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CORRESP

 Brighthouse Investment Advisers, LLC

One Financial Center

 Boston, MA 02111

brighthousefinancial.com

 January 11, 2022

U.S. Securities and Exchange Commission

 Division of Investment
Management

 100 F Street, N.E.

 Washington, DC 20549

Attn: Sonny Oh, Esq. and Tony Burak

Re:
 Brighthouse Funds Trust I (Registration No. 333-261439)

Dear Messrs. Oh and Burak:

 This letter responds to the comments
of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by telephone on December 27 and December 28, 2021, regarding the above-referenced registration statement on
Form N-14 (the “Registration Statement”) of Brighthouse Funds Trust I (the “Registrant”), filed with the Commission on December 1, 2021, pursuant to Rule 488 under the
Securities Act of 1933, as amended (the “Securities Act”). The Staff’s comments are summarized below, and each is followed by our response. Any terms that are used but not defined in this letter have the same meaning as used in
the Registration Statement.

 General Comments

1.
 Comment: The Staff reminds you that the Registrant is responsible for the accuracy and adequacy of its
disclosure, notwithstanding any review, comment, action or absence of action by the Staff. In addition, where a comment is made with respect to disclosure in one location, it may be applicable to other places in the Registration Statement.

 Response: The Registrant acknowledges its responsibility for the accuracy and adequacy of disclosure in the
Registration Statement. The Registrant further acknowledges that a Staff comment relating to one section of the Registration Statement may be applicable to other sections of the Registration Statement.

2.
 Comment: The Staff has taken the position that certain factors generally should be considered in
determining which Portfolio’s historical performance should be presented following a reorganization. See North American Security Trust, SEC No-Action Letter (pub. avail. Aug. 5, 1994)
(“North American Security Trust”). Because it is expected that the Selling Portfolio will be the accounting survivor, please supplementally describe the factors that serve as the basis for such expectation.

 Response: Since its inception in May 2011 through December 14, 2021, the Buying
Portfolio was subadvised by AQR Capital Management, LLC (“AQR”) using principal investment strategies different from those of the Selling Portfolio and the post-Reorganization Buying Portfolio. As of December 15, 2021, the
Buying Portfolio is subadvised by PanAgora Asset Management, Inc. (“PanAgora”) using principal investment strategies substantially identical to those that have been employed by PanAgora in managing the Selling Portfolio since its
inception in 2014. In addition, as of December 15, 2021, the Buying Portfolio’s portfolio management team is the same as that which is responsible for managing the Selling Portfolio, a majority of which has been managing the Selling
Portfolio since its inception in 2014. Accordingly, BIA believes that the performance history of the Selling Portfolio better reflects the principal investment strategies, subadviser and portfolio management team that will be in place for the Buying
Portfolio following the Reorganization.

 In contrast, nearly the entire performance history of the Buying Portfolio was achieved by a
subadviser, AQR, and portfolio management team that will have no role in managing the post-Reorganization Buying Portfolio. All of the Buying Portfolio’s performance history prior to December 15, 2021, was achieved using principal
investment strategies that differ from those currently used by the Buying Portfolio.

 BIA does not believe that the other factors cited in
North American Security Trust support a different result. For example, the Portfolios’ investment objectives are identical, their expense structures are substantially similar and, while their asset bases materially differ, BIA does not
believe that such difference changes the conclusion as to which Portfolio’s historical performance is more representative of the principal investment strategies and management of the post-Reorganization Buying Portfolio.

3.
 Comment: Please confirm that the only share class implicated in the proposed Reorganization is
Class B.

 Response: The Registrant so confirms.

4.
 Comment: The Staff notes that, as of the date of the initial Registration Statement relating to the
Reorganization, the Buying Portfolio had not been renamed “PanAgora Global Diversified Risk Portfolio II.” Please explain the use of this name throughout the Registration Statement.

Response: As reflected in supplements filed by the Registrant on December 1, 2021, AQR Global Risk Balanced Portfolio (i.e.,
the Buying Portfolio) was renamed “PanAgora Global Diversified Risk Portfolio II,” as of December 15, 2021.

5.
 Comment: Please consider revising the defined terms “Buying Portfolio” and “Selling
Portfolio” throughout the Registration Statement to read “Acquiring Portfolio” and “Target Portfolio,” respectively.

 Response: The Registrant respectfully declines to make this change. The adjectives
“Buying” and “Selling” are plain English terms. However, the Registrant will take this comment under advisement for future reorganization-related filings.

6.
 Comment: The Staff noted certain inconsistencies throughout the Registration Statement with respect to
references to the Buying Portfolio. Please ensure any such references are corrected, as appropriate.

 Response:
The requested corrections have been made.

 Q&A Section

7.
 Comment: The Staff noted the following disclosure under the question, “What is the proposal?”:
“The Participating Insurance Company that issued your Contract is the legal owner of the Selling Portfolio’s shares and will vote those shares at a joint special meeting of shareholders of the Selling Portfolio. However, as a Contract
Owner, you are entitled to instruct that Participating Insurance Company how to vote the shares attributable to your Contract.” Please disclose how shares will be voted if a Contract Owner does not provide instructions to the applicable
Participating Insurance Company.

 Response: The following disclosure has been added under the subject question:

 Each Participating Insurance Company intends to vote shares of which it is the legal owner and for which no voting instructions are
provided in the same proportion as the shares it owns and for which voting instructions have been provided.

 Combined Proxy Statement/Prospectus
(“Prospectus”)

8.
 Comment: The Staff noted the following disclosure in Section A under “How the Reorganization Will
Work”: “The costs of the Reorganization (excluding the costs associated with repositioning the portfolio holdings of the Selling Portfolio in connection with the December 15, 2021 change in its subadviser, which have already been
incurred by the Selling Portfolio) will be borne by the subadviser of the Buying Portfolio.” Please confirm whether references to the Buying Portfolio and Selling Portfolio in this disclosure are accurate and make any appropriate revisions.

 Response: The subject disclosure has been revised to read:

The costs of the Reorganization will be borne by the subadviser of the Buying Portfolio, except for the costs associated with repositioning
certain portfolio assets of the Selling Portfolio in connection with the Reorganization, which are estimated to be approximately $350,0000 (or 15 basis points) and will be borne by the Selling Portfolio.

9.
 Comment: The Staff notes that certain fee and expense information presented throughout the Registration
Statement is dated as of December 31, 2020. Please confirm whether all fee and expense information presented in the Registration Statement is current and make any appropriate revisions.

 Response: The Registrant confirms that all fee and expense information presented
throughout the Registration Statement is accurate as of the date indicated, and BIA does not believe that any updates or revisions are necessary at this time.

10.
 Comment: In the footnotes to the fee and expense tables under “Current and Pro Forma Expenses”
in Section A, please disclose whether BIA will retain the right to recoup any previously waived Selling Portfolio fees after the Reorganization.

Response: The Registrant respectfully declines to add such disclosure, as BIA does not, and following the Reorganization will not,
retain any right to recoup previously waived fees.

11.
 Comment: Please ensure the formatting of the fee and expense tables under “Current and Pro Forma
Expenses” in Section A is accurate.

 Response: The Registrant has revised the formatting of the fee and
expense tables under “Current and Pro Forma Expenses” in Section A.

12.
 Comment: Under “Comparison of Performance” in Section A, please provide a narrative comparison
of the performance of the Buying Portfolio and Selling Portfolio.

 Response: The requested change has been made.

13.
 Comment: Under “Tax Status of the Reorganization” in Section A, please make the following
disclosure bold: “Although it is not expected to affect Contract Owners or investors that hold shares in tax-advantaged accounts, as a result of the Reorganization, each Portfolio participating in the
Reorganization may lose the benefit of certain tax losses that could have been used to offset or defer future gains of the combined Portfolio, and the combined Portfolio will have tax attributes that reflect a blending of the tax attributes of each
Portfolio at the time of the Reorganization.”

 Response: The Registrant respectfully declines to make the
requested revision, as all accounts in the Buying Portfolio and Selling Portfolio are tax-advantaged accounts.

14.
 Comment: Under “Reasons for the Proposed Reorganization and Board Deliberations” in Section A,
please: (i) discuss BIA’s basis for proposing the Reorganization to the Board; and (ii) disclose material adverse factors the Board considered, if any, in connection with its approval of the Reorganization.

Response: The Registrant has reviewed the disclosure under the heading “Reasons for the Proposed Reorganization and Board
Deliberations” and respectfully submits that it, as revised in accordance with Registrant’s response to #15 below, together with all of the other information in the Prospectus, appropriately summarizes the information presented to the
Board by management in connection with the Reorganization proposal and the Board’s deliberations regarding such proposal, all in accordance with the relevant disclosure items in Form N-14.

15.
 Comment: Under “Reasons for the Proposed Reorganization and Board Deliberations” in Section A,
the Staff noted the following disclosure [emphasis added]: “…BIA also recommended that the Board approve the Reorganization in order to offer investors a risk parity strategy at scale…” and “…while
shareholders of the Buying Portfolio would experience a somewhat different risk parity strategy with better prior performance and lower fees…” Please explain the italicized phrases relating to the risk parity strategy
in plain English.

 Response: The Registrant has replaced the referenced disclosure with disclosure more tailored
for Contract Owners who will receive the Prospectus, including by replacing the referenced language with the following:

 “BIA also
recommended that the Board approve the Reorganization to offer investors in the Selling Portfolio the opportunity to continue to invest in a Portfolio with the same principal investment strategies, subadviser and portfolio managers, though in a
post-Reorganization Buying Portfolio with significantly greater current scale and, thus, greater potential to maintain scale over time.”

References to “a somewhat different risk parity strategy” were removed because on December 15, 2021, the Buying Portfolio began
to invest in accordance with principal investment strategies identical to those of the Selling Portfolio.

16.
 Comment: Under “Board Recommendation and Required Vote” in Section A, please explain how
shareholders will be notified of the outcome of the proxy vote, and whether the closing conditions of the Reorganization have been met.

Response: The Registrant respectfully submits that Form N-14 and Rule 14a-101 under the Securities Exchange Act of 1934, as amended, do not require that the Registrant disclose how shareholders will be notified of the outcome of the proxy vote, or whether the closing conditions of the
Reorganization have been met. However, BIA believes that Contract Owners affected by the Reorganization will be notified of the closing of the Reorganization no later than the delivery of their next regular account statement.

17.
 Comment: The Staff noted the following disclosure in Section B under “Tax Status of the
Reorganization”: “A portion of the portfolio assets of the Buying Portfolio or Selling Portfolio may be sold at any time before or after the Reorganization in connection with the Reorganization.” Please disclose in the Prospectus the
expected costs of any anticipated repositioning, including estimated brokerage commissions and tax impacts.

 Response: The following disclosure has been added:

Estimated costs associated with the sale of such portfolio assets in connection with the Reorganization are approximately $350,000 (or 15 basis
points) and will be borne by the Selling Portfolio.

18.
 Comment: The Staff noted the following disclosure in Section C under “Capitalization of Selling
Portfolios and Buying Portfolios” [emphasis added]: “The pro forma combined shares outstanding are determined by dividing the net assets of the Selling Portfolio by the net asset value per share of the Buying
Portfolio and adding the actual shares outstanding of the Buying Portfolio.” As the Selling Portfolio, and not the Buying Portfolio, is the expected accounting survivor of the Reorganization, “Selling Portfolio”
should be changed to “Buying Portfolio” in the above-referenced disclosure and vice versa.

 Response:
The requested change has been made.

19.
 Comment: Please update the capitalization table in Table C-1 to
reflect the capitalization of the Selling Portfolio and Buying Portfolio, as disclosed in such Portfolios’ most recent shareholder reports.

Response: The requested change has been made.

20.
 Comment: Under “Additional Information” in Exhibit A, please delete the qualifying clause in
the last sentence of the second paragraph that reads “that may not be waived” or specify what rights may be waived.

Response: The Registrant believes that it is helpful to note for investors that they may have rights under federal or state securities
laws that may not be waived. Accordingly, the Registrant respectfully declines to revise the above-referenced disclosure.

21.
 Comment: Under “The Subadviser” in Exhibit A, please disclose the subadvisory fee rate to be
paid to the Buying Portfolio’s current subadviser.

 Response: The requested change has been made.

22.
 Comment: Under “The Subadviser” in Exhibit A, the Staff noted the following statement:
“The following individuals are responsible for overseeing the day-to-day management of the Portfolio…” Please revise this disclosure to read, “The
following individuals are jointly and primarily responsible for overseeing the day-to-day management of the Portfolio…”

Response: The requested change has been made.

Statement of Additional Information (“SAI”)

23.
 Comment: The Staff notes that the SAI for the Buying Portfolio, dated April 30, 2021, has been
incorporated by reference into the SAI of the Registration Statement. Please confirm that such incorporation by reference is appropriate in light of recent changes to the name, investment strategies and subadviser of the Buying Portfolio.

 Response: The Registrant respectfully submits that such incorporation by reference is
appropriate. In addition, the Registrant has revised the languag