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FAEGRE DRINKER BIDDLE & REATH LLP

1500 K Street NW, Suite 1100

Washington, D.C. 20005

202-842-8800

Fax: 202-842-8465

www.faegredrinker.com

June 18, 2025

VIA EDGAR TRANSMISSION

Ken Ellington

Kim McManus

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

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

Registration Statement on Form N-14

File No.: 333-286982

Dear Mr. Ellington and Ms. McManus:

The purpose of this letter is to respond to oral
comments provided by the staff of the Securities and Exchange Commission (“Staff”) regarding RBB’s Registration Statement
on Form N-14 (the “Registration Statement”) filed on May 5, 2025. The Registration Statement relates to the proposed
conversion of (i) the Emerald Insights Fund into an exchange-traded fund through the acquisition by F/m Emerald Special Situations ETF,
a newly formed series of RBB, and (ii) the Emerald Growth Fund and Emerald Finance and Banking Innovation Fund into mutual funds through
the acquisition by Emerald Growth Fund and Emerald Banking and Finance Evolution Fund, respectively, each a newly formed series of RBB,
of the assets and liabilities of each acquired fund, in exchange for shares of its corresponding acquiring fund, referred to herein collectively
as the “Reorganizations.”

For your convenience, each comment made by the
Staff 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 the response to Staff 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.

Accounting Comments:

 1. Comment: Please disclose in a footnote to the fee tables for the Emerald Banking & Finance Evolution
Fund and the Emerald Growth Fund that “Other Expenses” are based on estimated amounts for the current fiscal year, according
to Instruction 6(a) to Item 3 of Form N-1A.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 2. Comment: Total Annual Fund Operating Expense before/after Fee Waiver/Expense Reimbursement for Class
A of the Emerald Growth Fund pro forma shares (10.20% instead of 1.05% and 0.99% instead of 1.02%) and for Investor Class of the Emerald
Growth Fund (1.07% instead of 1.10% and 1.04% instead of 1.07%) appear to be incorrect. Please revise.

Response: The Registrant will revise the "Total Annual Fund Operating Expenses" line items to reflect the most current fees in the amended Registration
Statement.

 3. Comment: The date of each fee table is October 31, 2024. Please confirm that the fees presented in
the fee tables are still current. See Item 3 of Form N-14.

Response: The Registrant confirms that
the fees presented in the fee tables are still current as required by Item 3 of Form N-14.

 4. Comment: The date of the Pro Forma Capitalization table is December 31, 2024. Please confirm that there
have been no material changes to each Acquired Fund’s balance sheet since that date.

Response: The Registrant confirms that
there have been no material changes to each Acquired Fund’s balance sheet since December 31, 2024.

 5. Comment: For the Emerald Insights Fund, please confirm that the expenses subject to recapture will
not be carried over to the merged entity. If they are subject to recapture, please add disclosure stating so.

Response: The Registrant confirms that
the expenses subject to recapture will not be carried over to the merged entity. The Registrant also confirms that the following disclosure
will be added to reflect that expenses will not be subject to recapture:

“Any such recapture rights will
not survive the Reorganization, and the Adviser will not seek to recover any waived or reimbursed expenses from the Acquiring Funds following
the closing of the Reorganization.”

 6. Comment: Disclosure in the Comparison of Fees and Expenses section for the Emerald Banking & Finance
Evolution Fund and the Emerald Growth Fund states that the table assumes that the Reorganization had occurred on May 1, 2024. Please confirm
if that date is correct and explain or revise if necessary.

Response: The Registrant will revise
this date to October 31, 2024 in the amended Registration Statement.

 7. Comment: The prospectus for the Emerald Special Situations ETF is incorporating by reference the Acquired
Fund’s (Emerald Insights Fund) Annual Report for the fiscal year end August 31, 2024, but the Acquired Fund’s fiscal year
end was October 31, 2024. Please explain or revise.

Response: The Acquired Fund’s
(Emerald Insights Fund) fiscal year end is April 30. The Registrant confirms that this date will be revised in the amended Registration
Statement.

 8. Comment: Please include the Fi-Hi table or incorporate by reference the Fi-Hi table of the Emerald
Banking & Finance Evolution Fund and the Emerald Growth Fund. See item 6 of Form N-14.

Response: The Registrant confirms that
the Fi-Hi tables for the Emerald Banking & Finance Evolution Fund and the Emerald Growth Fund will be included as “Appendix
D” into the amended Registration Statement.

 9. Comment: Disclosure in the N-14 states that the Emerald Insights Fund may need to dispose of certain
securities in advance of the Reorganization which will result in the recognition of gain or loss to the Acquired Fund. Please disclose
the following:

 a. An estimate of the percentage of the Emerald Insights Fund that is expected to be sold in connection
with the Reorganization.

 b. The portfolio transaction costs that are expected to be generated as a result of these trades.

 c. The estimated impact to shareholders regarding capital gains distribution including per share amounts.

Response: The Registrant will update
the disclosure to reflect the following:

 a. The Registrant expects the percentage of the Fund that will be disposed of in advance of the Reorganization
will be minimal. Approximately 80% of the Fund’s holdings are anticipated to be sold after the Reorganization.

 b. Transaction costs for the Acquiring Fund associated with the rebalancing following the Reorganization,
are expected to be $0.01 per share.

 c. At this time, the Registrant does not expect such capital gains distributions to increase materially as
a result of the Reorganization. Any capital gains realized by the Fund will be distributed in the ordinary course of business and are
not expected to increase as a result of the Reorganization.  The Adviser to the Fund will continue to manage the Fund in the best
interests of the shareholders throughout the Reorganization.

 10. Comment: Please provide a consent from the predecessor auditor for the April 30, 2023 financial statements
for the Acquired Funds (since the Statement of Changes in Assets incorporates by reference in the N-14 includes financial information
included by the predecessor auditor). See AICPA investment companies expert panel minutes dated September 20, 2018.

Response: The Registrant confirms that
it will provide a consent from the predecessor auditor in the amended Registration Statement.

 11. Comment: Please update the name of the sections titled “Pro forma Financial Statements”
to “Supplemental Financial Information”. See Article 6-11(d) of Regulation S-X.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 12. Comment: Please confirm in correspondence that there is no disclosure required under Article 6-11(d)(1)(ii)
or (iii) of Regulation S-X. Please consider stating that the realization will not result in (1) A material change to each Acquired Fund’s
investment portfolio due to investment restrictions or (2) A change in accounting policies. For example, if this is true consider stating
the following: “A Schedule of Investments of the Acquired Fund modified to show the effect of such change is not required and therefore,
not included. There are no material differences in the accounting policies of the Acquired Fund as compared to the combined fund”.

Response: The Registrant confirms that
that there is no disclosure required under Article 6-11(d)(1)(ii) or (iii) of Regulation S-X because the Reorganizations will not result
in (1) A material change to each Acquired Fund’s investment portfolio due to investment restrictions or (2) A change in accounting
policies. The Registrant will add the suggested disclosure language in the section entitled “OVERVIEW – The Reorganizations.”

 13. Comment: Please include hyperlinks to all documents that are incorporated by reference to the N-14.

Response: The Registrant will include
hyperlinks to all documents that are incorporated by reference to the N-14 in the amended Registration Statement.

Disclosure Comments:

 14. Comment: Please revise the N-14 as necessary to address comments issued on the 485(a).

Response: The Registrant will make the
necessary changes in the amended Registration Statement.

 15. Comment: Please include trustee and signatory information in the amended filing, as applicable.

Response: The Registrant will include
trustee and signatory information in the amended Registration Statement.

Proxy Statement/Prospectus for
the Emerald Growth Fund and

the Emerald Banking and Finance
Evolution Fund

 16. Comment: Prior disclosure indicates that the Acquiring Funds will pay a lower advisory fee following
the Reorganization. Please revise the Shareholder Fee table for the Emerald Growth Fund or the accompanying narrative, as necessary, to
ensure consistency with that disclosure. In addition, please correct the typographical error in the table where “Total Annual Fund
Operating Expenses” is shown as “10.2%,” which appears to be inconsistent with the other information provided.

Response: The Registrant will revise the Shareholder Fee Table to reflect the lower advisory fee following the Reorganization in the amended Registration
Statement. The registrant confirms that the typographical error in the “Total Annual Fund Operating Expenses” line item will
be corrected in the amended Registration Statement.

 17. Comment: In the heading directly above the section entitled “INFORMATION ABOUT THE REORGANIZATIONS”
that refers to “Proposals 1–3.” Please confirm whether this reference should be revised to “Proposals 1–2”.

Response: The Registrant will make the
noted change in the amended Registration Statement.

 18. Comment: Under the section entitled “Charter Documents,” the disclosure refers to “some
of the differences” between the governing documents of the Acquired and Acquiring Funds. Please revise to clarify that the chart
reflects “material differences” between the governing documents. In addition, please ensure that any material changes to shareholder
rights resulting from the reorganization into a Maryland corporation are disclosed prominently.

Response: The Registrant will revise
to clarify that the chart reflects “material differences” between the governing documents in the amended Registration Statement.
The Registrant will also ensure that any material changes to shareholder rights resulting from the reorganization into a Maryland corporation
are disclosed prominently in the amended Registration Statement.

 19. Comment: The Statement of Additional Information refers to a waiver of expenses. Please revise the
disclosure to clarify whether any fees or expenses waived by the Adviser for the predecessor (Acquired) Funds that are subject to recapture
will be recoverable by the Adviser from the respective Acquiring Funds after the Reorganization.

Response: The Registrant confirms that
the disclosure will be revised as follows to reflect that expenses will not be subject to recapture:

“Any such recapture rights will
not survive the Reorganization, and the Adviser will not seek to recover any waived or reimbursed expenses from the Acquiring Funds following
the closing of the Reorganization.”

Proxy Statement/Prospectus for
the F/m Emerald Special Situations ETF

 20. Comment: Under the Q&A section, the response to the question “Will any fund pay fees associated
with the Reorganization?” states that portfolio transaction costs may be incurred by the Acquiring Fund. Please revise this disclosure
to eliminate the reference to the Acquiring Fund incurring portfolio transaction costs, as the Acquiring Fund will have no operations
and no portfolio holdings to reposition in connection with the Reorganization. If applicable, clarify that any such portfolio transaction
costs will be borne solely by the Acquired Fund in advance of the Reorganization.

Response: The Registrant will make the
requested changes in the amended Registration Statement.

 21. Comment: Under the Q&A section, the response to the question “Will any fund pay fees associated
with the Reorganization?”, references potential portfolio repositioning by the Acquired Fund. If significant portfolio repositioning
is anticipated, please revise the disclosure to address the following:

 a. Disclose the approximate percentage of the Acquired Fund’s portfolio securities that are expected to be sold in connection
with the Reorganization.

 b. Identify who will bear the cost of any such portfolio repositioning.

 c. Quantify the expected transaction costs, both in dollars and as a percentage of the Acquired Fund’s net assets.

 d. Describe any expected tax consequences to shareholders, including whether any capital gains distributions may result from the sales,
and provide an estimate of such distributions, if applicable.

Response: The Registrant will revise
the disclosure to reflect the following:

 a. The Registrant expects the percentage of the Fund that will be disposed of in advance of the Reorganization
will be minimal. Approximately 80% of the Fund’s holdings are anticipated to be sold after the Reorganization rather than prior
to the Reorganization.

 b. The Registrant confirms that the Acquiring Fund, the F/m Emerald Special Situations ETF, will bear the
cost of the repositioning.

 c. The Registrant expects the cost of the post-Reorganization portfolio repositioning to be approximately
$0.01 per share. The total transaction cost will depend upon the number of shares of each security held in the portfolio. As of May 31,
2025 the Fund held 396,786 shares of stock. If 80% of the portfolio is sold at $0.01 per share, the estimated transaction cost would be
approximately $3,175. Based on the Fund’s net assets of $20,490,646.88 as of May 31, 2025, this would represent approximately
0.016% of net assets. The Registrant will update the amended Registration statement accordingly.

 d. At this time, the Registrant does not expect such capital gains distributions to increase materially as
a result of the Reorganization. Any capital gains realized by the Fund will be distributed in the ordinary course of business and are
not expected to increase as a result of the Reorganization.  The Adviser to the Fund will continue to manage the Fund in the best
interests of the shareholders throughout the Reorganization.

 22. Comment: Under the Q&A section it states:

“If shares are held in an account
that cannot accept ETF shares at the time of the Reorganization of the Acquired Fund, Acquiring Fund shares received in the Reorganization
will be held by a stock transfer agent, [U.S. Bank] (“[stock transfer agent]”), until a brokerage account is identified into
which [stock transfer agent] can transfer the shares. As planned, if Acquiring Fund shares are not transferred into a brokerage account
within a year of the date of the Reorganization, the Acquiring Fund shares will be converted to cash and the cash proceeds sent to the
account holder of record (subject to applicable federal or state laws concerning unclaimed property). The conversion of Acquiring Fund
shares to cash may be subject to fees and expense