CORRESP 1 filename1.txt 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. 1 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. 2 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. 3 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 4