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    One Financial Plaza, Hartford, CT 06103  |  800.248.7971  |  Virtus.com

December 27, 2024

Securities
and Exchange Commission

100 F Street,
NE

Washington, D.C. 20549

Attention: Ashley Vroman-Lee

    Re:
    Virtus Solutions SMA Trust (now known as “Virtus Managed Account
    Completion Shares (MACS) Trust”), File Nos. 333-280702 and 811-23968 (“Registrant”)

Dear Ms. Vroman-Lee:

Thank you for your letter dated July 5, 2024, conveying the comments
of the staff of the U.S. Securities and Exchange Commission (the “Staff”) on the initial registration statement for
the Registrant filed on the same date to register shares of Virtus Newfleet Asset-Backed Securities Completion Fund (now known
as “Virtus Newfleet ABS MACS”), Virtus Newfleet Commercial Mortgage-Backed Securities Completion Fund (now known as
“Virtus Newfleet CMBS MACS”), Virtus Newfleet Floating Rate Completion Fund (now known as “Virtus Newfleet Floating
Rate MACS”), Virtus Newfleet High Yield Completion Fund (now known as “Virtus Newfleet High Yield MACS”), Virtus
Newfleet Residential Mortgage-Backed Securities Completion Fund (now known as “Virtus Newfleet RMBS MACS”), Virtus
Seix High Yield Completion Fund (now known as “Virtus Seix High Yield MACS”), Virtus Stone Harbor Emerging Markets
Corporate Debt Completion Fund (now known as “Virtus Stone Harbor EMD MACS”), and Virtus Stone Harbor Emerging Markets
Sovereign Debt Completion Fund (now known as “Virtus Stone Harbor EMD Sovereign MACS”)(each a “Fund” and
together the “Funds”). Below, we describe the changes to be made to the registration statement in response to the
Staff’s comments and provide any responses to such comments, as requested.

Comments on cover page:

 1. Comment: Please
                                         update or confirm the Fund’s series and class identifiers in EDGAR.

Response: We have updated or confirmed each Fund’s
series and class identifiers in EDGAR.

 2. Comment: Please
                                         update each Fund’s ticker symbol in EDGAR and include the Fund’s ticker symbol
                                         on the cover page of the prospectus and the Statement of Additional Information. See
                                         Item 1(a)(2) of Form N-1A.

Response: We have updated each Fund’s ticker
symbol in EDGAR and included each Fund’s ticker symbol on the cover page of the prospectus and Statement of Additional Information.

Global
comments applicable to all Funds:

 3. Comment: Please
                                         supplementally explain to us what “completion” means, which is included in
                                         each Fund’s name.

Response: The word “completion” in
each Fund’s name was intended to reference the Fund’s expected use as a means to efficiently complete an investor’s
managed account portfolio. The Registrant has since amended both its name and the name of each Fund as follows in an effort to
clarify the meaning:

Registrant new name: Virtus Managed Account Completion
Shares (MACS) Trust

Fund
names:

    Name
    in initial filing
    New
    name

    Virtus
    Newfleet Asset-Backed Securities Completion Fund
    Virtus
    Newfleet ABS MACS

    Virtus
    Newfleet Commercial Mortgage-Backed Securities Completion Fund
    Virtus
    Newfleet CMBS MACS

    Virtus
    Newfleet Floating Rate Completion Fund
    Virtus
    Newfleet Floating Rate MACS

    Virtus
    Newfleet High Yield Completion Fund
    Virtus
    Newfleet High Yield MACS

    Virtus
    Newfleet Residential Mortgage-Backed Securities Completion Fund
    Virtus
    Newfleet RMBS MACS

    Virtus
    Seix High Yield Completion Fund
    Virtus
    Seix High Yield MACS

    Virtus
    Stone Harbor Emerging Markets Corporate Debt Completion Fund
    Virtus
    Stone Harbor EMD MACS

    Virtus
    Stone Harbor Emerging Markets Sovereign Debt Completion Fund
    Virtus
    Stone Harbor EMD Sovereign MACS

 4. Comment: Please
                                         disclose in a footnote to each Fund’s fee table that “Other Expenses”
                                         are based on estimated amounts for the current fiscal year as required by Instruction
                                         6(a) to Item 3 of Form N-1A.

Response: The referenced footnote has been added.

 5. Comment: Please
                                         confirm if the fees waived by the Adviser will be subject to recoupment. If so, please
                                         disclose the terms of recoupment and ensure the recoupment period is limited to three
                                         years from the date of the waiver/reimbursement. Please also disclose that any recoupments
                                         would be limited to the lesser of: (1) the expense limitation in effect at the time of
                                         waiver, and (2) the expense limitation in effect at the time of recapture.

Response: The Registrant confirms that there are
no fees payable to the Adviser, and expenses reimbursed by the Adviser will not be subject to recoupment. Therefore, no change
has been made in response to this comment.

 6. Comment: Disclosure
                                         says the “Fund may use derivatives, such as credit default swaps, to increase or
                                         hedge (decrease) investment exposure to various fixed income sectors and instruments.”
                                         For Funds using this strategy, please disclose these fixed income sectors and instruments.

Response: With respect to Virtus Newfleet ABS
MACS, Virtus Newfleet CMBS MACS and Virtus Newfleet RMBS MACS, the referenced disclosure has been removed. With respect to Virtus
Newfleet High Yield MACS, the referenced disclosure has been amended to: “The Fund may use credit default swaps to increase
or hedge (decrease) investment exposure to the high yield credit market or particular high yield fixed income securities.”

 7. Comment: Please supplementally identify the appropriate
                                         broad-based index each Fund intends to use.

Response: The two emerging markets Funds intend
to use the J.P. Morgan EMBI Global Diversified Index, and the remaining Funds intend to use the Bloomberg U.S. Aggregate Bond
Index.

 8. Comment: Please
                                         include that the portfolio managers are jointly and primarily responsible for the management
                                         of the Funds, if true. See, Form N-1A, Item 5, Instruction 2.

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Response: The Registrant confirms that the portfolio
managers are jointly and primarily responsible for the management of the Funds and disclosure to that effect has been added to
the summary section of the prospectus for each Fund.

    9.
    Comment:	Please include the term “junk bonds” whenever disclosure refers to “below-grade”
    or “non- investment grade” investments. Please include disclosure that junk bonds are speculative.

Response: The requested disclosure has been added.

 10. Comment: For
                                         Funds with risk disclosure related to industry/sector concentration or sector focus investing,
                                         please disclose the sectors the Fund will focus on, if known.

Response: With respect
to Virtus Newfleet ABS MACS, Virtus Newfleet CMBS MACS and Virtus Newfleet RMBS MACS, the sector in which the Fund focuses its
investments is already disclosed, so we have adjusted the risk disclosure for each to clarify the referenced sector. The industries/sectors
are not known for Newfleet High Yield MACS, so we have added disclosure that the fund is not limited with respect to which sectors
and industries in which to focus its investments.

 11. Comment: For
                                         Funds with disclosure saying the subadviser normally maintains an “average portfolio
                                         duration of between 2 and 7 years,” please disclose a brief explanation and example
                                         of duration.

Response: The following disclosure has been added:
“Duration measures the interest rate sensitivity of a fixed income security. Generally, the longer the maturity the greater
the duration and, therefore, the greater effect interest rate changes have on the price of the security. Typically, for a fund
maintaining a modified adjusted duration of 3.5 years, for example, a one percent increase in interest rates would cause a 3.5%
decrease in the value of the fund’s fixed income assets. Similarly, a one percent decrease in interest rates typically would
cause the value of the fund’s fixed income assets to increase by 3.5%.”

 12. Comment: Please
                                         supplementally explain if any Fund will engage in investment activities in securities
                                         or other assets through any entity primarily controlled by the Fund. We may have additional
                                         comments.

Response: None of the Funds is expected to engage
in investment activities in securities or other assets through an entity primarily controlled by the Fund.

Comments on Virtus Newfleet Asset-Backed Securities Completion
Fund (now known as Virtus Newfleet ABS MACS)

 13. Comment: The
                                         Fund’s investment objective includes achieving a “relatively high level”
                                         of income. Please disclose how the Fund is defining “relatively high level.”
                                         (page 3)

Response: The following disclosure has been added:
“As of the date of this prospectus, the fund defines a ‘relatively high level of income’ for this purpose as
a level of income comparable to the yield to maturity of the agency component of the Bloomberg US Mortgage Backed Securities (MBS)
Index. As of August 22, 2024, the yield to maturity of the agency component of this index was 4.59%.”

 14. Comment: The
                                         disclosure says the Fund will invest in “other types of ABS that the fund’s
                                         subadviser determines are appropriate for investment.” Please include these other
                                         types of asset-backed securities (“ABS”) that are appropriate for investment.
                                         (page 4)

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Response: The referenced disclosure was attempting
to provide flexibility to invest in future types of collateral that are not being securitized today. Therefore, in response to
this comment the referenced disclosure has been changed to, “any collateral type that is securitized but not listed above.”

 15. Comment: Please
                                         disclose and include greater detail regarding how the Fund is defining the following:
                                         timeshare receivables, equipment leases, rentals, whole business securitizations, credit
                                         card receivables, and student loans. (page 4)

Response: The following disclosure has been added
with respect to the referenced types of ABS: “Timeshare receivables are generated by vacation ownership interest in a divided
form of property ownership, in which collateral can be secured with a fee simple interest in real estate or unsecured with the
right to use the unit but no ownership interest in the real estate. Equipment lease securitizations represent interests in small,
medium and large equipment leases, in which collateral can consist of various types of equipment, such as copiers, trucks, or
construction equipment. Whole business securitizations represent franchise ownerships collateralized primarily by royalty fees
paid by franchisees to franchisors, such as a percentage of the amount of sales generated. In addition, if the franchisor owns
a store outright, a synthetic royalty or the operating profits of the owned store may be pledged as additional collateral to the
securitization. Credit card receivables represent the securitization of a pool of credit card debt owed by consumers. Student
loan securitizations are backed by pools of student loans. The cash flows generated from the underlying agreements for each of
these types of ABS provide the bond holders with regular income.”

 16. Comment: Please
                                         supplementally explain if the Fund will invest 15% or more of its assets in funds relying
                                         on the exclusions under 3(c)(1) and 3(c)(7) of the Investment Company Act of 1940 (“1940
                                         Act”). We may have additional comments. (page 4)

Response: The Fund is not expected to invest 15%
or more of its assets in funds relying on the exclusions under Sections 3(c)(1) and 3(c)(7) of the 1940 Act.

 17. Comment: Please
                                         include principal risk disclosure regarding the following types of ABS identified in
                                         the principal investment strategy: auto loans, timeshare receivables, consumer loans,
                                         equipment leases, rentals, whole business securitizations, credit card receivables, and
                                         student loans. (page 4)

Response: The Registrant respectfully disagrees
that the risks associated with investment in the types of ABS identified in the principal investment strategy are unique enough
to merit separate risk disclosure for each, and we have been unable to find other funds making such disclosures. However, we have
added the following disclosure to the long form of Asset-Backed Securities Risk: “Certain of these obligations, such as
credit card receivables, are generally unsecured, and the obligors are often entitled to protection under consumer credit laws
granting, among other things, rights to set off certain amounts owed on the credit cards, thus reducing the balance due. Other
obligations that are secured, such as automobile receivables, may present issuers with difficulties in perfecting and executing
on the security interests, particularly where the issuer allows the servicers of the receivables to retain possession of the underlying
obligations, thus increasing the risk that recoveries on defaulted obligations may not be adequate to support payments on the
securities.”

 18. Comment: Under
                                         the heading, “Illiquid and Restricted Securities Risk,” please consider adding
                                         more risk disclosure regarding investing in unregistered and privately offered shares,
                                         including whether there is less public information available regarding these investments.
                                         (page 4)

Response: The following disclosure has been added
to the long form of Illiquid and Restricted Securities Risk: “In addition, issuers whose securities are not publicly traded
may not be subject to the disclosure and other investor protection requirements that may be applicable if their securities were
publicly traded, and as a result a

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fund may get only limited information about the issuer
of a given restricted security making the fund potentially less able to predict a loss.”

Comments on Virtus Newfleet Commercial Mortgage-Backed Securities
Completion Fund (now known as Virtus Newfleet CMBS MACS)

 19. Comment: Please
                                         disclose if the Fund will be investing in non-agency commercial mortgage-backed securities
                                         (“CMBS”) and include applicable disclosure that the liquidity of non-agency
                                         CMBS may change dramatically over time.