JAMES ALPHA FUNDS TRUST
515 Madison Avenue, 24th Floor
New York, New York 10022
Ultimus Fund Distributors, LLC
225 Pictoria Drive, Suite 450
Cincinnati, Ohio 45246
January 25, 2021
Filing Desk
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: David Orlic and Tony Burak
Re: James Alpha Funds Trust (Registrant)
File No. 333-251519
Registration Statement on Form N-14 and Request for Acceleration
Dear Messrs. Orlic and Burak:
The above referenced Registration Statement on Form N-14, which was filed on December 18, 2020 and amended through a pre-effective amendment on January 25, 2021 (the “Registration Statement”), was filed with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, for the purpose of registering:
| · | Class I and Class R6 shares of beneficial interest, without par value, of the James Alpha Macro Fund, James Alpha Total Hedge Portfolio, James Alpha EHS Fund, James Alpha Event Driven Fund, James Alpha Family Office Fund, and James Alpha Relative Value Fund, each a series of the Trust, in connection with the solicitation of shareholders of the corresponding series of The Saratoga Advantage Trust to approve the reorganization of their funds into the new series of the Trust; and |
| · | Class A, Class C, Class I, and Class R6 shares of beneficial interest, without par value, of the James Alpha Global Real Estate Investments Fund, James Alpha Multi Strategy Alternative Income Fund, James Alpha Managed Risk Domestic Equity Fund, James Alpha Managed Risk Emerging Markets Equity Fund, James Alpha Hedged High Income Fund, and James Alpha Structured Credit Value Fund, each a series of the Trust, in connection with the solicitation of shareholders of the corresponding series of The Saratoga Advantage Trust to approve the reorganization of their funds into the new series of the Trust |
On behalf of the above referenced Registrant and its principal underwriter, Ultimus Fund Distributors, LLC and pursuant to the requirements of Rule 461 under the Securities Act of 1933, we respectfully request that the effectiveness of the Registrant’s Registration Statement on Form N-14 be accelerated to Tuesday, January 26, 2021, or as soon as practicable thereafter. It is our understanding that you have previously discussed the possible acceleration of the Registration Statement with Matthew DiClemente of Stradley Ronon Stevens & Young, LLP.
Please contact Matthew DiClemente (215) 564-8173 if you have any questions or comments regarding this filing or the acceleration request.
| /s/ Darrell Crate | /s/ Kevin Guerette | ||
| Darrell Crate | Kevin Guerette | ||
| President | President | ||
| James Alpha Funds Trust | Ultimus Fund Distributors, LLC |
cc: Matthew R. DiClemente, Esq.
