| Sullivan & Worcester LLP | T 202 775 1200 | |
| 1666 K Street, NW | F 202 293 2275 | |
| Washington, DC 20006 | www.sandw.com |
June 23, 2009
VIA EDGAR
EDGAR Operations Branch
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Virtus Opportunities Trust
(Virtus Wealth Builder Fund &
Virtus Wealth Guardian Fund)
CIK 0001005020
(File No. 811-07455)
Ladies and Gentlemen:
Pursuant to the Securities Exchange Act of 1934, as amended, and Rule 14a-6 thereunder, enclosed for filing electronically is the definitive proxy statement on Schedule 14A of Virtus Opportunities Trust, on behalf of the Virtus Wealth Builder Fund and Virtus Wealth Guardian Fund.
Any questions or comments with respect to this filing may be directed to the undersigned at (202) 775-1227.
Very truly yours,
/s/ Arie Heijkoop, Jr.
Arie Heijkoop, Jr.
Enclosures
| cc: | Kevin J. Carr, Esq. |
| Ann Flood |