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AQR Funds

 Simpson Thacher & Bartlett LLP

900 G STREET, NW

WASHINGTON, D.C. 20001

TELEPHONE:
+1-202-636-5500

FACSIMILE:
+1-202-636-5502

 Direct Dial Number

 +1-202-636-5806

 E-mail Address

ryan.brizek@stblaw.com

 VIA EDGAR

December 20, 2022

Re:
 AQR Funds

Investment Company Act File No. 811-22235

Ms. Christina DiAngelo Fettig

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, DC 20549

Dear Ms. Fettig:

 On behalf of AQR Funds (the
“Trust”), including each series of the Trust (each, a “Fund,” and together, the “Funds”), we herewith transmit the Trust’s responses to the telephonic comments provided by you on behalf of the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) on August 2, 2022 regarding the Trust’s Shareholder Reports on Form N-CSR filed with the Commission on
November 23, 2021 and February 25, 2022. The Staff’s comments are described below and have been summarized to the best of our understanding. Each comment applies to each Fund unless otherwise indicated. We have discussed the
Staff’s comments with representatives of the Trust. The Trust’s responses to the Staff’s comments are set out immediately under the restated comments. Unless otherwise indicated, defined terms used herein have the meanings set out in
the Shareholder Reports.

 Prospectus Disclosure Comments

Comment 1

AQR Long-Short Equity Fund and AQR Multi-Asset Fund. Both Funds have a blended index. Please explain how the blended benchmarks meet the definition of an “appropriate broad-based securities market index” as
defined in Instruction 5 to Item 27(b)(7) of Form N-1A.

Response

The Trust respectfully submits that AQR Long-Short Equity Fund’s and AQR Multi-Asset Fund’s blended indices are each an “appropriate broad-based securities market index” based on the Funds’ respective
principal investment strategies. For example, per AQR Long-Short Equity Fund’s Prospectus, the Fund’s investment

Ms. Christina DiAngelo Fettig

December 20, 2022

.

objective is to seek capital appreciation using long-term targeted beta exposure, on average, of 0.5 to broad global markets (which the Adviser currently considers to be those countries included in the MSCI World Index), and
potential gains from its market-neutral long-short equity positions and beta timing. Given the long-term target beta of 0.5, the Adviser has determined that the most appropriate benchmark is 50% MSCI World Index, and 50% cash/Treasury Bills
(i.e., 50% ICE BofAML US 3-Month Treasury Bill Index). Likewise, the Adviser believes that AQR Multi-Asset Fund’s blended index (60% S&P 500 Index / 40% Bloomberg Barclays U.S. Aggregate Bond
Index) is appropriate because the Fund invests across multiple asset classes.

The Trust is not aware of guidance from the Commission providing that a blended index cannot represent an “appropriate broad-based securities market index” as defined in Form N-1A.
Instruction 5 to Item 27(b)(7) defines “appropriate broad-based securities market index” to mean an index “that is administered by an organization that is not an affiliated person of the Fund, its investment adviser, or principal
underwriter, unless the index is widely recognized and used.” The Commission has stated that “[t]he purpose of including return information for a broad-based securities market index was to provide investors with a basis for evaluating a
fund’s performance and risks relative to the market.”1 The Trust maintains that (i) with respect to AQR Long-Short Equity Fund, a blended index that incorporates global equity
markets and U.S. treasuries, and (ii) with respect to AQR Multi-Asset Fund, a blended index that incorporates aspects of the stock and bond markets, is in each case a more appropriate basis for comparing such Fund’s performance than a
benchmark that is limited to a single asset type, etc.

Nonetheless, in response to the Staff’s comment, the Trust will disclose performance information for each index that makes up a component of the blended index for each of AQR Long-Short Equity Fund and AQR Multi-Asset Fund in
its Item 27(b)(7) disclosure moving forward.

Comment 2

AQR Long-Short Equity Fund, AQR Macro Opportunities Fund, AQR Managed Futures Strategy Fund, AQR Managed Futures Strategy HV Fund, AQR Risk-Balanced Commodities Strategy Fund, and AQR Sustainable Long-Short Equity Carbon Aware
Fund. Each of these Funds appears to be missing the graphical representation of holdings chart, as required by Item 27(d)(2) of Form N-1A. Please revise each Fund’s disclosure to include the
requirements of this Item.

1
 See Investment Company Act Rel. No. 19382 (Apr. 6, 1993).

Ms. Christina DiAngelo Fettig

December 20, 2022

Response

During the reporting period, the above-referenced Funds achieved their investment objectives through synthetic exposure rather than direct investments. Beginning with the June 30, 2022 Semi-Annual Report, the Trust has added a
graphical representation of holdings chart to each Fund’s Schedule of Investments reflecting the short-term investments held directly by such Fund, as well as all other assets in excess of liabilities, including any appreciation/depreciation on
forward foreign currency exchange, futures and swap contracts.

Comment 3

AQR Diversified Arbitrage Fund. As noted in its principal investment strategies, the Fund invests in special purpose acquisition companies (“SPACs”). However, it is difficult to locate these SPAC investments in
the Fund’s Schedule of Investments. In future filings, please consider making SPAC investments clearer and more distinguishable in the Schedule of Investments.

Response

Beginning with the June 30, 2022 Semi-Annual Report, in the Fund’s Schedule of Investments the Trust has appended a footnote to each SPAC investment that identifies it as a SPAC. Additionally, the Trust notes that the
“Securities and Other Investments—Special Purpose Acquisition Companies (‘SPACs’)” subsection of the “Notes to Financial Statements” section has included and will continue to include disclosure describing SPACs and
the risks associated with investments therein.

Comment 4

For each Fund that invests in the Goldman Sachs Financial Square Treasury Instruments Fund, please disclose the specific class of shares held in such fund as it offers multiple share classes.

Response

Beginning with the June 30, 2022 Semi-Annual Report, the Trust has updated the relevant Funds’ Schedules of Investments to reflect that the Funds hold Institutional Shares of the Goldman Sachs Financial Square Treasury
Instruments Fund.

Comment 5

For each Fund that files for tax reclaims, please supplementally describe the accounting policies related to any professional fees incurred in connection with such tax reclaims. The disclosure references an independent third
party service provider that reimburses such fees. Please supplementally describe the service provider and how the arrangement works.

Ms. Christina DiAngelo Fettig

December 20, 2022

Response

Generally tax reclaims are pursued by the Funds’ Custodian and Administrator. However, an independent third party service provider pursues European Union tax reclaims pursuant to European Court of Justice rulings (“EU
reclaims”). The third party service provider receives a set contingent fee based on any collected amounts for EU reclaims. The 12/31 FYE Funds did not receive any EU reclaims during fiscal year 2021; therefore, no such reclaims were reported in
the December 31, 2021 Annual Report. Five of the FYE 9/30 Funds received EU reclaims during fiscal year 2021, as reflected in the September 30, 2021 Annual Report, for which the contingent fees were each de minimis to the
relevant Fund. Beginning with the September 30, 2022 Annual Report, both the EU reclaims as well as the third party service provider’s contingent fee are shown as gross amounts on the Funds’ Statements of Operations and included on a
gross basis in the Funds’ income and expense ratios in the “Financial Highlights” subsection of the “Financial Statements” section of the Annual Reports.

Additionally, beginning with the September 30, 2022 Annual Report, the Trust has included the following disclosure regarding the contingent fee arrangement in the “Notes to Financial Statements” and plans to continue
to include such disclosure going forward, as applicable:

 “Expenses incurred related to EU reclaims that are contingent upon successful receipt of EU reclaims are reflected
in European Union tax reclaim fees in the Statements of Operations, if material.”

Comment 6

In future filings, please include in the “Notes to Financial Statements” section where related party transactions are discussed how often management fees are paid.

Response

Beginning with the June 30, 2022 Semi-Annual Report, the Trust has revised the following disclosure in the “Advisory and Other Agreements” subsection of the “Notes to Financial Statements” to reflect that
management fees are paid monthly:

 “Pursuant to the Advisory Agreement, the Funds currently calculate and accrue daily based on
the average daily net assets for each Fund and pay monthly the Investment Advisory fee calculated on the average daily net assets for each Fund in the annual ratios below: . . .”

Comment 7

For each Fund that consolidates its financial statements, please confirm that the auditor audited the consolidated statements and, in future filings, ensure the opinion references consolidated financial statements for such
Funds.

Ms. Christina DiAngelo Fettig

December 20, 2022

Response

The Trust confirms that PricewaterhouseCoopers LLP (“PwC”), the Funds’ auditor, audited the consolidated financial statements for each Fund that consolidates its financial statements. The Trust also confirms that
PwC’s audit opinion in future filings will reference “consolidated financial statements” with respect to such Funds.

Comment 8

AQR Small Cap Multi-Style Fund, AQR Managed Futures Strategy HV Fund, and AQR Long-Short Equity Fund. Please explain whether any types of expenses included in the “Fund Expense Examples” (“Expense
Examples”) section of the Funds’ Annual Reports were excluded from the expense ratios in the “Financial Highlights” subsection of the “Financial Statements” section of the Annual Reports and/or the expense ratios used
in the “Annual Fund Operating Expenses” tables (the “Fee Tables”) in the Funds’ Prospectuses.

Response

The Trust confirms that certain non-recurring expenses were included in the calculation of the ratios to average net assets of expenses, net of reimbursements and/or waivers (“Net Expense
Ratios”) in the “Financial Highlights” subsection of the Annual Reports but were not included in the calculation of actual expenses in the Expense Examples in the Annual Reports or the Net Expense Ratios in the Fee Table in the
Prospectuses, in each case as permitted by Form N-1A and as described in more detail below, for each of AQR Small Cap Multi-Style Fund and AQR Managed Futures Strategy HV Fund. All expenses that were included
in the Net Expense Ratio for AQR Long-Short Equity Fund were also included in its Expense Example.

AQR Small Cap Multi-Style Fund (9/30 FYE): The Net Expense Ratio in the “Financial Highlights” subsection of the Annual Report is for the fiscal year ended September 30, 2021 and reflects the inclusion of non-recurring expenses related to the Fund’s reorganization as well as a one-time IRS closing agreement payment. The Fund was reorganized in March 2021 and incurred these
non-recurring expenses in March 2021 or earlier. Per Instruction 2(c)(i) to Item 27(d)(1) of Form N-1A, a Fund should base “actual expenses” used to calculate
its Expense Example on amounts incurred during the Fund’s second fiscal half-year in the case of an annual report. Therefore, AQR Small Cap Multi-Style Fund’s actual expenses for the period April 1, 2021 through September 30,
2021 were used for its Expense Example, meaning the non-recurring expenses discussed above were not included in the calculation of the Expense Example

Ms. Christina DiAngelo Fettig

December 20, 2022

because they were incurred during the first fiscal half-year.2 The Trust provides additional detail regarding the reorganization in Note 2 in the “Financial Statements and
Notes” section of the Annual Report and in Footnote 8 to the “Financial Highlights” subsection of the Annual Report. Additionally, the Trust notes that net expenses in the Fee Table in the Fund’s Prospectus match the Expense
Example in the Annual Report because “Other Expenses” were restated to exclude the non-recurring expenses discussed above per Instruction 3(d)(ii) to Item 3 of Form
N-1A (as discussed in Footnote 1 to the Fee Table).

AQR Managed Futures Strategy HV Fund (12/31 FYE): The Net Expense Ratio in the “Financial Highlights” subsection of the Annual Report is for the fiscal year ended December 31, 2021 and reflects the inclusion of
de minimis non-recurring expenses related to a one-time excise tax payment of $45,005 incurred in April 2021. The Trust did not include this non-recurring expense in its calculation of the Fund’s Expense Example because it predated the period for which actual expenses were based (July 1, 2021 to December 31, 2021). The Expense Example matches
the net expenses reflected in the Fee Table in the Fund’s Prospectus because “Other Expenses” were restated to exclude the non-recurring expense (as discussed in Footnote 1 to the Fee
Table).

AQR Long-Short Equity Fund (FYE 12/31): The Trust confirms that all expenses included in the calculation of the Fund’s Net Expense Ratio in the “Financial Highlights” subsection of the Annual Report for the
fiscal year ended December 31, 2021 were included in its Expense Example in the Annual Report and in the Fee Table in the Prospectus. The Trust confirms that the Net Expense Ratio for Class R6 shares is 1 basis point higher than the
Expense Example due to rounding. The net expenses reflected in the Fee Table in the Fund’s Prospectus is 1 basis point higher than the Expense Example for each of Class I and Class N and 2 basis points higher than the Expense Example
for Class R6 due to acquired fund fees and expenses and rounding.

Comment 9

In future filings, please include disclosure in the Annual Report responsive to Item 27(b)(6) of Form N-1A regarding the availability of additional information about the Funds’
Trustees in the Statement of Additional Information (“SAI”).

2
 In contrast, these non-recurring expenses were included in the
Fund’s Expense Example in its March 31, 2021 Semi-Annual Report because such expenses were incurred during the first fiscal half-year. See Footnote 1 thereto.

Ms. Christina DiAngelo Fettig

December 20, 2022

Response

In future Annual Reports, the Trust will include disclosure explaining that the SAI includes additional information regarding the Funds’ Trustees and that the SAI is available, without charge, upon request by calling toll-free 866-290-2688.

Comment 10

Please note that Item 4(e)(2) of Form N-CSR requests disclosure of the percentage of services for which the pre-approval requirement was waived. The
Funds currently disclose the percentage of services for which the pre-approval requirement was not waived. Please update this disclosure to meet the Form requirement in future filings.

Response

In future filings made on Form N-CSR, the Trust will disclose the percentage of services for which the pre-approval requirements were waived, as
applicable.

Comment 11

AQR Macro Opportunities Fund. The Fund has a footnote in the Fee Table that states expenses have been restated to exclude non-recurring fees. In the Financial Highlights table, the
Fund includes a footnote that explains that the Fund incurred 22 basis points of non-recurring fees. The restatement of expenses in the Fee Table does not match the restatement of expenses in the Financial
Highlights table. Please supplementally explain the difference.