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WANGER ADVISORS TRUST

 Columbia Acorn Trust

Wanger Advisors Trust

 71
S. Wacker Drive, Suite 2500

 Chicago, Illinois 60606

February 9, 2023

 Via EDGAR

Ms. Emily Rowland

 U.S. Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

RE:
 Columbia Acorn Trust—Registration Statement on Form
N-14    File No. 333-269553

Wanger Advisors Trust—Registration Statement on Form N-14   File No. 333-269554

 Dear Ms. Rowland:

This letter responds (the “Response Letter”) to comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by telephone and email on February 7-8, 2023, regarding (1) the registration statement on Form N-14 relating to the
issuance of shares in connection with the reorganization of certain series of Columbia Acorn Trust (“CAT”) and (2) the registration statement on Form N-14 relating to the issuance of
shares in connection with the reorganization of certain series of Wanger Advisors Trust (“WAT”). Comments and responses are outlined below.

The CAT registration statement and the WAT registration statement are each referred to herein as a “Registration Statement” and are together
referred to herein as the “Registration Statements.” CAT and WAT are together referred to herein as the “Registrants.”

CAT REGISTRATION STATEMENT COMMENTS

Comment 1:

All Staff comments made regarding the CAT Registration Statement apply to the WAT Registration Statement unless otherwise indicated.

Response:

The requested disclosure changes pertaining to the CAT Registration Statement will be made in both Registration Statements unless otherwise indicated.

Comment 2:

In the Q&A regarding any changes to fees and expenses as a result of the Reorganization, and in references throughout the Registration Statement, state for each share class of the Target Fund whether the fees and expenses borne
by Target Fund shareholders as shareholders of the Acquiring Fund will be the same as or lower than the expenses they currently bear.

Response:

The requested change has been made.

Comment 3:

In the Q&A regarding why the Investment Managers proposed the Reorganization, and in references throughout the Registration Statement, add as the penultimate sentence a reference to Columbia Wanger’s agreement to limit the
Acquiring Fund’s operating expenses through April 30, 2025, that includes an explanation that the Acquiring Fund’s operating expenses could increase after the expiration date.

Response:

The requested change has been made.

Comment 4:

In the Q&A regarding potential costs associated with portfolio repositioning, confirm what the clause “if any” modifies in the following sentence: “The actual transaction costs will vary based on the degree of
portfolio overlap between the Target Fund and the Acquiring Fund at the time of the Reorganization and on market conditions at the time of sale, if any.”

Response:

The “if any” clause modifies “the sale.”

Comment 5:

In the Q&A regarding the U.S. federal income tax consequences of the Reorganization, the third and fourth sentences of the paragraph are unclear and duplicative of the last two sentences in the paragraph.

Response:

In the Q&A and throughout the Registration Statement, the third and fourth sentences have been removed and replaced with disclosure making clear that that because of the 98% overlap in portfolio holdings of the Target Fund and
the Acquiring Fund, portfolio and transaction costs are expected to be minimal, if any.

Comment 6:

In Section A, under the heading “SUMMARY—How the Reorganization Will Work,” the fifth bullet point is duplicative and should be removed.

Response:

The requested change has been made.

Comment 7:

In Section A, under the heading “SUMMARY—Synopsis of Reorganization: Comparison of Columbia Acorn USA and Columbia Acorn Fund—Comparison of Fees and Expenses,” unbold the second sentence and bold the third
sentence.

Response:

The requested change has been made.

Comment 8:

In Section A, under the heading “SUMMARY—Synopsis of Reorganization: Comparison of Columbia Acorn USA and Columbia Acorn Fund—Comparison of Fees and Expenses,” in the Expense Examples, confirm, and as appropriate
make revisions to reflect, that (i) the effect of the Target Fund’s current contractual fee waiver/expense reimbursement arrangement is reflected, consistent with the fee and expense table, and (ii) the amounts shown in the Expense
Example for the Target Fund are correct.

Response.

The narrative disclosure and amounts shown for the Target Fund in the Expense Example have been revised to reflect the Target Fund’s current contractual fee waiver/expense reimbursement arrangement. Previously, the Expense
Example for the Target Fund did not reflect the effect of the Target Fund’s current contractual fee waiver/expense reimbursement arrangement because it will not be in effect for one year from the date of the Reorganization.

Comment 9:

In Section A, under the heading “SUMMARY—Synopsis of Reorganization: Comparison of Columbia Acorn USA and Columbia Acorn Fund—Comparison of Performance,” confirm that the first quarter of 2020 had the lowest
returns during the 10-year period shown.

Response:

Confirmed.

Comment 10:

In Section B, under the heading “U.S. Federal Income Tax Status of the Reorganization,” in the sentence that begins “The opinion will be based,” remove the clause “but cannot be free from
doubt.”

Response:

The requested change has been made.

Comment 11:

In Exhibit A to the Registration Statement, under the heading “Table A-2. Financial Highlights,” add hyperlinks to (i) the auditor’s report, the Fund’s financial
statements and the Reorganization SAI referenced in the text that appears before the Audited Annual Financial Highlights table and (ii) the Fund’s financial statements and the Reorganization SAI referenced in the text that appears before
the Unaudited Semiannual Financial Highlights table.

Response:

The requested changes have been made.

Comment 12:

In the letter requesting acceleration, specify that the requested date of effectiveness is February 10, 2023, or as soon thereafter as possible.

Response:

The requested change has been made.

Comment 13:

Add the standard red herring language to the front cover of the Information Statement/Prospectus but maintain the February 10, 2023, date throughout the Registration Statement. When the Registrant receives notice from the Staff
that the Registration Statement has been made effective, the Registrant may remove the red herring language and deliver the Information Statement/Prospectus to shareholders.

Response:

The requested change has been made.

WAT REGISTRATION STATEMENT COMMENTS

Comment 14:

In the Q&A regarding Contract Owners’ ability to transfer their investments, state affirmatively that Contract Owners can transfer their investments before and after the Reorganization.

Response:

The requested change has been made.

Comment 15:

In the Q&A and throughout the Registration Statement, remove directions to (i) shareholders and Contract Owners to consult their own tax advisors about the potential tax consequences of the Reorganization to them and
(ii) Contract Owners to consult the description of the tax consequences of investing in Contracts that is provided in the prospectus or other information provided by the Participating Insurance Company. This language is potentially
confusing.

Response:

The requested change has been made.

Comment 16:

In the Q&A regarding the U.S. federal income tax consequences of the Reorganization, revise the following disclosure to reflect that there is minimal, if any, portfolio turnover expected in connection with the Reorganization:
“A portion of the portfolio assets of the Target Fund may be sold by the Acquiring Fund following the Reorganization. Any such sales will cause the Acquiring Fund to incur transaction costs.”

Response:

The requested change has been made.

Comment 17:

In Section A, under the heading “SUMMARY—Synopsis of Reorganization: Comparison of Wanger Select and Wanger Acorn—Comparison of Fundamental Policies,” remove the second paragraph of the disclosure shown for
Wanger Select regarding issuer diversification.

Response:

The requested change has been made.

Comment 18:

In Section C, under the heading “ADDITIONAL INFORMATION ABOUT THE ACQUIRING FUND,” confirm that the SAI, as supplemented, is hyperlinked, and under the heading “INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM,”
confirm that auditor’s report, financial highlights, and financial statements for each of the Acquiring Fund and the Target Fund, as well as the semi-annual report to shareholders, are hyperlinked.

Response:

Confirmed.

Comment 19:

Confirm that revisions made to the language regarding trustee indemnification in Part C align with the Funds’ governing documents.

Response:

Confirmed.

 * * *

 If you
have any questions, please contact counsel to the Registrant, Gwen Williamson (202.654.6399 or gwilliamson@perkinscoie.com) or Molly Moynihan (202.654.6254 or mmoynihan@perkinscoie.com).

Sincerely,

 Ryan C. Larrenaga

Assistant Secretary

 Columbia Acorn Trust

Wanger Advisors Trust

 71
S. Wacker Drive, Suite 2500

 Chicago, Illinois 60606

February 3, 2023

 Via EDGAR

Ms. Emily Rowland

 U.S. Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

Washington, D.C. 20549

RE:
 Columbia Acorn Trust—Registration Statement on Form N-14
    File No. 333-268903

 Wanger Advisors
Trust—Registration Statement on Form N-14    File No. 333-268904

Dear Ms. Rowland:

 This letter responds (the
“Response Letter”) to comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by telephone and email on January 17—February 2, 2023,
regarding (1) the registration statement on Form N-14 relating to the issuance of shares in connection with the reorganization of certain series of Columbia Acorn Trust (“CAT”) and
(2) the registration statement on Form N-14 relating to the issuance of shares in connection with the reorganization of certain series of Wanger Advisors Trust (“WAT”). Comments and
responses are outlined below.

 The CAT registration statement and the WAT registration statement are each referred to herein as a “Registration
Statement” and are together referred to herein as the “Registration Statements.” CAT and WAT are together referred to herein as the “Registrants.”

CAT REGISTRATION STATEMENT COMMENTS

Comment 1:

All Staff comments made regarding the CAT Registration Statement apply to the WAT Registration Statement unless otherwise indicated.

Response:

The requested disclosure changes pertaining to the CAT Registration Statement will be made in both Registration Statements unless otherwise indicated.

Comment 2:

Pursuant to Rule 488 under the Securities Act of 1933, a registration statement filed on Form N-14 by a registered open-end management investment
company for the purpose of registering securities to be issued in a business combination transaction cannot become effective more than 50 days after it is filed with the Commission. The Registration Statements were filed with the Commission on
December 20, 2022, with a proposed effective date two days beyond the February 8, 2023, close of the 50-day period. Before February 8, 2023, please withdraw the Registration Statements pursuant
to Rule 477 under the Securities Act of 1933 through submission type RW. Then refile each of the Registration Statements with (i) an indication on the facing sheet that the Registration Statement is thereby amended on such date or dates as may
be necessary to delay its effective date until the Registrant shall file a further amendment specifically stating that the Registration Statement shall thereafter become effective in accordance with Section 8(a) of the Securities Act of 1933 or
until the Registration Statement shall become effective on such date as the Commission, acting pursuant to said Section 8(a), may determine and (ii) a request for acceleration to the originally requested effective date of February 10,
2023. If the Staff agrees that the disclosure changes requested by the Staff have been made in the Registration Statements, the Staff is prepared to grant a request for acceleration to the originally requested effective date of February 10,
2023. Please provide the Staff with this Response Letter and marked copies of the Registration Statements no later than February 3, 2023.

Response:

Registrants consider that the stated proposed effective date of February 10, 2023, is a scrivener’s error and have respectfully requested that the Staff permit the filing to go effective on February 8, 2023, which
date would be noted on a pre-effective amendment to each Registration Statement. However, the Registrants will refile the Registration Statements and seek acceleration for an effective date of
February 10, 2023, as suggested.

Comment 3:

Remove the following language from the legal opinion included as an exhibit to the Registration Statement: “We are members of the Bar of the District of Columbia and our opinion, as it relates to the laws of the Commonwealth of
Massachusetts, is based solely on our review of the laws, and, where applicable, published cases, rules or regulations relating thereto, of the Commonwealth of Massachusetts that, in our experience, generally are applicable to the issuance of shares
by entities such as the Trust.” In addition, ensure that the necessary consents are included in the legal opinion.

Response:

The requested changes have been made.

Comment 4:

When the tax opinion is submitted as an exhibit in a post-effective amendment to the Registration Statement, ensure that the necessary consents are included as exhibits.

Response:

The necessary consents have been included.

Comment 5:

Confirm whether the investment objective of the Target Fund and the Acquiring Fund are substantially similar or the same and conform all references throughout the Registration Statement. See for example the discussion on page 2 in
the Q&A and in the letter from the CAT Co-Presidents.

Response:

For the CAT Registration Statement, the investment objective of the Target Fund and the Acquiring Fund are the same and the investment strategies and polices of the Target Fund and the Acquiring Fund are substantially similar. The
disclosure in the CAT Registration Statement has been conformed accordingly. For the WAT Registration Statement, the investment objective and investment strategies of the Target Fund and the Acquiring Fund are the same and the investment policies
are substantially similar. The disclosure in the WAT Registration Statement has been conformed accordingly.

Comment 6:

Confirm whether the fees and expenses borne by Target Fund shareholders as shareholders of the Acquiring Fund will be the same as or lower than the expenses they currently bear and conform all references throughout the Registration
Statement. See for example the discussion on page 3 in the Q&A.

Response:

The fees and expenses borne by Target Fund shareholders as shareholders of the Acquiring Fund will be lower than the expenses they currently bear. The disclosure has been revised accordingly.

Comment 7:

On page 3 in the Q&A, in the discussion regarding fees and expenses following the Reorganization, where any fee waiver/reimbursement agreement is in effect, state that Fund expenses could increase after the expiration of the
agreement, and state the expiration date.

Response:

The requested changes have been made.

Comment 8:

On page 2 in the Q&A, in the discussion of why the board of trustees (the Board”) approved the Reorganization, for factors (iii)—(v), indicate the Board’s understanding of each factor that it considered.

Response:

The requested changes have been made.

Comment 9:

On page 3 in the Q&A, in the discussion of cos