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CORRESP
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    Jessica L. Accurso

    Associate

    215.963.5266

    January 24, 2024

FILED AS EDGAR CORRESPONDENCE

Ms. Ellie Quarles, Esq.

U.S. Securities and Exchange Commission

Division of Investment Management

100 F
Street, NE

Washington, D.C. 20549

 Re: Response letter to comments on Post-Effective Amendment No. 134 to the Registration Statement of SEI Institutional Managed
Trust (File Nos. 033-09504 and 811-04878)

Dear Ms. Quarles:

On behalf of our client, SEI Institutional Managed
Trust (the “Trust” or “SIMT”), this letter responds to the comments and questions you provided via telephone on
January 12, 2024 regarding the Trust’s Post-Effective Amendment No. 134, under the Securities Act of 1933, as amended
(the “1933 Act”), and Amendment No. 136, under the Investment Company Act of 1940, as amended (the “1940 Act”),
to its Registration Statement filed with the SEC on November 29, 2023 pursuant to Rule 485(a)(1) under the 1933 Act (the
 “Amendment”), for the purpose of reflecting the addition of a long/short equity sleeve in the Large Cap Growth Fund (the “Fund”),
a series within the Trust. Below, we have briefly summarized your comments and questions, followed by our responses. Capitalized terms
not defined herein should be given the meaning provided in the Amendment.

Comments on the Prospectus

 1. Comment.       Please supplementally provide a completed fee table and expense examples for
the Fund.

    Response.       The
    completed fee tables and expenses examples are as follows:

ANNUAL FUND OPERATING EXPENSES

    (expenses that you pay each year as a percentage of the value of your investment)

    Class F Shares

    Management Fees

    	0.40
    %

    Distribution (12b-1) Fees

    None

    Other Expenses

    	0.58
    %

    Total Annual Fund Operating Expenses

    	0.98
    %

Ms. Ellie Quarles, Esq.

January 24, 2024

Page 2

    (expenses that you pay each year as a percentage of the value of your investment)

    Class I Shares

    Management Fees

    	0.40
    %

    Distribution (12b-1) Fees

    None

    Other Expenses

    	0.83
    %

    Total Annual Fund Operating Expenses

    	1.23
    %

    (expenses that you pay each year as a percentage of the value of your investment)

    Class Y Shares

    Management Fees

    	0.40
    %

    Distribution (12b-1) Fees

    None

    Other Expenses

    	0.33
    %

    Total Annual Fund Operating Expenses

    	0.73
    %

EXAMPLE

    1 Year
    3 Years
    5 Years
    10 Years

    Large Cap Growth Fund — Class F Shares
    $ 100
    $ 312
    $ 542
    $ 1,201

    1 Year
    3 Years
    5 Years
    10 Years

    Large Cap Growth Fund — Class I Shares
    $ 125
    $ 390
    $ 676
    $ 1,489

    1 Year
    3 Years
    5 Years
    10 Years

    Large Cap Growth Fund — Class Y Shares
    $ 75
    $ 23
    $ 406
    $ 906

 2. Comment.       In the “Fees and Expenses” section, please confirm that the Total
Annual Fund Operating Expenses are the amounts that would have been incurred absent expense reimbursements or fee waiver arrangements.

Response.       The
Trust confirms that the Total Annual Fund Operating Expenses are the amounts that would have been incurred absent expense non-contractual
reimbursement or fee waiver arrangements.

 3. Comment.       If Acquired
Fund Fees and Expenses (“AFFE”) are expected to exceed 0.01% of the average net assets of the Fund, please disclose these
fees as a separate line item within the table. If AFFE are not expected to exceed 0.01%, please include such expenses in the “Other
Expenses” line item in the table.

Response.       The
Trust confirms that AFFE are not expected to exceed 0.01% of the average net assets of the Fund and, accordingly, any such amounts are
included in the “Other Expenses” line item in the table.

 4. Comment.       If shorting will be a part of the Fund’s principal investment strategies,
please supplementally confirm that expenses such as dividends paid on stocks sold short will be included in the “Other Expenses”
line item in the fee table or as a separate line item if such expenses are expected to exceed 0.01% of the average net assets of the Fund.

Response.       The
Trust confirms that expenses such as dividends paid on stocks sold short are not expected to exceed 0.01% of the average net assets of
the Fund and, accordingly, all such amounts are included in the “Other Expenses” line item in the table.

Ms. Ellie Quarles, Esq.

January 24, 2024

Page 3

 5. Comment.       Please provide documentation supporting the range of market capitalization for
the Russell 1000 Growth Index as of December 31, 2023. Please also explain supplementally why a company with a market capitalization
in the millions would be a large capitalization company. The Staff notes that the Russell 1000 Growth Index fact sheet does not provide
the low end of the market capitalization range.

Response.       The
requested documentation has been provided to the Staff under separate cover. The Trust supplementally notes that the Russell 1000 Growth Index includes,
at the lower end of the range, companies with a market capitalization in the millions.

 6. Comment.       In the Fund’s Principal Investment Strategies, please incorporate clarifying
disclosure that the reference to the Russell 1000 Growth Index is solely for the definition of large capitalization companies and that
the Fund will not be limited to investing in securities in the Russell 1000 Growth Index.

Response.       The
Trust notes that the disclosure indicating, “[f]or purposes of this Fund, a large company is a company with a market capitalization
in the range of companies in the Russell 1000 Growth Index” does not limit the Fund’s investments to the securities of companies
included in the Russell 1000 Growth Index. Accordingly, the Fund respectfully declines to make the requested change.

 7. Comment.       If
special purpose acquisition companies (“SPACs”) or companies formed from a merger with a SPAC will be part of the Fund’s
principal investment strategy, please discuss SPACs in response to Item 4 and Item 9 and describe the related risks.

Response.       The
Trust confirms that SPACs are not part of the Fund’s principal investment strategy. Accordingly, no disclosure with respect to investing
in SPACs has been added.

 8. Comment.       The Fund’s
Principal Investment Strategy disclosure provides, “The Fund may also, to a lesser extent, invest in common and preferred stocks
of small capitalization companies.” Please confirm that small capitalization investments are a principal strategy for this Fund.

Response.       Although
common and preferred stocks of small capitalization companies currently represent a relatively small amount of the Fund’s total
investments, the Adviser confirms that the option to invest in such instruments to a greater degree continues to be a significant part
of the Fund’s investment strategy.

 9. Comment.       In the Fund’s
Principal Investment Strategies, please indicate whether the forward contracts and swaps relate to individual shares, exchange-traded
funds (“ETFs”), other indices or other types of investments such as currencies. With respect to currencies, the Staff notes
the reference to hedging positions in the currency risk disclosure.

Response.       The
Trust confirms that typically the Fund’s investments in forward contracts and swaps will use individual securities or baskets of
securities as reference assets. The Fund has revised the disclosure accordingly. The Trust supplementally confirms that the Fund’s
principal investment strategies do not involve currency hedging.

Ms. Ellie Quarles, Esq.

January 24, 2024

Page 4

 10. Comment.       With respect
to the Fund’s Principal Investment Strategy disclosure, please: (i) discuss how the long/short equity investment strategy fits
within the Sub-Advisers’ authority to invest; (ii) incorporate disclosure explaining how the model portfolio is constructed,
for example, industry, sector, foreign, etc., and explain further the determination of how investments are apportioned to each Sub-Adviser;
and (iii) confirm whether each Sub-Adviser uses a long/short strategy or whether the long/short strategy is limited to one Sub-Adviser.

Response.        With
respect to the first part of the Staff’s comment, the Trust notes that each Sub-Adviser is authorized to invest its sleeve of allocated
assets pursuant to its sub-advisory contract with SIMC and any investment guidelines that the Sub-Adviser and SIMC agree to apply to the
sleeve. In the case of Mackenzie Investments Corporation (“Mackenzie”), SIMC hired Mackenzie specifically for its long/short
equity investment strategy. Accordingly, the sub-advisory contract between Mackenzie and SIMC includes authorization from SIMC for Mackenzie
to invest its allocation assets in accordance with the agreed-upon strategy.

Regarding the second part of the Staff’s
comment, the Trust notes that the “model portfolios” provided by certain Sub-Advisers to the overlay manager will vary pursuant
to the Fund’s current Sub-Adviser lineup, but will, in each case, be considered by the overlay manager on a cumulative basis (i.e.,
among all Sub-Advisers that provide a model portfolio to the overlay manager) for adherence to the strategies described in the first three
paragraphs of the Fund’s Principal Investment Strategy disclosure. Because the Sub-Adviser lineup may change over time pursuant
to SIMC’s multi-manager approach, and because investors in the Fund will have exposure to the Fund’s portfolio as a whole,
the Trust respectfully declines to revise the disclosure to describe the portfolio construction of each current Sub-Adviser with respect
to its sub-advised sleeve.

With respect to the third part of
the Staff’s comment, the Trust supplementally confirms that, currently, only Mackenzie uses a long/short strategy within the
Fund. However, in order provide SIMC with the flexibility necessary to manage the Fund pursuant to its multi-manager approach,
including the potential of allocating Fund assets to additional Sub-Advisers to implement the long/short equity strategy in the
future, the Trust respectfully declines to revise the disclosure to limit the strategy to one Sub-Adviser.

 11. Comment.       Please
confirm that the incorporation of the long/short strategy is consistent with the Fund’s “growth” strategy as such strategy
is normally associated with “value” investing.

Response.        The
Trust is of the view that the long/short strategy is not inconsistent with the Fund’s “growth” strategy, particularly
given that the long/short sleeve of the Fund is only one of four sub-advised sleeves of the Fund and SIMC manages those assets of the
Fund that are not allocated to Sub-Advisers.

 12. Comment.       In the Fund’s Principal Investment Strategy disclosure, there is discussion
regarding the “short positions with respect to investments that are believed to have significant risk of decreasing in price.”
Please clarify why there is a significant risk (e.g., the security is deemed overvalued or growth prospects diminished to the point that
the stocks will drop, a lowering of the price to equity ratio or other multiple).

Response.        The
Trust notes that the disclosure is intended to convey to investors a general understanding of a long/short strategy, rather than to disclose
the specific circumstances in which SIMC or the Fund’s Sub-Adviser(s) might consider a security at risk of declining in value,
which

Ms. Ellie Quarles, Esq.

January 24, 2024

Page 5

circumstances are multivariant and wide ranging. To avoid confusing and possibly limiting disclosure, the Trust respectfully declines
to make the requested change.

 13. Comment.       Please summarize
and provide more detail in response to Item 9(b)(2) regarding how the Adviser, the Sub-Adviser or overlay manager determines when
to sell investments.

Response.        In
response to the Staff’s comment, the Trust has added disclosure to the Fund’s “More Information About Investments”
section with respect to how the Adviser, the Sub-Adviser or overlay manager determines when to sell investments.

 14. Comment.       Please consider whether “Management
Risk” will be a principal risk of investing in the Fund.

Response.        In
response to the Staff’s comment, “Management Risk” has been added to the Fund’s principal risk disclosure.

 15. Comment.       In the Fund’s
 “Principal Risks” section, please add a new sentence at the end of the “Exchange-Traded Funds Risk” that reads,
 “As a result, shareholders will be subject to two layers of fees and expenses with respect to investments in the Fund” or
similar disclosure to this effect.

Response.        In
response to the Staff’s comment, the “Exchange-Traded Funds Risk” has been revised as requested.

 16. Comment.       Please discuss the extent to which the Fund will use derivatives outside of
its long/short strategy or equity securities. If investing in other kinds of derivatives is part of the Fund’s principal investments,
please describe those investments in the Fund’s Item 4 and Item 9 disclosure.

Response.        The
Trust confirms that the Fund will not invest in derivatives on a principal basis outside of the Fund’s long/short strategy. Accordingly,
the Trust confirms that the disclosure is appropriately tailored to the Fund’s use of derivatives as-is.

 17. Comment.       In the Fund’s “Foreign Investment
Risk,” because there is discussion regarding emerging market risk the Fund’s Item 9 disclosure, please provide a summary of
that risk in the “Principal Risks” section as well.

Response.        The
Trust notes that the Item 9 risk disclosure is broader than the Item 4 disclosure in certain instances due to the integrated nature of
the Trust’s 485(b) filing, which contains each series of the Trust. For purposes of the Amendment, the Trust included only
the Large Cap Growth Fund. Accordingly, the Trust confirms that emerging market risk is not a principal risk of the Fund, but is properly
included in the Item 9 risk disclosure, where it will be relevant to other series of the Trust included in the annual amendment to the
registration statement filed pursuant to Rule 485(b).

 18. Comment.       If the Fund will invest significantly in China, please add a risk tile disclosing
this in the Fund’s “Principal Risks” section.

Response.        The
Trust confirms that the Fund will not invest significantly in China. Therefore, no additional risk disclosure regarding investing in China
has been added with respect to the Fund.

Ms. Ellie Quarles, Esq.

January 24, 2024

Page 6

 19. Comment.       In the “Currency
Risk” disclosure in the Fund’s “Principal Risks” section, to the extent currency hedging will be a principal investment
strategy of the Fund, please incorporate attendant strategy disclosure in response to Item 4 and Item 9.

Response.        The
Trust confirms that currency hedging is not a principal investment strategy of the Fund. Therefore, no strategy disclosure with respect
to currency hedging has been added with respect to the Fund.

 20. Comment.       In the Fund’s
 “Performance Information” section, please present the historical performance as a bar chart.

Response.        The
Trust confirms that the historical performance in the “Performance Information” section will be presented as a bar chart in
the annual amendment to the registration statement filed pursuant to Rule 485(b).

 21. Comment.       In the “Management”
section, please indicate whether the portfolio managers are jointly and primarily responsible for the day-to-day management of the Fund’s
portfolio.

Response.        The
Trust notes that Item 5(b) requires only that the Trust state the name, title, and length of service of the portfolio managers
that are primarily responsible for the day-to-day management of the Fund’s portfolio. The Trust’s current disclosure
meets these