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AMG FUNDS

 ROPES & GRAY LLP

 PRUDENTIAL
TOWER

 800 BOYLSTON STREET

 BOSTON, MA 02199-3600

WWW.ROPESGRAY.COM

 Lisa Mikhail Henry

 T +1 617 951 7780

lisa.henry@ropesgray.com

 April 24, 2024

 VIA
EDGAR

 Ms. Kimberly Browning, Esq.

 Securities and
Exchange Commission

 Division of Investment Management

 100 F
Street, N.E.

 Washington, D.C. 20549

 Re: AMG Funds
(Registration Nos. 333-84639 and 811-09521)

 Dear Ms. Browning:

I am writing on behalf of AMG Funds (the “Trust”) to respond to the comments of the staff (the “Staff”) of the Securities and Exchange
Commission (“SEC”) to Post-Effective Amendment No. 234 (the “485(a) Amendment”) under the Securities Act of 1933, as amended (the “1933 Act”), to the Trust’s Registration Statement on Form N-1A filed on
March 1, 2024, relating to AMG TimesSquare Global Small Cap Fund (the “Fund”). The Trust appreciates this opportunity to respond to the Staff’s comments. The Staff’s comments and the Trust’s responses are set forth
below. Certain defined terms used herein have the meaning set forth in the Fund’s prospectus (the “Prospectus”).

1.
 Comment: To the extent that the registration statement is incomplete, please confirm that the Trust will
provide a complete registration statement in the next registration statement filing.

 Response: The Trust confirms
that it will file a post-effective amendment (the “485(b) Amendment”) to include material information missing from the 485(a) Amendment.

2.
 Comment: If the Trust decline a comment, please say why in the letter along with a detailed analysis of
the reason for declining the comment.

 Response: The Trust acknowledges the Staff’s comment.

3.
 Comment: The Staff notes that all comments are universal and apply to all similar disclosures. The Staff
will not repeat a comment in each place that the disclosure appears, and it is incumbent upon the Trust to apply the comment to all similar disclosure.

Response: The Trust acknowledges the Staff’s comment.

4.
 Comment: Please provide responses to the Staff’s comments as soon as possible. With respect to any
comments that pertain to the Fund’s fee table, expense examples, and portfolio turnover, please provide such responses no less than five business days before the date of effectiveness.

Response: The Trust confirms that it is providing its responses within the timeframes requested by the Staff.

5.
 Comment: In the section titled “Summary of the Funds – Fees and Expenses of the Fund,”
the introduction to the fee table states, “You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.” Please revise this sentence so that it
appears in boldface font, per Item 3 of Form N-1A.

 Response: The requested change has been made.

6.
 Comment: Footnote 1 to the fee table states, “In general, for a period of up to 36 months after the
date any amounts are paid, waived or reimbursed by the Investment Manager, the Investment Manager May recover .... ” The phrase “in general” creates ambiguity. Please remove or explain its meaning in the disclosure.

 Response: The Trust respectfully submits that the referenced disclosure is an accurate summary of the recoupment
provision in the Fund’s expense limitation agreement and that the Investment Manager may only recover amounts that were paid, waived or reimbursed for a period of up to 36 months after the date any such amounts were paid, waived or reimbursed
by the Investment Manager. The Trust believes that the use of the phrase “in general” is appropriate in this context because the disclosure is summarizing a longer contractual provision and notes that it has taken this approach partly in
response to past comments from the Staff requesting the Trust to shorten the disclosure in this footnote.

7.
 Comment: Please disclose that the expense limitation agreement may only be terminated during the
one-year period with the approval of the Trust’s Board of Trustees or explain why the current disclosure regarding termination is adequate.

Response: The Trust notes that the contractual expense limitation agreement may only be terminated by mutual agreement between the
Investment Manager and the Trust’s Board of Trustees, with exceptions for certain enumerated extraordinary events, namely, in the event the Investment Manager or a successor ceases to be the investment manager of the Fund or a successor fund,
or in the event of the Fund’s liquidation unless the Fund is reorganized or is a party to a merger in which the surviving entity is successor to the accounting and performance information of the Fund. The Trust believes that the disclosure in
footnote 1 to the fee table appropriately describes this termination provision and is adequate.

8.
 Comment: The Principal Investment Strategies section states that “TimesSquare considers small cap
companies to be those within with market capitalizations at the time of purchase within the range of capitalizations of companies in the MSCI World Small Cap Index. As of [ ], the date of the latest rebalance of the MSCI World Small Cap Index, the
range of market capitalizations was $[ ] to $[ ].” Please provide the range 5 business days before the effective date of the registration statement. If this will show a range over $5 billion, please explain supplementally why a company at the
top of the range is considered a small capitalization company, taking into account industry indices, classifications used by mutual fund rating organizations, and definitions used in financial publications.

Response: The Trust has revised the above-reference disclosure as follows:

TimesSquare considers small cap companies to be those within with market capitalizations at the time of purchase within the range of
capitalizations of companies in the MSCI World Small Cap Index. As of [
]March 1, 2024, the date of the latest rebalance of the MSCI World Small Cap Index, the range of market
capitalizations was $[ ]31 million to $[ ]16.609
billion.

 The Trust notes that it has the flexibility to adopt a reasonable
definition of the term small-cap. The Trust believes that its definition of small-cap companies is reasonable and consistent with wide-spread industry practice to define small-cap securities by reference to an established securities market index
that focuses on the small cap sector. Other well- established securities market indexes that focus on the small-cap sector similarly include companies with market capitalizations that are substantially greater than the $5 billion level. For example,
the MSCI ACWI Small Cap Index and the Dow Jones U.S. Small- Cap Total Stock Market Index include companies with market capitalizations of up to $13 billion and $15.374 billion, respectively.

9.
 Comment: Please disclose information regarding the reconstitution of the MSCI World Small Cap Index in
either the Item 4 or Item 9.

 Response: The Trust has revised the disclosure in the section
“Summary of the Fund – Principal Investment Strategies” as follows:

 The Fund primarily invests in U.S. and non-U.S. small
cap companies, allocating investments across different countries and regions. TimesSquare considers small cap companies to be those with market capitalizations at the time of purchase within the range of capitalizations of companies in the MSCI
World Small Cap Index. As of [ ]March 1, 2024, the date of the latest rebalance of the MSCI World Small Cap Index, the range of market capitalizations was

$[ ]31
million to $[
]16.609 billion. This capitalization range will change over time. The Index is rebalanced quarterly. The Fund may continue to hold securities of a portfolio company whose market
capitalization subsequently drops below or appreciates above the Fund’s small market capitalization range. Because of this, the Fund may have less than 80% of its net assets in securities of small cap companies at any given time.

10.
 Comment: The Staff notes the reference to emerging market countries in the Fund’s principal
investment strategy disclosure. Please add disclosure explaining how the Fund determines an issuer to be a foreign issuer or an emerging market issuer. This can be added to the Item 9 disclosure. The Staff notes that the MSCI World Market
Index and the MSCI World Market Small Cap Index include developed countries so they should not be the test used for emerging markets.

Response: The Trust respectfully submits that the Fund describes what it considers to be an investment economically tied to a country
other than the U.S. under “Summary of the Fund – Principal Investment Strategies.” With respect to emerging market countries, the Trust notes that the Fund’s principal investment strategies do not include an investment policy
(minimum or maximum) on the Fund’s investments in emerging market countries. Since a country’s categorization as an emerging markets country is not relevant as to whether the Fund may invest in a security, the Trust believes that adding a
test for defining what qualifies as an emerging markets country would add unnecessary complexity to the disclosure without being meaningful to investors.

11.
 Comment: The Fund’s principal investment strategy disclosure refers to ADRs, GDRs, and “other
depositary receipts”. Please disclose the other depositary receipts that the Fund will use as part of its principal investment strategy along with the attendant risks. These can be added to the Item 4 or Item 9 disclosure.

 Response: The Trust notes that the Fund does not invest in depositary receipts as a principal investment
strategy. Therefore, the Trust has revised the Fund’s principal investment strategies as follows: “To gain exposure to foreign issuers, the Fund also may invest in
American Depositary Receipts (“ADRs”), Global Depositary Receipts (“GDRs”) and other depositary receipts of non-U.S. listed companies
and exchange- traded funds.”

12.
 Comment: The Fund’s principal investment strategy disclosure states, “With respect to each
potential investment, TimesSquare prepares an assessment of ESG indicators, as defined by TimesSquare using widely accepted sustainability standards, third-party data and internal expertise, with a focus on financial materiality.” This
disclosure indicates that the Fund uses scores from third party data providers. To the extent the Fund is using specific third party data service providers, they should be identified in Item 4. If there is one primary provider, then that
provider should be identified. Please briefly summarize each party, their criteria, and their methodology in the principal investment strategy. More fulsome clarification can go in the in Item 9. If the Fund is not currently using any third
party data service providers, please note that for the Staff.

 Response: As noted in the disclosure, TimesSquare uses a bottom-up investment process
driven by fundamental investment research conducted by its investment analysts. TimesSquare integrates into its fundamental research process an analysis of ESG data, which is just a part of TimesSquare’s overall investment process. The Trust
notes that the Fund’s disclosure states, “Except with respect to companies that violate such principles, the results of the Subadviser’s ESG assessment alone will not preclude an investment, and an investment could be made in a
company with a poor ESG assessment that meets the Subadviser’s other investment criteria.” Further, in preparing its assessment of ESG indicators, third party data is just one of the inputs used by TimesSquare. Given that the ESG
assessment is part of TimesSquare’s overall investment process and that TimesSquare does not rely solely on third-party data or scoring providers in forming its ESG assessment, the Trust does not believe that a summary of the third party data
providers’ criteria or methodologies is necessary and could potentially confuse investors as to the significance of third-party data. However, in response to this comment, the Trust will revise the Fund’s disclosure as follows:

With respect to each potential investment, TimesSquare prepares an assessment of ESG indicators, as defined by TimesSquare using widely
accepted sustainability standards, third-party data (including MSCI, Inc.) and internal expertise, with a focus on
financial materiality.

13.
 Comment: Please clarify in the Fund’s principal investment strategy disclosure (in the
Item 4) if the screens that that the Fund is using from third party data providers and sustainability standards are applied to all investments.

Response: The Trust confirms that the Subadviser prepares an assessment of ESG indicators for each potential investment, as disclosed in
the Fund’s principal investment strategies.

14.
 Comment: Please consider disclosing the risks related to third party data providers since criteria used
by third parties can differ significantly.

 Response: The Trust has revised ESG Investing Risk as marked below:

 ESG Investing Risk—because applying the Fund’s ESG investment criteria may result in the selection or exclusion of securities
of certain issuers for reasons other than financial performance, the Fund’s investment returns may underperform funds that do not incorporate ESG factors into their investment process. The incorporation of ESG criteria into the investment
process may affect the Fund’s investment exposure to certain companies, sectors, regions, countries or types of investments, which could negatively impact the Fund’s performance depending on whether such investments are in or out of favor.
Applying ESG criteria to investment decisions is qualitative and subjective by nature, and there is no guarantee that the criteria utilized by the Subadviser or any judgment exercised by the Subadviser will improve the financial performance of the
Fund or reflect the beliefs or values of any particular investor. ESG standards differ by region and industry, and a company’s ESG practices or the Subadviser’s assessment of a company’s ESG practices may change over time. The Subadviser’s evaluation of a company also may be dependent on the availability of timely, complete and accurate ESG data reported by issuers and/or third party data
providers. Different methodologies may be used by the various issuers and third party sources that provide ESG data, and such ESG data often lacks standardization, consistency and transparency.

 ESG Investing Risk. Applying the Fund’s ESG investment criteria may be viewed as
providing opportunities for long-term rather than short-term returns, and may result in the selection or exclusion of securities of certain issuers for reasons other than financial performance. As a result, the Fund may forego opportunities to buy
certain securities when it might be otherwise advantageous to do so, or sell certain securities when it might be otherwise disadvantageous to do so. ESG investing also carries the risk that the Fund’s investment returns may underperform funds
that do not incorporate ESG factors into their investment process. The incorporation of ESG criteria into the investment process may affect the Fund’s investment exposure to certain companies, sectors, regions, countries or types of
investments, which could negatively impact the Fund’s performance, depending on whether such investments are in or out of favor. Applying ESG criteria to investment decisions is qualitative and subjective by nature, and there is no guarantee
that the criteria utilized by the Subadviser or any judgment exercised by the Subadviser will improve the financial performance of the Fund or reflect the beliefs or values of any particular investor. In evaluating a company, the Subadviser is
dependent upon information and data obtained through voluntary or third-party reporting by issuers or reporting by third-party data providers that may be incomplete, inaccurate or unavailable, which could cause
the Subadviser to incorrectly assess a compan