Virtus Opportunities Trust N-14 Registration statement for investment companies business combination

April 23, 2009

Virtus Opportunities Trust

101 Munson Street

Greenfield, Massachusetts 01301

Telephone: 860-403-5246

Facsimile: 860-403-5670

VIA EDGAR

EDGAR Operations Branch

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Virtus Opportunities Trust

(Virtus Bond Fund)

Registration Statement on Form N-14

CIK 0001005020

Ladies and Gentlemen:

Pursuant to the Securities Act of 1933, as amended, and the General Rules and Regulations thereunder, enclosed for filing electronically is the Registration Statement on Form N-14 of Virtus Opportunities Trust (the “Trust”). This filing relates to the acquisition of the assets of Virtus Core Bond Fund, a series of the Trust, by and in exchange for shares of Virtus Bond Fund, a separate series of the Trust.

Any questions or comments with respect to this filing may be directed to Avery Maher of PNC Global Investment Servicing at 617-338-4057, Ann Flood at 860-263-4746, or the undersigned at 860-263-4791.

Very truly yours,

/s/ Kevin J. Carr, Esq.

Kevin J. Carr, Esq.

Enclosures
cc:	Ann Flood
	Avery Maher