August 1, 2007
Mr. John Ganley
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Touchstone Strategic Trust-Diversified Small Cap Growth Fund Class C Filing
File Nos. 333-134486, 811-03651 and 002-80859
Dear Mr. Ganley:
This will confirm our telephone conversation on Tuesday July 17, 2007 regarding
the 485(a) filing made by the Touchstone Strategic Trust ("Registrant") on June
1, 2007. Your comments and the Registrant's responses are set forth below:
PROSPECTUS
Comment
You requested that the Securities and Exchange Commission disclaimer be added to
the prospectus cover.
Response
The requested change has been made.
Comment
You requested an explanation of the term "secular" as used under Principal
Investment Strategies, or other terminology.
Response
The term secular has been removed and the phrase has been rewritten accordingly.
Comment
You asked if there was any acquired fund fee expense "AFFE" which should be
reflected in the Fund Fees and Expenses table since the Fund can invest in
"Other investment Companies" as referenced on page 5 of the prospectus.
Response
We are confirming to the Commission that the AFFE for this Fund is below one
basis point.
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Comment
You requested the word "contractually" be added to the 4th footnote under Fund's
Fees and Expenses table as follows: Under the Expense Limitation Agreement
between Touchstone Advisors and the Trust, Touchstone Advisors has contractually
agreed to waive a portion of its advisory fee and/or reimburse certain Fund
expenses in order to limit "Net Expenses" to......
Response
The requested change has been made.
Comment
On page 6, you requested 1) clarification of the definitions for Large Cap and
Mid Cap Companies in which the market capitalization between these two
overlapped, and 2) you requested an explanation as to why the Fund defines a
small cap company with a market capitalization higher than that of the
definition provided.
Response
1) We reduced the mid cap company to reflect a market capitalization of between
$1.5 billion and $10 billion.
2) This particular Fund's portfolio managers define the small cap company with
an increased market capitalization in comparison to the other Funds within this
Trust.
Comment
You requested additional information on the Sub-Advisor's management style,
referencing page 12 of the prospectus.
Response
We are confirming that the Sub-Advisor does not manage any other accounts with
this investment style.
Comment
On page 13, you requested the performance be updated with more current data.
Response
The performance information was updated to be for the 12-month period ended
March 31, 2007.
Comment
On page 13, you requested the performance information table be revised to
reflect performance numbers "including" and "excluding" sales loads.
Response
The requested change has been made.
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Comment
On page 13, you asked that we review rule 5(a)(1)(iii) and reconsider our
placement of, or explain our decision to place the Board approval language at
the end of this section.
Response
Since the discussion of both the Investment Advisor and Sub-Advisors must be
present to meet the requirement of section 5(a)(1), we believe the requirement
for section 5(a)(1)(iii) should follow after the discussion of both the
Investment Advisor and Sub-Advisors.
STATEMENT OF ADDITIONAL INFORMATION
Comment
On page 35 of the SAI, you requested the Trustee Ownership be broken out by each
Trustee's securities held within each registration.
Response
The requested change has been made.
In connection with this filing, the Trust acknowledges that: (1) the Trust is
responsible for the adequacy and accuracy of the disclosure in the filing; (2)
staff comments or changes to disclosure in connection with this filing, reviewed
by the staff do not foreclose the Commission from taking any action with respect
to the filing; and (3) the Trust 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.
Please contact the undersigned at 513-362-8217 if you have any questions or need
any additional information.
Very truly yours,
/s/ Jay S. Fitton
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Jay S. Fitton
Secretary
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