 | K&L Gates LLP 1601 K Street, N.W. Washington, DC 20006 T +1 202 778 9000 F +1 202 778 9100 klgates.com |
March 9, 2021
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Re: | Touchstone Strategic Trust |
Registration Statement on Form N-14
Dear Sir or Madam:
Transmitted herewith for filing on behalf of Touchstone Strategic Trust (the “Trust”), pursuant to the Securities Act of 1933, as amended (the “1933 Act”), and Regulation C thereunder, is a registration statement for the Trust on Form N-14 (the “Registration Statement”). The Registration Statement includes a Notice of Joint Special Meeting of Shareholders (the “Meeting”) of the AIG Active Allocation Fund, AIG Flexible Credit Fund, AIG Focused Alpha Large-Cap Fund, AIG International Dividend Strategy Fund, AIG Multi-Asset Allocation Fund, AIG Strategic Bond Fund, and AIG Strategic Value Fund (each, an “Acquired Fund”), each a series of the respective registrant as set forth below, a combined Proxy Statement and Prospectus, a Statement of Additional Information, and a proxy card relating to the Meeting to be delivered to shareholders of each Acquired Fund. The Meeting is being held to request shareholder approval of the reorganization of each Acquired Fund into the respective acquiring fund, each a series of the Trust, as set forth below (each, a “Reorganization”):
| Acquired Fund | Acquiring Fund |
| AIG Active Allocation Fund, a series of SunAmerica Series, Inc. | Touchstone Balanced Fund |
| AIG Flexible Credit Fund, a series of SunAmerica Income Funds | Touchstone Strategic Income Opportunities Fund |
| AIG Focused Alpha Large-Cap Fund, a series of SunAmerica Specialty Series | Touchstone Large Cap Focused Fund |
| AIG International Dividend Strategy Fund, a series of SunAmerica Equity Funds | Touchstone International Equity Fund |
| AIG Multi-Asset Allocation Fund, a series of SunAmerica Series, Inc. | Touchstone Balanced Fund |
| AIG Strategic Bond Fund, a series of SunAmerica Income Funds | Touchstone Strategic Income Opportunities Fund |
| AIG Strategic Value Fund, a series of SunAmerica Series, Inc. | Touchstone Value Fund |
Pursuant to Rule 488 under the 1933 Act, it is proposed that this Registration Statement will become effective 30 days after filing.
This transmission contains a conformed signature page. The manually signed original of this document is maintained at the offices of the Trust.
If you have any questions or comments concerning the foregoing, please call me at (617) 951-9053.
| | Very truly yours, | |
| | | |
| | /s/ Abigail P. Hemnes | |
| | | |
| | Abigail P. Hemnes | |
Attachments
K&L Gates LLP
Meredyth A. Whitford-Schultz
Touchstone Mutual Funds
