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SEC Correspondence Voya Funds Trust

VOYA INVESTMENT MANAGEMENT

7337 EAST DOUBLETREE RANCH ROAD, SUITE 100 SCOTTSDALE, AZ 85258

February 1, 2023

VIA EDGAR

Ms. Jaea F. Hahn, Esq.

Staff Counsel

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

   RE:

   Voya Funds Trust (the "Registrant")

   (File Nos. 333-59745; 811-08895)

Dear Ms. Hahn:

This letter responds to comments provided by telephone on January 10, 2023, by the Staff (the "Staff") of the U.S. Securities and Exchange Commission (the "SEC") with respect to Post-Effective Amendment No. 122 (the "Amendment") to the Registrant's Registration Statement on Form N-1A (the "Registration Statement"). This Amendment was filed with the SEC, via the EDGAR system, pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the "1933 Act"), on November 22, 2022. Our summary of the comments and our responses thereto are provided below. Capitalized terms used but not defined herein have the meanings assigned to them in the Registration Statement. The Registrant intends to file a future post-effective amendment pursuant to Rule 485(b) under the 1933 Act to, as applicable: (i) reflect the revisions discussed herein in response to the Staff's comments; (ii) make certain non-material changes, as appropriate; and (iii) file exhibits to the Registration Statement.

GENERAL

1.Comment: The Staff requested that the Registrant confirm that the Secretary for the Trust (the "Secretary") is authorized to sign the Registration Statement on behalf of the Registrant.

Response: The Registrant confirms that the Secretary is authorized to sign the Registration Statement on behalf of the Registrant. Section 3.7 of the Amended and Restated By-Laws for the Registrant state that "[t]he Secretary shall perform such additional duties as the Trustees may from time to time designate." In addition, the Board of Trustees of the Registrant took the following action at its meeting held on September 30, 2022:

RESOLVED, that the officers of Voya Funds Trust ("VFT"), on behalf of Voya Short Duration High Income Fund (the "Fund"), be, and each hereby is, authorized and directed to take all acts which such officers deem, in their discretion, necessary or desirable to prepare, execute, and file with the U.S. Securities and Exchange Commission a post-effective amendment to VFT's Registration Statement filed on Form N-1A under the Investment Company Act of 1940, for the purpose of registering shares of the Fund; and to take such other actions as may be deemed necessary or desirable by such officers or on the advice of counsel in connection with the registration of the Fund and its shares under such laws.

Based on the foregoing, the Registrant believes that the Secretary is authorized to sign the Registration Statement consistent with their duties as Secretary.

Ms. Jaea Hahn, Esq.

U.S. Securities and Exchange Commission

February 1, 2023

Page | 2

FEES AND EXPENSES OF THE FUND

2.Comment: The Staff requested that the Registrant confirm that if estimated acquired fund fees and expenses for Voya Short Duration High Income Fund (the "Fund") are over one basis point, the Fund will include a line item for acquired fund fees and expenses in the Fund's Annual Fund Operating

Expenses table.

Response: The Registrant confirms that the Fund does not expect acquired fund fees and expenses to be over one basis point and therefore a line item for acquired fund fees and expenses in the Fund's Annual Fund Operating Expenses table will not be included.

PRINCIPAL INVESTMENT STRATEGIES

3.Comment: The Staff requested that the Registrant explain the significance of the following

sentence: "The Fund may invest up to 10% of its net assets in securities rated CCC or below (or the equivalent) by S&P, Moody's, or Fitch, or in unrated securities determined by the Sub-Adviser to be of comparable quality."

Response: As disclosed in the Principal Investment Strategies, under normal market conditions, the Fund will invest at least 80% of its net assets (plus borrowings for investment purposes) in debt securities issued by public and private companies, which, at the time of purchase, are rated below investment grade. Although the investments cited by the Staff are also rated below investment grade, the Registrant believes it is appropriate to disclose that those investments may include securities in the lowest rating categories and that those investments are limited to 10% of the Fund's net assets.

4.Comment: The Staff requested that the Registrant supplementally explain how the Fund's investment strategy is appropriate for an open-end fund. The Staff noted that the response may include information regarding the relevant factors referenced in the Investment Company Liquidity Risk Management Programs, Release Nos. 33-10233; IC-32315 (Oct. 13, 2016) and may also include general market data with respect to the types of investments the Fund intends to hold.

Response: Consistent with Rule 22e-4 under the Investment Company Act of 1940, as amended, the Fund will adopt a liquidity risk management program to govern its approach to managing liquidity risk (the "Program"). The Board of Trustees of the Registrant has approved the designation of the Fund's investment adviser, Voya Investments, LLC (the "Investment Adviser"), as the program administrator (the "Program Administrator"). The Program Administrator will be responsible for implementing and monitoring the Program and the Program Administrator has formed a Liquidity Risk Management Committee (the "Committee") that will assess and review, on an ongoing basis, the Fund's liquidity risk. The Program will include a number of elements that support the management and assessment of liquidity risk, including an annual assessment of liquidity risk factors and the periodic classification (or re-classification, as necessary) of the Fund's investments into buckets (highly liquid, moderately liquid, less liquid and illiquid) that reflect the Committee's assessment of the investments' liquidity under current market conditions. The Committee also will utilize fund-specific data, including information regarding the Fund's shareholder base, characteristics of its investments, access to borrowing arrangements and anticipated redemptions in considering the Fund's ability to meet its redemption obligations in a timely manner.

It is anticipated that the Fund's investments will be readily tradeable and generally consist of non- investment grade debt securities issued by public companies with relatively short maturities. As a general matter, these types of investments are relatively standardized and settle on a T+2 basis. The Investment Adviser believes that the Fund's principal investment strategies are appropriate for an open-

Ms. Jaea Hahn, Esq.

U.S. Securities and Exchange Commission

February 1, 2023

Page | 3

end fund (and the liquidity of the Fund's portfolio is consistent with the Fund's status as an open-end fund) when viewed in light of the above and, among other things, the terms and operation of the Program and other factors that mitigate the Fund's liquidity risk, including the Fund's ability to honor redemptions through distribution of securities in kind.

5.Comment: The Staff requested that, in reference to the following sentence, the Registrant

describe in greater detail the types of loans in which the Fund expects to invest: "[t]he Fund may invest up to 20% of its assets in bank loans and floating rate secured loans, which may be included among the Fund's high-yield securities for purposes of the 80% policy described above." The Staff further requested that the Registrant add risk disclosure to the extent the Fund intends to invest in collateralized loan obligations or covenant lite loans as part of its principal investment strategies.

Response: The Registrant appreciates the Staff's comment but respectfully declines to make the requested disclosure changes to the Fund's principal investment strategies because the Registrant believes that references to "bank loans and floating rate secured loans" adequately describe potential investments for the Fund. The Registrant confirms that the Fund will not invest in collateralized loan obligations as part of its principal investment strategies. The Registrant confirms that the Fund may invest in loans that are considered "covenant-lite" loans and notes the following disclosure is included in the Fund's Statement of Additional Information and also will be added to the "Principal Risks" and "Additional Information About the Principal Risks" sections in the summary and statutory portions, respectively, of the Fund's Prospectus:

Covenant-Lite Loans: Loans in which the Fund may invest or to which the Fund may gain exposure indirectly through its investments in collateralized debt obligations, CLOs or other types of structured securities may be considered "covenant-lite" loans. Covenant-lite refers to loans which do not incorporate traditional performance-based financial maintenance covenants. Covenant-lite does not refer to a loan's seniority in the borrower's capital structure nor to a lack of the benefit from a legal pledge of the borrower's assets, and it also does not necessarily correlate to the overall credit quality of the borrower. Covenant-lite loans generally do not include terms which allow the lender to take action based on the borrower's performance relative to its covenants. Such actions may include the ability to renegotiate and/or re-set the credit spread on the loan with the borrower, and even to declare a default or force a borrower into bankruptcy restructuring if certain criteria are breached. Covenant-lite loans typically still provide lenders with other covenants that restrict a company from incurring additional debt or engaging in certain actions. Such covenants can only be breached by an affirmative action of the borrower, rather than by a deterioration in the borrower's financial condition. Accordingly, the Fund may have fewer rights against a borrower when it invests in or has exposure to covenant-lite loans and, accordingly, may have a greater risk of loss on such investments as compared to investments in or exposure to loans with additional or more conventional covenants.

6.Comment: The Staff noted that the Fund may invest up to 20% of its assets in foreign (non-U.S.) securities and requested that the Registrant disclose if the Fund may also invest in issuers of emerging market countries.

Response: The Registrant appreciates the Staff's comment. Although, at times, the Fund may invest in issuers of emerging market countries, it does not have a strategy to principally invest in such issuers. However, the Registrant will update the "Asset Class/Investment Technique" table in the

Statement of Additional Information to indicate that "Emerging Market Investments" is appliable to the Fund.

Ms. Jaea Hahn, Esq.

U.S. Securities and Exchange Commission

February 1, 2023

Page | 4

7.Comment: The Staff noted that the Fund may invest in bank loans and requested that the Registrant supplementally explain how the Fund intends to meet short term liquidity needs resulting from lengthy settlement periods of these types of investments.

Response: The Registrant notes that the Fund intends to keep adequate cash and other liquid assets the Investment Adviser considers adequate to meet shareholder redemptions.

PRINCIPAL RISKS

8.Comment: The Staff requested that, pursuant to ADI 2019 08 – Improving Principal Risks

Disclosure, the "Principal Risks" section be prioritized in order of those most likely to adversely affect the Fund's net asset value, yield, and total return first, followed by the remaining risks placed in alphabetical order.

Response: The Registrant believes that the current risk disclosure, including the alphabetical ordering of the list of the Fund's principal risks, is appropriate and consistent with Item 4 of Form N-1A, which requires that a fund summarize, based on disclosure in Item 9, the principal risks of investing in the fund, including the risks to which the fund's portfolio "as a whole" is subject. Form N-1A does not contemplate any particular ordering of the risks summarized in Item 4. Additionally, the Registrant believes that rank-ordering risks as the Staff suggests could create the risk that investors would mistakenly minimize or ignore risks that appear at the end or near the end of such a rank-ordered list of risks and is concerned that such a circumstance could cause an investor not to appreciate fully all of the principal risks to which the Fund's portfolio, as a whole, is subject.

Notwithstanding the foregoing, the Registrant notes that the following disclosure is included at the beginning of the "Principal Risks" and "Additional Information About the Principal Risks" sections in the summary and statutory portions, respectively, of the Fund's Prospectus:

The principal risks are presented in alphabetical order to facilitate readability, and their order does not imply that the realization of one risk is more likely to occur or have a greater adverse impact than another risk.

9.Comment: The Staff noted that the Fund may invest in derivatives including "credit default swaps, interest rate swaps, and futures contracts" and requested that the Fund include principal risk disclosure as to interest rate swaps and futures contracts, similar to that provided in the principal risk titled "Credit

Default Swaps."

Response: The Registrant notes that the Fund includes the following principal risk, which the Registrant believes adequately discloses the risks attributable to the Fund's investments in derivatives, including interest rate swaps and futures contracts. Accordingly, the Registrant respectfully declines to make the requested disclosure changes:

Derivative Instruments: Derivative instruments are subject to a number of risks, including the risk of changes in the market price of the underlying asset, reference rate, or index credit risk with respect to the counterparty, risk of loss due to changes in market interest rates, liquidity risk, valuation risk, and volatility risk. The amounts required to purchase certain derivatives may be small relative to the magnitude of exposure assumed by the Fund. Therefore, the purchase of certain derivatives may have an economic leveraging effect on the Fund and exaggerate any increase or decrease in the net asset value. Derivatives may not perform as expected, so

Ms. Jaea Hahn, Esq.

U.S. Securities and Exchange Commission

February 1, 2023

Page | 5

the Fund may not realize the intended benefits. When used for hedging purposes, the change in value of a derivative may not correlate as expected with the asset, reference rate, or index being hedged. When used as an alternative or substitute for direct cash investment, the return provided by the derivative may not provide the same return as direct cash investment.

10.Comment: The Staff noted that the Fund includes "Focused Investing" as a principal risk and

requested that the Registrant do the following: (i) confirm this is a principal risk for the Fund; and (ii) if so, add corresponding disclosure to the Fund's principal investment strategies.

Response: The Fund has removed the referenced principal risk.

11.Comment: The Staff noted that the principal risk titled "Interest in Loans" states that "[a]lthough loans may be fully collateralized when purchased, such collateral may become illiquid or decline in value." The Staff requested that the Registrant clarify whether the Fund is required to sell its interest in a loan if the collateral of such loan becomes illiquid following its purchase or if the Fund is permitted to retain such an investment.

Response: The Registrant notes that the Fund is not required to divest an interest in a loan (or other investment) if the collateral of