September 21, 2004 Mr. John Ganley Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549 Re: The Touchstone Strategic Trust - Micro Cap I shares 485(a) filing for Micro Cap Growth Fund Class I shares File #: 811-3651 ------------------------------------------------------ Dear Mr. Ganley: Thank you for your comments regarding the above-referenced filing. Please see our response to each specific comment below. 1. Principal Investment Strategies Please revise this section to define "equity securities". Response: Your comments have been noted and will be reflected in the final prospectus. 2. The Fund's Fees and Expenses Please omit the costs for owning Class I shares of the Micro Cap Growth Fund for the 5 and 10 year periods. Response: Your comments have been noted and will be reflected in the final prospectus. 3. Pricing of Fund Shares Please add language to the pricing policies regarding non-U.S. exchange traded securities clarifying that the Fund does not intended to invest in "foreign" securities as a principal investment strategy. Response: Your comments have been noted and the "Pricing of Fund Shares" section of the prospectus will be updated with the following language: o Although the Fund does not currently intend to invest in securities mainly traded on a non-U.S. exchange as a principal investment strategy, these securities are generally valued according to the preceding closing values on that exchange. However, if an event that may change the value of a security occurs after the time that the closing value on the non-U.S. exchange was determined, the security may be priced based on fair value. This may cause the value of the security on the books of the Fund to be significantly different from the closing value on the non-U.S. exchange and may affect the calculation of the NAV. o Because portfolio securities that are primarily listed on a non-U.S. exchange may trade on weekends or other days when the Fund does not price its shares, the Fund's NAV may change on days when shareholders will not be able to buy or sell shares. The Fund does not currently intend to invest in securities listed on non-U.S. exchanges as a principal investment strategy. 4. Statement of Additional Information Please add more detail to the Investment Advisor and Sub-Advisor section regarding the determination by the Board of Trustees to approve the Advisory and Sub-Advisory Agreements. Response: At this time the Trust's Counsel believes that the disclosure related to the approval of the Investment Advisory and Sub-Advisor contracts meets the requirements of Form N-1A. 5. Tandy Representation Please provide a Tandy representation regarding this filing. Response. This request is being considered. Should you have any questions or wish to discuss this further, please do not hesitate to contact me. Sincerely, /s/ Jay S. Fitton - ----------------------------------- Jay S. Fitton Assistant Secretary