1701 Market Street                                                 Morgan, Lewis
Philadelphia, PA  19103-2921                                       & Bockius LLP
215-963-5000                                                   Counselors at Law
Fax:  215-963-5001


July 2, 2008


Touchstone Funds Group Trust
303 Broadway
Suite 1100
Cincinnati, OH 45202

Re:   Opinion of Counsel regarding the Registration Statement filed on Form N-14
      under the Securities Act of 1933

Ladies and Gentlemen:

We have acted as counsel to the Touchstone Funds Group Trust (the "Trust"), a
Delaware business trust, in connection with the above-referenced registration
statement on Form N-14 (the "Registration Statement"), which relates to the
Trust's shares of beneficial interest, with a par value of $0.01 per share, of
the Touchstone International Growth Fund (collectively, the "Shares"). This
opinion is being delivered to you in connection with the Trust's filing of the
Registration Statement to be filed with the U.S. Securities and Exchange
Commission (the "SEC") pursuant to Rule 488(a) of the Securities Act of 1933
(the "1933 Act"). With your permission, all assumptions and statements of
reliance herein have been made without any independent investigation or
verification on our part except to the extent otherwise expressly stated, and we
express no opinion with respect to the subject matter or accuracy of such
assumptions or items relied upon.

In connection with this opinion, we have reviewed, among other things, executed
copies of the following documents:

      (a)   a certificate of the State of Delaware as to the existence of the
            Trust;

      (b)   the Agreement and Declaration of Trust for the Trust and all
            amendments and supplements thereto (the "Declaration of Trust");

      (c)   a certificate executed by Jay S. Fitton, Secretary of the Trust,
            certifying as to, and attaching copies of, the Trust's Declaration
            of Trust and Amended and Restated By-Laws (the "Amended and Restated
            By-Laws"), and certain resolutions adopted by the Board of Trustees
            of the Trust authorizing the issuance of the Shares; and



      (d)   a printer's proof of the Registration Statement.

In our capacity as counsel to the Trust, we have examined the originals, or
certified, conformed or reproduced copies, of all records, agreements,
instruments and documents as we have deemed relevant or necessary as the basis
for the opinion hereinafter expressed. In all such examinations, we have assumed
the legal capacity of all natural persons executing documents, the genuineness
of all signatures, the authenticity of all original or certified copies, and the
conformity to original or certified copies of all copies submitted to us as
conformed or reproduced copies. As to various questions of fact relevant to such
opinion, we have relied upon, and assume the accuracy of, certificates and oral
or written statements of public officials and officers or representatives of the
Trust. We have assumed that the Registration Statement, as filed with the SEC,
will be in substantially the form of the printer's proof referred to in
paragraph (d) above.

Based upon, and subject to, the limitations set forth herein, we are of the
opinion that the Shares, when issued and sold in accordance with the Trust's
Declaration of Trust and Amended and Restated By-Laws, and for the consideration
described in the Registration Statement, will be legally issued, fully paid and
non-assessable under the laws of the State of Delaware.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. In giving this consent, we do not concede that we are in
the category of persons whose consent is required under Section 7 of the 1933
Act.

Very truly yours,

/s/ Morgan, Lewis & Bockius LLP