SecProbe.io

CORRESP
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June 25, 2021

Via EDGAR

Alison T. White
 Senior Counsel
 Office of Disclosure and Review
 Division of Investment Management
 U.S. Securities and Exchange Commission
 100 F Street, N.E.
 Washington, DC  20549

 Re: Boston Trust Walden Funds: File Nos. 33-44964 and 811-06526

Dear Ms. White:

On May 4, 2021, Boston Trust Walden Funds (the
 “Trust”) filed Post-Effective Amendment No. 173 to its Registration Statement on Form N-1A (the “Amendment”).
On June 11, 2021, you provided oral and written comments. The following is a summary of our understanding of your comments and the Trust’s
responses. Where necessary, these responses will be incorporated into Post-Effective Amendment No. 174. Capitalized terms used herein
have the same meaning used in the Amendment.

 1. Comment: Items
# 4 and 9 of Form N-1A require registrants to disclose a fund's principal investment strategies, which, as noted in Instruction 2 to Item
9.b.(1) of Form N-1A, "depends on the strategy's anticipated importance in achieving the fund's investment objectives, and how the
strategy affects the Fund's potential risks and returns."  Several Funds’ disclosures indicate that, as part of the Fund’s
investment process, the adviser seeks to assess "the impact that ESG factors may have on revenues, expenses, assets, liabilities
and overall risks" and utilizes active ownership.

As written, it is unclear that the ESG
analysis is closely integrated into the investment decision making process to such an extent that it could be considered part of the Fund’s
principal strategies.  Please either (i) expand on the disclosure to address the specific E, S, and G factors considered - including
the types of data and analysis reviewed - and how the factors relate to buy/sell decisions or (ii) relocate the disclosure to a more appropriate
location.

With respect to (i) in the above paragraph,
to help us understand the Trust’s response and revised disclosure, please briefly, and at a high level, explain the adviser's actual
ESG analysis for a couple (2-3) of the more significant portfolio holdings for each Fund.

Michael.Wible@ThompsonHine.com Phone: 614.469.3297

Alison T. White

June 25, 2021

Page 2

Finally, if the Trust determines that
it is appropriate to discuss ESG investing in the principal investment strategies, please add corresponding principal risk disclosure
(as it has for the “Boston Trust Walden” Funds).

This Comment 1 applies to the Boston
Trust Asset Management Fund, Boston Trust Equity Fund, Boston Trust Midcap Fund and Boston Trust SMID Cap Fund.

Response:
The Trust believes it is appropriate to discuss ESG investing in the principal investment strategies section of the prospectus. Boston
Trust Walden Inc. (the “Adviser”) systemically integrates ESG factors into its investment decision-making process across
all strategies and funds. The Adviser defines ESG integration as the process of recognizing the financial materiality (or significance)
of environmental, social, and corporate governance factors. These factors include, but are not limited to, compliance with regulatory
requirements; the use of human, natural, and physical capital; and corporate governance structures and practices. The Adviser analyzes
these factors and other factors in identifying and investing in high quality enterprises with sustainable business models, strong financial
underpinnings, prudent management practices, and a governance structure that supports these objectives. Not all factors may be applicable
to all companies, nor may factor applicability be of equal importance across companies and industries. For example, a lawsuit pertaining
to an environmental hazard may or may not be found significant depending on the potential size of the exposure and the nature of the
company's business.

The Adviser’s ESG analysts work
simultaneously and collaboratively with the firm’s traditional securities analysts. Together they identify potential ESG risks
and opportunities considering regulatory compliance, sector and industry specific factors, the use of human, natural and physical capital
as well as corporate governance matters. The analysts determine whether these ESG factors could have a financially material impact on
revenue, expenses, assets, liabilities, and overall risk.

Consistent with the Adviser’s
investment process, the Item 4 disclosure for the Boston Trust Asset Management Fund, Boston Trust Equity Fund, Boston Trust Midcap
Fund and Boston Trust SMID Cap Fund (the “Boston Trust Funds”) states:

The Adviser evaluates financially material
environmental, social, and governance (ESG) factors as part of the investment decision-making process for the Fund. The

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June 25, 2021

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Adviser considers
financial materiality as it is understood in generally accepted accounting principles—information that would influence the judgment
of an informed investor. The Adviser assesses the impact that ESG factors may have on revenues, expenses, assets, liabilities, and overall
risk. In addition, the Adviser utilizes active ownership to encourage sustainable business policies and practices and greater ESG transparency.
Active ownership strategies include proxy voting, dialogue with company management, sponsorship of shareholder resolutions, and public
policy advocacy.

This
level of disclosure is appropriate for a fund summary and consistent with Form N-1A instructions. Additional information about the Adviser’s
ESG decision making process currently appears in the Item 9 disclosure on page 32 of the statutory prospectus under the caption ENVIRONMENTAL,
SOCIAL & GOVERNANCE (ESG) GUIDELINES. In response to the staff’s comment, the first paragraph of this disclosure
has been supplemented as follows to include additional information on the ESG factors considered by the Adviser:

The
Adviser evaluates financially material ESG factors as part of the investment decision-making process for all Funds. These factors include,
but are not limited to, compliance with regulatory requirements; the use of human, natural, and physical capital; and corporate governance
structures and practices. The Adviser considers financial materiality as it is understood in generally accepted accounting principles—information
that would influence the judgment of an informed investor. The Adviser assesses the impact that ESG factors may have on revenues, expenses,
assets, liabilities, and overall risk. Not all factors may be applicable to all companies, nor may factor applicability be of
equal importance across companies and industries.  For example, a lawsuit pertaining to an environmental hazard may or may not be
found significant depending upon the potential size of the exposure and the nature of the company’s business. The Boston Trust
Walden Balanced Fund, the Boston Trust Walden Equity Fund, the Boston Trust Walden Midcap Fund, the Boston Trust Walden SMID Cap Fund,
the Boston Trust Walden Small Cap Fund, and the Boston Trust Walden International Equity Fund are subject to further ESG screening
criteria, in which the Adviser excludes companies with significant exposure in specific products or services, considering their revenue
dependence (share of  revenue derived from undesirable products/services), market share (if a company is a market leader in an undesirable
product despite relatively small share of company revenue), and severity (how proximate the product or service is to the undesirable
product—e.g., minor electronic input to a weapon system). “Significant exposure” is a subjective determination. These

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June 25, 2021

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restrictions preclude these Funds from purchasing companies with significant involvement in:

You requested that the Trust briefly,
and at a high level, explain the Adviser's actual ESG analysis for a couple (2-3) of the more significant portfolio holdings for the Boston
Trust Funds. Below are examples of the Adviser’s analysis. Please note that the Boston Trust Funds’ holding overlap to some
extent; for efficiency, the Trust selected securities held across multiple Funds.

Example
1 (held by Boston Trust Asset Management Fund, Boston Trust Walden Balanced Fund, Boston Trust Equity Fund, Boston Trust
Walden Equity Fund, Boston Trust Midcap Fund, Boston Trust Walden Midcap Fund, Boston Trust SMID Cap Fund, Boston Trust Walden SMID Cap
Fund and Boston Trust Walden Small Cap Fund):	Donaldson Company, Inc. (ticker DCI) manufactures and sells filtration systems
for air and liquids for a wide variety of applications, as well as replacement parts for such systems, globally. The filters enhance customer
equipment efficiency and reduce air pollution. The company benefits from potential new market opportunities and increased demand for filtration
systems as stronger global regulations to protect the environment are enacted. Meeting this demand could increase revenue and profitability.
Company management has been constructively engaged with shareholders on a variety of topics including greenhouse gas targets for its operations
for a number of years. The Adviser believes such targets could enable the company to reduce expenses through more efficient operations,
potentially increasing overall profitability.

Example
2 (held by Boston Trust Asset Management Fund, Boston Trust Walden Balanced Fund, Boston Trust Equity Fund, Boston Trust
Walden Equity Fund, Boston Trust Midcap Fund, and Boston Trust Walden Midcap Fund):	 Hubbell Incorporated (ticker
HUBB) designs, manufactures, and sells electrical products. The company offers smart metering technologies that helps reduce energy and
water use, mitigate climate change, protect the environment, and save money. The Adviser determined that such products were likely to
increase revenue and assets.

Example
3 (held by Boston Trust Asset Management Fund, Boston Trust Walden Balanced Fund, Boston Trust Equity Fund, Boston Trust
Walden Equity Fund, Boston Trust Midcap Fund, and Boston Trust Walden Midcap Fund):	 Aptar Group (ticker ATR) is
a global manufacturer of consumer dispensing packaging and drug delivery devices. The company joined the CE100 Circular Economy Network,
working with customers to increase recyclability of products and incorporate higher quantities of post-consumer recycled resin

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June 25, 2021

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into products.
The Adviser determined that such actions will increase revenue and reduce risk.

Example
4 (held by Boston Trust SMID Cap Fund, Boston Trust Walden SMID Cap Fund, and Boston Trust Walden Small Cap Fund):
Lincoln Electric Holdings, Inc. (ticker LECO) manufactures welding, cutting and brazing products including consumables, equipment, automation
technology, cutting fume controls and accessories. LECO commands a leading global position in the brazing and soldering alloys market
and serves diversified end markets including general manufacturing, energy and process industries, auto, heavy industries and construction.
The efficiency of LECO’s welding, cutting and brazing products reduces consumption of energy and materials, is a key competitive
advantage, and selling point for its products. The company has set greenhouse gas reduction goals as well as energy efficiency goals,
resulting in more efficient operations and potentially leading to lower operating expenses. The Adviser believes the industry leading
efficiency of the company’s products combined with their leadership in setting goals for greenhouse gas reduction and energy efficiency
will continue to provide value for shareholders and reduce risks.

Example
5 (held by Boston Trust SMID Cap Fund, Boston Trust Walden SMID Cap Fund, and Boston Trust Walden Small Cap
Fund): Jones Lang LaSalle. The Case Study published by the Adviser and provided hereto as Attachment A details the
approach to ESG integration and the application of the approach to Jones Lang LaSalle.

The Adviser believes that ESG integration
is a critical tool in the assessment and management of risk at both a company and a portfolio level. The example below further illustrates
the Adviser’s approach to ESG integration.

Example
of Failed Security due to ESG Integration: Getty Realty Corp (ticker GTY) is a real estate investment trust. The company specializes
in the ownership, leasing, and financing of convenience stores and gasoline station properties. When researching the company, the analyst
discovered an off-balance sheet liability related to environmental remediation that was significant relative to the size of the company.
Additionally, the company was involved in several lawsuits related to environmental remediation. The Adviser’s Securities Research
Committee determined that such exposures could negatively impact the balance sheet (increase liabilities) and income statement (higher
expenses) and that the overall risk for the company was higher than comparable REITs. The stock was not added to the Approved List.

Finally,
you state that if the Trust determines that it is appropriate to discuss ESG investing in the principal investment strategies section
of the prospectus, ESG Screening Criteria Risk should be added to the Principal Investment Risk section of the summary prospectuses
for the

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Boston Trust Funds. The ESG Screening Criteria Risk describes the risk arising from the application of ESG screening criteria
to a fund’s investment options. The ESG screening criteria precludes the Boston Trust Walden Balanced Fund, Boston Trust Walden
Equity Fund, Boston Trust Walden Midcap Fund, Boston Trust Walden SMID Cap Fund, Boston Trust Walden Small Cap Fund, and Boston Trust
Walden International Equity Fund (the “Boston Trust Walden Funds”) from investing in companies with significant exposure in
specific products or services. As disclosed on page 32 of the prospectus, the ESG screening criteria applies only to the Boston Trust
Walden Funds. The Boston Trust Funds are not subject to ESG screening. As a result, the ESG screening criteria risk is inapplicable to
the Boston Trust Funds. To clarify this point, the word “further” has been added to the first paragraph under the caption
ENVIRONMENTAL, SOCIAL & GOVERNANCE (ESG) GUIDELINES as shown above. Because
the ESG screens are not applicable to the Boston Trust Funds, the Trust respectfully declines to make the requested change.

 2. Comment: In the preamble to the Example for Boston Trust Midcap Fund, if true, please indicate
that the Example reflects the fee waiver and expense reimbursement for the duration of the waiver/reimbursement period only.

Response:
The Trust has amended its disclosures on page 6 of the Prospectus to state the following:

Example:
The Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual
funds. The Example assumes a $10,000 investment, a 5% annual return, redemption at the end of each period and that the Fund’s operating
expenses remain the same. The Example reflects the fee waiver and expense reimbursement for the duration of the waiver/reimbursement
period only.  Although your actual costs may be higher or lower, based on these assumptions your costs would be:

 3. Comment: Please explain supplementally whether the Adviser has engaged in any of the active ownership
strategies listed in the Fund’s principal investment strategy disclosures. To the extent such activities are public, please provide
examples of such active ownership in correspondence so that the SEC has additional context for the Funds’ disclosure. Depending
on the nature of the examples, consider whether updated or revised disclosures are appropriate.

Response:
As disclosed in the Funds’ prospectus, the Adviser utilizes active ownership strategies to encourage sustainable business policies
and practices and greater ESG transparency.  The Adviser engages in the following strategies through an Active Ownership

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June 25, 2021

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Committee, a s