April 17, 2013
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Touchstone Strategic Trust (the “Trust”)
Form N-14/A for the reorganization of the Touchstone Focused Equity Fund (the “Acquired Fund”), a series of the Touchstone Funds Group Trust, into the Touchstone Focused Fund (the “Acquiring Fund”), a series of the Touchstone Strategic Trust.
Ladies and Gentlemen:
On behalf of the Trust, we are filing for your review Form N-14/A including the Combined Information Statement/Prospectus, Statement of Additional Information, and relevant exhibits, with respect to the acquisition of assets of the Acquired Fund for shares of the Acquiring Fund. This pre-effective amendment incorporates comments received by the staff on April 1, 2013. Accompanied with this filing is a request for acceleration to declare the filing effective at 8:00 a.m. on Thursday, April 18, 2013, or as soon as practicable thereafter.
Please direct any comments or questions on this filing to the undersigned at (513) 629-2941.
| Best regards, |
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| /s/ Bo James Howell |
| Bo James Howell |
| Counsel |
P.O. Box 9878 · Providence, RI 02940-8078
ph 800.543.0407 · TouchstoneInvestments.com
Touchstone Securities, Inc. · Member FINRA and SIPC