November 15, 2010


Mr. John Ganley
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC  20549

Re:   Touchstone Funds Group Trust
      File Nos. 33-70958 and 811-8104

Dear Mr. Ganley:

This will confirm our telephone conversation regarding the 485(a) filing made by
the Touchstone Funds Group Trust ("Registrant") on September 14, 2010. Your
comments and the Registrant's responses are set forth below:

PROSPECTUSES

Comment

Under the section "The Fund's Fees and Expenses," you asked that we provide the
page number of the sections referenced in the prospectus and statement of
additional information.

Response

We believe referencing the section names is sufficient information for the
shareholder since these sections will be included in the corresponding
document's table of contents.

Comment

In regards to the fee table footnotes, you requested that we move the following
sentence in footnote number 2 to a separate, stand alone footnote.

"Other Expenses" are based on estimated amounts for the current fiscal year.

Response

The requested change has been made.

Comment

You suggested that we add headings to the risks discussed in the section titled
"The Principal Risks" for the Fund.

Response

The Registrant believes that the risks are written in a concise, clear manner
and that further streamlining may make such disclosure less useful to the
reader.


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Comment

You suggested that we include a phrase under the section "What are the Principal
Risks of Investing in the Fund" that clarifies that this is information
regarding some of the principal risks of the Fund.

Response

The requested change has been made.

Comment

You suggested that we move "Manager of Managers Risk" from the section "What are
the Principal Risks of Investing in the Fund" to the section "What are some of
the Non-Principal Risks of Investing in the fund."

Response

The requested change has been made.

Comment

In reference to the "Portfolio Manger" section, you asked why the other team
members that are led by Frank Sands Jr. were not listed as Portfolio Managers.

Response

The sub-advisor has determined that Frank Sands Jr. is the only primary
Portfolio Manager of the fund. The sub-advisor believes that the team members
that work with Mr. Sands Jr. are acting in a supporting role and providing
research analysis for the investment decisions of Mr. Sands Jr.

SAI

Comment

You asked that we consider changing the word "Supplemented" with "Amended" when
referencing the revised date on the front cover of the SAI.

Response

The requested change has been made.

Comment

You asked that we consider putting the other accounts managed information of the
portfolio managers in table format.

Response

We will consider this change for the Annual update in January 2011.


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Comment

In reference to the section titled "Disclosure of Portfolio Holdings," you
suggested that we add language to specify why we would grant access of the
holdings to the sub-advisor.

Response

We will consider this change for the Annual update in January 2011.


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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 513-878-4066 if you have any questions or need
any additional information.

Very truly yours,

/s/ Jay S. Fitton

Jay S. Fitton
Secretary


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