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Response Letter

 February 8, 2023

VIA EDGAR AND E-MAIL

Ms. Elisabeth Bentzinger

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. 51
to the Registration Statement on Form N-1A of 1290 Funds (File Nos. 333-195390; 811-22959)

Dear Ms. Bentzinger:

On behalf of 1290 Funds (the “Trust”), set forth below are comments that you provided by telephone on
January 27, 2023, concerning Post-Effective Amendment No. 51 to the Trust’s Registration Statement on Form N-1A (the “Post-Effective Amendment”) with respect to 1290 Loomis Sayles
Multi-Asset Income Fund (formerly known as 1290 DoubleLine Dynamic Allocation Fund). The Post-Effective Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on December 12, 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.
 Summary Prospectus

a.
 Comment: The first paragraph of the “Principal Investment Strategy” section
provides that “[t]he Fund allocates its assets among asset classes and market sectors based upon the Sub-Adviser’s evaluation of global economic conditions and risk premiums of income producing asset
classes (that is, the expected return to be received from investing in income producing asset classes that carry greater risk).” Please disclose the market sectors across which the Fund allocates its assets and provide any corresponding
principal risks of such sectors.

 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 may, from time to time, based on market or economic conditions, have significant positions in one or more sectors of the market.
The Fund has revised the principal risk section in the summary prospectus to include the following general “Sector Risk” disclosure, which is introduced by a statement to that effect:

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February 8, 2023

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 Sector Risk — From time to time,
based on market or economic conditions, the Fund may have significant positions in one or more sectors of the market. To the extent the Fund invests more heavily in particular sectors, its performance will be especially sensitive to developments
that significantly affect those sectors. Individual sectors may be more volatile, and may perform differently, than the broader market. The industries that constitute a sector may all react in the same way to economic, political or regulatory
events.

 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 strategy 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 general “Sector Risk” 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.

b.
 Comment: The first paragraph of the “Fixed Income Allocation –” sub-section of the “Principal Investment Strategy” section provides that “[t]he Fund typically expects to invest…up to 40% of its net assets in any of the following: bank loans,
securitized instruments such as commercial and residential mortgage-backed securities, asset-backed securities, and collateralized loan obligations, floating or variable rate obligations, or emerging market debt.” Because the Fund may invest
significantly in less liquid securities, please explain supplementally how the Adviser has determined that this strategy is appropriate for a mutual fund.

Response: The Trust believes that there is an active market, or there are other relevant measures of liquidity, for
many, if not most, of such securities in which the Fund may invest and, at any rate, the Trust limits investments in illiquid securities to no more than 15% of the Fund’s net assets.

c.
 Comment: The second paragraph of the “Fixed Income Allocation –” sub-section of the “Principal Investment Strategy” section provides that “[t]he Fund may invest in fixed income securities of any credit quality, including below investment grade securities (commonly
known as “junk bonds”).” Please disclose whether the Fund may invest in securities that are in default as part of its principal investment strategy.

Response: The Trust has revised the second paragraph of the “Fixed Income Allocation –” sub-section of the “Principal Investment Strategy” section to include the following disclosure: “The Fund does not normally invest in securities that are in default or have defaulted with respect to
the payment of interest or repayment of principal, but may do so depending on market or other conditions. The Fund may continue to hold securities that go into default.”

d.
 Comment: Please disclose any criteria as to maturity that the Fund may use with respect to
its investments in fixed income securities.

 Response: The Fund does not have specific
criteria with respect to the maturity of the fixed income securities in which it may invest. The Trust has revised the sentence referenced in comment c above to read as follows: “The Fund may invest in fixed income securities of any maturity
or credit quality, including below investment grade securities (commonly known as “junk bonds”).”

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February 8, 2023

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 The Fund also does not have specific criteria with respect to the duration of
the fixed income securities in which it may invest; although, as stated in its summary prospectus, “[u]nder normal market conditions, the weighted average effective duration of the Fund’s fixed income allocation is expected to
range from zero to seven years.”

e.
 Comment: We note that the Fund may invest in ETFs; however, the fee table does not have a
line item for “acquired fund fees and expenses”; please confirm that those fees and expenses will not exceed one basis point.

Response: The Trust has updated the Fund’s fee table, and the updated fee table includes a line item for acquired
fund fees and expenses.

f.
 Comment: The Market Risk disclosure provides that “…[t]he
U.S. Federal Reserve [(“Fed”)] 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.” If there is anything to update with respect to current action taken by the Fed, please
consider revising the disclosure.

 Response: The Trust and its management have reviewed the
referenced disclosure and believe it remains relevant; however, in response to the comment, the Trust has expanded the referenced disclosure to include the following disclosure:

Policy changes by the U.S. government and/or the Fed and political events within the United States may
affect investor and consumer confidence and may adversely impact financial markets and the broader economy, perhaps suddenly and to a significant degree. A downgrade of the ratings of U.S. government debt obligations, or concerns about the U.S.
government’s credit quality in general, could have a substantial negative effect on the U.S. and global economies. High public debt in the United States and other countries creates ongoing systemic and market risks and policymaking uncertainty.

g.
 Comment: In the “Derivatives Risk” disclosure, please include specific
risk disclosure regarding futures, forwards and swaps, which are identified as principal investments of the Fund.

Response: The Trust believes that the current “Derivatives Risk” disclosure describes the principal risks
associated with investments in futures, forwards and swaps. The Trust also notes that the “Principal Investment Risks” sub-section in the “More information on strategies and risks” section
of the statutory prospectus includes additional risk disclosure specific to futures, forwards and swaps. This discussion supplements the summary “Derivatives Risk” discussion, consistent with Items 4 and 9 of
Form N-1A. The Trust believes that the current disclosure is appropriate and that no revisions are necessary.

h.
 Comment: In the “Emerging Markets Risk” disclosure, please disclose the risks
associated with investments in China or explain supplementally why those risks are not principal risks for the Fund. Please see the April 21, 2020 public statement by the SEC Chairman titled “Emerging Market Investments
Entail Significant Disclosure, Financial Reporting and other Risks; Remedies are Limited.”

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February 8, 2023

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 Response: The Trust does not consider risks associated with
investments in China to be principal investment risks for the Fund. The Trust confirms that it has reviewed the “Emerging Markets Risk” disclosure included in the Fund’s prospectus and has determined that the disclosure is
appropriate. The Trust has included information about the risks associated with investments in China specifically in the SAI.

i.
 Comment: Convertible Securities Risk – If the Fund may invest in contingent
convertible securities (“CoCos”), then please explain supplementally the extent to which it may do so. The Staff may have additional disclosure comments based on the response.

Response: The Trust confirms that the Fund does not invest in CoCos as a principal investment strategy. Accordingly, no
additional disclosure in the principal investment strategy or risk section is necessary. The Trust has included information about the risks associated with investments in CoCos specifically in the SAI.

j.
 Comment: In the “Loan Risk” disclosure, please make clear that this risk factor
refers to bank loans. Also, if the Fund may hold a significant amount of “covenant lite” loans, please disclose that in the “Principal Investment Strategy” section and revise the Loan Risk disclosure to address risks associated
with such loans.

 Response: The Trust has revised the “Loan Risk” disclosure to
clarify that this risk factor refers to bank loans. Also, the Trust confirms that the Fund does not invest in “covenant lite” loans as a principal investment strategy. Accordingly, no additional disclosure in the principal investment
strategy or risk section is necessary. The Trust notes, however, that risks associated with investments in “covenant lite” loans are currently included in the risk factor in the statutory risk section.

k.
 Comment: Portfolio Turnover Risk – The Staff assumes that this risk factor is included
because of the Fund’s repositioning; however, if the repositioning will result in higher portfolio turnover risk, please make that clear in the disclosure. Also, if there could be adverse tax consequences to shareholders as a result of the
repositioning, please disclose.

 Response: The Trust notes that, prior to the Fund’s
repositioning, the Fund’s principal investment strategy disclosed that “[t]he Fund’s holdings may be frequently adjusted to reflect the Sub-Adviser’s assessment of changing risks, which
could result in high portfolio turnover[,]” and the Fund included Portfolio Turnover Risk as a principal risk. Following the Fund’s repositioning, the Fund’s principal investment strategy continues to include that same sentence, and
the Fund continues to include Portfolio Turnover Risk as a principal risk. Thus, following its repositioning, the Fund continues to be subject to high portfolio turnover risk and its disclosure has not changed in this regard. The Trust further notes
that the Fund notified shareholders of its repositioning in a supplement to the Fund’s prospectus dated August 18, 2022. Among other aspects of the Fund’s repositioning, the supplement disclosed, in particular, the following:

In connection with its restructuring, the Fund will experience a transition period during which
substantially all of the securities held in the Fund will be sold and the Fund repositioned. The Fund may not pursue its investment objective and principal investment strategy during the transition period and may incur increased brokerage
commissions and other transaction costs in connection with the restructuring. The repositioning of the Fund’s securities holdings may result in

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higher taxes when Fund shares are held in a taxable account. Investors should consult with their own tax advisor concerning their particular tax situation.

In light of the foregoing, the Trust has concluded that no changes to the disclosure are necessary.

l.
 Comment: The Staff notes that “Real Estate Investing Risk” is included as a
principal risk. If there are any principal risks associated with investments in sub-prime mortgages, please disclose in the principal risk section as well as in the principal strategy section, and disclose
that the liquidity of those types of securities could change dramatically over time.

Response: The Trust confirms that the Fund does not invest in sub-prime
mortgages as a principal investment strategy. Accordingly, no additional disclosure in the principal investment strategy or risk section is necessary. The Trust notes, however, that risks associated with investments in
sub-prime mortgages, as well as disclosure that the liquidity of these types of securities could change dramatically over time, is currently included in the risk factor in the statutory risk section.

2.
 Statutory Prospectus

a.
 Comment: Per Item 9(b)(1) of Form N-1A, please
describe the Fund’s principal investment strategies in the Item 9 disclosure, which begins on page 17 in the section titled “More information on strategies and risks.” The Staff is looking for a layered disclosure approach where the
Fund has a summary and then more detailed disclosure in Item 9.

 Also, the first paragraph in
the section titled “Additional Information about the Investment Strategies” beginning on page 17 states that “The following provides additional information regarding the principal investment strategies discussed in the “About the
Fund — Investments, Risks, and Performance — Principal Investment Strategy” section for the Fund, and information about additional investment strategies that the Fund may employ in pursing its investment objective.” Please move
all non-principal investment strategies to the SAI or clearly distinguish which investment strategies are principal and which are not. See Items 9(b) and 16(b) of Form
N-1A as well as Guidance Regarding Mutual Fund Enhanced Disclosure, IM Guidance Update No. 2014-08 (June 2014). Similarly, the first paragraph in the section titled
“Risks” beginning on page 20 states that “Some of the risks of investing in the Fund are discussed below, including the principal risks of the Fund as discussed in “About the Fund — Investments, Risks, and Performance —
Principal Risks.” Please apply the same comment with respect to the “Risks” section.

 Response:
The Trust submits that the Item 4 disclosure included in the Fund’s summary prospectus is an adequate and appropriate summary of the F