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Direct Phone Number +1 202-654-4563

arie.heijkoop@haynesboone.com

January 12, 2023

VIA EDGAR

EDGAR Operations Branch

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Virtus Alternative Solutions Trust

Registration Statement on Form N-14

File Nos. 333-268768; 811-22906

Ladies and Gentlemen:

This letter sets forth responses to oral
comments received from Anu Dubey and Jason Fox of the staff of the Securities and Exchange Commission (the “SEC”) on
January 3 and January 5, 2023, respectively, pertaining to the Form N-14 prospectus/proxy statement that was filed by Virtus Alternative
Solutions Trust (the “Registrant”) on December 13, 2022. Where noted, changes, as applicable, have been made to the
prospectus/proxy statement.

Set forth below is each comment and the Registrant’s
response thereto.

    1.
    Comment: In the Notice of Meeting of Shareholders, insert “special” before “meeting” in the heading and throughout.

    Response: Requested change has been made in the heading and in the first sentence before the term is defined.

    2.
    Comment: In the last paragraph of the last page of the N-14 cover, add hyperlinks to the Selling Trust’s annual and semiannual reports cited here. (See Rule 411(d) under 1933 Act.)

    Response: Requested change has been made.

    3.
    Comment: Page 17, second paragraph under ‘How will a Reorganization affect me?’ Clarify that ‘net expenses’ means after expense waivers or reimbursements.

    Response: Requested disclosure has been added.

    Haynes and Boone, LLP

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    4.
    Comment: Page 19, Fees and expenses tables. For the Acquiring Funds, if the fund derives investment returns principally from swaps, in a footnote to the fee table, disclose the costs of investing in swaps, including 1) stating that embedded costs of swaps and operating costs of reference assets are indirect fund expenses not included in the fee table or example; and 2) an estimate of such costs for the most recent fiscal year as a percent of fund assets.

    Response:
    The following information has been added as a new footnote to Total Annual Fund Operating Expenses in this table: (g) As a result of the Fund’s investment in swaps, the Fund incurs indirect expenses from costs embedded in swap instruments and operating costs of reference assets that are not reflected in this expense table or the expense examples below.  During the past fiscal year, such costs were approximately 0.01% of Fund assets.

    5.
    Comment: Page 21, footnote (c); page 24, footnote (b). Disclose whether or not AlphaSimplex’s ability to recoup fees or expenses expires on the closing of the Reorganization. If not, the Staff may have more comments.

    Response: Subject to the provisions of the Amended and Restated Expense Limitation Agreement with the Acquiring Funds, VAIA (rather than AlphaSimplex) will have the right to recapture (recoup) fees and expenses waived and/or reimbursed prior to the Reorganizations under the existing Expense Limitation Agreement for the Acquired Funds. Disclosure will be added to the Registration Statement in this regard. The Acquiring Funds are “shell funds” that are being formed to acquire all of the assets and liabilities of the Acquired Funds. In this connection, the Acquiring Funds acquire contingent liabilities, such as the obligation to repay any previously waived and/or reimbursed fees and expenses that would have been payable by the Acquired Funds under the existing Expense Limitation Agreement. Any such repayments by the Acquiring Funds will be subject to the Amended and Restated Expense Limitation Agreement, as well as approval by the Board of Trustees of the Acquiring Funds. The Registrant also notes that AlphaSimplex, the current investment adviser to the Acquired Funds, will (i) be the subadviser to the Acquiring Funds and (ii) be an affiliate of VAIA by virtue of the closing of the Acquisition.

    6.
    Comment: Page 21, footnote (f). Disclose whether or not the undertaking by Natixis expires on the closing of the Reorganization.

    Response: Disclosure has been added that the undertaking will expire on the closing of the Reorganization.

    7.
    Comment: Page 26, Total returns table. In footnote (b), third to last sentence, disclose whether the index reflects a deduction for taxes. (See requirement under Item 4 of Form N-1A.)

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    Response: The referenced footnote currently indicates that the index reflects the managed fees and expenses of both the funds of funds in the index and the hedge funds in which they invest, which is the disclosure available from the index provider. The index provider does not indicate whether the referenced expenses for each such fund include taxes. Therefore, we have not made any changes in response to this comment.

    8.
    Comment: Page 26, Total returns table. In footnote (b), third to last sentence, please reconcile this sentence with the parenthetical after the index name in the table.

    Response: The parenthetical after the index name in the table has been removed.

    9.
    Comment: Footnotes (b) and (c) under the Total Return Table, page 28. Tell us which index is the broad-based securities market index and which is the additional index. Also, please explain how each index complies with the requirements of Form N-1A. For example, is the Credit Suisse Managed Futures Liquid Index a securities index? Also, why is it appropriate to use an index that includes the performance of AlphaSimplex Group?

    Response: The Credit Suisse Managed Futures Liquid Index is the Fund’s broad-based securities market index. The SG Trend Index is the Fund’s additional index. The Fund’s subadviser seeks to align the Fund’s principal investment strategies and underlying asset class exposures with appropriate indexes relative to those factors. As disclosed in the Fund’s prospectus:

    “The Fund’s subadviser, AlphaSimplex Group, LLC (“AlphaSimplex”), typically will make extensive use of a variety of derivative instruments, including futures and forward contracts, to capture the exposures suggested by its absolute return strategy…These market exposures, which are expected to change over time, may include, for example, exposures to the returns of U.S. and non-U.S. equity and fixed-income securities indices (including both broad- and narrow-based securities indices), currencies and commodities... AlphaSimplex uses proprietary quantitative models to identify price trends in equity, fixed-income, currency and commodity instruments across time periods of various lengths.”

    The Credit Suisse Managed Futures Liquid Index, which was developed and is maintained by Credit Suisse, is a broadly diversified index currently composed of 14 futures contracts and four commodity indices which provide exposure to a range of asset classes, including equities, fixed income, commodities and currencies. The index uses a proprietary quantitative methodology to seek to identify price trends in each of the aforementioned asset classes over a variety of time horizons. Given the commonalities between the Fund and the index, the Registrant believes this benchmark is an appropriate comparison for the Fund.

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    The SG Trend Index serves as the Fund’s additional index. The SG Trend Index is designed to track the performance
    of the ten largest trend following commodity trading advisors (CTAs) and to be broadly representative of trend followers in
    the managed futures space. AlphaSimplex only represents one of the ten underlying constituents. The index serves as the leading
    benchmark in the space and provides a relevant comparison to how the Fund’s returns compare to the returns of other
    trend followers. Thus, the Registrant believes this benchmark is an appropriate comparison for the Fund.

    10.
    Comment: Page 31. For Virtus AlphaSimplex Global Alternatives Fund, disclose the criteria showing the fund’s
    investments are tied to a number of countries in the world, given “Global” in the fund’s name.

    Response: The Registrant has carefully considered the Staff’s comment and respectfully submits that the use
    of the term “global” in a fund’s name does not require a fund to establish a percentage-based test or a
    test tied to a threshold number of countries.

    With respect to Virtus AlphaSimplex Global Alternatives Fund, the Registrant respectfully submit that the use of the term
    “global” as part of the phrase “global alternatives” in the Fund’s name does not give rise to
    confusion regarding the Fund’s investments. The phrase “global alternatives” refers to a type
    of investment strategy that is based on long and short exposure to global equity, bond, currency and commodity markets through
    a wide range of derivative instruments and direct investments. Accordingly, the Registrant respectfully submits that the phrase
    “global alternatives” refers to the Fund’s investment strategy, rather than the extent to which the Fund’s
    investments may be diversified among a number of different countries throughout the world.

    The Registrant notes that Rule 35d-1 under the 1940 Act does not apply to terms that suggest an investment objective or
    strategy. See Frequently Asked Questions about Rule 35d-1 (Investment Company Names) (hereinafter FAQ), at Question
    9, available at www.sec.gov/divisions/investment/guidance/rule35d-1faq.htm. Nor, as the SEC has made clear, does
    the rule apply to the word “global” itself. See Investment Company Names, Release No. IC-24828 at n.
    42 (Jan. 17, 2001) (hereinafter “Adopting Release”); FAQ at Question 10. Moreover, the Registrant notes
    that, for funds that use the term “global” to connote diversification among investments in a number of different
    countries throughout the world, the 40 percent/3 countries test suggested by the Staff represents only one effective way for
    these funds to explain how they intend to invest their assets consistent with this connotation. See Memorandum
    from Investment Company Institute to SEC Rules Members No. 47-12 et al. (June 4, 2012).

    The Registrant respectfully submits that the above-referenced 40 percent/3 countries test is not representative of a “global
    alternatives” investment strategy. For this reason, and

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    because the Staff does not believe that this approach
    is compulsory, even for traditional “global” funds, see id., the Registrant respectfully submits that the use
    of the term “global” as part of the phrase “global alternatives” in the Fund’s name does not
    require the Fund to establish a percentage-based test or a test tied to a threshold number of countries. Accordingly,
    no changes have been made to the Fund’s disclosure.

    11.
    Comment: Global comment for both Acquiring Funds: Principal Investment Strategies, second sentence. Please clarify
    what is meant at the end by “other instruments” or clarify it is a reference to other types of derivatives.

    Response: The term means instruments other than derivatives. Disclosure has been added to reflect “other
    instruments such as certificates of deposit.”

    12.
    Comment: Global comment for both Acquiring Funds: Principal Investment Strategies, first sentence of second paragraph.
    If seeking absolute return is part of a fund’s investment objective, which it appears to be based on this sentence,
    please update the investment objective to reflect this. Also, disclose what absolute returns are.

    Response: The investment objective of each Fund reflects that the funds pursue an absolute return strategy, so
    additional disclosure has not been added. Absolute returns simply reflect whatever a portfolio returned over a
    given period, so the Strategies disclosure for Global Alternatives Fund has been updated to reflect the Fund seeks to generate
    absolute “(positive)” returns, while the disclosure for Managed Futures Strategy Fund reflects that it “seeks
    to generate positive absolute returns” so no additional disclosure was added for this Fund.

    13.
    Comment: Global comment for both Acquiring Funds: Principal Investment Strategies, 4th sentence of second
    paragraph. Instead of disclosing examples, disclose the market exposures that the subadviser will capture as principal strategies.

    Response: Disclosure has been updated by replacing “, for example,” with “primarily.”

    14.
    Comment: Global comment for both funds: Principal Investment Strategies, last sentence of third paragraph. If the
    non-U.S. securities include emerging markets as a principal strategy, add disclosure of emerging markets here and add a corresponding
    risk description in the Principal Risk section.

    Response: Registrant confirms that the Funds do not consider emerging markets to be a principal investment strategy,
    so additional disclosure has not been added in response to this comment.

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    15.
    Comment: Principal Investment Strategies, page 35. Disclose the maturity policy with respect to the assets in the
    Money Market Portion.

    Response: The following disclosure has been added after the first sentence of the last paragraph on page 35: “Duration
    for all assets in the Money Market Portion is limited to 397 days or less and the weighted average maturity is limited to
    120 days or less.”

    16.
    Comment: Principal Risks introductory paragraph, page 42. In subsection (2) of the last sentence, add disclosure
    of the effect on the fund’s risks for this (similar to what is done in subsection (1)).

    Response: Registrant confirms subsection (2) of this paragraph was erroneously included as a difference in the
    risk profiles of the funds because investing in other investment companies is not a principal risk of AlphaSimplex Managed
    Futures Strategy Fund, so the disclosure in subsection (2) has been deleted.

    17.
    Comment: Global comment for both funds: Principal Risks. In the Commodity and Commodity-linked Instruments Risk
    description, consider whether not satisfying Regulation M under the Tax Code is a principal risk of the fund.

    Response: Registrant believes that the risk of not satisfying Regulation M is not a principal risk of the Funds due to their
    use of the Subsidiaries for commodity investments, so no change has been made to the disclosure in response to this comment.

    18.
    Comment: Global comment for both funds: Principal Risks. In Foreign Investing Risk, please further distinguish
    between the risk of foreign investing and foreign government, given the reference to non-U.S. government securities in the
    Principal Investment Strategies.

    Response: The following separate risk disclosure has been added for each Acquiring Fund:

    Non-U.S. Government Securities

    When the Fund invests in debt instruments issued by a government outside the U.S., the Fund is exposed to the risks that:
    (a) the governmental entity that controls the repayment of government debt may not be willing or able to repay the principal
    and/or to pay the interest when it becomes due, due to factors such as political considerations, the relative size of the
    governmental entity’s debt position in relation to the economy, cash flow problems, insufficient foreign currency reserves,
    the failure to put in place economic reforms required by the International Monetary Fund or other multilateral agencies, and/or
    other national economic factors; (b) the issuing government may default on its debt instruments, which may require holders
    of such securities to participate in debt

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    rescheduling; and (c) there is no legal or bankruptcy process by which defaulted
    government debt may be collected in whole or in part