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1290 FUNDS

 July 1, 2022

 VIA
EDGAR AND E-MAIL

 Matthew Williams

U.S. Securities and Exchange Commission

 100 F Street, NE

Washington, DC 20549

Re:
 Responses to U.S. Securities and Exchange Commission Staff Comments on Post-Effective Amendment No. 49 to
the Registration Statement on Form N-1A of 1290 Funds (File Nos. 333-195390; 811-22959)

Dear Mr. Williams:

 On behalf of 1290
Funds (the “Trust”), set forth below are comments that you provided on June 10, 2022, concerning Post-Effective Amendment No. 149 to the Trust’s Registration Statement on Form N-1A
(the “Post-Effective Amendment”). The Post-Effective Amendment was filed with the U.S. Securities and Exchange Commission on April 25, 2022, pursuant to the Securities Act of 1933, as amended, and Rule 485(a) of Regulation C
thereunder, and pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), and the regulations thereunder. Your comments are set forth in italics and are followed by the Trust’s responses. Unless otherwise noted,
defined terms have the same meanings as in the Post-Effective Amendment.

1.
 General Comments

a.
 Comment: Where a comment is made in one location, it is applicable to all similar disclosures
elsewhere in the registration statement. We remind you that the Fund and its management are responsible for the adequacy and the accuracy of the disclosure.

Response: The Trust will apply any revisions made in response to the Staff’s comments to disclosures throughout the registration
statement, to the extent applicable.

b.
 Comment: Please include the completed fee table and expense example for the Fund as part of
your response.

 Response: The Trust has attached to this letter as Appendix A the completed fee table and
expense example for the Fund.

c.
 Comment: Please update the share class tickers on EDGAR when they are available. See Rule 313
under Regulation S-T.

 Response: The Trust will update the share class
tickers on EDGAR when the next post-effective amendment is filed.

 K&L GATES LLP

1601 K STREET NW WASHINGTON DC 20006

 T +1 202 778 9000 F +1 202
778 9100 klgates.com

 U.S. Securities and Exchange Commission

July 1, 2022

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2.
 Summary Prospectus

a.
 Comment: The “Principal Investment Strategy” section of the summary prospectus
provides that the Fund considers a company “to be a ‘small-capitalization’ company if, at the time of purchase, its market capitalization is less than or equal to the market capitalization of the largest company included within the
Fund’s benchmark index.” The summary prospectus further provides that “[a]s of February 28, 2022, the market capitalization of the largest company included in the Fund’s benchmark index was approximately
$11.9 billion.” Please disclose the Fund’s benchmark index in the Fund’s principal investment strategy disclosure. Please revise the Fund’s definition of a small capitalization company so that it is reasonable.
Alternatively, please explain supplementally why the registrant considers a company with a market capitalization at the top of this range (i.e. $11.9 billion) to be a small capitalization company. Is it consistent with industry indices,
classifications used by industry rating organizations, or definitions used within financial publications? See Frequently Asked Questions about Rule 35d-1 (Investment Company Names), Question 6 (Dec. 4,
2001).

 Response: The Fund considers a small capitalization company to be a company with a market
capitalization, at the time of purchase, that is within the range of the market capitalization of the companies included in the Russell 2000® Growth Index. The Trust will disclose this
index in the Fund’s principal strategy disclosure. The Trust believes that this definition is reasonable and consistent with industry standards. For example, numerous other mutual funds that are categorized by Morningstar, Inc. as “small
growth” funds similarly define small capitalization companies, for purposes of their 80% investment policy pursuant to Rule 35d-1 under the 1940 Act, as those with a market capitalization that does not
exceed that of the largest company in the Russell 2000® Growth Index.1 The Staff’s comment refers to the market capitalization at
the top range of the index; however, the Fund generally expects the average weighted market capitalization of the Fund’s portfolio to be below that of the index. Accordingly, the Trust respectfully submits that no revisions are necessary.

b.
 Comment: The summary prospectus provides that the Fund’s investments include U.S. micro-cap companies, which, at the time of purchase, have capitalizations that place them among the smallest 5% of companies listed on U.S. exchanges or in over the courter (“OTC”) markets. It is not clear
whether the definition of “micro-cap companies” includes any OTC traded company or only the smallest 5% of companies traded OTC; please clarify.

Response: The referenced disclosure in the summary prospectus has been revised to omit the reference to OTC markets as follows:
“The Fund’s investments include U.S. micro-cap companies, which, at the time of purchase, have capitalizations that place them among the smallest 5% of companies listed on U.S. exchanges
or in over the counter (“OTC”) markets.”

c.
 Comment: Please consider updating the following disclosure, which appears in the last
paragraph of “Market Risk” in the “Principal Risks” section of the summary prospectus: “In

1
 For example, the definition of small cap company in the prospectus for each of American Century Small Cap
Growth Fund, Alger Small Cap Growth Fund, Goldman Sachs Small Cap Growth Fund, Putnam Small Cap Growth Fund, and Delaware Small Cap Growth Fund refers to the capitalization range of the Russell
2000® Growth Index.

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July 1, 2022

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addition, the U.S. Federal Reserve has invested or otherwise made available substantial amounts of money to keep credit flowing through short-term money markets and has signaled that it will
continue to adjust its operations as appropriate to support short-term money markets. Amid these efforts, concerns about the markets’ dependence on the Fed’s provision of liquidity have grown.”

Response: The Trust and its management have reviewed the referenced disclosure and believe it remains relevant and therefore,
respectfully submit that no updates are necessary at this time. In response to the comment, the Trust will further review the disclosure and consider making appropriate updates as part of the annual update of the Trust’s registration statement
or in a future post-effective amendment.

d.
 Comment: Regarding the “Sector Risk” disclosure, please identify in the principal
strategy section the sectors in which the Fund may be focused and include risk disclosure specific to each such sector. We note that the Item 9(c) disclosure includes sector-specific risk disclosures.

Response: The Fund does not have a principal investment strategy to focus its investments in, or concentrate its investments in, any
particular industry or sector, but the Fund, from time to time, based on market or economic conditions, may have significant positions in one or more sectors of the market. The Fund therefore includes general “Sector Risk” disclosure that
is introduced by a statement to that effect. For the Fund, industry and sector allocation is a result of the then-current investment opportunities identified by the Fund’s portfolio managers pursuant to the principal investment strategies
identified in the Fund’s Prospectus. Accordingly, the Fund’s investments in an industry or sector will vary over time depending on the portfolio managers’ then-current view of the investment opportunities presented by such industry or
sector. Therefore, the Trust believes that the current disclosure is consistent with, and appropriately tailored to, the broad investment mandate of the Fund, and that no additional disclosure in the principal investment strategy or risk section is
necessary.

e.
 Comment: In the “Principal Risks” section, please tailor the “Derivatives
Risk” disclosure to the types of derivatives the Fund intends to principally invest in and identify in the principal strategy disclosure the derivatives that the Fund intends to principally invest in. See ADI
2019-08 - Improving Principal Risk Disclosure.

 Response: The Trust
has revised the principal strategy disclosure to add the following: “The Fund may purchase put and call options on equity indexes and put and call options on exchange-traded funds tracking certain equity indexes to gain broad market exposure or
for hedging purposes.” The principal risks of these instruments are described in the “Derivatives Risk” risk factor and additional information about these instruments is provided in the statutory prospectus. The Trust respectfully
submits that the risk disclosure is appropriate and that no further revisions are necessary.

f.
 Comment: In the “Principal Risks” section, “Large Transaction Risk”
provides that “[a] significant percentage of the Fund’s shares may be owned or controlled by the Adviser and its affiliates.” If true, also add “and the Sub-adviser” here. Please
supplementally confirm whether Essex is an affiliate.

 Response: The referenced disclosure is intended to
address the circumstance that, as a new fund, a significant percentage of the Fund’s shares may be owned by the Adviser or its affiliates due to, for example, the contribution of seed capital. Essex Investment Management Company, LLC
(“Essex”), the Fund’s sub-adviser, is not expected to own or control a significant percentage of the Fund’s shares, nor is Essex an affiliate of the Adviser.

g.
 Comment: Please add disclosure regarding rights and warrants to the “Preferred Stock
Risk” section.

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July 1, 2022

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 Response: The Trust believes that the risks regarding stock rights and warrants are
the risks of equity securities, which are adequately described in the “Market Risk” and “Equity Risk” risk factors that are part of the Fund’s principal risk disclosure, and therefore respectfully submits that no revisions
are necessary.

h.
 Comment: Please supplementally identify the broad-based securities market index that the Fund
will utilize.

 Response: The Trust anticipates that the Fund will use the Russell 2000® Growth Index as the broad-based securities market index against which Fund performance can be compared.

i.
 Comment: The “Who Manages the Fund” section reads “However, the Adviser may not
enter into a sub-advisory agreement on behalf of the Fund with an ‘affiliated person’ of the Adviser unless the sub-advisory agreement is approved by the
Fund’s shareholders.” Please clarify here whether Essex is affiliated.

 Response: The Trust
confirms that Essex is not an affiliated person of the Adviser. The referenced disclosure accurately describes the Trust’s multi-manager exemptive relief; the Trust believes the disclosure is adequate and respectfully submits that no revisions
are necessary.

3.
 Statutory Prospectus

a.
 Comment: Page 10 of the prospectus, in the section “More information on fees and
expenses,” reads “The annual operating expenses of the Fund, as disclosed in this Prospectus, do not reflect any fees and expenses that are imposed by sponsors of products that offer the Fund as an underlying investment option, such as
retirement plans and/or variable life insurance contracts and variable annuity certificates and contracts. Such fees and expenses would increase the Fund’s overall fees and expenses, and would not be subject to the expense caps described above,
thereby reducing the Fund’s returns.” Are the funds in the Trust offered as investment options for variable life or variable annuity contracts? If so, please add appropriate fee table disclosure and other disclosure applicable to insurance
funds. Otherwise, please delete.

 Response: Like certain other series of the Trust, the Fund may be offered as
an underlying investment option in retirement plans and may be an underlying fund investment for other mutual funds that are underlying investment options for variable insurance contracts, and the disclosure is intended to address this fact. The
Fund is not itself an insurance fund and therefore no fee table disclosure or other disclosure applicable to insurance funds is necessary.

b.
 Comment: The Item 9(b) and Item 9(c) disclosure in the section “More information
on strategies and risks” does not clearly and concisely inform investors about how the Fund principally intends to invest and the related risks and impedes understanding of the principal strategy and risk disclosure. For example, the principal
risk disclosure does not appear tailored to the Fund. The principal strategy and principal risk disclosure herein also cross references Item 4, suggesting that the Fund has not provided summary disclosure in response to Item 4. Please clearly
distinguish which of the strategies and risks herein are principal and which are not, tailoring the disclosure to this Fund following the layered disclosure regime contemplated by Form N-1A, or move all non-principal strategies and risks to the SAI. See General instruction C(3)(b) of N-1A and see also IM Guidance Update 2014-06. Also
the Item 9 disclosure should include the detailed disclosure about the proprietary strategies that the Adviser uses in selecting which investments to buy and when to sell investments. A list of acceptable investments as cross referenced below is not
sufficient. See Item 9(b)(2) of Form N-1A.

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July 1, 2022

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 Response: The Trust notes that, as required by Item 4 of Form N-1A, the Fund’s principal risks are identified in the summary portion of the prospectus. The “More information on strategies and risks” section of the statutory prospectus affirms that the
Fund’s principal risks are discussed in the summary prospectus. In addition, this section includes a separate sub-section for principal investment risks, which provides additional information about the
Fund’s principal risks identified in the summary prospectus, and separate sub-sections for “General Investment Risks” (e.g., disclosure about recent market conditions and associated risks) and
“Additional Information about Risks,” which provides additional information that may be associated with the Fund’s principal risks but that may not be principal to the Fund’s investment strategies.

General Instruction C.(3)(a) of Form N-1A provides that “[i]nformation that is included in Items 2
through 8 need not be repeated elsewhere in the prospectus.” The Trust believes that the information disclosed in response to Item 4 need not be identified again as a principal risk in response to Item 9(b).

c.
 Comment: In the “80% Policies” section, the Prospectus reads “In
addition, the Fund may specify a market cap range for acquiring portfolio securities.” Please delete “may” and revise to state in the affirmative.

Response: The referenced sentence will be revised to read: “In addition, the Fund may specify specifies a
market cap range for acquiring portfolio securities.”

d.
 Comment: In the second paragraph of the “80% Policies” section, the Prospectus
reads, “The Sub-Adviser has complete discretion to select portfolio securities for the Fund’s assets (or portion thereof), subject to the Fund’s investment objective, restrictions and polices
and other parameters that may be developed from time to time by the Adviser.” Notwithstanding the prior comment regarding layered disclosure, please add this sentence to the Item 4(a) disclosure.

Response: The Fund’s Item 4 disclosure in the summary prospectus clearly discloses that the Fund is
sub-advised and the role of the Fund’s sub-adviser. The summary prospectus identifies the sub-adviser of the Fund, as
required by Form N-1A, and discloses that the portfolio manag