Advanced Series Trust
Gateway Center Three
100 Mulberry Street
Newark, New Jersey 07102
 

October 14, 2011

VIA EDGAR SUBMISSION

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
 

Re: Registration Statement on Form N-1A of Advanced Series Trust

(Securities Act File No. 33-24962 and Investment Company Act File No. 811-5186)
Post-Effective Amendment No. 91 to the Registration Statement under the Securities Act of 1933

and Amendment No. 93 to the Registration Statement under the Investment Company Act of 1940

Ladies and Gentlemen:
 

On behalf of Advanced Series Trust (the Registrant), pursuant to the Securities Act of 1933 (the 1933 Act) and the Investment Company Act of 1940 (the 1940 Act), transmitted herewith for filing with the Securities and Exchange Commission (the Commission) is Post-Effective Amendment No. 91 to the Registration Statement under the 1933 Act and Amendment No. 93 to the Registration Statement under the 1940 Act (the Amendment).  The Amendment is being filed pursuant to Rule 485(a)(2) under the 1933 Act. The Amendment is being filed for the purpose of adding the AST Bond Portfolio 2023 (the New Bond Portfolio) as a new series of the Registrant The Registrant has designated the effective date as the 75^th day after the filing of the Amendment (i.e., December 28, 2011).

The investment objective, policies, and restrictions, and advisory and subadvisory arrangements for the New Bond Portfolio are substantially identical to those for the AST Bond Portfolio 2015, the AST Bond Portfolio 2016, the AST Bond Portfolio 2017, the AST Bond Portfolio 2018, the AST Bond Portfolio 2019, the AST Bond Portfolio 2020, the AST Bond Portfolio 2021, and the AST Bond Portfolio 2022 (collectively, the Existing Bond Portfolios).Because the disclosure contained in the Amendment relating to the New Bond Portfolio is substantially similar to disclosure that was previously reviewed by the Commission staff with respect to the Existing Bond Portfolios, the Registrant asks for “limited review” or “no review” of the prospectus and statement of additional information relating to the New Bond Portfolio.

The Amendment is not intended to amend the Registrant’s current prospectuses, dated May 1, 2011 or October 5, 2011 (the Current Prospectus), or the Registrant’s current statement of additional information, dated May 1, 2011 or October 5, 2011 (the Current Statement of Additional Information).

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The Registrant acknowledges that (i) the Registrant is responsible for the adequacy and accuracy of the disclosure in the Amendment; (ii) Commission staff comments or changes to disclosure in the Amendment in response to Commission staff comments do not foreclose the Commission from taking any action with respect to the Amendment; and (iii) the Registrant may not assert Commission staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States..

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Should you have any questions or comments with respect to the foregoing, or if I can be of any further assistance in facilitating the Commission Staff’s review, please contact me at 973-367-3161.  Thank you for your assistance in this matter.

Respectfully submitted,
  /s/ John P. Schwartz
      John P. Schwartz

                                           Assistant Secretary