Transamerica Asset Management

1801 California St, Suite 5200

Denver, CO 80202

Transamerica Funds (the “Registrant”)

Fees and Expenses – Annual Fund Operating Expenses: Please confirm that all bracketed or missing information will be supplied in the Rule 485(b) filing, and provide the completed fee table and expense examples for each Fund in the response letter to these comments at least five days prior to the Funds’ Rule 485(b) filing.

Fees and Expenses – Annual Fund Operating Expenses: The Staff notes that contractual fee waivers can only be reflected in the fee tables if the duration of the waiver is at least one year from the effective date of the registration statement.

Principal Risks: Please consider including cybersecurity risk as a principal risk for the Funds.

Comment: Please supplementally confirm that the change in the Funds’ principal investment strategies and risks do not rise to the level of materiality requiring shareholder approval or further SEC review.

Fees and Expenses – Annual Fund Operating Expenses: Please supplementally clarify the reasoning for reduction in the management fee.

Principal Investment Strategies: The Staff notes that the Fund includes derivatives as a principal investment strategy. Please disclose whether the market value of these instruments at the time of investment will be included in the calculation of the Fund’s 80% investment policy.

Principal Risks: Please clarify whether “Structure Conflicts” and “Underlying Exchange-Traded Funds” are new principal risks for each of the Asset Allocation Funds and, if so, please indicate whether these new risks result from a material change in the investment strategies of the Asset Allocation Funds.

Principal Investment Strategies: Please explain what is meant by “primarily” in the following sentence in each of the Asset Allocation Funds:

Comment: Please confirm that all bracketed or missing information will be supplied in the Rule 485(b) filing.

Comment: The Staff notes that pursuant to the FAST Act, filings after April 1, 2020 (including 485(b) filings) must include hyper-links to every exhibit filed with the registration statement or incorporated by reference. See Instruction 5 to Item 28 of Form N-1A and Rule 102(d) and Rule 105(d) of Regulation S-T.

Class

Management fees¹

Distribution and service (12b-1) fees

Other expenses

Acquired fund fees and expenses^{2, 3}

Total annual fund operating expenses

Fee waiver and/or expense reimbursement⁴

Total annual fund operating expenses after fee waiver and/or expense reimbursement

Management fees have been restated to reflect a reduction in management fees effective August 28, 2020.

Acquired fund fees and expenses reflect the fund’s pro rata share of the fees and expenses incurred by investing in other investment companies. Acquired fund fees and expenses are not included in the calculation of the ratios of expenses to average net assets shown in the Financial Highlights section of the fund’s prospectus.

Acquired fund fees and expenses have been restated to reflect estimated fees for the current fiscal year following the change in sub-adviser on August 28, 2020.

Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through March 1, 2022 to waive fees and/or reimburse fund expenses to the extent that total annual fund operating expenses exceed 0.60% for Class A shares, 1.35% for Class C shares, 0.35% for Class I shares and 0.95% for Class R shares, excluding, as applicable, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to March 1, 2022 without the Board of Trustees’ consent. TAM is permitted to recapture amounts waived and/or reimbursed to a class during any of the 36 months from the date on which TAM waived fees and/or reimbursed expenses for the class if the class’ total annual fund operating expenses have fallen to a level below the limits described above. In no case will TAM recapture any amount that would result, on any particular business day of the fund, in the class’ total annual operating expenses exceeding the applicable limits described above or any other lower limit then in effect. In addition, TAM has contractually agreed to reimburse 0.09% of the sub-transfer agency fees and certain per account transfer agency fees on Class I shares through March 1, 2022.

If the shares are redeemed at the end of each period:

Class A

Class C

Class I

Class R

If the shares are not redeemed:

Class A

Class C

Class I

Class R

Class

Management fees¹

Distribution and service (12b-1) fees

Other expenses

Acquired fund fees and expenses^{2, 3}

Total annual fund operating expenses

Fee waiver and/or expense reimbursement⁴

Total annual fund operating expenses after fee waiver and/or expense reimbursement

Management fees have been restated to reflect a reduction in management fees effective August 28, 2020.

Acquired fund fees and expenses reflect the fund’s pro rata share of the fees and expenses incurred by investing in other investment companies. Acquired fund fees and expenses are not included in the calculation of the ratios of expenses to average net assets shown in the Financial Highlights section of the fund’s prospectus.

Acquired fund fees and expenses have been restated to reflect estimated fees for the current fiscal year following the change in sub-adviser on August 28, 2020.

Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through March 1, 2022 to waive fees and/or reimburse fund expenses to the extent that total annual fund operating expenses exceed 0.60% for Class A shares, 1.35% for Class C shares, 0.35% for Class I shares and 0.95% for Class R shares, excluding, as applicable, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to March 1, 2022 without the Board of Trustees’ consent. TAM is permitted to recapture amounts waived and/or reimbursed to a class during any of the 36 months from the date on which TAM waived fees and/or reimbursed expenses for the class if the class’ total annual fund operating expenses have fallen to a level below the limits described above. In no case will TAM recapture any amount that would result, on any particular business day of the fund, in the class’ total annual operating expenses exceeding the applicable limits described above or any other lower limit then in effect. In addition, TAM has contractually agreed to reimburse 0.09% of the sub-transfer agency fees and certain per account transfer agency fees on Class I shares through March 1, 2022.

If the shares are redeemed at the end of each period:

Class A

Class C

Class I

Class R

If the shares are not redeemed:

Class A

Class C

Class I

Class R

Class

Management fees¹

Distribution and service (12b-1) fees

Other expenses

Acquired fund fees and expenses^{2, 3}

Total annual fund operating expenses

Fee waiver and/or expense reimbursement⁴

Total annual fund operating expenses after fee waiver and/or expense reimbursement

Management fees have been restated to reflect a reduction in management fees effective August 28, 2020.

Acquired fund fees and expenses reflect the fund’s pro rata share of the fees and expenses incurred by investing in other investment companies. Acquired fund fees and expenses are not included in the calculation of the ratios of expenses to average net assets shown in the Financial Highlights section of the fund’s prospectus.

Acquired fund fees and expenses have been restated to reflect estimated fees for the current fiscal year following the change in sub-adviser on August 28, 2020.

Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through March 1, 2022 to waive fees and/or reimburse fund expenses to the extent that total annual fund operating expenses exceed 0.60% for Class A shares, 1.35% for Class C shares, 0.35% for Class I shares and 0.85% for Class R shares, excluding, as applicable, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to March 1, 2022 without the Board of Trustees’ consent. TAM is permitted to recapture amounts waived and/or reimbursed to a class during any of the 36 months from the date on which TAM waived fees and/or reimbursed expenses for the class if the class’ total annual fund operating expenses have fallen to a level below the limits described above. In no case will TAM recapture any amount that would result, on any particular business day of the fund, in the class’ total annual operating expenses exceeding the applicable limits described above or any other lower limit then in effect. In addition, TAM has contractually agreed to reimburse 0.09% of the sub-transfer agency fees and certain per account transfer agency fees on Class I shares through March 1, 2022.

If the shares are redeemed at the end of each period:

Class A

Class C

Class I

Class R

If the shares are not redeemed:

Class A

Class C

Class I

Class R

Class

Management fees¹

Distribution and service (12b-1) fees

Other expenses

Acquired fund fees and expenses^{2, 3}

Total annual fund operating expenses

Fee waiver and/or expense reimbursement⁴

Total annual fund operating expenses after fee waiver and/or expense reimbursement

Management fees have been restated to reflect a reduction in management fees effective August 28, 2020.

Acquired fund fees and expenses reflect the fund’s pro rata share of the fees and expenses incurred by investing in other investment companies. Acquired fund fees and expenses are not included in the calculation of the ratios of expenses to average net assets shown in the Financial Highlights section of the fund’s prospectus.

Acquired fund fees and expenses have been restated to reflect estimated fees for the current fiscal year following the change in sub-adviser on August 28, 2020.

Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through March 1, 2022 to waive fees and/or reimburse fund expenses to the extent that total annual fund operating expenses exceed 0.60% for Class A shares, 1.35% for Class C shares, 0.35% for Class I shares and 0.85% for Class R shares, excluding, as applicable, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to March 1, 2022 without the Board of Trustees’ consent. TAM is permitted to recapture amounts waived and/or reimbursed to a class during any of the 36 months from the date on which TAM waived fees and/or reimbursed expenses for the class if the class’ total annual fund operating expenses have fallen to a level below the limits described above. In no case will TAM recapture any amount that would result, on any particular business day of the fund, in the class’ total annual operating expenses exceeding the applicable limits described above or any other lower limit then in effect. In addition, TAM has contractually agreed to reimburse 0.09% of the sub-transfer agency fees and certain per account transfer agency fees on Class I shares through March 1, 2022.

If the shares are redeemed at the end of each period:

Class A

Class C

Class I

Class R

If the shares are not redeemed:

Class A

Class C

Class I

Class R

Class

Management fees¹

Distribution and service (12b-1) fees

Other expenses

Total annual fund operating expenses

Fee waiver and/or expense reimbursement²

Total annual fund operating expenses after fee waiver and/or expense reimbursement

Management fees have been restated to reflect a reduction in management fees effective December 1, 2020.

Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through March 1, 2022 to waive fees and/or reimburse fund expenses to the extent that total annual fund operating expenses exceed 1.15% for Class A shares, 1.90% for Class C shares, 0.83% for Class I shares, 0.72% for Class R6 shares and 0.72% for Class I2 shares, excluding, as applicable, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to March 1, 2022 without the Board of Trustees’ consent. TAM is permitted to recapture amounts waived and/or reimbursed to a class during any of the 36 months from the date on which TAM waived fees and/or reimbursed expenses for the class if the class’ total annual fund operating expenses have fallen to a level below the limits described above. In no case will TAM recapture any amount that would result, on any particular business day of the fund, in the class’ total annual operating expenses exceeding the applicable limits described above or any other lower limit then in effect. In addition, TAM has contractually agreed to reimburse 0.09% of the sub-transfer agency fees on Class I shares through March 1, 2022.

If the shares are redeemed at the end of each period:

Class A

Class C

Class I

Class R6

Class I2

If the shares are not redeemed:

Class A

Class C

Class I

Class R6

Class I2