PBARX / Virtus Multi-Sector S/T Bd B - Documents déposés auprès de la SEC, rapport annuel, procuration

Virtus Multi-Sector S/T Bd B
US ˙ N/A
CE SYMBOLE N'EST PLUS ACTIF

Statistiques de base
LEI 549300LSL433PMNG0O35
CIK 1005020
SEC Filings
All companies that sell securities in the United States must register with the Securities and Exchange Commission (SEC) and file reports on a regular basis. These reports include company annual reports (10K, 10Q), news updates (8K), investor presentations (found in 8Ks), insider trades (form 4), ownership reports (13D, and 13G), and reports related to the specific securities sold, such as registration statements and prospectus. This page shows recent SEC filings related to Virtus Multi-Sector S/T Bd B
SEC Filings (Chronological Order)
Cette page fournit une liste complète et chronologique des documents déposés auprès de la SEC, à l'exclusion des documents relatifs à la participation que nous fournissons ailleurs.
March 25, 2024 DEF 14C

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14C INFORMATION INFORMATION STATEMENT PURSUANT TO SECTION 14(c) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14C INFORMATION INFORMATION STATEMENT PURSUANT TO SECTION 14(c) OF THE SECURITIES EXCHANGE ACT OF 1934 Filed by the registrant ☒ Filed by a party other than the registrant ☐ Check the appropriate box: ☐ Preliminary Information Statement ☐ Confidential, For Use of the Commission Only (as permitted by Rule 14c-5(d)(2))

March 14, 2024 CORRESP

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com March 14, 2024 Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Attention: Brian Szilagyi Re: Virtus Alternative Solutions Trust (File No. 811-22906) and Virtus Opportunities Trust (File No. 811-07455) (each, a “Registrant” and collectively, the “Registrants”) Dear Mr. Szilagyi: Thank you for your telepho

January 19, 2024 CORRESP

* * *

One International Place 40th Floor 100 Oliver Street Boston, MA 02110-2605 +1 617 728 7100 Main +1 617 426 6567 Fax www.

November 17, 2023 EX-99.(J)(1)

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Exhibit 99. J.(1) CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the incorporation by reference in this Post-Effective Amendment to Registration Statement No. 033-65137 on Form N-1A of our report dated July 26, 2022, relating to the financial statements and financial highlights of Virtus Stone Harbor Emerging Markets Bond Fund (formerly, Virtus Stone Harbor Emerging Markets

November 17, 2023 EX-99.(I)(15)

CONSENT OF DECHERT LLP

Exhibit 99. I.(15) CONSENT OF DECHERT LLP We hereby consent to the reference to our firm under the caption “Legal Counsel to the Trust” in the Statement of Additional Information comprising a part of the Form N-1A Registration Statement of Virtus Opportunities Trust, File No. 033-65137. We do not thereby admit that we are within the category of persons whose consent is required under Section 7 of

November 17, 2023 EX-99.(J)(2)

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Exhibit 99. J.(2) CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-1A of Virtus Opportunities Trust of our report dated July 24, 2023, relating to the financial statements and financial highlights, which appears in the Virtus Stone Harbor Emerging Markets Bond Fund, Virtus Stone Harbor Emerging Mar

November 17, 2023 POS EX

As filed with the Securities and Exchange Commission on November 17, 2023

As filed with the Securities and Exchange Commission on November 17, 2023 File No.

April 25, 2023 NPORT-EX

VIRTUS Stone Harbor Emerging Markets Debt Allocation Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023

NPORT-EX 2 VISA060VIRTUS043023.htm VIRTUS Stone Harbor Emerging Markets Debt Allocation Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023 ($ reported in thousands) Shares Value Affiliated Mutual Funds—97.2% Fixed Income Funds—97.2% Virtus Stone Harbor Emerging Markets Debt Income Fund Class I(1)(2) 128,027 $  894 Virtus Stone Harbor Local Markets Fund Class I(1)(2)(3) 124,799   926 Total

April 25, 2023 NPORT-EX

VIRTUS Stone Harbor Local Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023

VIRTUS Stone Harbor Local Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023 ($ reported in thousands) Par Value(1) Value Foreign Government Securities—76.

April 25, 2023 NPORT-EX

VIRTUS Stone Harbor Emerging Markets Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023

VIRTUS Stone Harbor Emerging Markets Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—95.

April 25, 2023 NPORT-EX

VIRTUS Stone Harbor High Yield Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023

NPORT-EX 2 VISA020VIRTUS043023.htm VIRTUS Stone Harbor High Yield Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—96.3% Airlines—2.9% Air Canada 144A 3.875%, 8/15/26(1) $    1,075 $    968 United Airlines, Inc. 144A 4.375%, 4/15/26(1)       795     748 VistaJet Malta Finance plc 144A 7.875%, 5/1/27(1)     1,329   1

April 25, 2023 NPORT-EX

VIRTUS Stone Harbor Strategic Income Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023

VIRTUS Stone Harbor Strategic Income Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023 ($ reported in thousands) Par Value(1) Value U.

April 25, 2023 NPORT-EX

VIRTUS Stone Harbor Emerging Markets Debt Income Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023

VIRTUS Stone Harbor Emerging Markets Debt Income Fund SCHEDULE OF INVESTMENTS (Unaudited) February 28, 2023 ($ reported in thousands) Par Value(1) Value Foreign Government Securities—57.

February 28, 2023 NPORT-EX

VIRTUS Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VI44470VirtusPartF12.31.22.htm VIRTUS Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—99.9% Communication Services—7.5% NetEase, Inc. (China)     674,864 $    9,900 NetEase, Inc. ADR (China)     205,969    14,960 Telkom Indonesia Persero Tbk PT (Indonesia) 106,624,843    25,684 Tencen

February 28, 2023 NPORT-EX

VIRTUS Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VIPHJ10VIRT123122.htm VIRTUS Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—93.5% Consumer Discretionary—10.2% Ferrari N.V. (Italy)     78,719 $ 16,870 Flutter Entertainment plc (Ireland)(1)     73,197  10,014 Hermes International (France)     15,582  24,102 Yum China Holdings, Inc. (China)  

February 28, 2023 NPORT-EX

VIRTUS Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value U.

February 28, 2023 NPORT-EX

VIRTUS Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—100.

February 28, 2023 NPORT-EX

VIRTUS Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—86.

February 28, 2023 NPORT-EX

VIRTUS KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VIPHD50VIRT123122.htm VIRTUS KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—97.3% Communication Services—17.0% Addcn Technology Co., Ltd. (Taiwan)  1,037,009 $  6,411 Autohome, Inc. ADR (China)    153,462   4,696 Baltic Classifieds Group plc (United Kingdom)  5,875,586  10,001 Dayamitra Telek

February 28, 2023 NPORT-EX

VIRTUS KAR Developing Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS KAR Developing Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—97.

February 28, 2023 NPORT-EX

VIRTUS Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2023 NPORT-EX

VIRTUS FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VIPHA20VIRT123122.htm VIRTUS FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Short-Term Investments—92.5% Money Market Mutual Fund—8.5% Dreyfus Government Cash Management Fund - Institutional Shares (seven-day effective yield 4.190%)(1) 9,952,907 $  9,953 Total Money Market Mutual Fund (Identified Cost $9,953)   9

February 28, 2023 NPORT-EX

VIRTUS Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value U.

February 28, 2023 NPORT-EX

VIRTUS Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VIPHS10VIRT123122.htm VIRTUS Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value U.S. Government Security—0.5% U.S. Treasury Notes 2.500%, 5/31/24 $     1,000 $    970 Total U.S. Government Security (Identified Cost $996)     970 Corporate Bonds and Notes—2.7% Communication Services—0.6% iHeartCommunications,

February 28, 2023 NPORT-EX

VIRTUS Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—95.

February 28, 2023 NPORT-EX

VIRTUS Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2023 NPORT-EX

VIRTUS Seix Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VI44120VIRT123122.htm VIRTUS Seix Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value Municipal Bonds(1)—99.1% Alabama—1.3% Black Belt Energy Gas District, Natural Gas Purchase Revenue, Mandatory Put, Series A, 12/1/23, 4.000%, 12/1/48(2) $   910 $   911 Arizona—3.6% Arizona Board of Regents, Arizona State University Syste

February 28, 2023 NPORT-EX

VIRTUS Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—97.

February 28, 2023 NPORT-EX

VIRTUS Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value U.

February 28, 2023 NPORT-EX

VIRTUS KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2023 NPORT-EX

VIRTUS Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2023 NPORT-EX

VIRTUS Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

NPORT-EX 2 VI44060VIRT123122.htm VIRTUS Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Par Value Value U.S. Government Security—2.8% U.S. Treasury Note 0.125%, 3/31/23 $   13,200 $ 13,065 Total U.S. Government Security (Identified Cost $13,117)  13,065 Foreign Government Securities—0.4% Dominican Republic 144A 5.500%, 2/22/

February 28, 2023 NPORT-EX

VIRTUS Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022

VIRTUS Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—66.

October 28, 2022 NPORT-EX

VIRTUS STONE HARBOR EMERGING MARKETS DEBT FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022

NPORT-EX 2 VISA010VIRTUS103122.htm VIRTUS STONE HARBOR EMERGING MARKETS DEBT FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 ($ reported in thousands) Par Value(1) Value Foreign Government Securities—60.1% Angola —4.1% Republic of Angola 144A 8.250%, 5/9/28(2) $       1,715 $  1,488 144A 8.750%, 4/14/32(2)          449     366 144A 9.125%, 11/26/49(2)        2,088   1,557 RegS 8.750%, 4/1

October 27, 2022 NPORT-EX

VIRTUS STONE HARBOR STRATEGIC INCOME FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022

VIRTUS STONE HARBOR STRATEGIC INCOME FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 ($ reported in thousands) Par Value Value U.

October 27, 2022 NPORT-EX

VIRTUS STONE HARBOR EMERGING MARKETS DEBT ALLOCATION FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022

VIRTUS STONE HARBOR EMERGING MARKETS DEBT ALLOCATION FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 ($ reported in thousands) Shares Value Affiliated Mutual Funds—98.

October 27, 2022 NPORT-EX

VIRTUS STONE HARBOR HIGH YIELD BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022

VIRTUS STONE HARBOR HIGH YIELD BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—98.

October 27, 2022 NPORT-EX

VIRTUS STONE HARBOR EMERGING MARKETS CORPORATE DEBT FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022

VIRTUS STONE HARBOR EMERGING MARKETS CORPORATE DEBT FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—94.

October 27, 2022 NPORT-EX

VIRTUS STONE HARBOR LOCAL MARKETS FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022

VIRTUS STONE HARBOR LOCAL MARKETS FUND SCHEDULE OF INVESTMENTS (Unaudited) August 31, 2022 ($ reported in thousands) Par Value(1) Value Foreign Government Securities—84.

August 25, 2022 NPORT-EX

VIRTUS DUFF & PHELPS REAL ESTATE SECURITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS DUFF & PHELPS REAL ESTATE SECURITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET CORE PLUS BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS NEWFLEET CORE PLUS BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value U.

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET SENIOR FLOATING RATE FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VIPHS10VIRTUS063022.htm VIRTUS NEWFLEET SENIOR FLOATING RATE FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value U.S. Government Security—0.5% U.S. Treasury Notes 2.500%, 5/31/24 $    1,000 $    991 Total U.S. Government Security (Identified Cost $995)     991 Corporate Bonds and Notes—2.8% Communication Services—0.6% iHeartCommunications, In

August 25, 2022 NPORT-EX

VIRTUS VONTOBEL EMERGING MARKETS OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS VONTOBEL EMERGING MARKETS OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—98.

August 25, 2022 NPORT-EX

VIRTUS KAR EMERGING MARKETS SMALL-CAP FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS KAR EMERGING MARKETS SMALL-CAP FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—96.

August 25, 2022 NPORT-EX

VIRTUS VONTOBEL GREATER EUROPEAN OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS VONTOBEL GREATER EUROPEAN OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—95.

August 25, 2022 NPORT-EX

VIRTUS FORT TREND FUND CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VIPHA20VIRTUS063022.htm VIRTUS FORT TREND FUND CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Short-Term Investments—96.8% Money Market Mutual Fund—8.5% Dreyfus Government Cash Management Fund - Institutional Shares (seven-day effective yield 1.351%)(1) 10,649,287 $ 10,649 Total Money Market Mutual Fund (Identified Cost $10,649)  10

August 25, 2022 NPORT-EX

VIRTUS DUFF & PHELPS GLOBAL REAL ESTATE SECURITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VIPHJ50VIRTUS063022.htm VIRTUS DUFF & PHELPS GLOBAL REAL ESTATE SECURITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—98.4% Australia—3.6% GPT Group (The) - In Specie(1)(2)    13,566 $     — National Storage REIT 3,514,362   5,191 NEXTDC Ltd.(2)   443,476   3,257 Scentre Group 4,065,300   7,268  15,716 Belgium—1.5% Aedific

August 25, 2022 NPORT-EX

VIRTUS KAR INTERNATIONAL SMALL-MID CAP FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS KAR INTERNATIONAL SMALL-MID CAP FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—97.

August 25, 2022 NPORT-EX

VIRTUS VONTOBEL GLOBAL OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS VONTOBEL GLOBAL OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET HIGH YIELD FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VIPH100VIRTUS063022.htm VIRTUS NEWFLEET HIGH YIELD FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—83.8% Communication Services—11.0% Altice France Holding S.A. 144A 6.000%, 2/15/28(1) $      200 $   142 Altice France S.A. 144A 5.125%, 7/15/29(1)       200    151 CCO Holdings LLC 144A 5.125%, 5/1/27(1)       350

August 25, 2022 NPORT-EX

VIRTUS DUFF & PHELPS INTERNATIONAL REAL ESTATE SECURITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS DUFF & PHELPS INTERNATIONAL REAL ESTATE SECURITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—98.

August 25, 2022 NPORT-EX

VIRTUS KAR DEVELOPING MARKETS FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS KAR DEVELOPING MARKETS FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—97.

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET MULTI-SECTOR INTERMEDIATE BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VIPH050VIRTUS063022.htm VIRTUS NEWFLEET MULTI-SECTOR INTERMEDIATE BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value U.S. Government Securities—12.5% U.S. Treasury Bonds 1.875%, 11/15/51 $    3,165 $  2,375 U.S. Treasury Notes 0.125%, 3/31/23     1,255   1,231 0.125%, 8/31/23     3,775   3,652 2.500%, 4/30/24     7,675   7,608 0.250%, 5

August 25, 2022 NPORT-EX

VIRTUS DUFF & PHELPS GLOBAL INFRASTRUCTURE FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS DUFF & PHELPS GLOBAL INFRASTRUCTURE FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—99.

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET LOW DURATION CORE PLUS BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VI44060VIRTUS063022.htm VIRTUS NEWFLEET LOW DURATION CORE PLUS BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value U.S. Government Securities—6.3% U.S. Treasury Notes 0.125%, 3/31/23 $   25,855 $ 25,353 0.125%, 4/30/23     5,595   5,469 2.500%, 4/30/24     6,095   6,042 Total U.S. Government Securities (Identified Cost $37,171)  36,864 F

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET MULTI-SECTOR SHORT TERM BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VIPH040VIRTUS063022.htm VIRTUS NEWFLEET MULTI-SECTOR SHORT TERM BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value U.S. Government Securities—8.8% U.S. Treasury Notes 0.125%, 3/31/23 $    14,085 $   13,812 0.125%, 4/30/23    183,785   179,650 0.125%, 8/31/23     14,090    13,631 2.500%, 4/30/24    191,140   189,475 1.000%, 12/15/24     

August 25, 2022 NPORT-EX

VIRTUS VONTOBEL FOREIGN OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS VONTOBEL FOREIGN OPPORTUNITIES FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Common Stocks—95.

August 25, 2022 NPORT-EX

VIRTUS NEWFLEET TAX-EXEMPT BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

NPORT-EX 2 VI44120VIRTUS063022.htm VIRTUS NEWFLEET TAX-EXEMPT BOND FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Par Value Value Municipal Bonds(1)—97.1% Alabama—1.1% Black Belt Energy Gas District, Natural Gas Purchase Revenue, Mandatory Put 12/1/23, 4.000%, 12/1/48(2) $  910 $   926 Arizona—4.5% Arizona Board of Regents, Arizona State University System Revenue,

August 25, 2022 NPORT-EX

VIRTUS DUFF & PHELPS REAL ASSET FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022

VIRTUS DUFF & PHELPS REAL ASSET FUND SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—60.

August 10, 2022 DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a Party other than the Registrant ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ? Defin

June 30, 2022 DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

DEFA14A 1 tm2212785d7defa14a.htm DEFA14A UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (

June 17, 2022 DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

DEFA14A 1 tm2212785-6defa14a.htm DEFA14A UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (

May 20, 2022 DEF 14A

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.  )

? ? ? SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.

May 13, 2022 CORRESP

* * *

May 13, 2022 VIA EDGAR Edgar Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.

April 20, 2022 COVER

April 20, 2022

April 20, 2022 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F.

April 20, 2022 PRE 14A

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.__)

PRE 14A 1 tm2212785d1pre14a.htm PRE 14A SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.) Filed by the Registrant x Filed by a Party other than the Registrant ¨ Check the appropriate box: x Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ¨ Definitive Proxy Statement

April 6, 2022 CORRESP

* * *

Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com April 5, 2022 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Attn: Ms. Anu Dubey Re: Virtus Opportunities Trust (the ?Registrant?) Registration Nos. 033-6

April 4, 2022 CORRESP

* * *

Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com April 4, 2022 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Attn: Ms. Anu Dubey Re: Virtus Opportunities Trust (the ?Registrant?) Registration Nos. 033-6

February 28, 2022 NPORT-EX

VIRTUS Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—86.

February 28, 2022 NPORT-EX

VIRTUS Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—65.

February 28, 2022 NPORT-EX

VIRTUS Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value U.

February 28, 2022 NPORT-EX

VIRTUS Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—95.

February 28, 2022 NPORT-EX

VIRTUS Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—96.

February 28, 2022 NPORT-EX

VIRTUS Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2022 NPORT-EX

VIRTUS Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value U.

February 28, 2022 NPORT-EX

VIRTUS Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—3.

February 28, 2022 NPORT-EX

VIRTUS KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2022 NPORT-EX

VIRTUS Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—97.

February 28, 2022 NPORT-EX

VIRTUS Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value U.

February 28, 2022 NPORT-EX

VIRTUS Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value U.

February 28, 2022 NPORT-EX

VIRTUS KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2022 NPORT-EX

VIRTUS Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2022 NPORT-EX

VIRTUS Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—96.

February 28, 2022 DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

February 28, 2022 NPORT-EX

VIRTUS FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Short-Term Investments—94.

February 28, 2022 NPORT-EX

VIRTUS Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2022 NPORT-EX

VIRTUS Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Par Value Value Municipal Bonds(1)—96.

February 28, 2022 NPORT-EX

VIRTUS Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—97.

February 28, 2022 NPORT-EX

VIRTUS KAR Developing Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021

VIRTUS KAR Developing Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 ($ reported in thousands) Shares Value Common Stocks—94.

February 10, 2022 DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

January 14, 2022 DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

December 30, 2021 EX-99.17

*Form of Proxy Cards filed via EDGAR (as Exhibit 17) herewith.

Exhibit 17 KEEP THIS PORTION FOR YOUR RECORDS DETACH AND RETURN THIS PORTION ONLY TO VOTE, MARK BLOCKS BELOW IN BLUE OR BLACK INK AS FOLLOWS: Signature [PLEASE SIGN WITHIN BOX] Date Signature [Joint Owners] Date STONE HARBOR INVESTMENT PARTNERS LP 31 WEST 52ND STREET NEW YORK, NEW YORK 10019 D64037-S37427 ! ! ! For Against Abstain THE BOARD, INCLUDING THE INDEPENDENT TRUSTEES, UNANIMOUSLY RECOMMENDS THAT YOU VOTE ?FOR? THE PROPOSAL.

December 30, 2021 EX-99.14

*Consent of Independent Registered Public Accounting Firm filed via EDGAR (as Exhibit 14) herewith.

Exhibit 14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the incorporation by reference in this Registration Statement on Form N-14 of our report dated July 30, 2021, relating to the financial statements and financial highlights of Stone Harbor Emerging Markets Corporate Debt Fund, Stone Harbor Emerging Markets Debt Allocation Fund, Stone Harbor Emerging Markets Debt Fund,

December 30, 2021 N-14/A

As filed with the Securities and Exchange Commission on December 30, 2021

As filed with the Securities and Exchange Commission on December 30, 2021 1933 Act Registration No.

December 30, 2021 EX-99.11

*Opinion and consent of Kevin J. Carr, Esq., filed via EDGAR (as Exhibit 11) herewith.

Exhibit 11 One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com December 29, 2021 Virtus Opportunities Trust 101 Munson Street Greenfield, MA 01301 Ladies and Gentlemen: We have acted as counsel to Virtus Opportunities Trust (the ?Trust?) in connection with the Registration Statement of the Trust on Form 497 (the ?Registration Statement?) being filed by the Trust under the Securitie

December 29, 2021 CORRESP

* * *

Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com December 29, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Attn: Ms. Anu Dubey, Esq. Re: Virtus Opportunities Trust (the ?Registrant?) Response to Sta

December 29, 2021 CORRESP

* * *

Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com December 29, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Attn: Ms. Lauren Hamilton Re: Virtus Opportunities Trust (the ?Registrant?) Response to Sta

December 23, 2021 DEL AM

Paul J. Delligatti

DEL AM 1 tm2133731d6delam.htm DEL AM Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com December 23, 2021 VIA EDGAR SUBMISSION – FORM DEL AM U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Attn: Ms. Anu Dubey, Esq. Re:

December 6, 2021 COVER

Paul J. Delligatti

Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com December 6, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Virtus Opportunities Trust (the “Registrant”) Post-Effective Amendment No. 122 to the Re

November 24, 2021 EX-99.17

*Form of Proxy Cards filed via EDGAR (as Exhibit 17) herewith.

EX-99.17 14 tm2133731d1ex17.htm FORM OF PROXY CARDS EVERY SHAREHOLDER’S VOTE IS IMPORTANT EASY VOTING OPTIONS: VOTE ON THE INTERNET Log on to: www.proxy-direct.com or scan the QR code Follow the on-screen instructions available 24 hours VOTE BY PHONE Call 1-800-337-3503 Follow the recorded instructions available 24 hours VOTE BY MAIL Vote, sign and date this Proxy Card and return in the postage-pa

November 24, 2021 EX-99.10(MM)

*Amended and Restated Plan Pursuant to Rule 18f-3 under the 1940 Act effective as of October 28, 2021, filed via EDGAR (as Exhibit 10(mm)) herewith.

EX-99.10(MM) 8 tm2133731d1ex10mm.htm AMENDED AND RESTATED PLAN PURSUANT TO RULE 18F-3 UNDER THE 1940 ACT Exhibit 10(mm) VIRTUS FUNDS AMENDED AND RESTATED PLAN PURSUANT TO RULE 18f-3 under the INVESTMENT COMPANY ACT OF 1940 INTRODUCTION The Purpose of this Plan is to specify the attributes of the classes of shares of the funds of Virtus Funds including the expense allocations, conversion features a

November 24, 2021 EX-99.13(V)

Amendment to Sub-Transfer and Shareholder Services Agreement among VAST, Virtus Mutual Funds, VAT, VRT, Investment Trust, VST, Virtus Fund Services and BNY Mellon, dated as of August 2, 2021, filed via EDGAR (as Exhibit 13(v)) to VOT’s Form N-14 (File No. 333-261341) on November 24, 2021, and incorporated herein by reference.

EX-99.13(V) 10 tm2133731d1ex13v.htm AMENDMENT TO SUB-TRANSFER AND SHAREHOLDER SERVICES AGREEMENT Exhibit 13(v) Execution Amendment To Sub-Transfer Agency And Shareholder Services Agreement This Amendment To Sub-Transfer Agency And Shareholder Services Agreement (“Amendment”), dated as of August 2, 2021 (“Effective Date”), is being entered into by and among BNY Mellon Investment Servicing (US) Inc.

November 24, 2021 EX-99.6(B)

*Form of Subadvisory Agreement effective [_______] [___], [______], by and among Registrant, VAIA, and Stone Harbor Investment Partners (“Stone Harbor”) on behalf of the SHIP Funds, filed via EDGAR (as Exhibit 6(b)) herewith.

EX-99.6(B) 4 tm2133731d1ex6b.htm FORM OF SUBADVISORY AGREEMENT Exhibit 6(b) VIRTUS OPPORTUNITIES TRUST Virtus Stone Harbor [] Fund FORM OF SUBADVISORY AGREEMENT [] [], 2021 [Stone Harbor Investment Partners] 31 West 52nd Street, 16th Floor New York, NY 10019 RE: Subadvisory Agreement Ladies and Gentlemen: Virtus Opportunities Trust (the “Trust”) is an open-end investment company of the series type

November 24, 2021 EX-99.7(C)

*Amended Annex A to Form of Sales Agreement between VP Distributors and dealers effective October 2021 filed via EDGAR (as Exhibit 7(c)) herewith.

Exhibit 7(c) One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com Virtus Mutual Funds Sales Agreement Amended Annex A ? November 2021 VP Distributors, LLC Virtus Mutual Funds and Available Share Classes EQUITY FIXED INCOME Virtus AllianzGI Focused Growth Fund A C P R6 ADM INST Virtus AllianzGI Core Plus Bond Fund P R6 INST Virtus AllianzGI Health Sciences Fund A C P INST Virtus Alli

November 24, 2021 EX-99.9(BB)

Amendment to Foreign Custody Manager Agreement between Registrant, Virtus Mutual Funds, VAT, VRT, VVIT, VATS, Investment Trust, VST, DSE, Closed-End Funds, VCEFII, Investment Trust, VST, and The Bank of New York Mellon dated as of July 26, 2021, filed via EDGAR (as Exhibit 9(bb)) to VOT’s Form N-14 (File No. 333-261341) on November 24, 2021, and incorporated herein by reference.

Exhibit 9(bb) AMENDMENT TO FOREIGN CUSTODY MANAGER AGREEMENT This Amendment (?Amendment?) dated July 26, 2021 (?Effective Date?) is by and between each of Duff & Phelps Select MLP and Midstream Energy Fund Inc.

November 24, 2021 EX-99.16

*Power of Attorney for Donald C. Burke, Sidney E. Harris, John R. Mallin, Connie D. McDaniel, Philip R. McLoughlin, Geraldine M. McNamara, R. Keith Walton and Brian T. Zino filed via EDGAR (as Exhibit 16) herewith.

Exhibit 16 POWER OF ATTORNEY I, the undersigned member of the Board of Trustees of Virtus Opportunities Trust (the ?Trust?), hereby constitute and appoint George R.

November 24, 2021 EX-99.11

*Opinion and consent of Kevin J. Carr, Esq., filed via EDGAR (as Exhibit 11) herewith.

Exhibit 11 One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com November 19, 2021 Virtus Opportunities Trust 101 Munson Street Greenfield, MA 01301 Ladies and Gentlemen: We have acted as counsel to Virtus Opportunities Trust (the ?Trust?) in connection with the Registration Statement of the Trust on Form N-14 (the ?Registration Statement?) being filed by the Trust under the Securiti

November 24, 2021 COVER

Paul J. Delligatti

Paul J. Delligatti 202.346.4309 [email protected] Goodwin Procter LLP 1900 N Street, N.W. Washington, D.C. 20036 T: 202.346.4000 F: 202.346.4444 goodwinlaw.com November 24, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Virtus Opportunities Trust (the “Registrant”) Registration on Form N-14 Ladies and Gent

November 24, 2021 EX-99.13(Y)

*Form of Expense Limitation Agreement between Registrant and VAIA, effective [_______] [__], [_____], filed via EDGAR (as Exhibit 13(y)) herewith.

EX-99.13(Y) 11 tm2133731d1ex13y.htm FORM OF EXPENSE LIMITATION AGREEMENT Exhibit 13(y) FORM OF EXPENSE LIMITATION AGREEMENT VIRTUS OPPORTUNITIES TRUST This Expense Limitation Agreement (the “Agreement”), effective as of [] [], [], by and between Virtus Opportunities Trust, a Delaware statutory trust (the “Registrant”), on behalf of each series of the Registrant listed in Appendix A (each a “Fund”

November 24, 2021 EX-99.6(A)

Form of Investment Advisory Agreement between Registrant and VAIA, effective [____] [__], [___], with respect to Virtus Stone Harbor Emerging Markets Corporate Debt Fund, Virtus Stone Harbor Emerging Markets Debt Fund, Virtus Stone Harbor Emerging Markets Debt Allocation Fund, Virtus Stone Harbor High Yield Bond Fund, Virtus Stone Harbor Local Markets Fund and Virtus Stone Harbor Strategic Income Fund (each a “SHIP Fund” and collectively, the “SHIP Funds”) filed via EDGAR (as Exhibit 6(a)) to Form N-14 (File No. 333-261341) on November 24, 2021, and incorporated herein by reference.

EX-99.6(A) 3 tm2133731d1ex6a.htm FORM OF INVESTMENT ADVISORY AGREEMENT Exhibit 6(a) VIRTUS OPPORTUNITIES TRUST FORM OF INVESTMENT ADVISORY AGREEMENT THIS AGREEMENT, effective as of the [] day of [], 2021 (the “Contract Date”) is by and between Virtus Opportunities Trust, a Delaware statutory trust (the “Trust”), and Virtus Alternative Investment Advisers, Inc., a Massachusetts corporation (the “Ad

November 24, 2021 N-14

As filed with the Securities and Exchange Commission on November 24, 2021

As filed with the Securities and Exchange Commission on November 24, 2021 1933 Act Registration No.

November 24, 2021 EX-99.9(N)

Amendment and Custody Agreement between VAST, Virtus Mutual Funds, VRT, VAT, VVIT, VATS, Investment Trust, VST and the Bank of New York Mellon dated as of July 26, 2021, filed via EDGAR (as Exhibit 9(n)) to Form N-14 (File No. 333-261341) on November 24, 2021, and incorporated herein by reference.

EX-99.9(N) 6 tm2133731d1ex9n.htm AMENDMENT AND CUSTODY AGREEMENT Exhibit 9(n) AMENDMENT TO CUSTODY AGREEMENT This Amendment (“Amendment”) dated July 26, 2021 (“Effective Date”) is by and among Virtus Alternative Solutions Trust, Virtus Asset Trust, Virtus Equity Trust, Virtus Opportunities Trust, Virtus Retirement Trust, Virtus Variable Insurance Trust, VATS Offshore Fund, Ltd., Virtus Investment

November 24, 2021 EX-99.14

*Consent of Independent Registered Public Accounting Firm filed via EDGAR (as Exhibit 14) herewith.

EX-99.14 12 tm2133731d1ex14.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Exhibit 14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the incorporation by reference in this Registration Statement on Form N-14 of our report dated July 30, 2021, relating to the financial statements and financial highlights of Stone Harbor Emerging Markets Corporate Debt Fund, Sto

October 19, 2021 AW

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com October 19, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the ?Trust?) Request for Withdrawal on Form AW CIK 0001005020 File No. 333-259608 Ladies and Gentlemen: Pursuant to Rule 47

October 18, 2021 N-14/A

Agreement and Plan of Reorganization. Exhibit A to the Prospectus contained in Part A of this Registration Statement.

As filed with the Securities and Exchange Commission on October 18, 2021 1933 Act Registration No.

October 18, 2021 EX-99.14

Consent of Independent Registered Public Accounting Firm

EX-99.14 2 tm2127787d3ex99-14.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Exhibit 14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-14 of Virtus Opportunities Trust of our report dated November 20, 2020, relating to the financial statements and financial highlights, which appears

October 14, 2021 CORRESP

Securities distributed by VP Distributors, LLC

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com October 14, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the “Trust”) N-14 Filing CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Thank you for the

September 22, 2021 CORRESP

Virtus Opportunities Trust (the “Trust”) 485A Filing CIK 0001005020 File No. 811-07455

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com September 22, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the ?Trust?) 485A Filing CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Thank you for the additional telephonic

September 21, 2021 CORRESP

Virtus Opportunities Trust (the “Trust”) 485A Filing CIK 0001005020 File No. 811-07455

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com September 21, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the “Trust”) 485A Filing CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Thank you for th

September 17, 2021 EX-99.11

Opinion and consent of Jennifer Fromm, Esq., filed via EDGAR (as Exhibit 11) to VOT’s Form N-14 (File No. 333-259608) on September 17, 2021, and incorporated herein by reference.

EX-99.11 3 tm2127787d1ex99-11.htm OPINION AND CONSENT Exhibit 11 One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com September 15, 2021 Virtus Opportunities Trust 101 Munson Street Greenfield, MA 01301 Ladies and Gentlemen: I have acted as counsel to Virtus Opportunities Trust (the “Trust”) in connection with the Registration Statement of the Trust on Form N-14 (the “Registration S

September 17, 2021 EX-99.16

Power of Attorney for Donald C. Burke, Sidney E. Harris, John R. Mallin, Connie D. McDaniel, Philip R. McLoughlin, Geraldine M. McNamara, R. Keith Walton and Brian T. Zino filed via EDGAR (as Exhibit 16) to VOT’s Form N-14 (File No. 333-259608) on September 17, 2021, and incorporated herein by reference.

Exhibit 16 POWER OF ATTORNEY I, the undersigned member of the Board of Trustees of Virtus Opportunities Trust (the ?Trust?), hereby constitute and appoint George R.

September 17, 2021 N-14

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

N-14 1 tm2127787d1n14.htm VIRTUS OPPORTUNITIES TRUST As filed with the Securities and Exchange Commission on September 17, 2021 1933 Act Registration No. 333- UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ¨ Pre-Effective ¨ Post-Effective Amendment No. Amendment No. VIRTUS OPPORTUNITIES TRUST [Exact Name of

September 17, 2021 EX-99.6(DD)

Twenty-Ninth Amendment to the Amended and Restated Investment Advisory Agreement by and between the Registrant and VIA, effective September 24, 2021, filed via EDGAR (as Exhibit 6dd) to Form N-14 (File No. 333-259608) on September 17, 2021, and incorporated herein by reference.

EX-99.6(DD) 2 tm2127787d1ex99-6dd.htm 29TH AMENDMENT TO AMENDED AND RESTATED INVESTMENT ADVISORY AGREEMENT Exhibit 6(dd) TWENTY-NINTH AMENDMENT TO AMENDED AND RESTATED INVESTMENT ADVISORY AGREEMENT THIS AMENDMENT effective as of the 24th day of September 2021, amends that certain Amended and Restated Investment Advisory Agreement dated as of November 20, 2002, and amended as of June 8, 2006, June

September 17, 2021 EX-99.13(AAA)

Forty-Second Amended and Restated Expense Limitation Agreement between Registrant and VIA, effective September 24, 2021, filed (as Exhibit 13(aaa)) to VOT’s Form N-14 (File No. 333-259608) on September 17, 2021, and incorporated herein by reference.

Exhibit 13(aaa) FORTY-SECOND AMENDED AND RESTATED EXPENSE LIMITATION AGREEMENT VIRTUS OPPORTUNITIES TRUST This Forty-Second Amended and Restated Expense Limitation Agreement (the ?Agreement?), effective as of September 24, 2021, amends and restates that certain Forty-First Amended and Restated Expense Limitation Agreement effective as of June 14, 2021, by and between Virtus Opportunities Trust, a Delaware statutory trust (the ?Registrant?), on behalf of each series of the Registrant listed in Appendix A (each a ?Fund? and collectively, the ?Funds?) and the Adviser of each of the Funds, Virtus Investment Advisers, Inc.

September 17, 2021 EX-99.14

*Consent of Independent Registered Public Accounting Firm filed herewith.

EX-99.14 5 tm2127787d1ex99-14.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Exhibit 14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-14 of Virtus Opportunities Trust of our report dated November 20, 2020, relating to the financial statements and financial highlights, which appears

August 26, 2021 NPORT-EX

VIRTUS Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—96.

August 26, 2021 NPORT-EX

VIRTUS Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—96.

August 26, 2021 NPORT-EX

VIRTUS Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—99.

August 26, 2021 NPORT-EX

VIRTUS Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—65.

August 26, 2021 NPORT-EX

VIRTUS FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Short-Term Investments—90.

August 26, 2021 NPORT-EX

VIRTUS Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—98.

August 26, 2021 NPORT-EX

VIRTUS Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—98.

August 26, 2021 NPORT-EX

VIRTUS KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—93.

August 26, 2021 NPORT-EX

VIRTUS KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—93.

August 26, 2021 NPORT-EX

VIRTUS Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value Mortgage-Backed Security—0.

August 26, 2021 NPORT-EX

VIRTUS Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—99.

August 26, 2021 NPORT-EX

VIRTUS Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value Municipal Bonds(1)—97.

August 26, 2021 NPORT-EX

VIRTUS KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—95.

August 26, 2021 NPORT-EX

VIRTUS Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—3.

August 26, 2021 NPORT-EX

VIRTUS Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—97.

August 26, 2021 NPORT-EX

VIRTUS Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value U.

August 26, 2021 NPORT-EX

VIRTUS Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value U.

August 26, 2021 NPORT-EX

VIRTUS Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—99.

August 26, 2021 NPORT-EX

VIRTUS Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value U.

August 26, 2021 NPORT-EX

VIRTUS KAR Developing Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS KAR Developing Markets Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Shares Value Common Stocks—63.

August 26, 2021 NPORT-EX

VIRTUS Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021

VIRTUS Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 ($ reported in thousands) Par Value Value U.

July 26, 2021 COVER

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com 1933 Act/Rule 485(a) July 26, 2021 VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 RE: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No. 120 To The Commission Staff: On behalf of Virtus Opportunities Trust (the “Trust” or

July 13, 2021 CORRESP

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com July 13, 2021 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Ken Ellington and Anu Dubey, Division of Investment Management Re: Virtus Funds Shareholder Reports Dear Mr. Ellington and Ms. Dubey: Thank you for the additional comments of the staff of the U.S. Securities and Exch

June 21, 2021 CORRESP

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com June 21, 2021 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Ken Ellington, Division of Investment Management Re: Virtus Funds Shareholder Reports Dear Mr. Ellington: Thank you for the comments of the staff of the U.S. Securities and Exchange Commission (the ?Staff?) conveyed

June 17, 2021 CORRESP

Virtus Opportunities Trust 485(a) Filing CIK 0001005020 File No. 811-07455

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com June 17, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Kimberly Browning Virtus Opportunities Trust 485(a) Filing CIK 0001005020 File No. 811-07455 Dear Ms. Browning: Thank you for the additional

June 9, 2021 CORRESP

Virtus Opportunities Trust 485(a) Filing CIK 0001005020 File No. 811-07455

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com June 9, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Kimberly Browning Virtus Opportunities Trust 485(a) Filing CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Thank you for the telephonic comments of the staff

March 29, 2021 COVER

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com 1933 Act/Rule 485(a) March 29, 2021 VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 RE: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No. 117 To The Commission Staff: On behalf of Virtus Opportunities Trust (the “Trust” or

February 26, 2021 NPORT-EX

FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

FORT Trend Fund CONSOLIDATED SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Short-Term Investments—93.

February 26, 2021 NPORT-EX

Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value Mortgage-Backed Security—0.

February 26, 2021 NPORT-EX

Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value Municipal Bonds(1)—95.

February 26, 2021 NPORT-EX

Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

February 26, 2021 NPORT-EX

Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

February 26, 2021 NPORT-EX

KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—89.

February 26, 2021 NPORT-EX

Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

February 26, 2021 NPORT-EX

Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value U.

February 26, 2021 NPORT-EX

Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value U.

February 26, 2021 NPORT-EX

Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—5.

February 26, 2021 NPORT-EX

Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

February 26, 2021 NPORT-EX

Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

February 26, 2021 NPORT-EX

Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

February 26, 2021 NPORT-EX

Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value U.

February 26, 2021 NPORT-EX

Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—69.

February 26, 2021 NPORT-EX

KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—92.

February 26, 2021 NPORT-EX

Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Par Value Value U.

February 26, 2021 NPORT-EX

Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

February 26, 2021 NPORT-EX

Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Preferred Stock—2.

February 26, 2021 NPORT-EX

KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020

KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 ($ reported in thousands) Shares Value Common Stocks—89.

November 30, 2020 DEF 14C

- VIRTUS FORT TREND FUND

DEF 14C 1 tm2037236d2def14c.htm VIRTUS FORT TREND FUND UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14C INFORMATION INFORMATION STATEMENT PURSUANT TO SECTION 14(c) OF THE SECURITIES EXCHANGE ACT OF 1934 Filed by the registrant ý Filed by a party other than the registrant ¨ Check the appropriate box: ¨ Preliminary Information Statement ¨ Confidential, For Use of

October 20, 2020 DEFA14A

- VIRTUS RAMPART SECTOR TREND FUND

DEFA14A 1 tm2033787-1defa14a.htm VIRTUS RAMPART SECTOR TREND FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use

October 6, 2020 DEFA14A

- VIRTUS RAMPART MULTI-ASSET TREND FUND

DEFA14A 1 tm2032499d2defa14a.htm VIRTUS RAMPART MULTI-ASSET TREND FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, fo

October 6, 2020 DEFA14A

- VIRTUS RAMPART SECTOR TREND FUND

Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

September 21, 2020 DEFA14A

- VIRTUS RAMPART MULTI-ASSET TREND FUND

DEFA14A 1 tm2031295d2defa14a.htm VIRTUS RAMPART MULTI-ASSET TREND FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, fo

September 21, 2020 DEFA14A

- VIRTUS RAMPART SECTOR TREND FUND

Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

September 4, 2020 DEFA14A

- VIRTUS RAMPART SECTOR TREND FUND

DEFA14A 1 tm2030267d2defa14a.htm VIRTUS RAMPART SECTOR TREND FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use

September 4, 2020 DEFA14A

- VIRTUS RAMPART MULTI-ASSET TREND FUND

DEFA14A 1 tm2030267d1defa14a.htm VIRTUS RAMPART MULTI-ASSET TREND FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, fo

August 27, 2020 CORRESP

-

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com August 27, 2020 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Anu Dubey, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No. 114 Dear Ms. Dubey: Thank you for your additional telephonic comments on Aug

August 27, 2020 DEFA14A

- VIRTUS RAMPART SECTOR TREND FUND

Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

August 27, 2020 DEFA14A

- VIRTUS RAMPART MULTI-ASSET TREND FUND

DEFA14A 1 tm2029488d2defa14a.htm VIRTUS RAMPART MULTI-ASSET TREND FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, fo

August 26, 2020 NPORT-EX

Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value Mortgage-Backed Security—0.

August 26, 2020 NPORT-EX

Rampart Multi-Asset Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Rampart Multi-Asset Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—36.

August 26, 2020 NPORT-EX

Rampart Sector Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Rampart Sector Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

August 26, 2020 NPORT-EX

Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value U.

August 26, 2020 NPORT-EX

KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—91.

August 26, 2020 NPORT-EX

Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

August 26, 2020 NPORT-EX

Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

August 26, 2020 NPORT-EX

KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—86.

August 26, 2020 NPORT-EX

Horizon Wealth Masters Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Horizon Wealth Masters Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—100.

August 26, 2020 NPORT-EX

Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Preferred Stock—2.

August 26, 2020 NPORT-EX

Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value U.

August 26, 2020 NPORT-EX

Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Duff & Phelps Real Asset Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—69.

August 26, 2020 NPORT-EX

Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—6.

August 26, 2020 NPORT-EX

Rampart Equity Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Rampart Equity Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

August 26, 2020 NPORT-EX

Herzfeld Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Herzfeld Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Closed End Funds(1)—87.

August 26, 2020 NPORT-EX

Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—99.

August 26, 2020 NPORT-EX

Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—97.

August 26, 2020 NPORT-EX

Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

August 26, 2020 NPORT-EX

Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value U.

August 26, 2020 NPORT-EX

Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value Municipal Bonds(1)—97.

August 26, 2020 NPORT-EX

Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Par Value Value U.

August 26, 2020 NPORT-EX

Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—96.

August 26, 2020 NPORT-EX

KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—95.

August 26, 2020 NPORT-EX

Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020

Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 ($ reported in thousands) Shares Value Common Stocks—98.

August 24, 2020 CORRESP

-

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com August 24, 2020 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Anu Dubey, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No.114 Dear Ms. Dubey: Thank you for your telephonic com

July 2, 2020 COVER

Securities distributed by VP Distributors, LLC

  One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com 1933 Act/Rule 485(a) July 2, 2020 VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 RE: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No. 113 To The Commission Staff: On behalf of Virtus Opportunities Trust (the “Trust” or

February 28, 2020 NPORT-EX

Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Vontobel Foreign Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—95.

February 28, 2020 NPORT-EX

Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet Low Duration Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value U.

February 28, 2020 NPORT-EX

Rampart Equity Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Rampart Equity Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2020 NPORT-EX

Rampart Sector Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Rampart Sector Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2020 NPORT-EX

Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Duff & Phelps Global Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2020 NPORT-EX

Horizon Wealth Masters Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Horizon Wealth Masters Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2020 NPORT-EX

Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Vontobel Global Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—96.

February 28, 2020 NPORT-EX

Rampart Multi-Asset Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Rampart Multi-Asset Trend Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—35.

February 28, 2020 NPORT-EX

Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet Multi-Sector Short Term Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value U.

February 28, 2020 NPORT-EX

Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Duff & Phelps Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—99.

February 28, 2020 NPORT-EX

KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

KAR Emerging Markets Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—93.

February 28, 2020 NPORT-EX

Rampart Alternatives Diversifier Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Rampart Alternatives Diversifier Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Affiliated Mutual Funds(1)—52.

February 28, 2020 NPORT-EX

Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Duff & Phelps Global Infrastructure Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2020 NPORT-EX

Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet Core Plus Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value U.

February 28, 2020 NPORT-EX

KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

KAR International Small-Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—91.

February 28, 2020 NPORT-EX

Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet Tax-Exempt Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value Municipal Bonds(1)—95.

February 28, 2020 NPORT-EX

Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet High Yield Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value Foreign Government Security—0.

February 28, 2020 NPORT-EX

Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Vontobel Greater European Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Preferred Stock—3.

February 28, 2020 NPORT-EX

Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Vontobel Emerging Markets Opportunities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—98.

February 28, 2020 NPORT-EX

KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

KAR International Small-Mid Cap Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—93.

February 28, 2020 NPORT-EX

Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet Senior Floating Rate Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value Corporate Bonds and Notes—2.

February 28, 2020 NPORT-EX

Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Newfleet Multi-Sector Intermediate Bond Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Par Value Value U.

February 28, 2020 NPORT-EX

Herzfeld Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Herzfeld Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Closed End Funds(1)—94.

February 28, 2020 NPORT-EX

Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019

Duff & Phelps International Real Estate Securities Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 ($ reported in thousands) Shares Value Common Stocks—98.

February 26, 2020 CORRESP

PXRIX / Virtus Intl Real Estate Securities I CORRESP - -

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com February 26, 2020 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Anu Dubey, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No. 107 Dear Ms. Dubey: On February 21, 2020 a response letter was filed on be

February 21, 2020 CORRESP

PXRIX / Virtus Intl Real Estate Securities I CORRESP - -

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com February 21, 2020 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Anu Dubey, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No.107 Dear Ms. Dubey: Thank you for your telephonic comments on January 9, 20

January 28, 2020 DEFA14A

PDPAX / Virtus Rampart Alternatives Diversifier Fund DEFA14A - - VIRTUS RAMPART ALTERNATIVES DIVERSIFIER FUND

DEFA14A 1 tm206039-1defa14a.htm VIRTUS RAMPART ALTERNATIVES DIVERSIFIER FUND Filed by the Registrant x UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by a Party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidenti

January 9, 2020 CORRESP

PXRIX / Virtus Intl Real Estate Securities I CORRESP - -

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com January 9, 2020 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Anu Dubey, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No.107 Dear Ms. Dubey: Thank you for your telephonic comments on December 16, 20

November 26, 2019 DEFA14A

Virtus Opportunities Trust DEFA14A - - VIRTUS RAMPART ALTERNATIVES DIVERSIFIER FUND

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.

November 21, 2019 DEF 14A

Virtus Opportunities Trust DEF 14A - - VIRTUS OPPORTUNITIES TRUST

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.

November 20, 2019 CORRESP

PXRIX / Virtus Intl Real Estate Securities I CORRESP - -

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com November 20, 2019 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the “Trust”) Schedule 14A Proxy Statement CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Thank you for the additi

November 15, 2019 CORRESP

PXRIX / Virtus Intl Real Estate Securities I CORRESP - -

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com November 15, 2019 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the “Trust”) Schedule 14A Proxy Statement CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Thank you for the additi

November 15, 2019 COVER

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com 1933 Act/Rule 485(a) November 15, 2019 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 RE: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No. 107 To The Commission Staff: On behalf of Virtus Opportunities Trust (the “Trust” or “Registrant”), transmitted her

November 6, 2019 CORRESP

PXRIX / Virtus Intl Real Estate Securities I CORRESP - -

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com November 6, 2019 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Anu Dubey Virtus Opportunities Trust (the “Trust”) Schedule 14A Proxy Statement CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: T

October 25, 2019 COVER

Securities distributed by VP Distributors, LLC

One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com October 24, 2019 VIA EDGAR EDGAR Operations Branch Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Virtus Opportunities Trust (the “Trust”) CIK 0001005020 File No. 811-07455 Ladies and Gentlemen: Pursuant to the Securities Exchange Act of 1934, as amended, and Rul

October 25, 2019 PRE 14A

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.__)

PRE 14A 1 tm1920845-1pre14a.htm VIRTUS OPPORTUNITIES TRUST SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No.) Filed by the Registrant x Filed by a Party other than the Registrant ¨ Check the appropriate box: x Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ¨ Definit

September 30, 2019 CORRESP

Virtus Opportunities Trust CORRESP - -

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com September 30, 2019 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Anu Dubey, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No.102 Dear Ms. Dubey: Thank you for your additional

September 23, 2019 CORRESP

Virtus Opportunities Trust CORRESP - -

CORRESP 1 filename1.htm One Financial Plaza, Hartford, CT 06103 | 800.248.7971 | Virtus.com September 23, 2019 Securities and Exchange Commission Judiciary Plaza 100 F Street, NE Washington, D.C. 20549 Attention: Ed Bartz, Division of Investment Management Re: Virtus Opportunities Trust File Nos. 033-65137 and 811-7455 Post-Effective Amendment No.102 Dear Mr. Bartz: Thank you for your telephonic c

August 27, 2019 NPORT-EX

Virtus Opportunities Trust NPORT-EX - -

HTML DUFF & PHELPS GLOBAL INFRASTRUCTURE FUND SCHEDULE OF INVESTMENTS (Unaudited) JUNE 30, 2019 ($ reported in thousands) Shares Value COMMON STOCKS—98.

July 16, 2019 COVER

July 16, 2019

1933 Act/Rule 485(a) July 16, 2019 VIA EDGAR Securities and Exchange Commission 100 F Street, N.

March 1, 2019 N-Q

Virtus Opportunities Trust VIRTUS OPPORTUNITIES TRUST (Quarterly Schedule of Portfolio Holdings)

N-Q 1 d666495dnq.htm VIRTUS OPPORTUNITIES TRUST UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-07455 Virtus Opportunities Trust (Exact name of registrant as specified in charter) 101 Munson Street Greenfield, MA 01301-9668 (Address of princip

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