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1933 Act/Rule 485(a)

July 2, 2020

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

RE: Virtus Opportunities Trust

File Nos. 033-65137 and 811-7455

Post-Effective Amendment No. 113

To The Commission Staff:

On behalf of Virtus Opportunities Trust (the “Trust” or “Registrant”), transmitted herewith for filing under Rule 485(a) under the Securities Act of 1933 and the Investment Company Act of 1940, is Post-Effective Amendment No. 113 of the Registrant’s Registration Statement on Form N-1A.

This amendment contains disclosure changes that will result from a subadviser change anticipated to occur in September 2020, subject to shareholder approval.

Please contact Ralph Summa at (860) 503-1166 or the undersigned at (860) 263-4791 if you have any questions concerning this amendment.

Very truly yours,

/s/Kevin J. Carr

Kevin J. Carr

Senior Vice President,

Chief Legal Officer

Counsel and Secretary

Virtus Mutual Funds

cc: Ralph Summa

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