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Faegre Drinker Biddle & Reath LLP

1500 K Street, N.W., Suite 1100

Washington, DC 20005

(312) 569-1000 (Phone)

www.faegredrinker.com

April 4, 2025

VIA EDGAR TRANSMISSION

Mr. Daniel Greenspan

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    The RBB Fund, Inc. (the “Company”)

    Registration Statement on Form N-1A

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

Dear Mr. Greenspan:

The purpose of this letter is
to respond to the oral comments you provided regarding the Company’s post-effective amendment (“PEA”) No. 338 to its
registration statement on Form N-1A. PEA No. 338 was filed with the Securities and Exchange Commission (the “Commission”)
pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended, on Form N-1A on January 15, 2025.

 As discussed, the Company
will file a PEA under Rule 485(b) (the “Amended Registration Statement”) to update any missing information, respond to
Staff comments, and file updated exhibits with respect to the F/m High Yield 100 ETF ("ZTOP"), a series of the Company initially registered with PEA No. 338. Also as discussed and as indicated
below, with respect to the eleven (11) other series of the Company initially registered with PEA No. 338 (the "Other F/m Series"),
the Company will remain in discussion with the Staff and will file one or more delaying amendments with respect to PEA No. 338 until
a subsequent PEA is filed under Rule 485(b) (the "Subsequent Amendment") to update any missing information, respond to Staff
comments, and file updated exhibits with respect to the Other F/m Series.

For your convenience, each comment
has been reproduced in bold typeface immediately followed by the Company’s response. Capitalized but undefined terms used herein
have the meanings assigned to them in the Registration Statement. The Company 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 Company. The changes to the disclosures discussed below will be reflected in the next post-effective amendment
to the Registration Statement.

Prospectuses

 1. Comment: As a global comment for all funds, please complete the Fee and Expense tables. If
                                                                  there are any contractual fees, please make sure they are footnoted. Clearly indicate whether there are any waivers. Please also confirm supplementally that no waiver and/or recoupment arrangements are in place with the Adviser.

Response: The Company confirms the
remaining information for ZTOP will be completed in the Amended Registration Statement, and for the Other F/m Series in the Subsequent Amendment. The Company also confirms that there are no waiver and/or recoupment
arrangements in place with the Adviser.

 2. Comment: As a global comment for all funds, please review the Principal Investment Risks sections
and ensure that all the risks for similar funds are the same. For example, the F/m High Yield High Beta ETF Principal Investment Risk
section included a Distressed Securities Risk and Duration Risk but the F/m High Yield 100 ETF did not include these risks.

Response: The Company will make the requested
change in the Amended Registration Statement for ZTOP, and in the Subsequent Amendment for the Other F/m Series.

 3. Comment: As a global comment for all funds that have a “Duration Risk,” please provide
a brief discussion of how duration works, i.e. how sensitivity works in response to interest rate changes.

Response: In the Amended Registration
Statement for ZTOP, and in the Subsequent Amendment for the Other F/m Series, Statement, the Company will revise the existing
“Duration Risk” disclosure in the prospectuses to include the explanation that “as interest rates rise, the value
of a bond will fall in direct proportion to its duration and conversely, as interest rates fall, the value of a bond will increase
in direct proportion to its duration. Therefore, the longer a bond’s duration (measured in years), the more sensitive its
price will be to interest rate changes.”

 4. Comment: As a global comment for all funds that have a “Foreign Investment Risk”
and “Non-U.S. Issuer Risk,” to the extent they are overlapping, please consider consolidating.

Response: The Company will make
the requested changes in the Amended Registration Statement for ZTOP, and in the Subsequent Amendment for the Other F/m Series.

 5. Comment: Consistent with Rule 35d-1 under the Investment Company Act of 1940 (the “1940
Act”), the fund name of each of the F/m High Yield 100 ETF, F/m High Yield High Beta ETF, F/m High Yield High Quality ETF, F/m High
Yield Short Duration Quality ETF, F/m High Yield Senior Secured ETF, F/m U.S. Treasury 3-Month Bill Institutional ETF and F/m Current
Coupon Mortgage-Backed Securities ETF, should suggest that such fund tracks an index, as noted in each fund’s Principal Investment
Strategies and 80% Policy. Please either revise each fund’s name so it is clear that the fund tracks an underlying index, or revise
each fund’s 80% Policy to state that 80% of such fund’s assets are invested in securities suggested by the fund’s name.

Response: In the Amended
Registration Statement for ZTOP, and in the Subsequent Amendment for the Other F/m Series, the Company will (i) reflect a change in
the name of each of F/m High Yield High Beta ETF, F/m High Yield High Quality ETF, F/m High Yield Short Duration Quality ETF and F/m
High Yield Senior Secured ETF (the “Renamed HY Funds”) to, respectively, F/m High Beta High Yield ETF, F/m High Quality
High Yield ETF, F/m Short Duration Quality High Yield ETF and F/m Senior Secured High Yield ETF, (ii) and revise the prospectus for
each of the F/m High Yield 100 ETF, the Renamed HY Funds, F/m U.S. Treasury 3-Month Bill Institutional ETF and F/m Current Coupon
Mortgage-Backed Securities ETF to disclose that (a) the investment objective of the Fund is to seek investment results that
correspond (before fees and expenses) generally to the price and yield performance of the applicable specified index (each an
“Underlying Index”) and (b) each Fund is a passively managed ETF that tracks the Underlying Index and under normal
circumstances invests at least 80% of its net assets (plus any borrowings for investment purposes) in the particular type of
security or securities that is suggested by the Fund’s name.

 6. Comment: For the F/m High Yield 100 ETF, F/m High Yield High Beta ETF, F/m High Yield High Quality
ETF, F/m High Yield Short Duration Quality ETF, F/m High Yield Senior Secured ETF, F/m U.S. Treasury 3-Month Bill Institutional ETF and
F/m Current Coupon Mortgage-Backed Securities ETF, please supplementally provide the methodologies of the reference index or sub-index.

Response: The Company has supplementally provided by email
the methodology for the underlying and parent indices for the F/m High Yield 100 ETF.

The Company also has has
supplementally provided by email the relevant methodologies for the Renamed HY Funds and the F/m U.S. Treasury 3-Month Bill
Institutional ETF. Prior to the commencement of the operations of the F/m Current Coupon Mortgage-Backed Securities ETF, the Company will supplementally provide the staff with the
relevant methodologies.

 7. Comment: For the High Yield Short Duration Quality ETF, the Fund’s name includes the term
“Short Duration.” Please confirm that “duration” in this context refers to duration rather than maturity. Additionally,
please provide disclosure regarding the metrics or parameters the Fund uses to define “short duration, ” including the criteria
or standards applied. Further, please include a brief description of what duration means and explain the nexus between the Fund’s
name and its investment strategy regarding short duration.

Response: The Company confirms that
“duration” in the context of the F/m High Yield Short Duration Quality ETF (being renamed F/m Short Duration Quality High
Yield ETF) refers to duration, rather than maturity. Generally speaking, the Adviser will utilize option-adjusted duration (“OAD”
or “effective duration”) because the majority of high yield bonds are callable. The Company also confirms that “short
duration” is defined in the Fund’s 80% policy as “a duration of three (3) years or less.” In the Subsequent Amendment, the Company will add the following to the principal investment strategy disclosure for the Fund: “Duration is a measure
used to determine the sensitivity of a security’s price to changes in interest rates.”

 8. Comment: For the F/m High Yield Senior Secured ETF, please disclose how the Fund defines “senior
security.”

Response: In the Subsequent Amendment, the Company will add the following to the principal investment strategy disclosure in the prospectus for the F/m High Yield
Senior Secured ETF (being renamed F/m Senior Secured High Yield ETF): “The Fund defines a “senior security” as a high
yield bond1 that is (i) higher priority
in repayment order and (ii) secured by specific, tangible collateral of the issuer that can be seized in the case of a default. As a result
of its seniority in the capital structure, and therefore, a higher claim on the underlying collateral, a senior secured bond has a greater
chance of protecting an investor from a loss of principal in the event of default.”

 9. Comment: The “Additional Principal Investment Strategies for All Funds” section
in the first prospectus states that, “During unusual economic or market conditions, or for temporary defensive or liquidity purposes,
each Fund may invest up to 100% of its assets in money market instruments that would not ordinarily be consistent with such Fund’s
investment objective. If a Fund takes a temporary defensive position, it may be unable for a time to achieve its investment objective.”
The language “or for temporary defensive or liquidity purposes” is typically associated with actively managed funds rather
than passively managed index funds. Please explain how this disclosure is applicable to the Funds in this prospectus, as they are passively
managed index funds, or consider removing this language if it does not apply. If the language does not apply, be sure to remove it from the prospectus and the SAI.

Response: The Company will remove
the above-referenced language in the prospectuses and SAIs included with the Amended Registration Statement and the Subsequent Amendment.

 1 The Fund considers a bond to be “high yield” if
the middle rating of Moody’s, Fitch and S&P is Ba1/BB+/BB+ or below, respectively.

 10. Comment: The Principal Investment Strategies section of the U.S. Treasury 3-Month Bill Institutional
ETF notes that “F/m Investments LLC (the “Adviser”) uses a representative sampling indexing strategy in seeking to achieve
the Fund’s investment objective. Under normal market conditions, the Adviser seeks to achieve the Fund’s investment objective
by investing at least 80% of the Fund’s assets (plus any borrowings for investment purposes) in the securities comprising the Underlying
Index and in securities that the Adviser believes to have economic characteristics substantially identical to those of the securities
that comprise the Underlying Index, in this case, the U.S. Treasury 3-Month Bill ETF (TBIL), an affiliated ETF. that generally holds the
outstanding U.S. Treasury Bill that matures closest to, but not beyond, three months from each month end. The Fund may also invest in
cash and cash equivalents and/or money market instruments, such as repurchase agreements and money market funds, for cash management purposes.”
There is a syntax issue in this sentence, specifically the reference to “the U.S. Treasury 3-Month Bill ETF (TBIL), an affiliated
ETF.” This reference should point to the securities rather than the ETF itself.

Response: The Company will remove
the referenced language from the prospectus in the Subsequent Amendment.

 11. Comment: For the F/m Leveraged U.S. Treasury 3-Month Bill ETF, please include specialized risk
disclosures for leveraged funds.

Response: The Company will make
the requested change in the Subsequent Amendment.

 12. Comment: For the F/m Leveraged U.S. Treasury 3-Month Bill ETF, please confirm whether the Fund
intends to use relative Value at Risk (VaR) in complying with Rule 18f-4 under the 1940 Act. Additionally, please provide supplemental
information, including a hypothetical VaR calculation, to demonstrate how the Fund expects to achieve its leverage objective while remaining
in compliance with Rule 18f-4. Specifically, include a reference portfolio compared to the Fund’s hypothetical holdings and explain
how the Fund would be able to meet its leverage requirements.

Response: The F/m Leveraged U.S.
Treasury 3-Month Bill ETF confirms that it intends to use relative VaR in complying with Rule 18f-4 under the 1940 Act. Prior to the commencement
of operations of the Fund, the Company will supplementally provide the staff with the requested information, including a hypothetical
VaR calculation, to demonstrate how the Fund plans to comply with Rule 18f-4.

 13. Comment: For the F/m Leveraged U.S. Treasury 3-Month Bill ETF, the investment objective does
not clearly state whether the Fund seeks to achieve its leverage target on a daily basis. If this is the case, please clarify in the disclosure.
Additionally, please: include bolded disclosure on the cover page; in the Fund’s Summary, add bullet point disclosure to warn investors
about the risks associated with leveraged funds; and provide more prominent risk disclosures consistent with the higher risk profile of
the Fund.

Response: The Company intends to
seek to achieve its leverage target on a monthly, rather than daily, basis. Accordingly, the Company will add the requested prospects
disclosures for the F/m Leveraged U.S. Treasury 3-Month Bill ETF in the Subsequent Amendment.

 14. Comment: For the F/m Leveraged U.S. Treasury 3-Month Bill ETF, this Fund may pose increased
risk for investors who hold positions for longer or shorter than a full trading day, as effective compounding and volatility can cause
the Fund’s performance to deviate from expectations. Please add prominent disclosure stating that the Fund may not perform as expected
if held for longer than a day, as compounding effects and market volatility can cause deviations from the underlying index; that the Fund
is not suitable for all investors and is designed primarily for sophisticated investors who understand leveraged and volatile investment
strategies and that if the Fund moves more than 50% in an adverse direction on a single trading day, an investor could lose their entire
investment.

Response: The Company will make
the requested change in the Subsequent Amendment.

 15. Comment: For the F/m Leveraged U.S. Treasury 3-Month Bill ETF, the Principal Investment Strategies
section states, “The F/m Leveraged UST 3-Month Bill Fund is an actively-managed exchange-traded fund (“ETF”) that seeks
investment results, before fees and expenses, that correspond generally to 2x the price and yield performance of the U.S. 3-Month Treasury
Bill. Under normal market conditions, F/m Investments LLC (the “Adviser”) seeks to achieve the Fund’s investment objective
by investing at least 80% of the Fund’s net assets (plus any borrowings for investment purposes) in the U.S. 3-Month Treasury Bill
and U.S. 3-Month Treasury Bill options, futures and/or swaps. ” Please revise the 80% policy to clearly reflect that the Fund will
invest at least 80% of its assets in investments that seek to achieve twice the performance of the securities or reference assets, ensuring
that exposure is maintained at least two times (2x) the performance of the underlying assets.

Response: The Company will make
the requested change in the Subsequent Amendment.

 16. Comment: For the F/m Lev