REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Board of Trustees of Barings Funds Trust and
Shareholders of Barings Global Floating Rate Fund,
Barings Global Credit Income Opportunities Fund,
Barings Active Short Duration Bond Fund, Barings
Diversified Income Fund (formerly Barings Total Return
Bond Fund), Barings Emerging Markets Debt Blended
Total Return Fund, Barings Global Emerging Markets
Equity Fund, Barings Global High Yield Fund and Barings
U.S. High Yield Fund:
In planning and performing our audits of the financial
statements of Barings Funds Trust (the "Funds"),
including the Barings Global Floating Rate Fund, Barings
Global Credit Income Opportunities Fund, Barings
Active Short Duration Bond Fund, Barings Diversified
Income Fund (formerly Barings Total Return Bond
Fund), Barings Emerging Markets Debt Blended Total
Return Fund, Barings Global Emerging Markets Equity
Fund, Barings Global High Yield Fund and Barings U.S.
High Yield Fund, as of and for the year/period ended
June 30, 2019, in accordance with the standards of the
Public Company Accounting Oversight Board (United
States) (PCAOB), we considered the Funds' internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our
opinion on the financial statements and to comply with
the requirements of Form N-CEN, but not for the
purpose of expressing an opinion on the effectiveness
of the Funds' internal control over financial reporting.
Accordingly, we express no such opinion.
The management of the Funds is responsible for
establishing and maintaining effective internal control
over financial reporting. In fulfilling this responsibility,
estimates and judgments by management are required
to assess the expected benefits and related costs of
controls. A fund's internal control over financial
reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting
and the preparation of financial statements for external
purposes in accordance with generally accepted
accounting principles. A fund's internal control over
financial reporting includes those policies and
procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets of
the fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of financial statements in accordance with
generally accepted accounting principles, and that
receipts and expenditures of the fund are being made
only in accordance with authorizations of management
and directors of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection of
unauthorized acquisition, use, or disposition of a fund's
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk
that controls may become inadequate because of
changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does
not allow management or employees, in the normal
course of performing their assigned functions, to
prevent or detect misstatements on a timely basis. A
material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting,
such that there is a reasonable possibility that a
material misstatement of the fund's annual or interim
financial statements will not be prevented or detected
on a timely basis.
Our consideration of the Funds' internal control over
financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal control
that might be material weaknesses under standards
established by the PCAOB. However, we noted no
deficiencies in the Funds' internal control over financial
reporting and its operation, including controls for
safeguarding securities, that we consider to be a
material weakness, as defined above, as of June 30,
2019.
This report is intended solely for the information and
use of management and the Board of Trustees of
Barings Funds Trust and the Securities and Exchange
Commission and is not intended to be and should not
be used by anyone other than these specified parties.
/s/ DELOITTE & TOUCHE LLP
New York, NY
August 28, 2019