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CORRESP
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March 4, 2020

Via E-MAIL AND EDGAR

Christopher Bellacicco

Attorney, Disclosure Review
and Accounting Office

Division of Investment Management

U.S. Securities and Exchange
Commission

100 F Street NE

Washington, DC 20549

 Re: Rule 485(a) Filing
                                         of SCM Trust (File Nos. 811-05617; 333-176060) on November 21, 2019

Dear Mr. Bellacicco:

This letter responds to comments
provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission
in telephone conversations with you on December 31, 2019 regarding the above-referenced filing of various new series funds (the
“Funds”) of SCM Trust (“the Trust). Where applicable, the Trust will be amending the filing in response to certain
comments as noted below (the “Amended Filing”).

Please see a summary of the
Staff’s comments below, followed by responses on behalf of the Trust and the Funds. The initial 29 Comments related to the
Shelton Emerging Markets Fund, and as applicable the Responses also refer to changes made to the other two separate Prospectuses
and Statements of Additional Information (“SAIs”) in the above referenced filing relating to (i) the ICON Consumer
Select Fund, the ICON Natural Resources Fund, the ICON Health and Information Technology Fund and the ICON Utilities and Income
Fund and (ii) the ICON Equity Income Fund, the ICON Flexible Bond Fund and the ICON Equity Fund.

 1. Comment: Please include a cover
                                         letter with the Amended Filing explaining the background of the new Funds.

Response:
The new Funds will commence operations in conjunction with the proposed reorganizations of the series open-ended funds of ICON
Funds trust in various combinations into the Funds as described in the N-14 registration statement of the Trust filed on February
14, 2020 (Accession Number 0001398344-20-003619) (the “N-14”). The Trust will include a cover letter with the Amended
Filing to that effect.

 2. Comment: For the Shelton Emerging
                                         Markets Fund and all other Funds, please update the table of contents in the Prospectuses.

Response:
The tables of contents have been updated.

 3. Comment: For the Shelton Emerging
                                         Markets Fund, remove footnotes in the fee table and other disclosures relating to expense
                                         reimbursements as applicable.

Response:
The footnotes and other disclosures have been revised to reflect that Shelton Capital Management (the “Adviser”) has
contractually agreed to reimburse expenses incurred by the Acquiring Fund to the extent that total annual fund operating expenses
(excluding acquired fund fees and expenses, certain compliance costs, and extraordinary expenses such as litigation or merger
and reorganization expenses, for example) exceed 1.80% and 1.55% for Investor Class and Institutional Class shares, respectively,
until May 22, 2021. The footnotes and other disclosures for all of the Funds have been similarly updated to reflect the agreed
upon expense limitations as disclosed in the N-14.

 4. Comment: For the Shelton Emerging
                                         Markets Fund, include disclosure where appropriate that historic information relates
                                         to that of the predecessor ICON Emerging Markets Fund.

Response:
The disclosure immediately following the Example of Expenses as been revised to state:

The Shelton Emerging
Markets Fund of SCM Trust is the successor fund to the ICON Emerging Markets Fund (the “Predecessor Fund”), which
is proposed to be reorganized into the Shelton Emerging Markets Fund on or about May 22, 2020. All historic performance and financial
information presented is that of the Predecessor Fund, which was the accounting and performance survivor of the reorganization.
Historic information presented for the Institutional Class and Investor Class shares is based on that of the Class A and Class
S shares, respectively, of the Predecessor Fund.

Equivalent disclosure
has been added in respect of each of the Funds in the other Prospectuses.

 5. Comment: Provide a representation
                                         to the Staff that the Trust will not sell shares of a Fund until after a reorganization
                                         in respect of such Fund has occurred.

Response:
The Trust confirms that except for the issuance of an initial share to Shelton Capital Management for the sole purpose of allowing
the Shelton Capital Management as the sole shareholder of each Fund to approve certain organizational items on behalf of each
such Fund, it will not sell shares of a Fund until after a reorganization in respect of such Fund has occurred.

 6. Comment: Modify the disclosure
                                         regarding portfolio turnover to make clear that such turnover was that of the predecessor
                                         fund.

Response:
The disclosure has been modified to state: “During the most recent fiscal year, the Predecessor Fund’s portfolio turnover
rate was 78% of the average value of its portfolio.” Equivalent disclosure has been added in respect of each of the Funds
in the other Prospectuses.

 7. Comment: Please explain in your
                                         letter response how the notional value of derivatives will be calculated when confirming
                                         compliance with the name test of Rule 35d-1 under the Investment Company Act, as amended
                                         (the “Fund Name Test”).

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Response:
For the Shelton Emerging Markets Fund and all Funds which use derivatives and are subject to the Fund Name Test, the market value
of a Fund’s derivative investments will be used to calculate compliance with the Fund Name Test.

 8. Comment: Please ensure the Shelton
                                         Emerging Markets Fund prospectus includes principal risks which correspond to its principal
                                         investment strategies.

Response:
The heading of the principal investment risk disclosures responsive to Item 4 of Form N-1A has been revised to read “Summary
of Principal Risks”, and the heading of the investment risk disclosures responsive to Item 9 of Form N-1A has been revised
to read “Principal and Other Investment Risks” which now includes all investment risks. Further, the heading “Additional
Risks” has been removed from the Item 9 disclosures. The Trust notes there may have been some misunderstanding that this
is a single statutory prospectus, and not a summary prospectus along with a statutory prospectus. The Trust believes the principal
risks as summarized in the Item 4 disclosures and in certain instances elaborated more fully in the Item 9 disclosures correspond
to the principal investment strategies.

Equivalent changes
in disclosures have been added in respect of each of the Funds in the other Prospectuses.

 9. Comment: For the Shelton Emerging
                                         Markets Fund, please describe valuation risk consistently as either a principal risk
                                         or and additional risk.

Response:
With the clarifying changes to the headings described in Response 8 above, valuation risk is now consistently disclosed as a principal
risk.

 10. Comment: Please ensure that
                                         the inception dates of the Shelton Emerging Markets Fund are consistently disclosed on
                                         the cover and in the Prospectus.

Response:
The dates of and within all the disclosures documents have been consistently revised to read March __, 2020. It is currently anticipated
that the Funds will commence operations (have an investment inception date) on or about May 22, 2020 in conjunction with the reorganizations
as described in the N-14.

 11. Comment: For the Shelton Emerging
                                         Markets Fund, the first instance of “Summary of Other Important Information About
                                         Fund Shares” seems to be out of order, and does not disclose information about
                                         both classes of shares.

Response:
That section of the Prospectus should not have been included and has been deleted; the relevant information is now included later
in the Prospectus.

 12. Comment: For the Shelton Emerging
                                         Markets Fund, under the heading “Investment Objective and Principal Strategies”
                                         please state the investment objective and whether it may be changed without approval
                                         of shareholders.

Response:
The following sentences have been added immediately under the heading:

The Fund seeks to
achieve long-term capital appreciation. This investment objective may not be changed without shareholder approval.

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 13. Comment: For the Shelton Emerging
                                         Markets Fund, please ensure that the investment risk disclosures in response to Item
                                         9 of form N-1A are not identical to disclosures in response to Item 4 of form N-1A.

Response:
The Trust believes the risk disclosures are appropriately summarized and elaborated upon with the changes made as noted in Response
8 above.

 14. Comment: For the Shelton Emerging
                                         Markets Fund, if any disclosed investment risks are non-principal risks, please move
                                         them to the “Additional Risks” section.

Response:
Please see Response 8 above.

 15. Comment: For the Shelton Emerging
                                         Markets Fund, consistent with Form N-1A Instruction 9(b)4, reconsider the disclosure
                                         regarding concentration risk if there is no investment intent to concentrate in securities
                                         of issuers in a particular industry or group of industries (i.e., investing more than
                                         25% of a Fund’s net assets in a particular industry or group of industries).

Response:
Because the Fund will normally invest in the securities of approximately 30 to 50 issuers, the Trust believes the current concentration
risk disclosure detailing the associated risks where a fund’s portfolio is concentrated in few companies or economic sectors,
is appropriate and important in the context of many investors’ understanding of a relatively “concentrated portfolio”
and does not conflict with the Fund’s fundamental investment restrictions relating to concentration in an industry or group
of industries.

 16. Comment: For the Shelton Emerging
                                         Markets Fund, please further tailor the derivatives risk disclosure to more specifically
                                         cover the types of derivatives used.

Response:
The following has been added as a second paragraph to the Fund’s derivatives risks disclosures:

The Fund may enter
into foreign currency transactions to attempt to “hedge” the currency risk associated with investing in foreign securities.
Although such transactions tend to minimize the risk of loss that would result from a decline in the value of the hedged currency,
they also may limit any potential gain that might result should the value of such currency increase. The forecasting of currency
market movement is extremely difficult, and whether any hedging strategy will be successful is highly uncertain.

 17. Comment: For the Shelton Emerging
                                         Markets Fund, please remove duplicative emerging markets risk disclosures.

Response:
Please see Response 8 above; the Trust believes that the summary disclosure provided in response to Item 4 of Form N-1A and the
additional detail provided in response to Item 9 of Form N-1A appropriately mesh to provide materially complete disclosure of
these risks.

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 18. Comment: For the Shelton Emerging
                                         Markets Fund, please relocate the disclosures relating to Portfolio Turnover to the investment
                                         strategies section unless it will be a principal risk if frequent trading is anticipated.
                                         Likewise, please relocate disclosure regarding Temporary Defensive Positions to the investment
                                         strategy section.

Response:
The disclosures for both Portfolio Turnover and Temporary Defensive Positions have been relocated to the Investment Objective
and Strategies section.

 19. Comment: For the Shelton Emerging
                                         Markets Fund, in the Fund Organization and Management section, please state the advisory
                                         fee as a percentage of NAV and disclose any applicable expense limit. Include disclosure
                                         that the basis for SCM Trust Board approval of the advisory contract may be found in
                                         the applicable shareholder report.

Response:
The following disclosure has been added as the third paragraph of the section:

The Fund pays Shelton Capital Management
an annual investment advisory fee equal to 1.00% of the Fund’s average daily net assets. Shelton Capital Management has
contractually agreed to reimburse expenses incurred by the Fund to the extent that total annual fund operating expenses (excluding
acquired fund fees and expenses, certain compliance costs, and extraordinary expenses such as litigation or merger and reorganization
expenses, for example) exceed 1.55% and 1.80% for Institutional Class and Investor class shares, respectively, until May 22, 2021.
This agreement may only be terminated with the approval of the SCM Trust Board. Shelton may be reimbursed for any foregone advisory
fees or unreimbursed expenses within three fiscal years following a particular reduction or expense, but only to the extent the
reimbursement does not cause the Fund to exceed applicable expense limits, and the effect of the reimbursement is measured after
all ordinary operating expenses are calculated. Any such reimbursement is subject to the review and approval of the SCM Trust
Board. A discussion regarding the basis for the Board of Trustee’s approval of the investment advisory contract of the Fund
will be available in the Fund’s semi-annual report to shareholders for the period ending June 30.

 20. Comment: For the Shelton Emerging
                                         Markets Fund and other Funds, consider revising the disclosure under the heading Procedures
                                         to Limit Short-Term Trading in Fund Shares to specifically disclose the number of purchases
                                         and sales of shares within a certain period that will result in action to limit short-term
                                         trading.

Response:
The Trust believes the current disclosure is an accurate disclosure of its policies, and provides adequate disclosure while not
providing a degree of specific information that could limit the Trust’s ability to protect other shareholders by taking
action as disclosed.

 21. Comment: For the Shelton Emerging
                                         Markets Funds and the other Funds, please add the missing 811 Investment Company Act
                                         registration number to the back cover of the prospectuses.

Response:
The registration number has been added.

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 22. Comment: For the Shelton Emerging
                                         Markets Fund, please disclose on page 2 of the SAI t