January 27, 2012

Ms. Laura Hatch
Staff Accountant
Securities and Exchange Commission
Division of Investment Management, Office of Disclosure
Mailstop 0505
Washington, DC 20549

This correspondence is being submitted via Edgar.

Dear Ms. Hatch;

We thank you for your comments which you relayed to us in our
telephone conversation
on the annual filings for the fiscal year ending May 31, 2011 for the
Wells Fargo Master Trust.

With respect to your comments, we submit the following responses.
Additionally, Wells Fargo Funds Management acknowledges that the
fund is responsible for the adequacy and accuracy of the disclosure in the
filings; staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and the
fund may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.

****

SEC FILINGS
SEC Comment:
The staff noted the Fidelity Bond Filing (40-17G) was filed as a
joint secured bond. There is a requirement to include a statement
indicating the amount of the single insured fund.

Wells Fargo Funds Management Response:
A cover letter with the Funds' 40-17g Fidelity Bond filing was
filed with the SEC on August 31, 2010 which reflects the statement
of the amount of the single insured fund for Wells Fargo Master
Trust. Please note that this filing was for the Fidelity Bond policy
covering the period of July 9, 2010 to September 1, 2011. The
accession number for the filing is 0000907244-10-001132.

SEC Comment:
In the prospectus filed September 26, 2011 for Wells Fargo
International Equity Portfolio there isn't any policy or statement
included which describes how much the fund invests in foreign
securities. The Wells Fargo International Growth Portfolio and
Wells Fargo International Value Portfolio both disclose
percentages. Is there is a policy for the Wells Fargo International
Equity Portfolio.

Wells Fargo Funds Management Response:
The investment strategy for Wells Fargo Advantage International
Equity Portfolio is to invest at least 80% of the Portfolio's assets in
equity securities of foreign issuers. The Portfolio's prospectus will
be amended to clarify this disclosure in the next prospectus filing.

SEC Comment:
In the Registration Statement for the Wells Fargo Small Cap Value
Portfolio, Wells Fargo Small Company Growth Portfolio and
Wells Fargo Small Company Value Portfolio each are showing a
different definition of a small cap company. Wells Fargo Small
Cap Value Portfolio is showing market capitalizations of up to
$7.3 billion, Wells Fargo Small Company Growth Portfolio is
showing market capitalizations of $3 billion or less and Wells
Fargo Small Company Value Portfolio is showing market
capitalizations of up to $3.1 billion.

Wells Fargo Funds Management Response:
Since each Portfolio is managed by a different portfolio
management team employing different investment strategies, the
definition of the small cap universe from which the portfolio
managers select securities is intentionally different across these
Portfolios.

* * * *

ANNUAL REPORT
SEC Comment:
In the annual report there isn't a graphical representation of the
holdings at the end of the Portfolio of Investments.

Wells Fargo Funds Management Response:
Graphical representations of the portfolios for the Master Trust are
reflected in the Manager's Discussion within the Performance
Highlights section of the report. The master portfolios offer their
shares to feeder funds and other master portfolios within the Wells
Fargo Advantage Funds complex rather than directly to the public.
For feeder funds investing in a single master portfolio, the
graphical representation of the holdings of the master portfolio is
identical to the graphical representation included in the feeder
fund. For feeder funds investing in multiple master portfolios, the
portfolio composition for each of the master portfolios is combined
and reflected, in the aggregate, as the portfolio composition of the
feeder fund. Since the feeder funds are the only investors in the
master portfolios, a graphical representation of the portfolio of the
feeder fund is more relevant to shareholders than a graphical
representation of a master portfolio in which individual
shareholders are not directly invested.

SEC Comment:
In the Portfolio of Investments for multiple portfolios the Short-
Term Investments market value exceeds cost of Short-Term
Investments. Why is there a difference?

Wells Fargo Funds Management Response:
The Short-Term Investments category is comprised of three
different subcategories of investments. Investments within the
Investment Companies subcategory represent short-term
investment vehicles, which are valued at net asset value.
Investments within the US Treasury Securities subcategory are
valued using amortized cost, which is deemed to approximate fair
value, and therefore cost and market value are the same. The third
subcategory is Corporate Bonds and Notes which contains two
securities, Gryphon Funding Limited and VFNC Corporation.
These securities are valued at their fair value in accordance with
the funds' valuation procedures. The fair value of these securities
will fluctuate and will not necessarily approximate cost. Effective
with the Wells Fargo Funds Trust Annual Reports for periods
ended August 31, 2011 these securities have been moved out of the
Short-Term Investments category and into their own category.

SEC Comment:
In the Notes to Financial Statements the Security Loans note
discusses the side pocket agreement that was put in place on
February 13, 2009. Are the portfolios still subject to the
arrangement and if so it is suggested that we include what each
portfolio's ownership is?

Wells Fargo Funds Management Response:
The funds subject to the side-pocketing arrangement set in 2009
are still subject to the arrangement and include appropriate
language in the Security Lending note. The holdings related to the
side-pocketing arrangement are noted on the Portfolio of
Investments for each impacted fund. The Security Lending note
which currently describes the arrangement will be updated to make
reference to the section of the Portfolio of Investments where the
value of the side-pocketed holdings is shown.

* * * *

If you have any further questions regarding the responses contained
herein, please contact me at 617.210.3272.

Sincerely,

/s/ Kasey Phillips
Treasurer Wells Fargo Advantage Funds

cc: Lynda Graham, Partner - KPMG