Voya MUTUAL FUNDS CORRESPCorrespondence with SEC

Dear Messrs Burak and Long:

This letter responds to comments provided on June 4, 2020 to Kevin Gleason, Todd Modic, Paul Caldarelli, Jay Stamper, Tin Bui and Dorothy Roman, by the Staff of the U.S. Securities and Exchange Commission ("Staff") with respect to the Sarbanes-Oxley Review of Form N-CSR filings and where applicable, Form N-1A and Form N-CEN filings. Form N-CSR was filed on March 9, 2020 for Voya Balanced Portfolio, Voya Intermediate Bond Portfolio, Voya Investors Trust, Voya Partners, Inc., Voya Strategic Allocation Portfolios, Voya Variable Funds, Voya Variable Products Trust, Voya Variable Portfolios and Voya Variable Insurance Trust; on January 8, 2020 for Voya Mutual Funds and former registrant, Voya Series Fund, Inc.; on August 8, 2019 for Voya Equity Trust, Voya Separate Portfolios Trust and former registrant, Voya Series Fund, Inc.; and on June 7, 2019 for Voya Funds Trust, Voya Separate Portfolios Trust and former registrant, Voya Series Fund, Inc. (each a "Registrant" and collectively, the "Registrants). Our summary of the comments and our responses thereto are provided below.

General Comments

1.Comment: The Staff requested that the Principal Risks section be prioritized in order of those most likely to adversely affect a mutual fund's net asset value, yield, and total return first, followed by the remaining risks placed in alphabetical order.

Page 2

Response: The Registrants believe that the current risk disclosure, including the alphabetical ordering of the list of a mutual fund's principal risks, is appropriate and consistent with Item 4 of Form N-1A, which requires that a fund summarize, based on disclosure in Item 9, the principal risks of investing in the fund, including the risks to which the fund's portfolio "as a whole" is subject. Form N-1A does not contemplate any particular ordering of the risks summarized in Item 4. Additionally, the Registrants believe that rank- ordering risks as the Staff suggests could create the risk that investors would mistakenly minimize or ignore risks that appear at the end or near the end of such a rank-ordered list of risks and is concerned that such a circumstance could cause an investor not to appreciate fully all of the principal risks to which a Portfolio's portfolio as a whole is subject.

Form N-1A

2.         Comment: The Staff noted Voya Limited Maturity Bond Portfolio, Voya Intermediate Bond Portfolio, Voya Floating Rate Fund and Voya Securitized Credit Fund had exposure to the London Interbank Offered Rate ("LIBOR") and requested corresponding additional Principal Risk disclosure.

Form N-CEN

4.         Comment: The Staff noted the below Voya mutual funds experienced a return of capital during the fiscal year. The Staff commented that Item B.23 on Form N-CEN did not indicate any written statements pursuant to Section 19(a) of the 1940 Act and Rule 19a-1 were filed.

Response: Registrants confirm Section 19(a) of the 1940 Act requires that a payment made from a mutual fund that is from a source other than net investment income be accompanied by a written statement adequately disclosing the source of that payment. Voya has several mutual funds that pay a level distribution and therefore Section 19 notices routinely accompany these payments since the distribution is estimated at the time to include either return of capital or capital gains.

For the Voya mutual funds noted in the Staff's review, at the time of the distributions, the payments were estimated to made from net income as of the close of the period as of which such distributions were made. Section 19 notices did not accompany these payments since, in order to do so, the return of capital would have had to be anticipated prior to making the distributions. More details regarding each fund are included below.

Page 3

Funds with a fiscal year end of December 31, 2019:

VY® Barron Growth Portfolio and VY® JPMorgan Small Cap Core Equity Portfolio – These funds paid their accumulated long-term capital gains ("LTCG") in anticipation of the redemption of a substantial amount of the funds' net assets (39% and 31% respectively) on December 9, 2020. This was done to avoid having a large capital gain distribution being executed across a smaller shareholder base post-redemption, which would have resulted in a substantial erosion of the funds' NAVs. Subsequent to the distribution, but prior to year-end, the funds realized capital losses. This resulted in a small amount of return of capital for each fund.

VY® Baron Growth Portfolio paid out $14.04 per share as LTCG distributions of which $0.15 (1%) was ultimately return of capital. VY® JPMorgan Small Cap Core Equity Portfolio paid out $4.78 per share as distributions from realized gains of which $0.23 (5%) was ultimately return of capital. Please note that VY® JPMorgan Small Cap Core Equity Portfolio also paid out $0.03 per share of net investment income during the year, all of which was ultimately net investment income.

Funds with a fiscal year end of October 31, 2019:

Voya Global Bond Fund paid out $0.44 per share as net investment income distributions throughout the year of which $0.05 (11%) was ultimately return of capital. This fund has substantial foreign currency exposure and the return of capital was a result of foreign currency losses which offset ordinary income for tax purposes. At the time of the distribution, the entire payment was estimated to be from net investment income on a GAAP basis.

Voya Global Equity Dividend Fund paid out $0.95 as net investment income distributions throughout the year of which $0.01 (1%) was ultimately return of capital. This fund pays its net investment income on a calendar quarterly basis. Included as income on the records of the fund for the quarter-ended September 30, 2019 was $0.025 of class action proceeds which were subsequently reclassed to realized gains for GAAP and tax purposes during the October 31, 2019 financial statement audit. This resulted in the small amount of return of capital.

Funds with a fiscal year end of March 31, 2019:

Voya Securitized Credit Fund paid out $0.47 per share as net investment income distributions throughout the year of which $0.01 (2%) was ultimately return of capital. This fund accrues ordinary income distributions daily. Falling interest rates late in the year resulted in this unintentional return of capital.

Voya Emerging Markets Local Currency Debt Fund paid out $0.33 per share as net investment income distributions throughout the year of which $0.27 (82%) was ultimately return of capital. This fund has substantial foreign currency exposure and the return of capital was a result of foreign currency losses which offset ordinary income for tax purposes. At the time of the distribution, the entire payment was estimated to be from net investment income on a GAAP basis. It should also be noted that this fund is 100% owned by other Voya Funds and therefore, the Fund has no external shareholders to report to in the case that Section 19 notices had been required.

5.         Comment: Based on the response filed for Item B.22 on Form N-CEN, the Staff noted there was an error in calculating the net asset value ("NAV") for Voya Global Bond Fund and Voya Global Bond Portfolio. The Staff requested the Registrants identify the circumstances relating the NAV error and disclose any weakness in controls that were identified.

Page 5

Should you have any questions or comments regarding this letter, please contact the undersigned at 480.477.2649.

Very truly yours,

/s/ Paul Caldarelli Paul Caldarelli

Vice President and Senior Counsel

Voya Investment Management

cc:Todd Modic

Voya Investment Management

Huey P. Falgout, Jr., Esq. Voya Investment Management