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Faegre Drinker Biddle & Reath LLP

One Logan Square, Ste. 2000

Philadelphia, PA 19103-6996

(215) 988-2700 (Phone)

(215) 988-2757 (Facsimile)

www.faegredrinker.com

June 29, 2023

VIA EDGAR TRANSMISSION

Ms. Lisa N. Larkin

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: The RBB Fund, Inc. (the “Registrant” or “RBB”)

Registration Statement on Form N-1A

(File Nos.: 033-20827 and 811-05518)

Dear Ms. Larkin:

The purpose of this letter is
to respond to the oral comments you provided regarding RBB’s registration statement on Form N-1A (the “Registration Statement”)
filed on April 27, 2023, to register Oakhurst Fixed Income Fund, Oakhurst Short Duration Bond Fund, Oakhurst Short Duration High Yield
Credit Fund (together, “Oakhurst Funds”), and F/m Investments Large Cap Focused Fund (the “F/m Fund,” together
with Oakhurst Funds, the “Funds” and each a “Fund”).

For your convenience, each comment
has been reproduced in bold typeface immediately followed by the Registrant’s response. Capitalized but undefined terms used herein
have the meanings assigned to them in the Registration Statement. The Registrant confirms that, where applicable, the responses to the
comments provided in one section of the Registration Statement will be similarly updated in other parallel sections of the Registration
Statement, except as noted by the Registrant. The changes to the disclosures discussed below will be reflected in an amendment to the
Registration Statement.

PROSPECTUS – OAKHURST FUNDS

Summary Sections – Oakhurst Fixed Income
Fund

 1. Comment: Please remove the repetitive phrases “Fee
Waivers and/or Expense Reimbursements” in the Expenses and Fees table.

Response: The Registrant
has made the requested change.

 2. Comment: Please confirm that no shares of the Fund
will be offered pursuant to the Registration Statement before the reorganization set forth in the Registrant’s Registration Statement
on Form N-14 filed April 28, 2023 (the “Reorganization”) takes place.

Response: The Registrant
so confirms.

 3. Comment: Footnote (2) to the Expenses and Fees table
states that the Total Annual Fund Operating Expenses and Total Annual Fund Operating Expenses After Management Fee Reduction will differ
from the Fund’s respective expense ratios to average net assets in the Fund’s Financial Highlights, which do not reflect
“Acquired Fund Fees and Expenses.” Footnote (3) states that “acquired fund fees and expenses” are not included
in the expense limitation agreement between the Adviser and the Registrant. However, Acquired Fund Fees and Expenses is not a line item
in the Expenses and Fees table. Please clarify whether such fees and expenses should be referenced in the footnotes and reconcile between
Footnote (2), Footnote (3) and the Expenses and Fees table.

  Response: The Fund does not expect to incur acquired fund fees and expenses in an amount
                                                                                             equal to or in excess of 0.01% of the Fund’s average net assets during its initial year of investment operations. Therefore,
                                                                                             Footnote (2) to the Expenses and Fees table has been removed.

 4. Comment: Footnote (3) to the Expenses and Fees table
states that the Adviser has agreed to a staggered fee waiver, with different expense limitation percentages for the first year following
the Reorganization and for the second year following the Reorganization. Please confirm the Registrant will file a supplemental registration
statement in the event of a change to the Expenses and Fees table because of a change to the applicable expense limitation percentage.

Response: The Registrant
so confirms.

 5. Comment: Per Rule 35d-1 under the Investment Company
Act of 1940, as amended (“1940 Act”), the Funds’ 80% policy should be calculated on net assets plus any borrowings
for investment purposes. Please revise the first sentence of the second paragraph under the section entitled “Principal Investment
Strategies” on p.3 accordingly.

Response: The Registrant has made
the requested revision.

 6. Comment: Please revise the first two sentences of
the third paragraph under the section entitled “Principal Investment Strategies” of the Prospectus to clarify what industry
the Fund’s agency and non-agency mortgage-backed securities will be concentrated in.

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Response: The Registrant
treats agency and non-agency mortgage-backed securities as a single industry for concentration purposes.

Former Guide 19 to Form N-1A stated that “[a]
registrant may...select its own industry classifications, but such classifications must be reasonable and should not be so broad that
the primary economic characteristics of the companies in a single class are materially different.” Guide 19 thus permitted registrants
to define their own industry classifications so long as the classifications are reasonable and the companies within a single industry
have materially similar primary economic characteristics. Although Guide 19 does not apply to registration statements currently filed
under Form N-1A, the Securities and Exchange Commission (“SEC”) has continued to cite this section of former Guide 19 approvingly
with respect to industry concentration. (See the SEC’s Brief Amicus Curiae dated March 25, 2010, In re: Charles Schwab Corp. Securities
Litigation, Master File No. C-08-01510-WHA (N. D. Cal.) at 8 and 9; SEC Release No. IC-29776 (August 31, 2011), footnote 167 and accompanying
text.)

The Registrant believes that treating agency and non-agency
mortgage-backed securities as a single industry for concentration purposes is reasonable and is not so broad that the primary economic
characteristics of the companies in the class are materially different. This position aligns with the position of other registrants (See,
e.g. SEC, No-Action Letter to Morgan Stanley Mortgage Securities Trust, (pub. avail. July 8, 2013), https://www.sec.gov/divisions/
investment/noaction/2013/morganstanley071013-17d.htm). Therefore, no changes have been made to the disclosure in response to this comment.

 7. Comment: The last sentence of the third paragraph
under the section entitled “Principal Investment Strategies” states that “The Fund will not invest more than 15% of
the value of its net assets in securities or other investments that are illiquid.” Please rephrase the disclosure as a positive
strategy, instead of a negative strategy.

  Response: The Registrant has rephrased the disclosure to state “To the extent
                                                                             consistent with its investment policies, the Fund may invest up to 15% of the value of its net assets in securities or other
                                                                             investments that are deemed illiquid.”

 8. Comment: The Fund’s principal risks are presented
in alphabetical order under the “Principal Risks” section. Please re-order the risks based on the significance to the Fund.

  Response: The Registrant is not aware of any statute or rule from the SEC that would require
                                                                             the principal risks to be disclosed in any particular order. The Registrant has considered the SEC’s written guidance on
                                                                             ordering of risks, and the Registrant believes that each risk disclosed in response to Item 4(b) of Form N-1A is a principal risk of
                                                                             the Fund and that each such risk is relevant for investors, and that displaying the risk factors in alphabetical order facilitates
                                                                             finding particular risks and comparing them with other funds. Accordingly, the Registrant respectfully declines to re-order the risk
                                                                             factors.

    3

 9. Comment: The second and third paragraphs under the
section entitled “Principal Risks” appear to be a summary of various risks that the Fund is subject to. Please add a heading
as appropriate, or clarify the purpose of these two paragraphs.

  Response: The Registrant
                                            has added headings to each of those paragraphs noting them as “Investment and Market
                                            Risk” and “Sector Concentration Risk”, respectively.

 10. Comment: Please remove the repetitive paragraph about
Credit Risk under “Other Fixed Income Securities Risks.”

Response: The Registrant
has made the requested change.

 11. Comment: Please include pre-payment and extension
risk as one of the principal risks in the Summary Prospectus.

Response: The Registrant
has made the requested change.

 12. Comment: Please add a bullet point for the paragraph
with the heading “Privately Placed and Rule 144A Securities.”

Response: The Registrant
has made the requested change.

 13. Comment: The section with the heading “Other
Fixed Income Securities Risks” and the section with the heading “Risks Associated With Other Types of Fixed-Income Securities”
overlap. Please revise or consolidate the two sections to reduce investor confusion.

  Response: The Registrant has revised the heading “Risks Associated With Other Types of
                                                                             Fixed-Income Securities” to “Risks Associated With Particular Types of Fixed-Income Securities.”

Summary Sections – Oakhurst Short Duration
High Yield Credit Fund

 14. Comment: Under the section entitled “Principal
Investment Strategies,” the second sentence of the first paragraph states “For the purposes of this Fund, High Yield Securities
include, but are not limited to, traditional corporate bonds, senior loans (including senior “lite” loans) and participation
interests…” Please explain or revise the term “senior “lite” loan.”

Response: The Registrant
has replaced “senior “lite” loan” with “covenant “lite” loan.”

 15. Comment: Under the section entitled “Principal
Investment Strategies,” the second sentence of the fourth paragraph states “The Sub-Adviser generally will look for companies
whose prospects are stable or improving and offer an assurance of debt repayment.” Please confirm if this disclosure is accurate,
given the Fund’s principal investment strategy of investing in junk bonds and High Yield Securities, which tend to be with unstable
companies.

    4

Response: The Registrant
has removed this disclosure.

 16. Comment: In the discussion of senior loans under “Loan
Interests Risk” section, please include the disclosure of extended settlement time associated with senior loans.

Response: The Registrant
has made the requested addition.

 17. Comment: Consider adding risk of preferred securities
under the section “Other Fixed Income Securities Risks.”

Response: The Registrant
has made the suggested addition.

Additional Information About Each Fund’s
Principal Investments

 18. Comment: Under “Investment Objectives”
section, it states that “Each Fund’s investment objective may be changed by the Board of Directors of the Company (the “Board”)
without shareholder approval. Shareholders will, however, receive 60 days’ prior notice of any changes.” Please add a similar
statement for the change of the Fund’s 80% policy.

Response: The Registrant
has made the requested change.

PROSPECTUS – F/m FUND

Summary Section

 19. Comment: The last sentence contained in Footnote (3)
to the Expenses and Fees table states that “The Adviser has the right to seek reimbursement from the Fund for amounts up to the
aggregate amount that the Adviser had waived or reimbursed the Predecessor Fund under an expense limitation agreement with the Predecessor
Fund for the three-year period ending after the specific fee waiver or reimbursement, but only if such reimbursement can be achieved
without exceeding the expense limitation in place at the time of the waiver or reimbursement.” Please explain the basis for this
right of recoupment.

Response: The Registrant
has removed this disclosure.

SAI – F/m FUND

 20. Comment: Under the section entitled “Investment
Limitations,” please revise the language contained in the first paragraph following “The Fund may not…,” to
align with the relevant language contained in 1940 Act, and Form N-1A.

Response: The Registrant
has revised the paragraph in conformity with the requirements under the 1940 Act and Form N-1A.

    5

* * * * *

We trust that the foregoing is
responsive to your comments. Questions and further comments concerning this filing may be directed to the undersigned at (215)-988-3307.

  Sincerely,

  /s/ Jillian L. Bosmann

  Jillian L. Bosmann

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