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          August 17, 2023

          ATTORNEYS AT LAW

          777 EAST WISCONSIN AVENUE

          MILWAUKEE, WI  53202-5306

          414.271.2400 TEL

          414.297.4900 FAX

          www.foley.com

          WRITER’S DIRECT LINE

          414.297.5596

          pfetzer@foley.com EMAIL

          CLIENT/MATTER NUMBER

          082961-0150

  Via EDGAR System

          Ms. Rebecca Ament Marquigny

          Ms. Christina DiAngelo Fettig

          U.S. Securities and Exchange Commission

          Division of Investment Management

          Washington, D.C.  20549

   Re: Hennessy Funds Trust (File Nos. 811-07168 and 033-52154)

         Registration Statement on Form N-14 (No. 333-272430), Filed June 5, 2023

  Dear Ms. Marquigny and Ms. Fettig:

  Our client, Hennessy Funds Trust (the “Company”), filed the above referenced Registration Statement on Form N-14 on June 5, 2023 (the “Filing”).  The
    Filing relates to a special meeting of shareholders of the CCM Core Impact Equity Fund and the CCM Small/Mid-Cap Impact Value Fund (each, a “Target Fund” and together, the “Target Funds”), each a series of Quaker Investment Trust, a
    Delaware statutory trust.  The prior letter to you, dated August 4, 2023 (the “Prior Letter”), provided details on the meeting.  Capitalized terms used herein and not otherwise defined shall have the meanings given to them in the Prior Letter or
    the Filing.

  On behalf of the Company, set forth below are the Company’s responses to oral comments of the Staff of the Securities and Exchange Commission (the “Staff”)
    regarding the Filing.  The numbered items set forth below briefly express (in bold italics) the significant comments of the Staff, and following such comments are the Company’s responses (in regular type). The attached redlined Proxy
    Statement/Prospectus reflects responses to all of the comments of the Staff and additional changes made in connection with said comments (the “Redlined Document”).

  The Company will file a pre-effective amendment to revise the Filing in response to the Staff’s comments and to provide any outstanding information (all outstanding
      information is contained in the Redlined Document). The Company will then file a request for the filing to go effective, followed by a filing of the definitive Proxy Statement and Prospectus, along with the Statement of Additional Information, under
      Rule 497 of the Securities Act of 1933.  We would like to be effective on or by August 25, 2023.

  1. Please enhance the disclosure regarding the impact of holding shares through a retirement plan that cannot hold ETF shares.  Please confirm that the Target Funds do not have variable
      annuity accounts invested in the Funds, or address what happens when a variable annuity account cannot hold ETF shares.

  Response:  Please find the revised language below and in the Redlined Document.  We confirm that the Target Funds do not have variable annuity accounts
    invested in the Funds.

      A. Revised Disclosure Question 7:

  Upon completion of the Reorganization, you will own shares of the Acquiring Fund having an aggregate net asset value (“NAV”) equal to the aggregate NAV of
    the shares of the Target Fund you owned immediately prior to the Reorganizations, if you hold your Target Fund shares in an
        account that is permitted to hold Acquiring Fund shares, as described below. Because shares of the Acquiring Fund are not issued in fractional shares, shareholders will receive cash in lieu of fractional shares of the Acquiring Fund.
    The payment of cash for fractional shares iswill be a taxable event subject tofor U.S. federal income tax purposes, provided that non-U.S. or tax-exempt shareholders

    or those who hold their shares in retirement accounts generally will not be subject to U.S. federal income tax foron such payments.

  As noted above, if Target Fund shareholders hold shares in a brokerage
      account that permits them to purchase securities traded in the stock market, such as ETFs or other types of stocks, then those shareholders will be eligible to receive shares of the Acquiring Fund in the Reorganization, and no further action is
      required. That said, the following account types generally cannot hold shares of ETFs:

      •  Non-Accommodating Brokerage Accounts. A brokerage account with a financial intermediary that only allows you to hold shares of mutual funds.

      •  Retirement Accounts Held with Financial Intermediary. An individual retirement account (“IRA”) or group retirement plan whose plan sponsor does not have the ability to hold shares of ETFs
          on its platform.

      •  Directly Held Retirement and Qualified Accounts. Shares held directly with the Target Funds in a retirement account, such as an IRA, or Coverdell account (a “Directly Held Qualified
          Account”).

      •  Direct Accounts. Shares of the Target Funds held in an account directly with the Target Funds at their transfer agent
            (i.e., not held at the plan level or as an omnibus position) (“Direct Account”).

  With regard to the account types listed above, in order to receive shares
      of the Acquiring Fund as part of the Reorganizations, shareholders of the Target Funds should take the following actions:

  Non-Accommodating Brokerage Accounts. If you hold your shares of the Target Funds in a brokerage account with a financial intermediary that only allows you to hold shares of mutual funds in the account, you
        will need to contact your financial intermediary to set up a brokerage account that permits investments in ETF shares. If such a change is not made before the Reorganizations, you will not receive shares of the Acquiring Fund as part of the
        Reorganizations. Instead, your investment will be liquidated and you will receive cash equal in value to the NAV of your Target Fund shares, which generally will be a taxable event for U.S. federal income tax purposes.

  Retirement Accounts Held with Financial Intermediary. If you hold your shares of the Target Funds through an IRA or group retirement plan whose plan sponsor does not have the ability to hold shares of ETFs on its platform,
        you need to transfer your shares to a brokerage account that permits investments in ETF shares prior to the Reorganizations or, your financial intermediary may transfer your shares to a brokerage account that permits investments in ETF shares prior
        to the Reorganizations. If such a change is not made before the Reorganizations, you will not receive shares of the Acquiring Fund as part of the Reorganizations. Instead, your investment will be liquidated and you will receive cash equal in value
        to the NAV of your Target Fund shares.

  Directly Held Retirement and Qualified Accounts. If you own Target Fund shares directly

          with the Target Funds in a retirement account, such as an IRA, or Directly Held Qualified Account, you need to (i) transfer your Target Fund
        shares to a brokerage account that permits investments in ETF shares and be established as a Qualified Account, as applicable, prior to the Reorganizations, or (ii) provide instructions for the exchange or reinvestment of Target Fund shares into a
        brokerage account that permits investments in ETF and be established as a Qualified Account, as applicable, prior to the Reorganizations. If such a change is not made before the Reorganizations, you will not receive shares of the Acquiring Fund as
        part of the Reorganizations. Instead, your investment will be liquidated and you will receive cash equal in value to the NAV of your Target Fund shares.

  Direct Accounts. If you hold your Target

        Fund shares are held outside ofshares of the Target Funds in a Direct Account, you should transfer your shares of the Target Funds to a
    brokerage account or are held in an account that cannot accept Acquiring Fund shares at the time ofthat permits investments in ETF shares prior to the Reorganizations. If such a change is not made before the Reorganization, Acquiring Fund shares received in the ReorganizationReorganizations will
    be held by athe Acquiring Fund’s stock transfer agent, U.S. Bancorp Fund
    Services, LLC, d/b/a U.S. Bank Global Fund Services (“. If Acquiring Fund Services”), untilshares are not transferred into a brokerage account is

        identified into which Fund Services can transfer the shares.that permits investments in ETF shares within at least one year of the date of the
        Reorganizations, the Acquiring Fund shares may be converted to cash and the cash proceeds sent to the accountholder of record (subject to applicable federal or state laws concerning unclaimed property). The conversion of Acquiring Funds shares to
        cash may be subject to fees and expenses and generally will be a taxable event for U.S. federal income tax purposes.

  If you hold your shares of the Target Funds through an account with a
      financial intermediary that is not able to hold shares of the Acquiring Fund, like many group retirement plans, your financial intermediary may transfer your investment in the Target Funds to a different investment option prior to the Reorganization.
      Please consult with your financial intermediary for more information on the impact that the Reorganizations will have on you and your investments.

  In some cases, the liquidation of a shareholder’s investment and return of cash, or the transfer of a
      shareholder’s investment, may be subject to fees and expenses and may also be subject to U.S. federal income taxation. It may take time for a shareholder to receive the cash. Shareholders should consult with their financial intermediary or tax and
      financial advisors for more information on the impact that the Reorganizations will have on them and their investments.

  If you are unsure about the ability of your account to
        accept shares of the Acquiring Fund, please call (888) 272-0007 (toll-free) or contact your financial intermediary. We will continue to contact you to assist you in transferring your shares into a brokerage account that is permitted to hold ETF shares.

  If a shareholder does not wish to exchange their Target Funds shares for Acquiring Fund shares, the shareholder must liquidate their Target Fund shares prior to
    consummation of the Reorganizations. Shareholders who hold their shares in retirement accounts generally will not be subject to state or U.S.
    federal income taxestaxation if they liquidate
    their holdings prior to the Reorganizations and do not withdraw such proceeds from their retirement accounts.  If a shareholder chooses to liquidate their Target Fund shares instead of exchanging such Target Fund shares for Acquiring Fund shares, it is
    recommended that the shareholder consult with their tax advisor.

      B. Revised Disclosure Question 11:

  Answer:  Each Reorganization is expected to qualify as a “reorganization” for U.S. federal income tax purposes. Accordingly, it is expected that Target Fund
    shareholders who receive shares of the Acquiring Fund in the Reorganizations will not recognize gain or loss as a direct result of the Reorganizations except with respect to cash received in lieu of fractional shares of the Acquiring Fund. Please refer
    to the enclosed Proxy Statement/Prospectus for a detailed explanation of the Reorganizations.

  You may experience tax consequences if your investment is liquidated and the
        cash value of your Target Fund Shares is returned to you or if your shares of the Target Funds are transferred by your financial intermediary to a different investment option because you did not hold your shares of the Acquired Fund through a brokerage
        account that can accept shares of the Acquiring Fund. Different tax considerations apply to you if you hold your shares of the Target Funds through an individual retirement account or Coverdell account.

  The information about tax consequences in this document relates to the federal income tax
      consequences of the Reorganization only. Shareholders should consult their tax advisors about possible federal, state and local tax consequences of the Reorganization.

      C. Revised Disclosure Important Notice About Your Account Holding Target Fund Shares:

  Q:         What types of accounts cannot receive shares of the Acquiring Fund as part of the Reorganizations?

  A:         The following account types generally cannot hold shares of ETFs:

      •  Non-Accommodating Brokerage Accounts. A brokerage account with a financial intermediary that only allows you to hold shares of mutual funds.

      •  Retirement Accounts Held with Financial Intermediary. An individual retirement account (“IRA”) or group retirement plan whose plan sponsor does not have the
        ability to hold shares of ETFs on its platform.

      •  Directly Held Retirement and Qualified Accounts. Shares held directly with the Target Funds in a retirement account, such as an IRA, or Coverdell account (a
        “Directly Held Qualified Account”).

      •  Direct Accounts. Shares of the Target Funds held in an account directly with the Target Funds at their transfer agent (i.e., not held at the plan
        level or as an omnibus position) (“Direct Account”).

  If you are unsure about the ability of your account to accept shares of the Acquiring Fund, please call (888) 272-0007 (toll-free) or contact
    your financial intermediary.

  Q:         How do I transfer my Target Fund shares from a Directly
      Held Qualified Account to a brokerage account that will accept Acquiring Fund shares?

  A:         Transferring your Target Fund shares from a Directly Held Qualified Account to a brokerage account that can accept shares of the Acquiring Fund should be a simple process. If you have a
        brokerage account or a relationship with a brokerage firm, please contact your broker and inform the broker that you would like to transfer a mutual fund position that you hold directly with the Target Funds into your brokerage account. Also inform
        your broker that such an account will need to be set up to accept ETF shares, such as the Acquiring Fund. If you do not have a brokerage account or a relationship with a brokerage firm, you will need to establish such a relationship and open such
        an account.

  We suggest you provide your broker with a copy of your quarterly
        statement from the Target Funds. Your broker will require your account number with the Target Funds, which can be found on your statement. Your broker will help you complete a form to initiate the transfer. Once you sign that form, your broker will
        submit the form to the Target Funds’ transfer agent directly, and the shares will be transferred into your brokerage account. The sooner you initiate this transfer, the better.

  Q:         How do I transfer my Target Fund shares from a
      non-accommodating brokerage account to a brokerage account that will accept Acquiring Fund shares?

  A:         The broker where you hold your
        Target Fund shares should be able to assist you in changing the characteristics of your brokerage account to an account that is permitted to hold ETF shares. Contact your broker right away to make the necessary changes to your account.

  Q:         What will happenWill I receive shares of the Acquiring Fund if I do not have a brokeragean account that can accept Acquiring Fund shares at the time of the Reorganizations?

  A:         No, you will not. In

    order to receive shares of the Acquiring Fund as part of the Reorganizations, you must hold your shares of the Target Funds through a brokeragean account that can accept shares of an ETF (the Acquiring Fund) on the closing date of the Reorganizations.

  Non-Accommodating Brokerage Accounts. If you hold your