Mayer Brown LLP 1221 Avenue of the Americas New York, NY 10020-1001 United States of America   T: +1 212 506 2500 F: +1 212 262 1910 mayerbrown.com   Bradley Berman Counsel T: +1 212 506 2321 BBerman@mayerbrown.com
May 8, 2020
Via EDGAR and Email

Edward P. Bartz
Senior Counsel
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549

Dear Mr. Bartz:

On behalf of our client, m+ funds Trust, we submitted to the Securities and Exchange Commission on May 8, 2020 Pre-effective Amendment No. 1 to the above-referenced registration statement (the “Amendment”) for the m+ Growth 150 Fund, m+ funds Trust, Series 3-2 (the “Trust”), a series of the m+ funds Trust. The Amendment incorporates responses to the comments transmitted telephonically by the Staff.

We identify in bold the Staff’s comment to which we are responding in this letter and note in regular type our response. Page number references in our response refer to the EDGAR version of the Amendment.

PROSPECTUS

Cover Page

Revise the first bullet point to add “(1.5 times)” after every occurrence of 150% and present the maturity as 1 year and 8 months.

We have made these changes in the first bullet point and throughout the prospectus.

Revise the fifth bullet point to clarify that investors who purchase units at a price above the Inception Value will realize a maximum total return per unit that will be less than the Capped Return, rather than the price increase in the Reference Asset.

Mayer Brown is a global services provider comprising an association of legal practices that are separate entities including
Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England), Mayer Brown (a Hong Kong partnership)
and Tauil & Chequer Advogados (a Brazilian partnership).

Mayer Brown LLP

Edward P. Bartz

May 8, 2020

Page 2

We have revised the disclosure in the fifth bullet point on the cover page to disclose that investors who purchase units above the Inception Value will realize a maximum total return per unit that will be less than the Capped Return.

Principal Investment Strategy (Page 3)

In the introductory sentence to the hypothetical performance return examples, refer to three examples.

We have revised the reference from four to three examples.

Hypothetical Performance Return Examples (Page 4)

Add an additional table showing a decrease in the Final Reference Value of -40%.

We have added an additional hypothetical table showing the effect of a -40% decrease in the Final Reference Value.

Summary of Defined Terms (Page 7)

Add a definition of “Capped Return” to the summary of defined terms.

We have added a definition of “Capped Return” to the summary of defined terms.

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Please feel free to call me at (212) 506-2321 with any questions.

Sincerely,

/s/ Bradley Berman

Bradley Berman