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January 28, 2015	William M. Beaudoin
	T +1 617 854 2337
	william.beaudoin@ropesgray.com

VIA EDGAR

Ms. Ashley Vroman-Lee, Esq.

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re: AMG Funds I (Registration Nos. 033-44909 and 811-06520)

Dear Ms. Vroman-Lee:

I am writing on behalf of AMG Funds I (the “Trust”) to respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (“SEC”) to Post-Effective Amendment No. 78 under the Securities Act of 1933, as amended (the “1933 Act”), to the Trust’s Registration Statement on Form N-1A (the “Registration Statement”) filed on December 3, 2015, relating to AMG Managers Brandywine Advisors Mid Cap Growth Fund (the “Fund”), a series of the Trust. The Trust appreciates this opportunity to respond to the Staff’s comments. The Staff’s comments and the Trust’s responses are set forth below. Certain defined terms used herein have the meaning set forth in the Fund’s prospectus (the “Prospectus”).

General

1.       Comment: The Staff notes that certain material information was omitted from Post-Effective Amendment No. 78. Please confirm all information will be filed with the SEC in the post-effective amendment to the Trust’s Registration Statement relating to the Fund to be filed pursuant to Rule 485(b) under the 1933 Act (the “485(b) Amendment”).

          Response: The Trust confirms that the information omitted from Post-Effective Amendment No. 78 will be filed with the SEC in the 485(b) Amendment.

Prospectus

2.       Comment: The disclosure under “Summary of the Fund – Principal Investment Strategies” indicates that the Fund may invest in securities and instruments that are economically tied to foreign issuers. Please confirm whether the Fund invests in emerging market securities. If applicable, please add principal investment strategy and principal investment risk disclosure relating to investments in emerging markets. Further, if the Fund invests in emerging market securities, state up to what percentage of the Fund’s assets would be invested in such securities.

         Response: Although emerging market securities are a permissible investment of the Fund, the Fund confirms that the Fund does not currently intend to invest in emerging market securities as a principal investment strategy. Therefore, the Trust has not revised its disclosure in response to this comment.

3.      Comment: The disclosure in “Summary of the Fund – Principal Investment Strategies” indicates that the Fund may invest in equity securities including convertible securities. Please confirm whether the Fund invests in convertible debt securities. If applicable, please add the ratings criteria used when investing in convertible debt securities.

         Response: Although convertible debt securities are a permissible investment of the Fund, the Fund confirms that the Fund does not currently intend to invest in convertible debt securities as a principal investment strategy. The Trust has revised the Fund’s disclosure under “Summary of the Fund – Principal Investment Strategies” as follows:

In addition to common stocks and ADRs, equity securities in which the Fund may invest include preferred stocks, convertible securities, rights, and warrants.

In addition, the Trust believes that the current disclosure in the Fund’s statement of additional information (the “SAI”) under “Additional Investment Policies – Investment Techniques and Associated Risks – 5) Convertible Securities” appropriately discloses the criteria for convertible securities, including convertible debt, in which the Fund invests. The section provides that, “[t]he Fund may invest in convertible securities, subject to any restrictions set forth in the Fund’s Prospectus and this SAI.”

4.      Comment: The disclosure in “Principal Risks – Focused Investment Risk” indicates that the Fund may be “focused in a relatively small number of securities.” Please add principal investment strategy disclosure relating to focused investments.

         Response: The requested change has been made.

5.      Comment: The table providing “Average Annual Total Returns as of 12/31/15” contained bracketed placeholders in Post-Effective Amendment No. 78. Please provide the average annual total returns via correspondence letter in advance of the effective date for the 485(b) Amendment.

         Response: The requested information is provided below:

Average Annual Total Returns as of 12/31/15
AMG Managers Brandywine Advisors Mid Cap Growth Fund	1 Year	5 Years	10 Years
Return Before Taxes	-6.46%	1.46%	0.57%
Return After Taxes on Distributions	-6.46%	1.46%	0.21%
Return After Taxes on Distributions and Sale of Fund Shares	-3.66%	1.12%	0.58%
S&P 500® Index (reflects no deduction for fees, expenses, or taxes)	1.38%	12.57%	7.31%
Russell Midcap® Index (reflects no deduction for fees, expenses, or taxes)	-2.44%	11.44%	8.00%
Russell Midcap® Growth Index (reflects no deduction for fees, expenses, or taxes)	-0.20%	11.54%	8.16%

6.      Comment: The Staff notes that the “Additional Investment Policies” section states that “[t]he Fund reserves the right, without notice, to make any investment, or use any investment technique, except to the extent that such activity would require a shareholder vote, as discussed below under ‘Fundamental Investment Restrictions.’” The Fund is required to invest consistent with its stated investment strategy consistent with Item 16(b) of Form N-1A. Please revise the above-referenced disclosure in light of the Staff’s view that the disclosure gives the Fund too much discretion.

         Response: The Trust respectfully submits that the current disclosure is appropriate and in compliance with the requirements of Form N-1A. Item 16(b) of Form N-1A requires the Fund to “describe any investment strategies, including a strategy to invest in a particular type of security, used by an investment adviser of the Fund in managing the Fund that are not principal strategies and the risks of those strategies.” Consistent with this requirement, the “Additional Investment

Policies – Investment Techniques and Associated Risks” section provides a description of the types of securities and techniques that are currently intended to be utilized by the Fund. In addition to listing the types of securities and techniques that are currently intended to be utilized by the Fund, the Fund also includes the above-referenced disclosure to inform shareholders that the Fund’s permissible investments could change over time. Therefore, the Trust respectfully declines to make the requested change.

As requested, we acknowledge the following: (i) the Trust is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) Staff comments or changes to disclosure in response to such comments in the filings reviewed by the Staff do not foreclose the SEC from taking any action with respect to the filing; and (iii) the Trust may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. As indicated in the SEC’s June 24, 2004, release regarding the public release of comment letters and responses, you are requesting such acknowledgements from all companies whose filings are being reviewed and this request and these acknowledgements should not be construed as suggesting that there is an inquiry or investigation or other matter involving the Trust.

Please direct any questions you may have with respect to this filing to me at (617) 854-2337.

Very truly yours,

/s/ William M. Beaudoin

William M. Beaudoin

cc: Mark Duggan, Esq.

Maureen A. Meredith, Esq.

Gregory C. Davis, Esq.

Adam M. Schlichtmann, Esq.