our
Principal Risk disclosure to remove reference to small and mid cap companies in response to this comment.

Comment
3:
 In
the section entitled “Principal Investment Strategies”, please confirm whether investments in exchange
traded funds are part of the Portfolio’s principal investment strategies. If so, please include a corresponding
risk tile or remove references to such investments in the principal investment strategies. Please also
include the acquired fund fees and expenses line item in the fee table to the extent applicable.

Response:
 We
removed reference to exchange traded funds as part of the Portfolio’s principal investment strategy
in response to this comment.

Comment 4:  In the section entitled
“Principal Investment Strategies,” please clarify whether derivatives will be counted towards the
Portfolio’s 80% policy.

Response:  The Registrant confirms
that the Portfolio includes the following disclosure in the section entitled, “More About Investment
Strategies and Risks:”

To the extent a Portfolio
invests in derivatives, such investments may be counted on a mark-to-market basis for purposes of the
80% policy.

Comment
5:
 In
the section entitled “Principal Risks,” please tailor the “Market Capitalization Risk” to the
types of issuers described in the principal investment strategies with respect to market capitalization.

Response:
 We
revised our disclosure in response to this comment.

Comment 6:  In the section entitled
“Principal Risks,” please tailor the “Derivatives Risk” to the types of derivatives that the
Portfolio will use as part of its principal investment strategies.

Response:
 We
revised our disclosure in response to this comment.

Comment 7:   In the section entitled,
“More About Investment Strategies and Risks” please confirm whether “Sector Risk” should be selected
as a principal risk as such risk is not included as a principal risk in Item 4.  Please reconcile.

Response:
 We
revised our disclosure in response to this comment.

Comments related to
NYLI VP Shroders Mid Cap Opportunities Portfolio

Comment 1:  Please confirm whether
the reference to over-the-counter securities relates to investments in equity securities.  If not, please
explain.

Response:  The Registrant confirms that the reference
to over-the-counter securities relates to investments in types of equity securities.

Comment 2:
 Please
confirm that the Portfolio will not invest in foreign securities as part of its principal investment
strategy.

Response:  We confirm that foreign securities are
not part of the Portfolio’s principal investment strategy at this time

Comment 3:
 In
the section entitled “Principal Risks,” please revise the “Growth Stock Risk” and “Value Stock
Risk” tiles to disclose the methodology for determining growth and value stocks, respectively.

Response:
 Upon
further review, we have deleted these risk tiles.

Comment
4:
 Please
confirm that the Portfolio will not concentrate its investments in a particular industry or group of
industries, except as permitted under the 1940 Act.

Response:  The Registrant confirms
that the Portfolio will not concentrate its investments in a particular industry or group of industries,
except as permitted under the 1940 Act.  We have revised our disclosure in response to this comment.

Comment to SAI

Comment 1:    Please confirm that
the Acquired Fund will look through its holdings of investment companies for purposes of concentration
testing.

Response:  Disclosure describing this can be found
in the second paragraph of the section in the Statement of Additional Information entitled “Investment
Practices, Instruments and Risk Common to the Portfolios and Underlying Portfolios/Funds – Investment
Companies.”

Sincerely,

/s/ Thomas C. Humbert Jr.
Thomas
C. Humbert, Jr.
Assistant Secretary