TOUCHSTONE INVESTMENTS November 8, 2004 Mr. John M. Ganley Senior Counsel Office of Disclosure and Review Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Touchstone Strategic Trust (the "Trust") Large Cap Growth Fund Class I Registration Statement File Number 811-3651 and 2-80859 Dear Mr. Ganley, Thank you for your comments on the Trust's post-effective amendment filing to register Class I shares of its Large Cap Growth Fund series. I have listed below a summary of your comments and the Trust's response. 1. Comment. The footnote under the bar chart in the Prospectus indicates that Navellier & Associates, Inc. assumed the sub-advisory duties of Navellier Management, Inc. Why was this change made without a shareholder vote? Response: The Trust and Touchstone Advisors, Inc. have obtained an exemptive order from the SEC that permits the Trust and Touchstone Advisors to change unaffiliated sub-advisors without first obtaining shareholder approval. 2. Comment. The discussion of the advisory agreement renewal in the SAI needs more disclosure about each factor the Board considered when making its determination in accordance with Item 12(b)(10) instructions. The discussion must explain what the comparison of the Fund's fees and performance with industry averages showed. Response: The discussion has been revised as follows: In determining whether to approve the continuation of the investment advisory agreement for the Fund, the Advisor furnished information necessary for a majority of the Independent Trustees to make the determination that the continuance of the advisory agreement is in the best interests of the Fund and its shareholders. Specifically, the Board was provided (1) industry data comparing advisory fees and expense ratios of comparable investment companies, (2) comparative performance information and (3) the Advisor's revenues and costs of providing services to the Fund. The Board compared the advisory fees and total expense ratios for the Fund with the industry median advisory fees and expense ratios in its investment category and found the Fund's Class A advisory fees and expense ratios were below the category averages and were reasonable and appropriate under all facts and circumstances. The Board noted that during the Navellier reorganization on October 6, 2003, the Advisor replaced the Fund's sub-advisor with a sub-advisor that has consistently performed above the average in its Lipper category and that the Fund assumed the performance history of the Navellier Performance Large Cap Growth Portfolio, which was also advised by the Fund's new sub-advisor. The Board compared this performance with the performance of other funds in the Lipper category and found that the Fund performed above the average in its category during periods ending September 30, 2003. The Board also considered the effect of the Fund's growth and size on its performance and expenses and was mindful of the Advisor's efforts to improve economies of scale by increasing Fund assets through the reorganization of the Navellier portfolios. The Board further noted that the Advisor has consistently waived advisory fees and reimbursed expenses for the Fund as necessary to reduce its operating expenses to targeted levels. The Board also took into consideration the financial condition and profitability of the Advisor and the direct and indirect benefits derived by the Advisor from its relationship with the Fund. The Board also considered the level and depth of knowledge of the Advisor. It discussed the Advisor's effectiveness in monitoring the performance of the Sub-Advisor and its timeliness in responding to performance issues. It noted that the Advisor provides the Board on a quarterly basis detailed information about the Fund's performance results, portfolio composition and style adherence. In evaluating the quality of services provided by the Advisor, the Board took into account its familiarity with the Advisor's senior management through Board meetings, conversations and reports during the preceding year. The Board took into <page> account the Advisor's willingness to consider and implement organizational and operational changes designed to improve investment results. It noted the Advisor's efforts to further strengthen operations by hiring additional qualified and experienced members to its senior management team. The Board also considered the Advisor's role in coordinating the activities of the Fund's other service providers, including its efforts to consolidate service providers and reduce costs to the Fund. The Board also considered the strategic planning process implemented by the Advisor and the results gained from this process. No single factor was considered to be determinative in the Board's decision to approve the Advisory Agreement. Rather, the Trustees concluded that, in light of weighing and balancing all factors, the continuation of the Advisory Agreement for the Fund was in the best interests of shareholders. 3. Comment. The paragraph in the SAI stating that the Fund Sub-Advisors may consider sales of shares of the Trust as a factor in the section of broker-dealers to execute portfolio transactions should be removed since the SEC has adopted rules prohibiting the use of directed brokerage arrangements. Response: This paragraph has been removed. 4. Comment. The response letter must contain Tandy representations. Response: In connection with this filing, the Fund acknowledges that:(1) the Fund is responsible for the adequacy and accuracy of the disclosure in the filings; (2) 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 (3) 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. Very truly yours, /s/ Betsy Santen Betsy Santen Assistant Secretary 221 East Fourth Street o Suite 300 o Cincinnati, OH 45202-4133 PH:513.362.8000 o 800.638.8194 o FAX:513:362-8320 www.touchstoneinvestments.com Touchstone Securities, Inc, o Member NASD and SIPC A Member of Western & Southern Financial Group