1933 Act/Rule 485(a)

July 16, 2019

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

RE:        Virtus Opportunities Trust

File Nos. 033-65137 and 811-7455

Post-Effective Amendment No. 102

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. 102 of the Registrant’s Registration Statement on Form N-1A.

This amendment contains the Prospectus and Statement of Additional Information for the Virtus KAR International Small-Mid Cap Fund, which is being registered as a new series of the Registrant.

Please contact Ann Flood at (860) 263-4746 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

cc: Ann Flood