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February 9, 2011
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 AlphaSector Rotation 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 AlphaSector Allocation Fund, a series of the Trust, by and in exchange for shares of Virtus AlphaSector Rotation Fund, another series of the Trust. As of January 31, 2011, assets of the Virtus AlphaSector Allocation Fund are $41.7 million, which are less than 10% of the assets of Virtus AlphaSector Rotation Fund at $446.2 million, so pro forma financial information is not included with this filing.
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 |