3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799
215.981.4000
Fax 215.981.4750
Lisa D. Zeises
direct dial: (215) 981-4722
zeisesl@pepperlaw.com
October 28, 2011
Via EDGAR
Filing Desk U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 |
Re: Touchstone Strategic Trust
Registration Statement on Form N-14
Ladies and Gentlemen:
Touchstone Strategic Trust (the “Trust”) is hereby transmitting for filing a registration statement on Form N-14 (the “Registration Statement”) under the Securities Act of 1933 (the “1933 Act”) to register shares of beneficial interest (the “Shares”) of the following series of the Trust: Touchstone Dynamic Equity Fund, Touchstone Emerging Growth Fund, Touchstone International Equity Fund, Touchstone Conservative Allocation Fund, Touchstone Balanced Allocation Fund, Touchstone Moderate Growth Allocation Fund, Touchstone Growth Allocation Fund, Touchstone US Long/Short Fund, Touchstone Value Fund, Touchstone International Small Cap Fund, Touchstone Capital Growth Fund, Touchstone Mid Cap Value Opportunities Fund, Touchstone Small Cap Value Opportunities Fund and Touchstone Focused Fund (each an “Acquiring Fund” and collectively, the “Acquiring Funds”).
It is anticipated that the Shares would be issued to shareholders of a corresponding series of Old Mutual Funds I or Old Mutual Funds II (each an “Old Mutual Fund” and collectively, the “Old Mutual Funds”), in connection with proposed reorganizations of each Old Mutual Fund into a corresponding Acquiring Fund, pursuant to Agreements and Plans of Reorganization (the “Agreements”).
The Agreements are subject to the requisite approval of the Old Mutual Funds’ shareholders at a meeting to be held in February 2012.
Pursuant to Rule 488 under the 1933 Act, it is proposed that this filing will become effective on November 28, 2011.
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www.pepperlaw.com
U.S. Securities and Exchange Commission
October 28, 2011
If you have any questions regarding the Registration Statement, please contact the undersigned at 215.981.4722 or John M. Ford at 215.981.4009.
cc: Brian Hirsch, Esq.
John M. Ford, Esq.