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                                                               Direct
    Phone Number +1 202-654-4563

    arie.heijkoop@haynesboone.com

May 8, 2023

VIA EDGAR

EDGAR Operations Branch

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Virtus Alternative Solutions Trust

    Post-Effective Amendment No. 46 to the Registration Statement on Form N-1A

    File Nos. 333-191940; 811-22906

Ladies and Gentlemen:

This letter sets forth responses to oral comments received
from Anu Dubey of the staff of the Securities and Exchange Commission (the “SEC”) on January 3, 2023, pertaining to the above-referenced
post-effective amendment to the registration statement on Form N-1A for Virtus Alternative Solutions Trust (“Registrant”),
filed with the Securities and Exchange Commission (the “Commission”) on December 12, 2022. Below, we describe the changes
made to the registration statement in response to the Staff’s comments and provide any responses to or any supplemental explanations
of such comments, as requested. These changes will be reflected in a subsequent post-effective amendment to be filed under Rule 485(b)
on or about the effectiveness of our previous filing on May 12, 2023.

 1. Comment:	Please represent to the Staff in letter that no sales of shares will be made off this registration until the Reorganizations
are completed.

Response:	Other than shares for seed capital that
will be redeemed prior to the time of the Reorganizations, the Registrant represents that no shares will be sold under this registration
until the Reorganizations are completed.

 2. Comment:	Cover page of the Prospectus. As both funds are commodity pools, please add a reference to the Commodity Futures
Trading Commission in the first sentence of the legend at the bottom of the page.

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Response:	Requested disclosure
has been added.

 3. Comment:	Global comment for both funds: Please replace “all” with “the” in the first sentence of
the fee table introductory paragraph.

Response:	Requested change has been made.

 4. Comment:	Global comment for both funds: Footnotes to fee table. 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 the expense table for Virtus AlphaSimplex Global Alternatives Fund:

“(e) 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 Predecessor Fund
assets.”

 5. Comment:	Global comment for both funds: Footnote (d) to fee table. Please confirm that the contractual expense limitation
agreement will be filed as an exhibit to the registration statement.

Response:	Registrant confirms that the expense limitation
agreement will be filed as an exhibit.

 6. Comment:	Global comment for both funds: Principal Investment Strategies. Please tell us, in the letter, whether the fund
will use absolute or relative Value-at-risk (VaR) under Rule 18f-4. If relative VaR, tell us the index used.

Response:	Registrant confirms that each Fund will
use absolute VaR for 18f-4 purposes.

 7. Comment:	Global comment for both 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.”

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 8. Comment:	Global comment for both 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.

 9. Comment:	Global comment for both 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.”

 10. Comment:	Global comment for both funds: Principal Investment Strategies, first full sentence on page 5. 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.

 11. Comment:	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:	Registrant notes the Staff’s position
that use of “Global” in a fund’s name would connote that a fund’s investments are diversified among a number of
countries throughout the world, and confirms that the Fund’s investment holdings comply. While the Fund is not managed to have exposure
to a minimum number of countries, the Fund’s investments, historically and currently, are diversified among different countries.
For example, the Fund’s shareholder report as of June 30 reflects that it had exposure to at least 10 foreign countries through
financial and currency futures and forward foreign currency contracts, in addition to holding shares of a number of foreign companies
and commodities. Due to the nature of the Fund’s holdings in alternative investments that are

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by their nature global, the Fund is
a global fund even without a formal test that does not apply precisely to the strategies in which the Fund invests.

 12.	 Comment:	Global comment for both funds: Principal Investment Strategies, second paragraph on page 5. Describe in plain English what “standard
deviation of the fund’s returns” means.

Response:	Disclosure has been updated to add the
following explanation:

“The standard deviation is a measure of how disbursed
the data are in relation to the average data point. For a particular time period, the standard deviation of the fund’s returns is,
therefore, a measure of how dispersed daily fund returns are relative to the average daily fund return during this period. A low standard
deviation means that daily returns are clustered around the average daily return. On the other hand, a high standard deviation means that
daily returns are more spread out.”

 13. Comment:	Global comment for both funds: Principal Investment Strategies, 4th paragraph on page 5:

1) disclose somewhere that the investment adviser for the Subsidiary complies with the 1940 Act provisions related to advisory contracts
(Section 15) as if it were an investment adviser to a fund under Section 2(a)(20) of the 1940 Act. Confirm that the advisory agreement
between the investment adviser and the Subsidiary is filed as an exhibit to the Registration Statement.

Response:	In approving each parent fund’s
advisory contract pursuant to Section 15 of the 1940 Act, the Board of Trustees of the fund may consider the activities of the fund’s
Subsidiary, the related nature and quality of the services provided with respect to the Subsidiary and the lack of pass-through fees (as
discussed below). However, the Funds’ Board of Trustees does not approve the Subsidiaries’ advisory contracts pursuant to
Section 15 as the Subsidiaries are not registered investment companies under the 1940 Act and therefore are not subject to the requirements
of Section 15 thereof.

The Registrants respectfully note that Form N-1A, Item 28(d),
which relates to the filing of investment advisory contracts as exhibits to a registration statement, requires the filing of investment
advisory contracts relating to the management of a Fund’s assets, not a Subsidiary’s assets. Furthermore, the Registrants
do not believe a Subsidiary’s investment advisory contracts, nor any other Subsidiary-level service provider contracts, fall within
the meaning of “Other Material Contracts” set forth in Form N-1A, Item 28(h), particularly in light of the fact that the Funds’
investment advisory contracts state that the calculation of fees applicable thereunder will not include the assets on which fees are paid
under the Subsidiaries’ investment advisory contracts. Accordingly, the

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Registrant has not included the Subsidiaries’ investment
advisory contracts as exhibits to the Registrant’s registration statement.

2) explain in the letter to us whether the financial statements
of the fund are consolidated with those of the Subsidiary.

Response:	Registrant confirms that each fund’s
financial statements will be consolidated with its respective Subsidiary.

3) confirm to us that the Subsidiary and its board will agree
to inspection by the Staff of the Subsidiary’s books and records, which will be maintained under Section 31 of the 1940 Act and
the rules thereunder.

Response:	Each Subsidiary and its board agree to
inspection by the SEC of its books and records maintained under Section 31 of the 1940 Act and rules thereunder.

4) confirm that the Subsidiary
and its board will agree to designate an agent for service of process in the U.S.

Response:	Each Subsidiary and its board have designated
an agent for service of process in the U.S.

 14. Comment:	Global comment for both funds: Principal Investment Strategies, 5th paragraph on page 5. Consider moving
the disclosure in second and third sentence and last part of 5th sentence to the Principal Risks section. (See General Instruction
C.3(a) to Form N-1A, requiring information required by Items 2 through 8 be disclosed in numerical order.)

Response:	Requested disclosure has been moved to
the Portfolio Turnover Risk description in the Principal Risks section for each Fund.

 15. 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.

 16. Comment:	Fund of Funds Risk, page 6. There is no reference to investing in other funds in the Principal Investment Strategies.
Add discussion there, or explain why it is not appropriate to add.

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Response:	Investing in other funds is not a principal
investment strategy, so the risk factor has been removed and included as an additional risk factor on page 32.

 17. Comment:	Global comment for both funds: Principal Risks. In Foreign Investing Risk, please further distinguish between the
risk of foreign investing and foreign government securities, 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 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 rescheduling; and (c) there is
no legal or bankruptcy process by which defaulted government debt may be collected in whole or in part.

 18. Comment:	Global comment for both funds: Principal Risks, Index/Tracking Error Risk. Consider renaming this factor given
the fund is not an index fund.

Response:	The Index/Tracking Error Risk has been
renamed “Hedge Fund Correlation Risk.”

 19.	 Comment:	Total Return Table, page 8. Explain to us how the Barclay Fund of Funds Index is a broad-based market index because this fund is not a fund
of funds.

Response:	The Fund seeks to provide capital appreciation
consistent with the risk-return characteristics of a diversified portfolio of hedge funds. The Barclay Fund of Funds Index is a measure
of the average return of all Funds of Funds (“FoFs”) in the Barclay database. Index returns are recalculated by Barclay Hedge,
Ltd. throughout each month. The index is administered by Barclay, which is an organization that is not an affiliated person of the Fund,
its investment adviser, or principal underwriter, as required by Instruction 5 to Item 27(b) (7) of Form N-1A to meet the definition of
an appropriate broad-based securities index. Accordingly, we believe this index meets the requirements for use as the Fund’s broad-based
market index.

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 20. Comment:	In the paragraph under the Total Return Table, page 8, third to last sentence, disclose whether the index reflects
a deduction for taxes. (See requirement under Item 4 of Form N-1A.)

Response:	The Barclay Fund of Funds Index measures
only the arithmetic average of the net returns of all funds of funds in the Barclay database that have reported during that month, which
would not include any calculation for expenses or taxes at the index level. As noted in the referenced footnote however, the net returns
of all funds of funds in the index reflect the managed fees and expenses of both the funds of funds in the index and the hedge funds in
which they invest, and net returns are generally deemed to reflect a deduction for any applicable taxes. The third from last sentence
in Footnote B will therefore be revised as follows:

“The performance of the Index reflects the managed fees
and other expenses of both the funds of funds in the Index and the hedge funds in which these funds of funds invest, but does not reflect
the deduction of fees, expenses or taxes at the Index level.”

 21. Comment:	Principal Investment Strategies, page 11, third sentence of first 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, s