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    Sidley Austin LLP

787 Seventh Avenue

New York, NY 10019

+1 212 839 5300

+1 212 839 5599 Fax

AMERICA  ·  ASIA PACIFIC  ·  EUROPE

+1 212 839 8679

MKUTNER@sidley.com

December 18, 2023

Emily Rowland

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management, Disclosure Review and Accounting Office

100 F. Street, N.E.

Washington, DC 20549

    Re:
    First Eagle Funds (the “Trust”)

    File Nos.:  033-63560 and 811-7762

    Post-Effective Amendment Nos. 110 and 111 to the Trust’s Registration Statement on Form N-1A

Dear Ms. Rowland:

Thank you for your comments regarding Post-Effective
Amendment No. 110 to the Trust’s registration statement on Form N-1A, filed with the Securities and Exchange Commission (the
“Commission”) on October 13, 2023 (the “Short Duration High Yield Municipal Fund PEA”) and Post-Effective
Amendment No. 111 to the Trust’s registration statement on Form N-1A, filed with the Commission on October 16, 2023 (the
“High Yield Municipal Fund PEA,” and together with the Short Duration High Yield Municipal Fund PEA, the “PEAs”).
The Short Duration High Yield Municipal Fund PEA was filed for the purpose of registering shares of the First Eagle Short Duration High Yield
Municipal Fund (the “Short Duration High Yield Municipal Fund”), a new series of the Trust. The High Yield Municipal
Fund PEA was filed for the purpose of revising (1) the name, investment objective and principal investment strategy, and the associated
risks; and (2) the fees and expenses, including the implementation of a revised contractual expense limitation arrangement, of
the First Eagle High Income Fund (to be renamed the First Eagle High Yield Municipal Fund) (the “High Yield Municipal Fund,”
and together with the Short Duration High Yield Municipal Fund, the “Funds”), a series of the Trust. This letter responds
to your comments, which you provided to us by telephone on November 16, 2023.

Below, we describe changes the Trust will
make to the PEAs in response to the Staff’s comments, generally described by reference to where the responsive disclosures
will appear in the Filing, as defined below.

We anticipate making one or more filings
of a post-effective amendment to the Funds’ registration statement delaying effectiveness of the PEAs. We also anticipate
making the applicable changes

Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP
and practicing in affiliation with other Sidley Austin partnerships.

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in a filing pursuant to Rule 485(b) under the Securities Act of 1933, as amended (the “Securities
Act”), on or about December 27, 2023, with immediate effectiveness (the “Filing”). All text changes described
below will be implemented substantially as noted here, though some variation in the Filing may be appropriate.

Capitalized terms used, but not otherwise
defined, have the meaning ascribed to them in the PEAs.

GENERAL COMMENTS

 1. COMMENT: You asked that the Funds please provide its responses to the Staff’s comments
no later than five business days prior to the effective date of the filing to give the Staff adequate time to review the Funds’
responses. You also asked that the Funds provide the Staff with a marked draft of the Filing showing the revisions to the disclosure.
You noted that the Funds and management are responsible for the accuracy of the disclosure notwithstanding any review by the Staff.

RESPONSE: The Funds’
responses to the Staff’s comments are included herein, and the Funds will provide a marked copy of the Filing to the Staff
as requested.

 2. COMMENT: You noted that where a comment is made to one section of the PEAs, the comment
is applicable to all similar disclosure appearing elsewhere in the PEAs.

RESPONSE: The Funds will
incorporate the Staff’s comments throughout the Filing.

High Yield Municipal Fund Prospectus
(and to the extent applicable, the Short Duration High Yield Municipal Fund Prospectus):

GENERAL

 3. COMMENT: You asked that the High Yield Municipal Fund please update its name on EDGAR
in connection with the filing.

RESPONSE: The Fund will
update its name on EDGAR in connection with the filing.

FEES AND EXPENSES

 4. COMMENT: You asked the Fund to revise the Footnote *** (“‘Other Expenses’
are based on estimated expenses for the current fiscal year to reflect certain changes to the Fund’s principal investment
strategies; actual expenses may vary.”) to indicate that “Other Expenses” are restated to reflect estimated expenses
for the current fiscal year due to changes to the Fund’s principal investment strategies.

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RESPONSE: The Fund will
revise Footnote *** as follows:

“Other Expenses”
are restated to reflect based on estimated
expenses for the current fiscal year due to reflect certain
changes to the Fund’s principal investment strategies; actual expenses may vary.

PORTFOLIO TURNOVER

 5. COMMENT: With respect to the section titled “Portfolio Turnover Rate,” you
asked that the following be deleted: “There are transaction costs due to the bid/ask spread in the case of bonds or commissions
in the case of stocks.” You noted that this disclosure is neither required nor permitted.

RESPONSE: The Fund will
delete the sentence quoted above.

 6. COMMENT: You asked that since the Fund’s portfolio is being repositioned as a result
of the changes to the Fund’s principal investment strategies that the Fund include disclosure regarding any anticipated
variation in the portfolio turnover rate in the SAI in response to Item 16(e) of Form N-1A.

RESPONSE: The Fund
will add a footnote to the table in the Portfolio Turnover section of the SAI describing the anticipated variation in the Fund’s
portfolio turnover rate as a result of the changes to the Fund’s principal investment strategies, substantially as follows:

The Fund anticipates that
100% of its portfolio will turnover as a result of the changes to the Fund’s principal investment strategies. Although the
Fund cannot predict its annual portfolio turnover rate following the repositioning of the Fund’s portfolio, it is generally
not expected to exceed 50% under normal conditions.

PRINCIPAL INVESTMENT STRATEGIES

 7. COMMENT: You asked the Fund to disclose in its principal investment strategies how the
Adviser decides whether to sell Fund investments. You asked that it be summarized in the principal investment strategy in response
to Item 4 of Form N-1A with a more full description in response to Item 9 of Form N-1A.

RESPONSE: The Fund will
revise its disclosure to include the following: “In deciding whether to sell a security, the Adviser considers various factors
related to the market and the portfolio, which may include whether: a security has become overvalued; the Adviser

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detects credit
deterioration or modifies its portfolio strategy, such as sector and/or state allocations; or a security exceeds the portfolio’s
diversification targets.”

 8. COMMENT: You noted that the disclosure states that: “[t]he Fund ‘counts’
relevant derivative positions towards its ‘80% of assets’ allocation and, in doing so, values each position at the
price at which it is held on the Fund’s books (generally market price, but anticipates valuing each such position for
purposes of assessing compliance with this test at notional value in connection with new rules requiring that treatment, which
come into effect in 2025).” You noted that the Staff would not object if the Fund values derivative positions at notional
value before the new rules are effective.

RESPONSE: The Fund acknowledges
this Staff comment.

 9. COMMENT: You noted that the disclosure of the Fund’s principal investment strategies
in response to Item 4 of Form N-1A includes the following sentence: “A debt instrument’s ‘duration’ is
a way of measuring a debt instrument’s sensitivity to a potential change in interest rates.” You asked that the Fund
describe any criteria that it uses as to duration or alternatively, to strike this sentence. You asked that if the Fund does use
criteria as to duration, include after this sentence or in response to Item 9 of Form N-1A, an example of duration (for instance,
a duration of 3 years would be expected to…).

RESPONSE: The Fund will
revise its disclosure in response to Item 9 of Form N-1A to include the following with respect to “duration”: “A
debt instrument’s “duration” is a way of measuring a debt instrument’s sensitivity to a potential change
in interest rates. An increase in interest rates tends to reduce the market value of debt instruments, while a decline in interest
rates tends to increase their values. Generally, debt instruments with long maturities and low coupons have the longest durations.
Longer-duration instruments tend to be more sensitive to interest rate changes than those with shorter durations. For example,
if a debt instrument has a duration of five years and interest rates increase (decrease) by 1%, then the value of that debt instrument
would be expected to decline (increase) by approximately 5%.”

 10. COMMENT: You noted that the disclosure of the Fund’s principal investment strategy
in response to Item 4 of Form N-1A includes the following sentence: “The Fund may also invest (typically for hedging purposes
or to manage the effective maturity or duration of securities in the Fund’s portfolio) in derivative instruments such
as options, futures contracts and options on futures contracts, and interest rate swaps.” You asked that the Fund specify
the effective duration, if there is any.

RESPONSE: While the Fund’s
investment strategies do not refer to criteria for effective maturity or duration, the Fund may invest in derivative instruments,
such as options, futures

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contracts and options on futures contracts, and interest rate swaps, to manage the effective maturity
or duration of the Fund’s portfolio, for example, in relation to the indices against which the Fund measures it performance.
The Fund respectfully declines to make any changes to the highlighted disclosure at this time.

 11. COMMENT: You asked that the following be deleted: “The Fund may invest in securities
with any investment rating or time to maturity.” You asked that the sentence be deleted because the Fund will make significant
investment in below investment grade and over 10 year maturity.

RESPONSE: The Fund will
revise its disclosure to clarify that while the Fund will generally maintain, under normal market conditions, an investment portfolio
with an overall weighted average maturity of greater than 10 years and, under normal market conditions, will invest at least 65%
of its net assets in low- to medium-quality bonds rated BBB/Baa or lower at the time of purchase by at least one independent rating
agency or, if unrated, judged by the Fund’s Adviser to be of comparable quality, the Fund may invest in securities with any
investment rating or time to maturity.

 12. COMMENT: You asked that the Fund remove the cross reference to the More Information about
the Fund’s Investments section from the Fund’s Summary. You noted that the Staff does not believe cross references
in the Fund’s Summary are appropriate.

RESPONSE: The Fund respectfully
declines to make any changes to the cross references at this time. The Fund notes that these cross references are intended to refer
readers to sections that include additional information about the Fund’s investment strategy in response to Item 9 of Form
N-1A.

PRINCIPAL INVESTMENT RISKS

 13. COMMENT: With respect to the Fund’s Credit and Interest Rate Risk, you asked the
Fund to address the risks of investing in longer-duration interest rate investments, including with regard to sensitivity to interest
rate changes and volatility. You also asked that the Fund update this disclosure to make it more current. You asked the Fund to
revise the disclosure to address the impact of both potential interest rate increases and decreases on the Fund’s portfolio.

RESPONSE: The Fund will
revise the Credit and Interest Rate Risk as follows:

Credit and Interest Rate
Risk — The value of the Fund’s portfolio may fluctuate in response to the risk that the issuer of a bond or other
instrument will not be able to make payments of interest and principal when due. In

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addition, fluctuations in interest rates can
affect the value of debt instruments held by the Fund. A debt instrument’s “duration” is a way of measuring a
debt instrument’s sensitivity to a potential change in interest rates. An increase in interest rates tends to reduce the
market value of debt instruments, while a decline in interest rates tends to increase their values. Generally, debt instruments
with long maturities and low coupons have the longest durations. Longer-duration instruments tend to be more sensitive to interest
rate changes than those with shorter durations. Recent market conditions and events, including increases
in interest rates a global public health crisis and actions taken by governments in response,
may exacerbate the risk that borrowers will not be able to make payments of interest and principal when due. During
periods of decreasing or prolonged low interest rates, financial markets in which the Fund invests could be negatively affected
by, for example, increased volatility, reduced value and liquidity of the Fund’s investments, and perceptions of broader
economic decline. In addition, there is risk of significant future rate moves and related economic and market impacts. As
of the date of this Prospectus, there have been significant recent rates increases in the United States to combat inflation in
the U.S. economy, and additional rate increases are possible. Credit spread risk is the risk that economic and
market conditions or any actual or perceived credit deterioration may lead to an increase in the credit spreads (i.e., the difference
in yield between two securities of similar maturity but different credit quality) and a decline in price of an issuer’s securities.

 14. COMMENT: With respect to the Fund’s Swaps Risk, you asked that the Fund address the risks of interest rate
swaps given that interest rate swaps are the types of swaps identified as being part of the Fund’s principal investment strategy.

RESPONSE: The Fund will
revise the Swaps Risk as follows:

Swaps Risk — Swap
agreements (including interest rate, total return, credit default and index) are derivatives contracts where the parties agree
to exchange the returns (or differentials in rates of return) earned or realized on particular predetermined investments or instruments.
In addition to the risks generally applicable to derivatives, risks associated with swap agreements include adverse changes in
the returns of the underlying instruments, failure of the counterparties to perform under the agreement’s terms and the possible
lack of liquidity with respect to the agreements. In addition, interest rate
swaps may fail to perform as intended and may not offset adverse changes in interest rates fully or at all. Interest rate swaps
may also reduce the Fund’s gains due to favorable changes in interest rates and result

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in losses to the Fund. Counterparties
to interest rate swaps are subject to manipulation in the marketplace of the floating rate benchmarks, which may affect the utility
of interest rate swaps as a hedge.

 15. COMMENT: With respect to the Fund’s LIBOR Risk, you asked the Fund to consider
whether the risk is applicable to the Fund or, alternatively, to update this disclosure to make it more current.

RESPONSE: The Fund will
replace the Fund’s LIBOR Risk in response to Item 4 of Form N-1A with the following:

Reference Rate Transition Risk
— The Fund may be exposed to financial instruments that recently transitioned from, or continue to be tied to, the London
Interbank Offered Rate (“LIBOR”). The effect of the transition away from LIBOR and the effectiveness of replacement
rates remain uncertain. T