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SEC Response Letter

 June 13, 2023

VIA EDGAR AND EMAIL

 U.S. Securities & Exchange
Commission

 Division of Investment Management

 Office of
Disclosure Review & Accounting

 100 F Street, NE

Washington, D. C. 20549

 Attention: Mr. Tony Burak

(202) 551-6750

burakt@sec.gov

Re:
 The Advisors’ Inner Circle Fund (File No. 811-06400);

 The Advisors’ Inner Circle Fund II (File No. 811-07102); &

 The Advisors’ Inner Circle Fund III (File No. 811-22920)

 Mr. Burak:

 This letter responds to comments of
the Securities & Exchange Commission (the “SEC”) Staff given by you to Philip Dick, Director of Fund Administration at SEI Investments Global Funds Services (“SEI”), the Administrator to each of (a) The
Advisors’ Inner Circle Fund (“AIC I”) (File No. 811-06400), (b) The Advisors’ Inner Circle Fund II (“AIC II”) (File
No. 811-07102), and (c) The Advisors’ Inner Circle Fund III (“AIC III”) (File No. 811-22920) (AIC I, AIC II, and AIC III hereinafter
referred to collectively as the “Trusts”), in regard to certain series funds of the Trusts (each a “Fund,” and, collectively, the “Funds”), in a telephone conversation on May 8, 2023. SEI provides the Trusts and
the Funds with administrative and accounting services, officers, and other personnel, and submits these responses on behalf of the Trusts and the Funds.

The SEC Staff comments provided relate to:

a.
 the Trusts’ annual reports as of March 31, 2022, July 31, 2022, September 30, 2022,
October 31, 2022, December 31, 2022, as filed on Form N-CSR (the “Form N-CSR Annual Reports”);

b.
 the Trusts’ annual reports as of December 31, 2022, as filed on Form
N-CEN (the “Form N-CEN Annual Reports”) (said Form N-CSR Annual Reports and Form
N-CEN Annual Reports hereinafter referred to collectively as the “Reports”);

The Advisors’ Inner Circle Fund (File No. 811-06400);

June 13, 2023

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

c.
 the corresponding Prospectuses of the certain Funds, as included in the Trusts’ Registration Statements on
Form N-1A; and

d.
 related filings of the Trusts.

The SEC Staff comments provided specifically relate to the Funds set forth immediately below, but these comments, to the extent applicable, should be applied
to all Funds in the Trusts going forward. As noted above, each of these Funds is a series of a Trust.

The Advisors’ Inner Circle Fund I

Cambiar International Small Cap Fund

The Advisors’ Inner Circle Fund I

Cambiar Small Cap Fund

The Advisors’ Inner Circle Fund I

Cambiar Aggressive Value Fund

The Advisors’ Inner Circle Fund I

Cambiar International Equity Fund

The Advisors’ Inner Circle Fund I

Cambiar Opportunity Fund

The Advisors’ Inner Circle Fund I

Cambiar SMID Fund

The Advisors’ Inner Circle Fund I

Rice Hall James Small Cap Portfolio

The Advisors’ Inner Circle Fund I

Rice Hall James Micro Cap Portfolio

The Advisors’ Inner Circle Fund I

LSV Conservative Value Equity Fund

The Advisors’ Inner Circle Fund I

LSV Global Managed Volatility Fund

The Advisors’ Inner Circle Fund I

LSV Global Value Fund

The Advisors’ Inner Circle Fund I

LSV U.S. Managed Volatility Fund

The Advisors’ Inner Circle Fund I

LSV Value Equity Fund

The Advisors’ Inner Circle Fund I

LSV Emerging Markets Equity Fund

The Advisors’ Inner Circle Fund I

LSV Small Cap Value Fund

The Advisors’ Inner Circle Fund I

Edgewood Growth Fund

The Advisors’ Inner Circle Fund I

Acadian Emerging Markets Portfolio

The Advisors’ Inner Circle Fund I

Hamlin High Dividend Equity Fund

The Advisors’ Inner Circle Fund I

CIBC Atlas Disciplined Equity Fund

The Advisors’ Inner Circle Fund I

CIBC Atlas Equity Income Fund

The Advisors’ Inner Circle Fund I

CIBC Atlas Mid Cap Equity Fund

The Advisors’ Inner Circle Fund I

CIBC Atlas All Cap Growth Fund

The Advisors’ Inner Circle Fund I

CIBC Atlas Income Opportunities Fund

The Advisors’ Inner Circle Fund I

CIBC Atlas International Growth Fund

The Advisors’ Inner Circle Fund I

Sands Capital Global Growth Fund

The Advisors’ Inner Circle Fund I

Haverford Quality Growth Stock Fund

The Advisors’ Inner Circle Fund I

Sarofim Equity Fund

The Advisors’ Inner Circle Fund I

Loomis Sayles Full Discretion Institutional Securitized Fund

The Advisors’ Inner Circle Fund II

Champlain Mid Cap Fund

The Advisors’ Inner Circle Fund II

Champlain Small Company Fund

The Advisors’ Inner Circle Fund II

Reaves Infrastructure Fund

The Advisors’ Inner Circle Fund II

Cardinal Small Cap Value Fund

The Advisors’ Inner Circle Fund III

Mesirow Small Company Fund (formerly Mesirow Small Company Sustainability Fund)

The Advisors’ Inner Circle Fund III

Mesirow High Yield Fund

The Advisors’ Inner Circle Fund III

Mesirow Enhanced Core Plus Fund

 Page 2 of 13

©2023 SEI

The Advisors’ Inner Circle Fund (File No. 811-06400);

June 13, 2023

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

The Advisors’ Inner Circle Fund III

Aperture Endeavour Equity Fund

The Advisors’ Inner Circle Fund III

Aperture New World Opportunities Fund

The Advisors’ Inner Circle Fund III

Aperture International Equity Fund

The Advisors’ Inner Circle Fund III

Aperture Discover Equity Fund

The Advisors’ Inner Circle Fund III

PineBridge Dynamic Asset Allocation Fund

The Advisors’ Inner Circle Fund III

Penn Mutual AM 1847 Income Fund

The Advisors’ Inner Circle Fund III

Penn Mutual AM Strategic Income Fund

The Advisors’ Inner Circle Fund III

Nicholas Partners Small Cap Growth Fund

The Advisors’ Inner Circle Fund III

Ninety One Global Franchise Fund

The Advisors’ Inner Circle Fund III

Ninety One International Franchise Fund

The Advisors’ Inner Circle Fund III

Ninety One Global Environment Fund

The Advisors’ Inner Circle Fund III

Ninety One Emerging Markets Equity Fund

The Advisors’ Inner Circle Fund III

GQG Partners Global Quality Equity Fund

The Advisors’ Inner Circle Fund III

GQG Partners US Quality Dividend Income Fund

The Advisors’ Inner Circle Fund III

GQG Partners US Select Quality Equity Fund

The Advisors’ Inner Circle Fund III

GQG Partners Emerging Markets Equity Fund

The Advisors’ Inner Circle Fund III

GQG Partners International Quality Dividend Income Fund

The Advisors’ Inner Circle Fund III

GQG Partners Global Quality Dividend Income Fund

The Advisors’ Inner Circle Fund III

MetLife Core Plus Fund

The Advisors’ Inner Circle Fund III

KBI Global Investors Aquarius Fund

The Advisors’ Inner Circle Fund III

Redwheel Global Emerging Equity Fund

 We have reproduced the substance of your comments below, followed by the Trusts’ corresponding responses.

SEC Comment 1:

 The Annual Report disclosure
and the Prospectus disclosure regarding the period during which a Redemption Fee will be charged to Fund shareholders is not consistent in regard to the following Funds:

•

 The N-CSR filing for the Acadian Emerging Markets Portfolio shows the
fund may charge a redemption fee on shares held less than 90 days whereas the Prospectus shows the period as less than 30 days.

•

 The N-CSR filing for the Cambiar International Small Cap Fund shows
the fund may charge a redemption fee on shares held less than 90 days whereas the Prospectus shows the period as less than 180 days.

•

 The N-CSR filing for the Cambiar Opportunity Fund shows the fund may
charge a redemption fee on shares held less than 90 days whereas the Prospectus does not disclose the fund having a redemption fee.

 Page 3 of 13

©2023 SEI

The Advisors’ Inner Circle Fund (File No. 811-06400);

June 13, 2023

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

 Please confirm the time period and correct going forward.

Trust Response to Comment 1:

With regard to the Acadian Emerging Markets Portfolio, it is confirmed that the fund may charge a redemption fee on shares held less than 30
days. The Registrant will correct the N-CSR on a going forward basis.

 With regard to the
Cambiar International Small Cap Fund, it is confirmed that the fund may pay a redemption fee on shares held less than 180 days. The Registrant will correct the N-CSR on a going forward basis.

With regard to the Cambiar Opportunity Fund, it is confirmed that the fund does not have a redemption fee. The Registrant will correct the N-CSR on a going forward basis.

*        *        *
 *        *

 SEC Comment 2:

Item B.22 to the Annual Report on Form N-CEN requires a Registrant to identify whether, during the reporting
period, there were any payments made to shareholders or whether shareholder accounts were reprocessed as a result of an error in calculating the registrant’s net asset value (“NAV”) (or NAV per share). The response to Item B.22 in the
December Form N-CEN Annual Report for the Aperture Discover Equity Fund indicates that payments were made to the Fund’s shareholders or that Fund shareholder accounts were reprocessed as a result of an
error in calculating the Funds NAV (or NAV per share).

 Please explain: (i) the circumstances related to this NAV calculation error;
(ii) whether any internal control weaknesses were identified; and (iii) if any internal control weaknesses were identified, what actions, if any, have been taken by the Fund and the Fund’s manager to remedy these weaknesses.

Trust Response to Comment 2:

On March 7, 2022, SEI’s trade team incorrectly processed a sale of a Morgan Stanley Total Return Swap in the Aperture Discover
Equity Fund (the “Fund”). The incorrect transaction converted the swap’s unrealized gain to realized gain and removed the swap from the Fund’s Schedule of Investments. The incorrect transaction resulted in a break in our daily
cash and asset reconciliation. During the course of the period from March 7th through March 16th, SEI’s Fund Accounting team worked with the counterparty and custodian to understand why the breaks on the reconciliation occurred. As the position
was no longer in the Fund’s holdings, SEI Fund Accounting was not pricing the swap on a daily basis, resulting in an error equal to the swap’s daily change in valuation from March 7th through March 16th. On March 17th, it was determined by
Fund Accounting that the initial sale should not have been processed. At that time, the Fund Accounting team attempted to reverse the sale which took place on March 6th. This reversal was performed incorrectly and was subsequently corrected on March
18th.

 Page 4 of 13

©2023 SEI

The Advisors’ Inner Circle Fund (File No. 811-06400);

June 13, 2023

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

Management does not believe control weaknesses exist as the complimentary controls in place at the time of the error identified the initial incorrect booking of the trade. Management has
reinforced the Fund’s policies and procedures to the members of the Trade Team, Recon Team and Fund Accounting team to ensure more appropriate and timely communication when potential errors are identified.

*        *        *
 *        *

 SEC Comment 3:

Since the Fund’s commencement of operations on November 14, 2017, the Ninety One Global Franchise Fund’s Prospectus, under “Principal
Investment Strategies,” has disclosed that “under normal circumstances,” the Fund “invests at least 40% of its total assets in securities of non-U.S. companies.” This Prospectus
disclosure currently specifically provides that:

 Under normal circumstances, the Fund invests in at least three countries,
including the U.S., and invests at least 40% of its total assets in securities of non-U.S. companies. The Fund considers a company to be a non-U.S. company if:
(i) at least 50% of the company’s assets are located outside of the U.S.; (ii) at least 50% of the company’s revenue is generated outside of the U.S.; (iii) the company is organized or maintains its principal place of business outside
of the U.S.; or (iv) the company’s securities are traded principally outside of the U.S.

 For the past three years, however, the
Fund’s Schedule of Investments included in the Fund’s Annual Reports and Semi-Annual Report have indicated that the Fund has invested only between approximately 20% and 32% of the Fund’s total assets in securities of non-U.S. companies. For example, the Fund’s Schedule of Investments: (i) included in the Fund’s October 31, 2022 Annual Report appears to indicate that the Fund had invested only 27.4% of the
Fund’s total assets in securities of non-U.S. companies; and (ii) included in the Fund’s April 30, 2022 Semi-Annual Report appears to indicate that the Fund had invested only 31.7% of the
Fund’s total assets in securities of non-U.S. companies.

 Please explain how the Ninety One Global
Franchise Fund is investing in accordance with the Fund’s Prospectus disclosure.

 Trust Response to Comment 3:

The Registrant confirms that the Ninety One Global Franchise Fund (the “Fund”) has invested at least 40% of the Fund’s total
assets in securities of “non-U.S. companies” since the Fund’s inception, as disclosed in the Fund’s Prospectus and consistent with the Fund’s principal investment strategy. The
Registrant believes that purported deficiency in assets in securities by non-U.S. companies may be due to a failure to count among the “non-U.S. companies”
certain issuers of United States Common Stock.

 Page 5 of 13

©2023 SEI

The Advisors’ Inner Circle Fund (File No. 811-06400);

June 13, 2023

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

Going forward, we will indicate via an appropriate footnote on the Fund’s Schedule of Investments which issuers listed under “United States Common Stock” are considered to be “non-U.S. companies” for purposes of the Fund’s principal investment strategies. The footnote would incorporate the Fund Prospectus’ definition of the term
“non-U.S. companies.”

*        *        *
 *        *

 SEC Comment 4:

In the Semi and Annual Shareholder Report for the Penn Mutual AM Strategic Income Fund and the Penn Mutual AM 1847 Income Fund, the disclosure related to
the voting of proxies at the bottom of the page containing the Table of Contents erroneously refers to information during the most recent year “ended December 31.” Per the requirement under N1-A,
this disclosure should refer to the most recent year ended “June 30,” consistent with the annual period covered by the Form N-PX filing of the Fund. Please correct going forward.

Trust Response to Comment 4:

Acknowledged. The Registrant will update the disclosure for the Semi and Annual Reports for the Penn Mutual AM Strategic Income Fund and the
Penn Mutual AM 1847 Income Fund to correctly reflect the ended June 30 on a going forward basis.

*        *        *
 *        *

 SEC Comment 5:

The Annual and Semi-Annual Shareholder Reports for each of the Aperture Endeavour Equity Fund, the Aperture New World Opportunities Fund, the Aperture
International Equity Fund, and the Aperture Discover Equity Fund (collectively, the “Aperture Funds”), require a correction to a reference in the Statement of Operations. Specifically, the “Shareholder Servicing Fee” line item of
the Statement of Operations includes a parenthetical reference to the Class A shares only, however, the Aperture Funds’ Class X shares are also subject to Shareholder Servicing Fees. Please correct parenthetical reference going
forward.

 Trust Response to Comment 5:

Acknowledged. The Registrant will update the line item in the Statement of Operations of the Semi and Annual Shareholder Reports on a going
forward basis to reference the Aperture Funds’ Class X shares as being subject to a shareholder servicing fee. Note that the Aperture Funds do not have Class A Shares, and only the Class X Shares are subject to a shareholder
servicing fee.

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