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SCHWARTZ INVESTMENT TRUST

April 21, 2020

FILED VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Schwartz Investment Trust (the “Trust”)

File Nos. 811-07148; 33-51626

Response to
Staff’s Comments on Post-Effective Amendment No. 43

Ladies and Gentlemen:

Ms. Lisa Larkin of the
Commission’s staff contacted us on March 26, 2020 to provide comments on Post-Effective Amendment No. 43 to the Trust’s
registration statement on Form N-1A for the purpose of registering a new series: the Ave Maria Focused Fund (the “Fund”).
The following are the comments provided by the staff and the Trust’s response to each:

PROSPECTUS

Risk/Return Summary: Annual Fund Operating Expense Table

1. The caption for the
fee waiver arrangement, “Less Management Fee Reductions” should be revised to conform to the language in Item 3(e)
of the N-1A instructions.

RESPONSE: The caption has been renamed “Fee
Waiver and/or Expense Reimbursement.”

2. The following revisions
should be made to footnote (2) to the table of Annual Fund Operating Expenses to conform to the language in Item 3(e) of the N-1A
instructions:

 (i) replace the word “incurred” to “waived or reimbursed,”

 (ii) replace the phrase “to exceed the 1.25% limitation” to “to exceed the net expense
ratio at the time such amount was waived or repaid.”

RESPONSE: The requested changes have been made.

Risk/Return Summary: Example

3. Confirm supplementally
that the costs of investing in the Fund (based upon the assumptions stated in the Example) during the one- and three- year periods
will be the same regardless of the time a shareholder elects to redeem his or her shares during those periods.

RESPONSE:	We confirm that the amount of
expenses set forth in the Example accurately reflects the net operating expenses of the Fund during the one- and three-year periods.
The contractual fee waiver arrangement by Schwartz Investment Counsel, Inc. (the “Adviser”) is in effect for a period
of three years from the date of the Fund’s May 1, 2020 prospectus.

Risk/Return Summary: What are the Fund’s Principal Investment
Strategies?

4. In the discussion of
the Fund’s policy to invest all of the Fund’s equity investments and at least 80% of the Fund’s net assets in
companies meeting the Fund’s religious criteria (i) include “the amount of borrowings for investment purposes”
in the definition of net assets; and (ii) include the description of the Fund’s moral investment policy in the 80% investment
policy.

RESPONSE: We have revised this sentence as
follows, Under normal circumstances, all of the Fund’s equity investments and at least 80% of the Fund’s net assets
(plus the amount of borrowings for investment purposes) will be invested in companies that are believed to offer products or services
or engage in practices that are not contrary to core values and teachings of the Roman Catholic Church.

5. State supplementally
if the Fund will continue to treat the 80% investment policy described above as fundamental.

RESPONSE: The Fund will
continue to treat the 80% investment policy described above as fundamental.

6. In the discussion of
the Fund’s foreign securities investments, please indicate the type of foreign securities in which the Fund may invest, i.e.,
debt securities, equity or both.

RESPONSE: The requested change has been made.

7. In the discussion of
the Fund’s investments in special situation companies, please indicate the type of special situation companies in which the
Fund may invest, i.e., debt securities, equity or both.

RESPONSE: The requested change has been made.

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8. State supplementally
the percentage of the Fund’s assets that may be invested in special situation companies.

RESPONSE: The Fund does not expect to invest
more than 30% of its net assets in “special situation companies” as that term is defined in the prospectus, but reserves
the right to go beyond the 30% limitation if there is a high availability of special situation companies that present attractive investment opportunities.

9. The discussion of the
Fund’s moral investment policy states that the Catholic Advisory Board is “guided by the magisterium of the Roman Catholic
Church.” Explain what is meant by that statement.

RESPONSE: We have added the following sentence,
“The magisterium of the Roman Catholic Church is the authority or office of the Roman Catholic Church to teach the authentic
interpretation of the Word of God, whether in its written form or in universal faith and moral practices.”

10. In the discussion of
the Catholic Advisory Board’s role in the Fund’s moral investment process, consider cross referencing to the “Catholic
Advisory Board” section that appears later in the prospectus.

RESPONSE: The requested change has been made.

11. The discussion of the
sell strategy of the Fund states that the Adviser may sell (but is not required to sell) a stock based upon the Catholic Advisory
Board’s determination that such company operates in a way that is inconsistent with the core values and teachings of the
Roman Catholic Church. Explain how this sentence is consistent with the Fund’s policy to invest at least 80% of its net assets
in companies meeting the Fund’s religious criteria.

RESPONSE: We have added the following sentence
to this section. “A stock will automatically be sold, if necessary, to ensure that the Fund meets its policy of investing
at least 80% of its net assets in morally responsible investments.”

12. The following sentence,
“The Adviser may sell (but is not required to sell) a stock based upon the Catholic Advisory Board’s determination
that such company operates in a way that is inconsistent with the core values and teachings of the Roman Catholic Church”
appears in both the third and the fourth paragraphs of this section. Consider deleting or revising one of these sentences.

RESPONSE: We have removed the sentence from
the fourth paragraph of this section.

13. Expand the discussion
of the role of the Catholic Advisory Board to include an explanation of how the Catholic Advisory Board makes its moral determinations,
how often these determinations are made, and how these determinations are communicated to the Adviser.

RESPONSE: We revised the “Catholic Advisory
Board” section as follows.

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The Catholic
Advisory Board consists of prominent lay members of the Roman Catholic Church and one or more Ecclesiastical Advisors, whose purpose
is to set the criteria for screening companies based upon the morally responsible investment practices of the Ave Maria Mutual
Funds. The screening criteria that is currently in place seeks to avoid investments in companies that are involved in the practice
of abortion, have policies that are judged to be antifamily, contribute funds to Planned Parenthood, or support embryonic stem
cell research. The Catholic Advisory Board meets with the Adviser twice a year, or more often if necessary, to review the criteria
that is utilized in the screening process and to determine if it is appropriate to maintain the existing criteria. The Catholic
Advisory Board may determine to make a change to the screening criteria, but does so infrequently. The criteria for screening companies
is based upon the teaching authority of the Roman Catholic Church that is vested in the Pope and exercised by a council of bishops
approved by the Pope. The role of the Ecclesiastical Advisor is to provide the Catholic Advisory Board with access to the council
of bishops.

The Catholic
Advisory Board acts in an advisory capacity only and has no discretionary authority to make investment decisions for the Fund.
The Catholic Advisory Board will make its best determination as to whether a particular screen is consistent with core values and
teachings of the Roman Catholic Church; however, the members of the Board do not represent the Roman Catholic Church and there
is no guarantee that the Catholic Advisory Board will be successful in its mission.

14. In the principal risks
section, add risk disclosures related to (i) preferred stocks, (ii) convertible stocks; (iii) special situation companies; and
(iv) micro-cap stocks.

RESPONSE: The following language has been added
to this section:

Preferred Stock Risks. Preferred stock
is subject to the risks of equity securities as well as risks associated with fixed income securities, such as interest rate risk.
Because a company will generally pay dividends on preferred stock only after the company makes required payments to creditors,
the value of a company’s preferred stock may react strongly to actual or perceived changes in the company’s financial
condition or outlook. Preferred stock may be less liquid than common stock and generally has limited or no voting rights. In addition,
preferred stock is subject to the risk that a company may defer or not pay dividends, may call or redeem its preferred stock, or
convert it to common stock.

Convertible Stock Risks. A convertible
security is a bond or preferred stock that can be exchanged or converted into a specific number of shares of the issuer’s
common stock. When the price of the underlying stock falls, the price of a convertible security tends to decline. Because a company
must generally pay interest on its nonconvertible secured debt before it can pay interest on its convertible securities, the credit
rating of a company’s convertible securities is generally lower than on its secured nonconvertible debt securities. A convertible
security may be “callable,” which means the issuer can redeem the security prior to its maturity.

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Special Situation Company Risks. Investing
in special situation companies carries an additional risk of loss if the expected development does not occur or produce the intended
results. The availability of special situation companies that present attractive investment opportunities may be sporadic, or rare
in certain instances, which may detract from the Fund’s ability to pursue its investment objectives.

The following sentence has been added to the
Market Capitalization Risk section:

Micro-cap companies may have limited product
lines, markets and access to financing, and may lack the management depth of larger companies.

15. The paragraph describing
the risks of foreign investments should be expanded to include the risks of investing in depository receipts.

RESPONSE: The following language has been added
to the foreign investment risk disclosures:

Depository receipts are subject to some of
the same risks as direct investment in foreign companies and certain additional risks. In a sponsored depository arrangement, the
foreign issuer assumes the obligation to pay some or all of the depository’s transaction fees. Under an unsponsored depository
arrangement, the foreign issuer assumes no obligation and the depository’s transaction fees are paid directly by the depository
holders. Because unsponsored depository arrangements are organized independently and without the cooperation of the issuer of the
underlying securities, available information concerning the foreign issuer may not be as current as for sponsored depositories
and voting rights with respect to the deposited securities are not passed through to the holders.

Risk/Return Summary: Additional Investment Information

16. Expand the Additional
Investment Information section to include a description of the Fund’s principal investment strategies and the principal
risks of investing in the Fund pursuant to Item 9(b) and Item 9(b)(1) of the Form N-1A instructions.

RESPONSE: We have copied the Principal Investment
Strategies and Principal Risk disclosures from the Summary Section and added it to the Additional Investment Information
section.

17. In the sentence, “Under
normal market conditions, the Fund will limit its investment in ETFs, debt securities (including junk bonds) and cash or cash equivalents
to no more than 30% of its net assets,” indicate how much of the 30% bucket may be invested in junk bonds. If the Fund is
permitted to invest up to 30% of its net assets in junk bonds, these investments should be disclosed in the principal strategy
section.

RESPONSE: We have added the following sentence:
“The Fund will not invest more than 15% of its net assets in junk bonds.”

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How to Purchase Shares

18. Expand the following
sentence, “The minimum investment requirements may also be waived for certain financial intermediaries and organizations
that have lower minimum investment amounts” to specify the type of financial intermediaries (either by listing the names
of the intermediaries or stating that they include omnibus accounts).

RESPPONSE: The sentence has been revised to
include omnibus accounts in the discussion of entities that may waive the Fund’s minimum investment requirements.

19. Consider adding a
sentence describing the risks of the corona virus.

RESPONSE: We have added the following disclosure
to General Market Risks in the Principal Risks section:

Natural or environmental disasters, such as
earthquakes, fires, floods, hurricanes and tsunamis, and widespread disease, including pandemics and epidemics, have been and can
be highly disruptive to the economies and the markets. For example, the outbreak of an infectious respiratory illness caused by
a novel coronavirus, known as COVID-19, has resulted in significant disruptions in global business activities and has adversely
affected the economies of many countries, including the U.S.

STATEMENT OF ADDITIONAL INFORMATION

Investment Policies and Risk Considerations

20. In the disclosure of
the risks of foreign securities, consider if the language describing the potential impact of Brexit needs to be updated.

RESPONSE: We have updated the language as follows:

The UK left the EU on January 31, 2020. Under
the UK-EU withdrawal agreement, a transition period will end on December 31, 2020 unless extended, during which time the UK will
be treated for most purposes as if it were still an EU member state. During this transition period, most EU laws will continue
to apply to the UK. There is still considerable uncertainty relating to the potential consequences for the exit and how new trade
agreements will be conducted, and whether the UK’s exit will increase the likelihood of other countries also departing the
EU.

Investment Limitations

21. The fundamental investment
limitation adopted by the Fund with regards to industry concentration should be revised to conform with Item 9(b)(1)4 and Item
16 (c)(1)(iv) of the Form N-1A instructions.

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RESPONSE: The fundamental investment limitation
adopted by the Fund with regards to industry concentration has been revised as follows:

The Fund will not:

Invest more than 25% of its net assets in a
particular industry or group of industries.

Trustees, Officers and Catholic Advisory
Board Members

22. In the table of Trustees
and Executive Officers, replace the comma after Timothy Schwartz’s biography with a period.

RESPONSE. The requested change has been made.

23. Describe
the role of the “Trustee Emeritus.”

RESPONSE: We have added the following footnote
to the table of Trustees and Executive Officers:

 *** Trustee Emeritus serve on the Board in an advisory capacity for a period of three years following
their retirement from the Board. Trustee Emeritus attend Board and Committee meetings, but have no voting authority.

24. In the discussion of
the role of the Catholic Advisory Board on page 20, explain the basis of the statement that the Adviser does not expect the Fund’s
moral investment policy to have a material effect on the Fund’s performance either positively or negatively, given that moral
investing is a fundamental part of the Fund’s investment strategy.

RESPONSE: We have removed this sentence.

25. Explain supplementally
why the Adviser believes that the Catholic Advisory Board is not required to register under Section 203(a) of the Investment Advisers
Act of 1940, as amended