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October 15, 2024

VIA EDGAR TRANSMISSION

Ms. Samantha Brutlag

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0506

Re: Mutual Fund Series Trust, File Nos. 333-132541
and 811-21872

Dear Ms. Brutlag:

On August 23, 2024, the Registrant, on behalf of its
series, Catalyst Insider Buying Fund (the “Fund”), filed a registration statement (“Registration Statement”) under
the Securities Act of 1933 (the “Securities Act”) and the Investment Company Act of 1940, as amended (the “1940 Act”).
In separate a telephone conversation on October 7, 2024, you provided comments to the Registration Statement. Below, please find a summary
of your comments and the Registrant’s responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Additional
or revised disclosures are italicized herein.

Comment 1: Before the Registration Statement’s
effectiveness, please provide a completed Fee Table and Expense Example.

Response: The completed Fee Table and Expense
Example appear below:

    Shareholder Fees

    (fees paid directly from your investment)

    Class

A
    Class

C
    Class

I

    Maximum Sales Charge

(Load) Imposed on Purchases (as a % of offering price)
    5.75%
    None
    None

    Maximum Deferred Sales Charge (Load)

(as a % of the original purchase price)
    1.00%1
    None
    None

    Maximum Sales Charge (Load) Imposed

    on Reinvested Dividends and other Distributions

    None
    None
    None

    Redemption Fee
    None
    None
    None

    Annual Fund Operating Expenses

    (expenses that you pay each year as a percentage of
    the value of your investment)

    Management Fees
    1.00%
    1.00%
    1.00%

    Distribution and/or Service (12b-1) Fees
    0.25%
    1.00%
    0.00%

    Other Expenses
    0.99%
    1.02%
    0.97%

    Total Annual Fund Operating Expenses
    2.24%
    3.02%
    1.97%

Ms. Samantha Brutlag

October 15, 2024

Page 2

    Fee Waiver and/or Expense Reimbursement 2
    (0.71)%
    (0.74) %
    (0.69) %

    Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
    1.53%
    2.28%
    1.28%

1
The 1.00% maximum deferred sales charge may be assessed in the case of investments at or above
the $1 million breakpoint (where you do not pay an initial sales charge) on shares redeemed within two years of purchase.

2
The Fund’s investment advisor, Catalyst Capital Advisors LLC (the “Advisor”),
has contractually agreed to waive management advisory fees and/or reimburse expenses of the Fund to the extent
necessary to limit total annual fund operating expenses (excluding brokerage costs; borrowing costs, such as (a) interest and (b) dividends
on securities sold short; taxes; underlying fund expenses; and extraordinary expenses, such as regulatory inquiry and litigation expenses)
at 1.53%, 2.28% and 1.28% for Class A shares, Class C shares and Class I shares, respectively, through October 31, 2025. This agreement
may only be terminated by the Board of Trustees on 60 days’ written notice to the Advisor advisor and upon
the termination of the investment advisory agreement between the Trust and the Advisor advisor. Fee waivers and
expense reimbursements are subject to possible recoupment by the advisor from the Fund in future years on a rolling three-year basis (within
the three years after the fees have been waived or reimbursed) so long as such recoupment does not cause the Fund’s expense ratio
(after the repayment is taken into account) to exceed the lesser of: (i) the Fund’s expense limitation at the time such expenses
were waived and (ii) the Fund’s current expense limitation at the time of recoupment.

Example: This Example is
intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that
you invest $10,000 in the Fund for the time periods indicated, and then hold or redeem all of your shares at the end of those periods.
The Example only accounts for the Fund’s expense limitation in place through its expiration period, October 31, 2025, and then depicts
the Fund’s total annual expenses thereafter. The Example also assumes that your investment has a 5% return each year and that the
Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs
would be:

    YEAR
    Class A
    Class C
    Class I

    1
    $722
    $231
    $130

    3
    $1,171
    $864
    $552

    5
    $1,645
    $1,522
    $999

    10
    $2,950
    $3,285
    $2,240

Comment 2: In the paragraph under the heading
“Investments in Subsidiary” on page 4 of the Prospectus, please clarify that the subsidiary is a wholly-owned Cayman Island
subsidiary.

Response: The Registrant has amended its disclosures
to state the following:

The Sub-Advisor executes a portion
of the Fund’s strategy by investing up to 25% of the Fund’s total assets in the Subsidiary, a wholly-owned subsidiary of
the Fund organized under the laws of the Cayman Islands. The Subsidiary invests the majority of its assets in structured notes and
total return swap contracts. The Subsidiary is subject to the same investment restrictions as the Fund, when viewed on a consolidated
basis.

Comment 3: In the prefatory paragraph to the
Fund’s principal investment risks, the Staff noted an extended discussion of potential loss of money or investment. Please consider
whether this is

Ms. Samantha Brutlag

October 15, 2024

Page 3

emphasized more than necessary and whether, if merited,
additional disclosure should be added to identify who would be the most appropriate investor in the Fund.

Response: The Registrant has given the Staff’s
position careful consideration and respectfully declines to amend its disclosures. The notice given to investors about the potential loss
of money or investment is consistent across all series of the Trust. The disclosure is not intended to suggest that the Fund is any greater
investment risk than other mutual funds or that the Fund would only be appropriate for a sophisticated or qualified investor.

Comment 4: The Staff’s position on risk
disclosures has been to disclose risks in the order of significance or prominence to a fund’s strategy. Disclosing risks in alphabetical
order suggests that each are equally imminent, whereas the risk disclosures should give shareholders which risks are of greater concern
or salient to the Fund. Please re-order the Fund’s principal risk disclosures so that they appear in order of materiality (from
most material to least material) in lieu of disclosing them in alphabetical order. See ADI 2019-08, “Improving Principal
Risks Disclosure” at www.sec.gov. At the very least, please list first the top three to five risks
that are most likely to impact the Fund’s yield, NAV or total return.

Response: The Registrant has given the Staff’s
position and ADI 2019-08 thoughtful consideration. The Registrant respectfully declines to re-order the Fund’s risk disclosures
as requested. The materiality of each risk is fluid, i.e., what is the most material risk today may not be the most material risk
tomorrow. Recent market disruptions and volatility as a result of the global COVID-19 pandemic demonstrate that it is not possible to
anticipate which risk will present the greatest concern to the Fund at any given moment. Therefore, the Registrant believes that emphasizing
one risk over another may be misleading to investors.

Comment 5: In the Fund’s disclosure of
“Duration Risk,” please include an example of duration to illustrate how it works. Consider adding the average duration of
the Fund’s portfolio in the disclosure of the Fund’s principal investment strategies.

Response: The Registrant has amended its Item
9 disclosure of “Duration Risk” to state the following:

Duration Risk. Longer-term securities
may be more sensitive to interest rate changes. A heightened risk is posed by rising interest rates to a fund whose portfolios include
longer-term fixed income securities. The longer a security’s duration, the more sensitive it will be to changes in interest rates.
The more sensitive a security is to changes in interest rates, the higher its volatility risk. For example, if a bond has a duration of
5 years, a 1% rise in rates would result in a 5% decline in share price. If a bond has a duration of 10 years, a 1% rise in interest rates
would result in a 10% decline in share price. Effective duration estimates price changes for relatively small changes in rates.

Ms. Samantha Brutlag

October 15, 2024

Page 4

The Fund has further amended its Item 9 principal
investment strategy disclosures to state the following:

The Overlay Component generally seeks
to gain this exposure by investing in one or more structured notes with an average duration target of 12 months and/or one or more
non-exchange-traded total return swap contracts.

Comment 6: With respect to the Fund’s
wholly-owned and controlled Subsidiary:

 (a) please disclose that the Fund does not intend to create or acquire primary
control of any entity which primarily engages in investment activities in securities or other assets, other than entitites that are wholly-owned
by the Fund;

 (b) please disclose that the Fund complies with Section 18 of the Investment
Company Act governing investment policies, capital structure and leverage on an aggregate basis with the Subsidiary so that the Fund treats
the Subsidiary’s debt as its own;

 (c) please confirm in correspondence that the Subsidiary and its Board of Directors
will agree to inspection of its books and records by the Staff, and that such books and records will be maintained in accordance with
Section 31 of the Investment Company Act and the rules thereunder;

 (d) please confirm that the Subsidiary and its Board of Directors will agree
to designate agents for service of process in the United States; and

 (e) please confirm that the Subsidiary’s advisory fee, including any performance
fee, and the Subsdiary’s expenses are included in the Fund’s Fee Table.

Response: The Registrant has amended its disclosure
on page 15 of the Prospectus to state the following:

The Fund executes a portion of its
strategy by investing up to 25% of its total assets in a wholly-owned and controlled Subsidiary, which is wholly-owned by the Fund
and organized under the laws of the Cayman Islands. The Fund does not intend to create or acquire primary control of any other
entity.  The Subsidiary invests the majority of its assets in structured notes and swap contracts subject to the same investment restrictions
as the Fund, when viewed on a consolidated basis. The principal investment strategies and principal investment risks of the Subsidiary
are also principal investment strategies and principal risks of the Fund and are reflected in this Prospectus. The financial statements
of the Subsidiary are consolidated with those of the Fund. By investing in commodities indirectly through the Subsidiary, the Fund obtains
exposure to the commodities markets within the federal tax requirements that apply to the Fund. Specifically, the Subsidiary provides
the Fund with exposure to the commodities markets within the limitations of the federal tax requirements of Subchapter M of the Internal
Revenue Code of 1986, as amended (the “Code”). Subchapter M requires, among other things, that at least 90% of the Fund’s
income be derived from securities or derived with respect to its business of investing in securities

Ms. Samantha Brutlag

October 15, 2024

Page 5

(typically referred to as “qualifying
income”). The Fund makes investments in certain commodity-linked derivatives through the Subsidiary because income from these derivatives
is not treated as “qualifying income” for purposes of the 90% income requirement if the Fund invests in the derivative directly.

The Registrant notes that, in the fourth paragraph
under the heading “Subsidiary” on page 15 of the Prospectus, it discloses that the Fund complies with the provisions of the
1940 Act governing investment policies, capital structure and leverage on an aggregate basis with the Subsidiary. The Registrant further
confirms that the Subsidiary will maintain its books and records in accordance with Section 31 of the Investment Company Act and that
the Subsidiary and its Board of Directors will permit the inspection by the Staff of such books and records. The Registrant also confirms
that the Subsidiary’s fees and expenses are incorporated into the Fee Table.

The Registrant states that both directors of the Subsidiary
are U.S. citizens and are subject to service of process at 36 N. New York Avenue, Huntington, NY 11743.

If you have any questions, please call JoAnn Strasser
at (614) 469-3265 or the undersigned at (614) 469-3217.

Very truly yours,

/s/ Philip B. Sineneng

Philip B. Sineneng

cc: JoAnn M. Strasser

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