September 21, 2004

Mr. John Ganley
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re:      The Touchstone Strategic Trust - Micro Cap I shares
         485(a) filing for Micro Cap Growth Fund Class I shares
         File #: 811-3651
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Dear Mr. Ganley:

Thank you for your comments regarding the above-referenced filing. Please see
our response to each specific comment below.

1.    Principal Investment Strategies

      Please revise this section to define "equity securities".

      Response: Your comments have been noted and will be reflected in the final
      prospectus.

2.    The Fund's Fees and Expenses

      Please omit the costs for owning Class I shares of the Micro Cap Growth
      Fund for the 5 and 10 year periods.

      Response: Your comments have been noted and will be reflected in the final
      prospectus.

3.    Pricing of Fund Shares

      Please add language to the pricing policies regarding non-U.S. exchange
      traded securities clarifying that the Fund does not intended to invest in
      "foreign" securities as a principal investment strategy.

      Response: Your comments have been noted and the "Pricing of Fund Shares"
      section of the prospectus will be updated with the following language:

      o     Although the Fund does not currently intend to invest in securities
            mainly traded on a non-U.S. exchange as a principal investment
            strategy, these securities are generally valued according to the
            preceding closing values on that exchange. However, if an event that
            may change the value of a security occurs after the time that the
            closing value on the non-U.S. exchange was determined, the security
            may be priced based on fair value. This may cause the value of the
            security on the books of the Fund to be significantly different from
            the closing value on the non-U.S. exchange and may affect the
            calculation of the NAV.

      o     Because portfolio securities that are primarily listed on a non-U.S.
            exchange may trade on weekends or other days when the Fund does not
            price its shares, the Fund's NAV may change on days when
            shareholders will not be able to buy or sell shares. The Fund does
            not currently intend to invest in securities listed on non-U.S.
            exchanges as a principal investment strategy.



4.    Statement of Additional Information

      Please add more detail to the Investment Advisor and Sub-Advisor section
      regarding the determination by the Board of Trustees to approve the
      Advisory and Sub-Advisory Agreements.

      Response: At this time the Trust's Counsel believes that the disclosure
      related to the approval of the Investment Advisory and Sub-Advisor
      contracts meets the requirements of Form N-1A.

5.    Tandy Representation

      Please provide a Tandy representation regarding this filing.

      Response. This request is being considered.

Should you have any questions or wish to discuss this further, please do not
hesitate to contact me.

Sincerely,


/s/ Jay S. Fitton
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Jay S. Fitton
Assistant Secretary