ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM |
November 29, 2017 | Nathan Somogie T +1 617 951 7326 nathan.somogie@ropesgray.com |
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re: | Brighthouse Funds Trust I (the “Trust”) (File No. 811-10183) |
Ladies and Gentlemen:
On behalf of the Trust, electronically transmitted herewith is the Trust’s registration statement on Form N-14 (the “Registration Statement”) relating to the issuance of shares in connection with the reorganization of Pyramis Managed Risk Portfolio into Schroders Global Multi-Asset Portfolio, each a series of the Trust, and the reorganization of Allianz Global Investors Dynamic Multi-Asset Plus Portfolio into JPMorgan Global Active Allocation Portfolio, each a series of the Trust.
The Registration Statement is proposed to become effective on December 29, 2017 pursuant to Rule 488 under the Securities Act of 1933, as amended. We would greatly appreciate receiving any comments you might have at your earliest convenience.
Please direct any questions you may have with respect to this filing to the undersigned at (617) 951-7326.
Very truly yours,
/s/ Nathan D. Somogie
Nathan D. Somogie, Esq.
cc: | Andrew Gangolf, Esq. |
Michael Lawlor, Esq.
Brian D. McCabe, Esq.
Jeremy C. Smith, Esq.