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MAINSTAY FUNDS TRUST

 1900 K Street, NW

Washington, DC 20006-1110         

+1 202 261 3300 Main

+1 202 261 3333 Fax

 www.dechert.com

 COREY F.
ROSE

 corey.rose@dechert.com

+1 202 261 3314 Direct

 +1 202 261 3333 Fax

 VIA EDGAR CORRESPONDENCE

May 1, 2024

Ms. Kimberly Browning

Mr. Ken Ellington

Division of Investment Management, Disclosure Review Office

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re:

Response to Comments on the Proxy Statements/Prospectuses (each a “Proxy Statement/Prospectus” and collectively, the “Proxy Statement/Prospectuses”) filed on Form N-14 for
the following funds (each, an “Acquiring Fund” or “Registrant” and collectively, the “Acquiring Funds” or the “Registrants”):

 MainStay MacKay Arizona Muni Fund (SEC File Nos.
333-277907 and 811-22321)

 MainStay MacKay
Colorado Muni Fund (SEC File Nos. 333-277908 and 811-22321)

MainStay MacKay Utah Muni Fund (SEC File Nos. 333-277909 and 811-22321)

 MainStay MacKay Oregon Muni Fund (SEC File Nos. 333-277910 and 811-22321)

 MainStay MacKay
Strategic Municipal Allocation Fund (SEC File Nos. 333-277911 and 811-22321)

Dear Ms. Browning and Mr. Ellington:

This letter responds to comments provided by you via telephone on March 21, 2024, April 4, 2024, April 5, 2024,
April 30, 2024 and May 1, 2024 with respect to the Proxy Statements/Prospectuses. The Proxy Statements/Prospectuses were filed with the Securities and Exchange Commission (“SEC”) on March 14, 2024 and relate to the following
proposed reorganizations: (i) Aquila Tax-Free Trust of Arizona with and into MainStay MacKay Arizona Muni Fund; (ii) Aquila Tax-Free Fund of Colorado with and
into MainStay MacKay Colorado Muni Fund; (iii) Aquila Tax-Free Fund for Utah with and into MainStay MacKay Utah Muni Fund; (iv) Aquila Tax-Free Trust of Oregon
with and into MainStay MacKay Oregon Muni Fund; (v) Aquila Churchill Tax-Free Fund of Kentucky with and into MainStay MacKay Strategic Municipal Allocation Fund; and (vi) Aquila Narragansett Tax-Free Income Fund with and into MainStay MacKay Strategic Municipal Allocation Fund (each, a “Reorganization” and together, the “Reorganizations”).

On behalf of the Registrants, your comments and our responses thereto are provided below. All defined terms in this letter
have the same meaning as in the Proxy Statements/Prospectuses, except as defined herein.

 Comments from Ms.
Browning

 Comments applicable to the MainStay MacKay Arizona Muni Fund, MainStay MacKay Colorado Muni Fund,
MainStay MacKay Utah Muni Fund and MainStay MacKay Oregon Muni Fund (each, a “Shell Reorganization” and together, the “Shell Reorganizations”) Proxy Statements/Prospectuses

Comment 1: Please revise the approximate date of the proposed offering of securities on the facing page
to conform with Item 1(a) of Form N-14.

 Response: The Registrant has revised the disclosure in
accordance with this comment.

 Comment 2: In the “Notice to Shareholders” section, it
states that the Agreement and Plan of Reorganization proposes the transfer of assets of the Acquired Fund to the Acquiring Fund in exchange for the assumptions of all of the liabilities of the Acquired Fund by the Acquiring Fund. Please include a
statement of which liabilities will be assumed by the Acquiring Fund within the Proxy Statement/Prospectus.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 3: In the Notice to Shareholders section, it states that proxies may be revoked by giving written
notice of revocation to the Acquired Fund. Please provide the address where written notice of revocation must be sent and discuss any other means by which a shareholder can revoke his or her proxy, as applicable.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 4: In the section entitled “Questions and Answers Relating to the Reorganizations”
(“Q&A Section”), please consider streamlining the discussion. We note that certain topics are discussed in several places throughout the Proxy Statement/Prospectus.

Response: The Registrant respectfully declines to revise this section in accordance with this comment.

 Comment 5: In the Q&A Section, please consider adding separate questions for separate topics
rather than including multiple topics under one question.

 Response: The Registrant respectfully
declines to adding further questions to the Q&A Section in accordance with this comment.

 Comment 6:
Please revise each Proxy Statement/Prospectus to state whether there are material differences between the Acquired Fund and Acquiring Fund’s fundamental investment restrictions and use the same terminology throughout. For any material
differences, please summarize the differences. Please also supplementally confirm that all material differences are described in the Proxy Statement/Prospectus or revise accordingly.

Response: The Registrant has revised the disclosure in accordance with this comment and hereby confirms that it
believes that all material differences between the Acquired Fund and the Acquiring Fund are disclosed in the Proxy Statement/Prospectus.

Comment 7: Within each Proxy Statement/Prospectus, the consummation of the Reorganization is referred to
as both the “completion” and “closing.” Please resolve the use of two terms to describe the consummation of the reorganization and define the term in its first instance.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 8: When answering the question entitled “How will the Reorganization affect me?”,
please disclose with greater specificity what “about” means with respect to the disclosure that “the Reorganization will take place on or about July 19, 2024” or supplementally explain why it is not possible to do so in the
document itself. Please also supplementally confirm whether you intend to notify shareholders of any delays to each Reorganization.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 9: Please supplementally explain to the staff whether an assignment of the Acquired Funds’
investment advisory agreement with Aquila Investment Management LLC would take place as part of the Reorganizations.

 Response: The Registrant confirms that no assignment of any
Acquired Fund’s investment advisory agreement would take place prior to or in connection with the Reorganizations.

Comment 10: Please explain the “other conditions” of the Reorganizations, which is referenced
throughout the Proxy Statement/Prospectus. Please consider adding a separate question or heading to make the discussion clearer.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 11: In the Q&A Section and throughout the Proxy Statements/Prospectuses, the Registrant
states that the Acquired Fund and Acquiring Fund are “substantially similar.” However, each Proxy Statement/Prospectus indicates that there are several material differences between each Acquired Fund and Acquiring Fund. Please revise the
statement that the Funds are “substantially similar.”

 Response: The Registrant has revised the
disclosure in accordance with this comment.

 Comment 12: In the section entitled “Board
Considerations”, please discuss or enhance the discussion of the Board’s consideration of material differences between the Acquired Fund and Acquiring Fund.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 13: In the section entitled “Proposal - Fundamental Investment Restrictions”,
concerning the discussion of the 80% fundamental policies for the Shell Reorganizations, please discuss all material differences between the fundamental policies, including the treatment of income that is exempt from federal alternative minimum
taxes, if applicable. Please also revise the “Board Considerations” section to include a discussion of the differences between the fundamental investment restrictions of the Acquired Fund and the Acquiring Fund.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 14: When answering the question entitled “What are the potential benefits from the
Reorganization?”, the answer first discusses net fees and expenses. Please revise to first discuss gross fees and expenses, and then discuss net fees and expenses separately. In addition, if the management fee of the Acquiring Fund is higher
than the Acquired Fund, or vice versa, please begin the response to this question with that disclosure. Please also consider relocating this question or creating another Question and Answer that is specific to fees.

Response: The Registrant has revised the disclosure in response to the question entitled “What are the
potential benefits from the Reorganization?” in accordance with this comment. The Registrant respectfully declines to create a separate question specific to fees because the Registrant believes the current disclosure, including as revised,
clearly provides information regarding the material differences in the fees and expenses of each Acquired Fund and its corresponding Acquiring Fund.

Comment 15: When answering the question entitled “What are the potential benefits from the
Reorganization?”, consider making the discussion of each share class a separate bulleted list. Please also consider revising the discussion of fee waivers into a separate bulleted list or Question and Answer.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 16: In the Q&A Section, please add a specific section that discusses the differences between
the fee waivers.

 Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 17: Please supplementally confirm that previously waived fees or expenses with respect to the
Acquired Fund are not subject to recoupment.

 Response: The Registrant confirms that previously waived
expenses with respect to the Acquired Funds are not subject to potential recoupment.

 Comment 18:
Please consider adding the closing date of the Reorganizations in the shareholder letter.

 Response: The
Registrant has revised the disclosure in accordance with this comment.

 Comment 19: In the Q&A
Section, please consider adding a discussion of the fundamental investment restrictions.

 Response: The
Registrant has revised the disclosure in accordance with this comment.

 Comment 20: When answering
the question entitled “Are there differences between the Funds?”, please consider breaking up this information. Please also consider revising the section to include a Question and Answer specific to service providers and whether the
services or fees will change or remain the same after the Reorganizations.

 Response: The Registrant
respectfully declines to revise the disclosure in accordance with this comment.

 Comment 21: In the
Q&A Section, please revise the question entitled “How will the Reorganization affect shareholder fees and expenses?” to “How will the Reorganization affect total annual fund operating expenses?” The current response does not
discuss shareholder fees.

 Response: The Registrant has revised the disclosure in accordance with this
comment.

 Comment 22: When answering the question entitled “How will the Reorganization affect
shareholder fees and expenses?”, the Registrant discusses the expense limitation agreement between New York Life Investment Management LLC (“New York Life Investments”) and the Acquiring Fund. Earlier in the Proxy Statement/Prospectus
the term “waiver” is used to describe this agreement. Please reconcile the two terms or supplementally explain if they are different.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 23: In connection with New York Life Investments’ exemptive order that permits it to use the
“manager of managers” structure, please discuss whether the Board of Trustees (the “Board”) of the Acquired Funds considered that the Reorganizations would cause shareholders of the Acquired Funds to no longer have the power to
change a subadvisor under certain circumstances. Please disclose in the Proxy Statement/Prospectus that after the Reorganizations, shareholders will not have a right to vote on changes to the Funds’ subadvisor if the conditions under the
“manager of managers” exemptive relief order are met.

 Response: The Registrant has revised the
disclosure in accordance with this comment.

 Comment 24: When answering the question entitled
“Who will bear the expenses of the Reorganization and related costs”, please delete “not limited to” and insert “estimated” before costs, if accurate.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 25: When answering the question entitled “Who will bear the expenses of the Reorganization
and related costs?”, please state the expenses will be borne by New York Life Investments out of its own legitimate profits, if accurate.

Response: The Registrant has revised the disclosure to clarify that New York Life Investments will bear these
expenses from its legitimate profits.

 Comment 26: On the first page of the Proxy
Statement/Prospectus, please add fundamental investment restrictions to the discussion of the Acquired Fund and Acquiring Fund.

 Response: The Registrant has revised the disclosure in
accordance with this comment.

 Comment 27: Please revise throughout the Proxy Statement/Prospectus
where it states that Acquired Fund shareholders will receive shares “equal in value” to shares “equal in net asset value.”

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 28: In the section entitled “Summary”, please add a brief discussion about the
principal risks and fundamental investment restrictions.

 Response: The Registrant has revised the
disclosure in accordance with this comment.

 Comment 29: In the section entitled “Summary”,
in the sixth bullet point, where the management fees payable by the Acquiring Fund and Acquired Fund are discussed, please state the management fee rates.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 30: Please consider adding a discussion of the best interests determinations that the Board of
the Acquired Funds made in the letter to be sent to shareholders.

 Response: The Registrant has revised the
disclosure in accordance with this comment.

 Comment 31: Please disclose in the body of the Proxy
Statement/Prospectus that the Board of the Acquired Funds unanimously approved the Reorganizations and resolve any inconsistencies to the extent the disclosure appears elsewhere in the Proxy Statement/Prospectus.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 32: Please confirm whether the Board of the Acquired Funds was advised by independent legal
counsel in connection with its determinations and, if so, please state that in the section entitled “Board Considerations.”

Response: The Registrant confirms that the Board was advised by independent legal counsel in connection with its
consideration of the Reorganizations. The Registrant has revised the disclosure in accordance with this comment.

Comment 33: In the section entitled “Board Considerations”, please clarify what information was
considered by the Board of the Acquired Funds and the sources of the information. For example, please disclose whether the information was provided by Aquila Investment Management LLC (“Aquila”), investment adviser to the Acquired Funds,
and whether the Board of the Acquired Funds considered possible conflicts of interest related to Aquila and the Reorganizations.

Response: The Registrant has revised the disclosure in accordance with this comment.

Comment 34: In the section entitled “Board Considerations”, please delete “may be”
from the stateme