MAINSTAY VP FUNDS TRUST
51 Madison Avenue
New York, NY 10010
January 3, 2017
VIA EDGAR
Mr. Jason Fox
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
| Re: | MainStay VP Funds Trust (“Registrant”) Form N-CSR Filing (File Nos. 002-86082 / 811-03833-01) |
Dear Mr. Fox:
This letter responds to comments you provided telephonically on December 21, 2016 regarding the Annual Reports to Shareholders for the various series of the Registrant (“Funds”) filed with the Commission on March 7, 2016 on Form N-CSR.
Your comments and the Registrant’s responses are provided below.
Comment 1:Financial highlights. Please provide a note to total return that states that total returns do not reflect any deduction of sales charges, mortality and expense charges, contract charges or administrative charges.
Response:Going forward, we will include the requested information in a footnote to the Funds’ financial highlights tables.
Comment 2: Expense waivers.Please confirm if any of the expense reductions from the contractual waivers are subject to potential recoupment.
Response: The Registrant confirms that the expense reductions from the contractual waivers are not subject to potential recoupment.
If you have any questions or comments in connection with the foregoing, please contact the undersigned at 201-685-6232.
Very truly yours,
/s/ Y. Rachel Kuo
Y. Rachel Kuo
Assistant Secretary
