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CORRESP
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    September
    23, 2020

    VIA
    EDGAR CORRESPONDENCE

    Securities
    and Exchange Commission

    100
    F Street, NE

    Washington,
    DC  20549

    Attention:  Ms.
    Elena Stojic

    Re:
    The
    Arbitrage Funds (Registration No. 333-30470/811-09815)

    Response
    to Examiner Comments on Post-Effective

Amendment
No. 47

Dear:  Ms.
Stojic:

This
letter responds to your comments provided via telephone on September 14, 2020 and September 22, 2020 to Post-Effective Amendment
No. 47 (“PEA No. 47”) to the Registration Statement on Form N-1A of The Arbitrage Funds (the “Registrant”)
filed on July 31, 2020. The name of Water Island Diversified Event-Driven Fund is changing to Water Island Event-Driven Fund effective
September 30, 2020. For clarity, the Registrant has chosen to use the new Fund name throughout this correspondence.

Staff
Comments with respect to PEA No. 47 generally or to more than one Fund

1. Comment:        For
                                         each Fund please provide the final fee table including filling in all bracketed information
                                         as the Staff believes this information is material to its review.

 Response:        Final
                                         fee tables for each Fund are included below.

Fees and Expenses Table of
Arbitrage Fund

This
table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. You may qualify for sales charge
discounts on Class A Shares if you and your family invest, or agree to invest in the future, at least $50,000 in the Fund. More
information about these and other discounts is available from your financial professional and in “How to Purchase Shares”
beginning on page 56 of the statutory prospectus and in Appendix A to the prospectus, titled “Intermediary-Specific Sales
Charge Reductions and Waivers.”

Shareholder
Fees (fees paid directly from your investment)

    Class
    R

    Shares
    Class
    I

    Shares
    Class
    C

    Shares
    Class
    A

    Shares

    Maximum
    Sales Charge (Load) Imposed

    on Purchases (as a percentage of

    offering price)
    None
    None
    None
    2.75%

    Maximum
    Deferred Sales Charge (Load)

    (as a percentage of original purchase

    price)
    None
    None
    1.00%(1)
    1.00%(2)

Annual Fund Operating Expenses (expenses that you pay
each year as a

percentage of the value of your investment)

    Class
    R

    Shares
    Class
    I

    Shares
    Class
    C

    Shares
    Class
    A

    Shares

    Management
    Fees
    1.06%
    1.06%
    1.06%
    1.06%

    Distribution
    and/or Service (12b-1) Fees
    0.25%
    None
    1.00%
    0.25%

    Other
    Expenses
    0.35%
    0.35%
    0.35%
    0.35%

    Dividend
    on Short Positions and

    Interest Expense on Short Positions

    and/or Borrowings
    0.16%
    0.16%
    0.16%
    0.16%

    All
    Remaining Other Expenses
      0.19%
    0.19%
    0.19%
    0.19%

    Acquired
    Fund Fees and Expenses(3)
    0.05%
    0.05%
    0.05%
    0.05%

    Total
    Annual Fund Operating Expenses(4)
    1.71%
    1.46%
    2.46%
    1.71%

 (1) This
                                         contingent deferred sales charge applies to Class C shares redeemed within 12 months
                                         of purchase.

 (2) A
                                         deferred sales charge of up to 1.00%
                                         may be imposed on purchases of $250,000 or more of
                                         Class A shares purchased without a front-end sales charge that are redeemed within 18
                                         months of purchase.

 (3) Acquired
                                         Fund Fees and Expenses are expenses incurred indirectly by the Fund through its ownership
                                         of shares in other investment companies.

 (4) The
                                         Total Annual Fund Operating Expenses in this fee table do not correlate to the expense
                                         ratio in the financial highlights because the expense ratios in the Financial Highlights
                                         do not reflect Acquired Fund Fees and Expenses.

Fees and Expenses Table of Water Island Event-Driven Fund

This table describes the fees and expenses
that you may pay if you buy and hold shares of the Fund. You may qualify for sales charge discounts on Class A Shares if you and
your family invest, or agree to invest in the future, at least $100,000 in the Fund. More information about these and other discounts
is available from your financial professional and in “How to Purchase Shares” beginning on page 56 of the statutory
prospectus and in Appendix A to the prospectus, titled “Intermediary-Specific Sales Charge Reductions and Waivers.”

Shareholder Fees (fees paid directly from your investment)

    Class
    R

    Shares
    Class
    I

    Shares
    Class
    C

    Shares
    Class
    A

    Shares

    Maximum
    Sales Charge (Load) Imposed

    on Purchases (as a percentage of

    offering price)
    None
    None
    None
    3.25%

    Maximum
    Deferred Sales Charge (Load)

    (as a percentage of original purchase

    price)
    None
    None
    1.00%(1)
    1.00%(2)

Annual Fund Operating Expenses (expenses that you pay
each year as a

percentage of the value of your investment)

    Class
    R

    Shares
    Class
    I

    Shares
    Class
    C

    Shares
    Class
    A

    Shares

    Management
    Fees(3)
    1.10%
    1.10%
    1.10%
    1.10%

    Distribution
    and/or Service (12b-1) Fees
    0.25%
    None
    1.00%
    0.25%

    Other
    Expenses
        0.70%
    0.70%
    0.70%
    0.70%

    Dividend
    on Short Positions and

    Interest Expense on Short Positions

    and/or Borrowings
    0.14%
    0.14%
    0.14%
    0.14%

    All
    Remaining Other Expenses
    0.56%
    0.56%
    0.56%
    0.56%

    Acquired
    Fund Fees and Expenses(4)
    0.01%
    0.01%
    0.01%
    0.01%

    Total
    Annual Fund Operating Expenses
    2.06%
    1.81%
    2.81%
    2.06%

    Fee
    Waiver(5)
    (0.22)%
    (0.22)%
    (0.22)%
    (0.22)%

    Total
    Annual Fund Operating Expenses After Fee Waiver(6)
    1.84%
    1.59%
    2.59%
    1.84%

 (1) This
                                         contingent deferred sales charge applies to Class C shares redeemed within 12 months
                                         of purchase.

 (2) A
                                         deferred sales charge of up to 1.00% may be imposed on purchases of $250,000 or more
                                         of Class A shares purchased without a front-end sales charge that are redeemed within
                                         18 months of purchase.

 (3) Management
                                         fees have been restated to reflect the Fund’s current management fees effective
                                         November 1, 2019.

 (4) Acquired
                                         Fund Fees and Expenses are expenses incurred indirectly by the Fund through its ownership
                                         of shares in other investment companies.

 (5) The
                                         Fund has entered into an Expense Waiver and Reimbursement Agreement with the Fund’s
                                         investment adviser pursuant to which the adviser has contractually agreed to limit the
                                         total annual operating expenses of the Fund, not including taxes, interest, dividends
                                         on short positions, brokerage commissions, acquired fund fees and expenses and other
                                         costs incurred in connection with the purchase or sale of portfolio securities, so that
                                         they do not exceed 1.69% of the Fund’s average daily net assets allocable to the
                                         Class R shares, 1.44% of the Fund’s average daily net assets allocable to the Class
                                         I shares, 2.44% of the Fund’s average daily net assets allocable to the Class C
                                         shares, and 1.69% of the Fund’s average daily net assets allocable to the Class
                                         A shares. The agreement remains in effect until September 30, 2021 unless terminated
                                         at an earlier time by the Fund’s Board of Trustees. The adviser may recoup any
                                         waived amount from the Fund pursuant to the agreement, if such recoupment does not cause
                                         the Fund to exceed existing expense limitations in effect at the time the amounts were
                                         waived, the recoupment does not cause the Fund to exceed the current expense limitation
                                         and the recoupment is done within three years after the date on which the expense was
                                         waived.

 (6) The
                                         Total Annual Fund Operating Expenses in this fee table do not correlate to the expense
                                         ratio in the financial highlights because the expense ratios in the Financial Highlights
                                         do not reflect Acquired Fund Fees and Expenses or the restated management fees.

Fees and Expenses Table of Water Island Long/Short Fund

This table describes the fees and expenses
that you may pay if you buy and hold shares of the Fund.

Shareholder Fees (fees paid directly from your investment)

    Class
    R Shares
    Class
    I Shares

    Maximum
    Sales Charge (Load) Imposed on Purchases (as a

    percentage of offering price)
    None
    None

    Maximum
    Deferred Sales Charge (Load) (as a percentage of

    original purchase price)
    None
    None

Annual Fund Operating Expenses (expenses that you pay
each year as a

percentage of the value of your investment)

    Class
    R Shares
    Class
    I Shares

    Management
    Fees
    1.25%
    1.25%

    Distribution
    and/or Service (12b-1) Fees
    0.25%
    None

    Other
    Expenses
    11.29%
    11.28%

    Dividend
    on Short Positions and Interest Expense on

    Short Positions and/or Borrowings
    0.23%
    0.22%

    All
    Remaining Other Expenses
    11.06%
    11.06%

    Acquired
    Fund Fees and Expenses(1)
    0.05%
    0.05%

    Total
    Annual Fund Operating Expenses
    12.84%
    12.58%

    Fee
    Waiver(2)
    (10.87)%
    (10.87)%

    Total
    Annual Fund Operating Expenses After Fee Waiver(3)
    1.97%
    1.71%

 (1) Acquired
                                         Fund Fees and Expenses are expenses incurred indirectly by the Fund through its ownership
                                         of shares in other investment companies.

 (2) The
                                         Fund has entered into an Expense Waiver and Reimbursement Agreement with the Fund’s
                                         investment adviser pursuant to which the adviser has contractually agreed to limit the
                                         total annual operating expenses of the Fund, not including taxes, interest, dividends
                                         on short positions, brokerage commissions, acquired fund fees and expenses and other
                                         costs incurred in connection with the purchase or sale of portfolio securities, so that
                                         they do not exceed 1.69% of the Fund’s average daily net assets allocable to the
                                         Class R shares and 1.44% of the Fund’s average daily net assets allocable to the
                                         Class I shares. The agreement remains in effect until September 30, 2021 unless terminated
                                         at an earlier time by the Fund’s Board of Trustees. The adviser may recoup any
                                         waived amount from the Fund pursuant to the agreement, if such recoupment does not cause
                                         the Fund to exceed existing expense limitations in effect at the time the amounts were
                                         waived, the recoupment does not cause the Fund to exceed the current expense limitation
                                         and the recoupment is done within three years after the date on which the expense was
                                         waived.

 (3) The
                                         Total Annual Fund Operating Expenses in this fee table do not correlate to the expense
                                         ratio in the financial highlights because the expense ratios in the Financial Highlights
                                         do not reflect Acquired Fund Fees and Expenses.

Fees and Expenses Table of Water Island Credit Opportunities
Fund

This table describes the fees and expenses
that you may pay if you buy and hold shares of the Fund. You may qualify for sales charge discounts on Class A Shares if you and
your family invest, or agree to invest in the future, at least $100,000 in the Fund. More information about these and other discounts
is available from your financial professional and in “How to Purchase Shares” beginning on page 56 of the statutory
prospectus and in Appendix A to the prospectus, titled “Intermediary-Specific Sales Charge Reductions and Waivers.”

Shareholder Fees (fees paid directly from your investment)

    Class
    R

    Shares
    Class
    I

    Shares
    Class
    C Shares
    Class
    A Shares

    Maximum
    Sales Charge (Load) Imposed

    on Purchases (as a percentage of

    offering price)
    None
    None
    None
    3.25%

    Maximum
    Deferred Sales Charge (Load)

    (as a percentage of original purchase

    price)
    None
    None
    1.00%(1)
    1.00%(2)

Annual Fund Operating Expenses (expenses that you pay
each year as a

percentage of the value of your investment)

    Class
    R

    Shares
    Class
    I

    Shares
    Class
    C

    Shares
    Class
    A

    Shares

    Management
    Fees
    0.95%
    0.95%
    0.95%
    0.95%

    Distribution
    and/or Service (12b-1) Fees
    0.25%
    None
    1.00%
    0.25%

    Other
    Expenses
    0.76%
    0.76%
    0.76%
    0.76%

    Dividend
    on Short Positions and

    Interest Expense on Short Positions

    and/or Borrowings
    0.12%
    0.12%
    0.12%
    0.12%

    All
    Remaining Other Expenses
    0.64%
    0.64%
    0.64%
    0.64%

    Acquired
    Fund Fees and Expenses(3)
    0.01%
    0.01%
    0.01%
    0.01%

    Total
    Annual Fund Operating Expenses
    1.97%
    1.72%
    2.72%
    1.97%

    Fee
    Waiver(4)
    (0.61)%
    (0.61)%
    (0.61)%
    (0.61)%

    Total
    Annual Fund Operating Expenses After Fee Waiver(5)
    1.36%
    1.11%
    2.11%
    1.36%

 (1) This
                                         contingent deferred sales charge applies to Class C shares redeemed within 12 months
                                         of purchase.

 (2) A
                                         deferred sales charge of up to 1.00% may be imposed on purchases of $250,000 or more
                                         of Class A shares purchased without a front-end sales charge that are redeemed within
                                         18 months of purchase.

 (3) Acquired
                                         Fund Fees and Expenses are expenses incurred indirectly by the Fund through its ow