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CORRESP
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MAINSTAY
FUNDS TRUST
51 MADISON AVENUE
NEW YORK, NEW YORK 10010

VIA
EDGAR CORRESPONDENCE

September 23, 2021

Mr. Mark Cowan
Division of Investment
Management, Disclosure Review Office
Securities and Exchange Commission
100
F Street, NE
Washington, DC 20549

RE: Response to Comments on the Registration Statement (the “Registration
Statement”) for MainStay Funds Trust (the “Registrant”) (SEC File Nos. 333-160918 and 811-22321)
relating to MainStay ESG Multi-Asset Allocation Fund (the “Fund”)

Dear
Mr. Cowan:

This letter responds to comments provided by you on August
9, 2021 with respect to the Registration Statement.  The Registration Statement was filed with the Securities
and Exchange Commission on June 28, 2021.  On behalf of the Registrant, your comments and our responses
thereto are provided below.

All defined terms in this letter have the
same meaning as in the Registration Statement, except as otherwise defined herein.

Prospectus
Comments

Comment 1:     On
the front cover of the prospectus, please remember to update the series/class identifiers on EDGAR to
reflect the ticker symbols once they are available. See Rule 313 of Regulation
S-T.

Response:  We have revised the front cover as required.

Comment
2:     Please format the
following sentence in bold per Item 3 of Form N-1A:

You may pay other fees,
such as brokerage commissions and other fees to financial intermediaries, which are not reflected in
the tables and examples below.

Response:    We have made the requested revision.

Comment 3:     Please
delete the following sentence. The information in the introduction should be specific to the Fund described
in the fee table.  Otherwise, modify it so it is clear that it includes the Fund and other certain funds
that would count within the $50,000 criterion for a discount.

This
amount may vary depending on the MainStay Fund in which you invest.

Response:  Although this
information is not Fund-specific, we believe that it is important for an investor to understand how sales
charge discounts work across our fund complex.  Therefore, we respectfully decline to make the requested
edit.

Comment 4:     Please
provide a completed fee table and example to the staff at least 5 days prior to the effective date.

Response:
 We acknowledge this request.  Completed fee and example tables are included in Appendix 1.

Comment
5:     Add a reference
to footnote 2 in the Fees and Expenses table for the line item entitled “Acquired (Underlying) Fund
Fees and Expenses”.

Response:  We have revised the disclosure in response
to this comment.

Comment 6:   Add
the word “Estimated” to footnote 2 in the Fees and Expenses table.

Response:
 We have revised the disclosure in response to this comment.

Comment 7:   Revise footnote 3 in the Fees and Expenses table to indicate
that there are two agreements.

Response:  We respectfully decline to make the requested
edit.   Although there is more than one waiver, the waivers are all set forth in a single agreement.

Comment
8:     Please confirm
to the staff that the contractual waiver/expense reimbursement will remain in effect at least one year
from the effective date.

Response:  We confirm that the contractual waiver/expense
reimbursement will remain in effect for at least one year from the effective date.

Comment 9:
    The Fund should more clearly explain its
definition of “ESG” and its specific ESG area(s) of focus, including the focus of the Underlying
ETFs that the Fund invests in.

Response:  We have revised the disclosure in response
to this comment.

Comment 10:
Please disclose any criteria as to credit quality, maturity or duration of the Underlying Fixed-Income
ETFs.

Response:  We have revised the disclosure in response to this comment.

Comment
11:    If true, please
indicate that the Underlying Equity ETFs will invest in both growth and value stocks.  Also, if true,
please disclose that the Underlying Equity ETFs may invest in companies of any market capitalization.

Response:
 We have revised the disclosure in response to this comment.

Comment 12:     We note that the Fund intends to use one or multiple third-party
data/scoring providers. In the principal strategies, please identify the provider or providers that the
Fund intends to use, or the primary providers if the Fund intends to use multiple third-party providers.

The disclosure notes that the Fund selects its ETF investments with the use of
third-party provider screens for ETFs that explicitly include “consideration of ESG factors” in their
strategy.  Given how broad the definition of ESG can be, the Fund should more explicitly explain its
definition/focus areas of these “ESG factors.” Does this include all ESG area(s) of focus or only
certain areas of focus among Environmental, Social, or Governance? Will it use an inclusion or exclusion
based approach, or both?   Will the ESG factors differ with respect to the Equity ETFs and Fixed Income
ETFs, in particular those Fixed Income ETFs that invest significantly in municipal bonds, government
sponsored ABS/MBS, or government securities (e.g., US Treasuries)?

Please also explain what
is meant by “integral to their investment process”..  Do all the Underlying ETFs have an 80% policy
as to one or more ESG areas of focus?  Please specify.  In addition, please make clear whether its ESG
criteria are applied to every investment it makes, or only to some of its investments.

Please
summarize this information in the Summary and add additional detail in Item 9.

Response:
 With respect to naming our third-party data/scoring providers, because we may use multiple providers,
which can change over time, we respectfully decline to make the requested edit.  With respect to the
remainder of the comment, we have revised our disclosure to address the issues raised.

Comment
13:   If third-party generated ESG scores are
not available for an Underlying ETF, please explain the Fund’s screening methodology.  Will it perform
its own independent analysis or will it rule out any Underlying ETFs that do not have a third-party generated
score?

Also, please describe the screening criteria and/ or methodology
briefly here and in more detail in item 9.  What score must be achieved in order to be selected for investment?

Response:
 We have revised the disclosure to more clearly describe the process employed when considering an Underlying
ETF that does not have an ESG score.

Comment 14:     Please also consider including risk disclosure related to
the Fund’s use of third-party data providers, since the criteria used by providers can differ significantly
or explain to us why such a risk is not appropriate.

Response:  We have revised
the disclosure in response to this comment.

Comment 15:     Please consider including, if appropriate, ESG tracking error
risk, noting that ESG scores and other analysis might be incorrect or only take into account one of many
ESG-related components of portfolio companies.

Response:  We have revised
the disclosure in response to this comment.

Comment 16:     The Exchange Traded Fund (“ETF”) Risk needs to be more
fulsome.  For example, the disclosure should cover the following risks:

The
underlying Funds the Fund invests in, are structured as ETFs and as a result are subject to special risks,
including:

Trading in UF Shares on the exchange that the UF trade on
may be halted due to market conditions or for reasons that, in the view of the Exchange, make trading
in UF Shares inadvisable, such as extraordinary market volatility. There can be no assurance that UF
Shares will continue to meet the listing requirements of the Exchange. An active trading market for a
UF Shares may not be developed or maintained.

If the UF Fund’s Shares are traded outside a collateralized settlement system,
the number of financial institutions that can act as authorized participants that can post collateral
on an agency basis is limited, which may limit the market for the UF Fund’s Shares and could lead to
differences between the market price of the UF Shares and the underlying value of those shares.

The market prices of UF Shares will fluctuate in response to changes in NAV and
supply and demand for UF Shares and will include a “bid-ask spread” charged by the exchange specialists,
market makers or other participants that trade the particular security. There may be times when the market
price and the NAV vary significantly. This means that UF Shares may trade at a discount to NAV.

In times of market stress, market makers may step away from their role market
making in shares of UF Shares and in executing trades, which can lead to differences between the market
value of UF Shares and the UF’s net asset value.

The market price for the
UF Shares may deviate from the UF’s net asset value, particularly during times of market stress, with
the result that investors may pay significantly more or significantly less for UF Shares than the UF's
net asset value, which is reflected in the bid and ask price for UGF shares or in the closing price.

When all or a portion of an UF’'s underlying securities trade in a market that
is closed when the market for the UF’s shares is open, there may be changes from the last quote of
the closed market and the quote from the UF’s domestic trading day, which could lead to differences
between the market value of the UF’s shares and the UF’s net asset value.

In
stressed market conditions, the market for the UF’s shares may become less liquid in response to the
deteriorating liquidity of the UF’s portfolio. This adverse effect on the liquidity of the UF’s shares
may, in turn, lead to differences between the market value of the UF’s shares and the UF’s net asset
value.

Response:
 We have revised the disclosure in response to this comment.

Comment 17:
    To the extent the Fund intends to invest
significantly in either a single Underlying ETF or significantly exposed to a single industry or economic
sector through an Underlying ETF, please disclose in the strategy and disclose the associated principal
risks.

Response:  Although it is possible that the Fund may from time to time
invest more than 25% of its assets in one Underlying ETF, it does not anticipate being significantly
exposed to any one ETF, industry or sector.  Therefore, we believe that no further edits are necessary.

Comment 18:     In
the Debt Securities risk, please add disclosure regarding the impact of the current low interest rate
environment and the Federal Reserve’s expectation not to increase rates in the immediate future on
the Fund. Please also discuss the impact to the Fund of governmental interventions aimed at curtailing
the distress to the financial markets caused by the COVID-19 outbreak. If you believe no additional disclosure
is required, please explain your basis.

Response:  We have revised
the disclosure in response to this comment.

Comment 19:     Consider clarifying/disclosing in Item 9 that because the
Fund’s ESG criteria may exclude the securities of certain issuers for nonfinancial reasons, the Fund
may forgo some market opportunities available to funds that do not use ESG criteria. Also, ESG considerations
may be linked to long term rather than short term returns.

Response:  We believe that
our Item 9 disclosure sufficiently describes the risks associated with ESG investing.  Therefore, we
respectfully decline to make the requested edit.

Comment 20:     Please include any risk related to BREXIT if appropriate.

Response:  Risk disclosure relating to BREXIT is already discussed
in the section entitled “More About Investment Strategies and Risks - Geographic Risk.”

Comment
21:   In the Emerging Markets risk, please also
consider risks related to market manipulation concerns, limited reliable access to capital, and limitations
on the rights and remedies available to the Fund, individually or in combination with other shareholders,
with respect to issuers of securities the Fund invests in.

See ADI 2020-11 Registered
Funds’ Risk Disclosure Regarding Investments in Emerging Markets.

Response:
 We have revised the disclosure in response to this comment.

Comment 22:     Please disclose in the principal strategy that the Fund will
invest in Underlying ETFs that hold Mortgage-Related and Other Asset-Backed Securities.   Otherwise,
please disclose the associated strategy that gives rise to this principal risk.

Response:
 We have revised the disclosure in response to this comment.

Comment 23:     Please supplementally inform the staff the broad-based securities
market index that will be used to compare performance.

Response:  The Fund intends
to use S&P 500® Index as its broad-based securities market index.

Comment
24:     In the section
entitled “More About Investment Strategies and Risks – Investment Policies and Objectives” please
include the principal investment strategy disclosure required by Item 9 that serves as the basis for
the Summary section. This disclosure must contain detailed disclosure of the Fund’s principal investment
strategies and risk in response to each item of item 9.

Response:  The Fund describes
its principal investment strategies in the Summary section in response to Item 4 of Form N-1A. In response
to Item 9 of Form N-1A, the Fund includes the following sentence in the section entitled “More About
Investment Strategies and Risks”: “Information about the Fund’s investment objective, principal
investment strategies, investment practices and principal risks appears in the summary section for the
Fund at the beginning of this Prospectus.” The Registrant confirms that all pertinent information about
the Fund’s principal investment strategies is disclosed in response to Item 4 and believes the current
approach is sufficient given General Instruction C.3(a) of Form N-1A, which states that “Information
that is included in response to Items 2 through 8 need not be repeated elsewhere in the prospectus.”
The Registrant further notes that this approach is consistent across the prospectuses used by the MainStay
Group of Funds.

Comment 25:     Please
restate the Fund’s 80% policy in the section entitled “More About Investment Strategies and Risks
– Investment Policies and Objectives”.

Response:  Information regarding
the Fund’s non-fundamental investment policy related to Rule 35d-1 is already disclosed in the Statement
of Additional Information under the section entitled “Non-Fundamental Investment Policies Related to
Fund Names”.  Additionally, information regarding the Fund’s investment strategy is disclosed in
the Summary section.  We believe that repeating such information in multiple places in the registration
statement may cause confusion and increases the possibility for error.  Therefore, we respectfully decline
to make the requested edits.

Comment 26:     If
the Fund will use synthetic investments, please disclose in the Summary.  Otherwise, please clarify whether
it is only the Underlying ETFs that will make such investments.

Also,
if synthetic instruments will be counted towards the Fund’s 80% policy, please disclose that these
instruments will be valued at market value when counted towards the Fund’s 80% policy

Response:
 The Fund does not intend to use synthetic investments at this time.  However, we believe that this is
important disclosure as the Fund may invest in synthetic investments in the future.  Therefore, we respectfully
decline to make the requested edit.

Comment 27:     In the section entitled “More About Investment Strategies
and Risks – Investment Policies and Objectives”, you state that in most cases the Underlying ETFs
have adopted 35d-1 policies which are non-fundamental and will provide shareholders with at least 60
days’ prior notice of any change in such policy.  Please explain what has been done in other cases.
 Have they adopted fundamental policies?

Response:  We respectfully
decline to revise this disclosure.  The Underlying ETFs may be affiliated or unaff