July 25, 2013

Ms. Kathy Churko
Staff Accountant
Securities and Exchange Commission
Division of Investment Management
Washington, DC  20549

This correspondence is being submitted via Edgar.

Dear Ms. Churko:

We thank you for your comments which you relayed to us via telephone
conversation on various annual filings of Wells Fargo Funds Trust for
the fiscal year ended January 31, 2013, December 31, 2012,
October 31, 2012, September 30, 2012, August 31, 2012, July 31, 2012,
June 30, 2012, May 31, 2012, March 31, 2012, February 29, 2012, for
Wells Fargo Advantage Income Opportunities Fund for the fiscal year
ended April 30, 2012 and for Wells Fargo Advantage Global Dividend
Opportunity Fund and Wells Fargo Advantage Multi-Sector Income Fund
for the fiscal year ended October 31, 2012.

With respect to your comments, we submit the following responses:

ANNUAL REPORTS
SEC Comment:
SEC staff indicated that Item 2 on Form N-CSR should include responses
indicating if there were any amendments to the code of ethics and if
there were any waivers granted from a provision of the code.

Wells Fargo Funds Management Response:
For Form N-CSRs filed subsequent to June 30, 2013, responses to
Item 2 indicate if there were any amendments or waivers related to
the code of ethics.

SEC Comment:
SEC staff suggested that language in MDFP be expanded to include
disclosures on the impact the use of derivatives may have on
performance of a fund, where applicable.

Wells Fargo Funds Management Response:
For Funds which use derivatives as part of their principal investment
strategy, the MDFP will discuss such derivative use and its
contribution or detraction from performance.

SEC Comment:
SEC staff suggested that investments in affiliated money market funds
and 3c-7 products be included in the notes to financial statements
for affiliated transaction under Rule S-X 12-14.

Wells Fargo Funds Management Response:
Each fund's investments in affiliated money market funds and the
3c-7 fund are primarily for short-term purposes to sweep cash overnight
and reinvest collateral for securities lending purposes and not as a
part of the investment strategy of the fund.  As the purpose of these
investments are short-term in nature, Management believes the current
disclosures presented in the various sections of the financial
statements sufficiently address these investments as affiliates and
any additional disclosures under Rule S-X 12-14 are not material.

SEC Comment:
SEC staff suggested that the total return for Class A on the same page
as the line graph be revised to include the maximum sales load for
Class A.

Wells Fargo Funds Management Response:
Management implemented a redesign of the MDFP section of the report
in the latter part of 2012 which included changes to show total return
performance for each class of the fund, reflecting returns with and
without sales loads, on the same page as the line graph.

SEC Comment:
SEC staff suggested that the 1, 5 and 10 year performance table be
placed in a table adjacent to the line graph.

Wells Fargo Funds Management Response:
Management implemented a redesign of the MDFP section of the report
in the latter part of 2012 which included changes to show the 1, 5
and 10 year performance table for each class of the fund on the same
page as the line graph.

SEC Comment:
Wells Fargo Advantage 100% Treasury Fund (January 31, 2012)
SEC staff commented that the Class A gross expense ratio reported in
the prospectus was not the same as the gross expense ratio in the
Financial Highlights on the shareholder report.

Wells Fargo Funds Management Response:
During the year, any unused portion of the shareholder servicing fee
is returned to the fund/class.  Various fund classes pay a 0.25% annual
shareholder servicing fee which Funds Management utilizes to pay the
brokers.  These amounts paid to brokers could be less than the 0.25%
which could result in unused amounts returned to the funds.  These
amounts reduce the gross expense ratio of any class that has had
shareholder servicing fee amounts returned.  As the amounts returned
to any class vary from period to period, the prospectus ratio reflects
the full shareholder servicing fee contract rate whereas the Financial
Highlights report actual expense ratios for each class.

SEC Comment:
Wells Fargo Advantage Asia Pacific Fund (October 31, 2012)
SEC staff commented that gross expense ratios reported in the prospectus
was not the same as the gross expense ratios in the Financial Highlights
on the shareholder report.

Wells Fargo Funds Management Response:
Effective March 1, 2013 (date of the prospectus), the advisory fee
schedule for the fund changed from a tiered schedule starting at 1.10%
and declining to 0.95% to a tiered schedule starting at 0.95% and
declining to 0.80%.  The prospectus reflects the new fee schedule
whereas the annual report reflects amounts calculated using the previous
fee schedule.

SEC Comment:
SEC staff commented that on many funds, cash collateral was invested in
illiquid securities rather than short-term highly liquid securities.

Wells Fargo Funds Management Response:
On many funds, the securities lending collateral invested in these
securities were originally purchased in 2007 by the funds' securities
lending agent through a joint account with cash collateral received by
the funds pursuant to loans of securities. Although considered
high-quality, short-term money market instruments when originally
purchased by the securities lending agent through the joint account,
the securities defaulted, and were restructured following default.
There was no market for the securities for a period of time but recently
in February 2013, the securities were sold.  The funds now invest all
collateral received from securities lending in Wells Fargo Securities
Lending Cash Investments, LLC which invests in high-quality, U.S.
denominated short-term money market instruments.

SEC Comment:
Wells Fargo Advantage Small/Mid Cap Value Fund (October 31, 2012)
SEC staff noted that the Fund held EnteroMedics Incorporated which is
designated as illiquid on the Portfolio of Investments but categorized
as a Level 1 security in the Notes to Financial Statements.

Wells Fargo Funds Management Response:
The Fund held three positions in EnteroMedics.  One was a common stock
which was footnoted as a non-income producing security.  The common
stock position did not have an illiquid footnote designation.  The Fund
also held two warrants that were noted as illiquid, fair valued and
non-income producing.  The holding in common stock was classified as a
Level 1 input.  Both warrants were illiquid and classified as a Level 2
security.  As a result Management feels the disclosures in the financial
statement are appropriate.

SEC Comment:
Wells Fargo Advantage Short Duration Government Bond Fund (August 31, 2012)
SEC staff commented that gross expense ratios reported in the prospectus
was not the same as the gross expense ratios in the Financial Highlights
on the shareholder report.

SEC staff commented that the advisory fee reported in the shareholder
report indicated an annual fee of 0.37% but the prospectus showed an
advisory fee of 0.32%.

SEC staff commented that the portfolio turnover rate of 399% was high and
Item 9 in the prospectus should include additional disclosure with regard
to an active trading strategy and tax consequences to shareholders.

Wells Fargo Funds Management Response:
Effective January 1, 2013 (date of the prospectus), the advisory fee
schedule for the fund changed from a tiered schedule starting at 0.40% and
declining to 0.30% to a tiered schedule starting at 0.35% and declining to
0.25%.  The prospectus reflects the new fee schedule whereas the annual
report reflects amounts calculated using the previous fee schedule.

In addition, Item 9 disclosure in the fund's full prospectus currently
includes a reference to active trading and discusses the risks associated
with such trading, including the potential tax consequences for
shareholders.

SEC Comment:
Wells Fargo Advantage Government Securities Fund (August 31, 2012)
Wells Fargo Advantage Capital Growth Fund (July 31, 2012)
SEC staff commented that the portfolio turnover rate was high and Item 9
in the prospectus should include additional disclosure with regard to an
active trading strategy and tax consequences to shareholders.

Wells Fargo Funds Management Response:
Item 9 disclosure in each fund's full prospectus currently includes a
reference to active trading and discusses the risks associated with such
trading, including the potential tax consequences for shareholders.

SEC Comment:
Wells Fargo Advantage High Income Fund (August 31, 2012)
Wells Fargo Advantage High Yield Bond Fund (August 31, 2012)
Wells Fargo Advantage Income Opportunities Fund (April 30, 2012)
SEC staff noted that the funds held PIK securities.  Income from the PIK
securities should be broken out on the Statement of Operations if the
amount is greater than 5% of income.  If amount is less than 5% of income,
disclosure should be included in the Notes to Financial Statements.
In addition, if a portion of the PIK is paid out in cash, the ratio of cash
vs PIK income should be included as part of the description of the security
on the Portfolio of Investments.

Wells Fargo Funds Management Response:
Each fund's holdings in PIK securities are immaterial and as such any
related income earned would be immaterial to the fund and would not require
separate disclosure.  As of the report dates noted above, High Income Fund,
High Yield Bond Fund and Income Opportunities Fund held 0.91%, 1.02% and
1.76%, respectively, of total net assets in PIK securities.  Management
noted any PIK securities with a portion related to cash payout would be
appropriately noted in the description of the security in future reports.

SEC Comment:
Wells Fargo Advantage Short-Term Bond Fund (August 31, 2012)
Wells Fargo Advantage Short-Term High Yield Bond Fund (August 31, 2012)
Wells Fargo Advantage Ultra Short-Term Income Fund (August 31, 2012)
Wells Fargo Advantage Ultra Short-Term Municipal Income Fund (June 30, 2012)
Wells Fargo Advantage Target Date Funds (February 28, 2012)
SEC staff commented that gross expense ratios reported in the prospectus was
not the same as the gross expense ratios in the Financial Highlights on the
shareholder reports.

Wells Fargo Funds Management Response:
Effective January 1, 2013 (date of the prospectus), the advisory fee schedule
for Short-Term High Yield Bond Fund changed from a tiered schedule starting at
0.50% and declining to 0.40% to a tiered schedule starting at 0.45% and
declining to 0.35%.

Effective January 1, 2013 (date of the prospectus), the advisory fee schedule
for Short Term Bond Fund and Ultra Short-Term Income Fund changed from a
tiered schedule starting at 0.40% and declining to 0.30% to a tiered schedule
starting at 0.35% and declining to 0.25%.

The prospectus for these funds reflects the new fee schedules whereas the
annual report reflects amounts calculated using the previous fee schedule.

During the year, any unused portion of the shareholder servicing fee is
returned to the fund/class.   This return reduced the gross expense ratio of
Administrator Class of Ultra Short-Term Municipal Income Fund.  Amounts
returned to various classes of the fund cannot be guaranteed into future
periods and as such the prospectus ratio reflects the full shareholder
servicing fee contract rate whereas the Financial Highlights report actual
expense ratios for each class.

For the Target Date Funds, the gross expense ratios reported in the prospectus
differed from the gross expense ratios in the Financial Highlights by 1 basis
point on a few classes.  This is primarily due to rounding differences that
may result when fund level expenses are allocated to the classes.

SEC Comment:
Wells Fargo Advantage Short-Term Bond Fund (August 31, 2012)
SEC staff commented that the advisory fee amount reported in the Notes to
Financial Statements did not agree with the amount reported in the prospectus.

Wells Fargo Funds Management Response:
Effective January 1, 2013 (date of the prospectus),  the advisory fee schedule
for Short Term Bond Fund changed from a tiered schedule starting at 0.40% and
declining to 0.30% to a tiered schedule starting at 0.35% and declining to
0.25%.  The prospectus reflects the new fee schedule whereas the annual report
reflects amounts calculated using the previous fee schedule.

SEC Comment:
Wells Fargo Advantage Specialized Technology Fund (March 31, 2012)
SEC staff noted that the advisory fee reported in the March 31, 2012 annual
report was 1.05% but was 0.95% in the prospectus.

Wells Fargo Funds Management Response:
Effective August 1, 2012 (date of the prospectus), the advisory fee schedule
for the fund changed from a tiered schedule starting at 1.05% and declining
to 0.90% to a tiered schedule starting at 0.95% and declining to 0.80%.  The
prospectus reflects the new fee schedule whereas the annual report reflects
amounts calculated using the previous fee schedule.

SEC Comment:
Wells Fargo Advantage Absolute Return Fund (September 30, 2012)
SEC staff noted that the Financial Highlight ratios should only show gross
and net ratios and that the ratios should be based on expenses on the
Statement of Operations.  Ratios excluding GMO Benchmark-Free Allocation
Fund should not be included in the table but rather in a footnote.

Wells Fargo Funds Management Response:
Management recognized the need to present only the gross and net ratios
in the Financial Highlights and amended the presentation in the
March 31, 2013 semi annual report.  The fund is a feeder fund in a
master/feeder structure.  The GMO Benchmark-Free Allocation Fund (Master
Fund) is unitized and therefore the fees of the Master Fund are embedded in
its NAV, and not allocated to the feeder as would occur in a typical
master/feeder structure where the master fund is structured as a partnership.
Management believes the incorporation of the expenses related to the Master
Fund in the gross and net expense ratios of the feeder fund is an appropriate
master/feeder presentation and is a more informative measure for investors.
The net expense ratios excluding the Master Fund expenses is disclosed as a
footnote to the Financial Highlights.

SEC Comment:
Wells Fargo Advantage Asset Allocation Fund (September 30, 2012)
SEC staff inquired as to whether the fee table in the prospectus reflects
that aggregate expenses of the Fund and GMO Asset Allocation Fund and if
there should be additional disclosure.

Wells Fargo Funds Management Response:
The fee table in the fund's prospectus reflects all expenses associated
with investing in other investment companies, including Asset Allocation
Trust.  Management does not believe additional disclosure is necessary as
the fee table complies with N-1A requirements.

SEC Comment:
Wells Fargo Advantage Income Opportunities Fund (April 30, 2012)
Wells Fargo Advantage Multi-Sector Income Fund (October 31, 2012)
SEC staff noted that the Financial Highlights ratios should be based on the
expenses on the Statement of Operations.  Only the gross and net expense
ratios should be included in the table.  The impact of interest expense on
the ratios can be shown in a footnote to the table.

Wells Fargo Funds Management Response:
Management will incorporate changes in the next applicable financial
statements.

SEC Comment:
Wells Fargo Advantage Income Opportunities Fund (April 30, 2012)
SEC staff noted that the audit fees for FYE 2012 were much higher than
audit fees for FYE 2011 on Item 4 on Form N-CSR.

Wells Fargo Funds Management Response:
The amounts reported on the Form N-CSR were incorrectly calculated for
both periods causing the amounts to be skewed with one period having much
higher fees that the other period.  Management has filed an amended N-CSR
filing for the fund with corrected amounts.

Wells Fargo Funds Management acknowledges that management 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 management 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.

If you have any further questions regarding the responses contained
herein, please contact me at 617.210.3588.

Sincerely,

/s/ Jeremy DePalma
Jeremy DePalma
Treasurer
Wells Fargo Funds Trust

/s/ Nancy Wiser
Nancy Wiser
Treasurer
Wells Fargo Funds Trust

cc: Lynda Graham, Partner - KPMG