May22, 2014
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re:
The Saratoga Advantage Trust
Securities Act File No. 033-79708
Investment Company Act File No. 811-08542
Post-Effective Amendment No. 49
Dear Sir or Madam:
On behalf of The Saratoga Advantage Trust, a Delaware business trust (the “Trust”), attached herewith for filing is the above-referenced Post-Effective Amendment No. 49 (the “Amendment”) to the Trust’s Registration Statement pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the “1933 Act”), and Amendment No. 51 pursuant to the Investment Company Act of 1940, as amended, adding the James Alpha Multi Strategy Alternative Income Portfolio, a new portfolio of the Trust.
We anticipate filing a Rule 485(b) filing to include all consents and opinions, as well as any other required information. No fees are required in connection with this filing.
Should you have any questions regarding the Amendment or the foregoing matters, please do not hesitate to contact Stuart M. Strauss at (212) 698-3529.
Very truly yours,
/s/ Stuart M. Strauss
Stuart M. Strauss