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CORRESP
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MAINSTAY FUNDS TRUST

51 MADISON AVENUE

NEW
YORK, NEW YORK 10010

VIA EDGAR CORRESPONDENCE

April
12, 2023

Mr. Michael A. Rosenberg

Division of Investment Management, Disclosure
Review Office

Securities and Exchange Commission

100 F Street, NE

Washington,
DC 20549

Re: Response
to Comments on N-14 filing (the “Proxy Statement/Prospectus”) for MainStay Funds Trust (the “Registrant”)
(SEC File Nos. 333-270485)

Dear Mr. Rosenberg:

This letter responds to comments provided
by you telephonically on April 5, 2023 with respect to the Proxy Statement/Prospectus.  This letter also
responds to comments provided by Mr. Jason Fox on March 23, 2023 via email.

The
Proxy Statement/Prospectus was filed with the Securities and Exchange Commission on March 13, 2023.
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 Proxy Statement/Prospectus, except as otherwise
defined herein.

Comment 1:  Confirm in correspondence that the fees
presented represent current fees, in accordance with item 3 of Form N-14.

Response:
  We hereby confirm that fees are current as of the last shareholder report filed by the Acquired Fund.

Comment
2:
 Please
confirm in correspondence that there is no disclosure required under Regulation S-X 6-11(d)(1)(ii) or
(iii).  Please consider stating that the Reorganization will not result in 1) a material change to the
Acquired Fund's investment portfolio due to investment restrictions or 2) a change in accounting policies.

Response:
 We hereby confirm that such disclosure is not required.  We believe that the suggested
disclosure additions are already adequately addressed in the disclosure.

Comment
3:   Please confirm that shares
of the Acquiring Fund will not be sold under the Proxy Statement/Prospectus prior to the consummation
of the Reorganization.

Response:   We hereby confirm that shares of the
Acquiring Fund will not be sold under the Proxy Statement/Prospectus prior to the consummation of the
Reorganization.

Comment 4:   In the section entitled “Questions and
Answers Relating to the Reorganization – Are there differences between the Funds?” disclose that
the differences also include: (i) the ability of Acquiring Fund to rely on exemptive relief regarding
a “manager of mangers” arrangement; (ii) differences in the Declaration of Trust and By-laws of the
Acquired Fund and Acquiring Fund; and (iii) the appointment of different service providers.  Include
cross-references to the appropriate sections for further discussion.

Response:
 We have made the requested edits.

Comment
5:  In the section entitled
“Summary – Board Considerations”, disclose that the Board considered the following items: (i) following
expiration of any expense cap agreements it is possible that the Total Annual Fund Operating Expenses
of each class of the Acquiring Fund may be higher than those of the corresponding share class of the
Acquired Fund; (ii) the Acquiring Fund and New York Life Investments may rely on exemptive relief regarding
a “manager of mangers” arrangement; and (iii) the service providers of the Acquired Fund are different
than the service providers of the Acquiring Fund.

Response:
 We
have made the requested edits, consistent with the Board’s considerations.

Comment
6:  In the section entitled
“Proposal – Comparison of the Acquired Fund and the Acquiring Fund” make sure to describe the differences
between the Acquiring Fund and the Acquired Fund noted in the comments above.

Response:
 We have revised the disclosure in the sections entitled “Questions and Answers
Relating to the Reorganization – Are there differences between the Funds?” and “Summary – Board
Considerations” to address the comments above. We believe that the disclosure, as revised, appropriately
discloses the differences. For these reasons, the Registrant respectfully declines to make any further
changes.

Comment 7:
In the section entitled “Proposal – Comparison of the Acquired Fund and the
Acquiring Fund – Principal Investment Strategies – Acquiring Fund” describe how a third party determines
an issuer’s “country of risk”.

Response:  Although the Fund will
generally rely on an issuer’s “country of risk,” as determined by Bloomberg, when categorizing
securities as either U.S. or foreign-based, it is not required to do so.  The factors used by a third
party may vary over time and may be different from one third party to another.  Therefore, we respectfully
decline to make the requested edit.

Comment 8:  In the section entitled
“Proposal – Comparison of the Acquired Fund and the Acquiring Fund – Principal Risks” please
include disclosure regarding the risks associated with companies that are in the earlier stages of their
growth cycle.

Response:  We have made the requested
edit.

Comment 9:  Please confirm that the Acquired Fund will
look through its holdings of investment companies for purposes of concentration testing.

Response:
 We
confirm this.

Comment 10:   In the section entitled
“Voting Information – Broker Non-Votes and Abstentions” note that Staff’s view is that broker
non-votes may not be counted for quorum purposes.  Please revise the disclosure to state that if a beneficial
owner does not provide voting instructions to its broker, the broker is not permitted to give a proxy
with respect to such beneficial owners’ shares.  Accordingly, such shares will not count as present
for quorum purposes or for purposes of  Section 2(a)(42) of the Investment Company Act.

Response:
We
respectfully disagree with the Staff’s view on this point with respect to the theoretical use of broker
non-votes for quorum purposes. Nevertheless, we have revised the disclosure in response to the Staff’s
comment.

***

Sincerely,

/s/ Thomas C. Humbert, Jr.

Thomas C. Humber, Jr.

Assistant
Secretary