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    www.dechert.com

June 13, 2024

VIA EDGAR

Filing Desk

Securities and
Exchange Commission

100 F Street, N.E.

Washington, DC
20549

Attn: Deborah O’Neal

Re: Schwab Capital
Trust (“Trust”) (File Nos. 33-62470 and 811-7704) (the “Registrant”)

Dear Ms. O’Neal
:

This letter responds
to the comments of the U.S. Securities and Exchange Commission (“SEC”) staff on Post-Effective Amendment (“PEA”)
No. 226 to the Registrant’s registration statement on Form N-1A (“Registration Statement”) under the Securities
Act of 1933, as amended (“1933 Act”), and Amendment No. 227 under the Investment Company Act of 1940, as amended (the
 “1940 Act”), filed pursuant to Rule 485(a)(1) under the 1933 Act on April 5, 2024. PEA No. 226 relates
to amending the registration statement to make certain changes to the Schwab Fundamental Emerging Markets Large Company Index Fund, Schwab
Fundamental Global Real Estate Index Fund, Schwab Fundamental International Large Company Index Fund, Schwab Fundamental International
Small Company Index Fund, Schwab Fundamental US Large Company Index Fund, and Schwab Fundamental US Small Company Index Fund (each a
 “Fund”), including changes to certain Funds’ names, changes to each Fund’s comparative index and related changes
to each Fund's investment objective and principal investment strategies. The SEC staff’s (the “Staff”) comments were
provided by you to Stephen T. Cohen of Dechert LLP on May 20, 2024.

Throughout this
letter, capitalized terms have the same meaning as in PEA No. 226, unless otherwise noted. A summary of the Staff’s comments,
followed by the responses of the Registrant, is set forth below:

 1. Comment:
                                            In the “Average Annual Total Returns” table,
                                            please add “fees,” before “expenses or taxes” in the parenthetical
                                            for the row “Comparative Indices (reflects no deduction for expenses or taxes).”

Response:
The Registrant has incorporated the requested comment.

                           June 13,
    2024

    Page 2

 2. Comment:
                                            In the “Fund Management” section of
                                            the Schwab Fundamental Index Funds’ prospectus, please confirm that the most recent
                                            discussion regarding the basis for the Board of Trustees’ approval of each fund’s
                                            Amended and Restated Investment Advisory Agreement is available in the funds’ 2023
                                            annual report, which covers the period from November 1, 2022 through October 31,
                                            2023.  Please also note that, going forward, this section will need to be updated to
                                            note that the discussion will be in the Form N-CSR filing for the funds.

Response:
The Registrant confirms that the most recent discussion regarding the basis for the Board of
Trustees’ approval of each fund’s Amended and Restated Investment Advisory Agreement is available in the funds’ 2023
annual report, which covers the period from November 1, 2022 through October 31, 2023.  The Registrant will refer to the
Form N-CSR filing in the future.

*	          *	          *

Should you have
any questions or comments, please contact the undersigned at 202.261.3304.

Sincerely,

/s/ Stephen
T. Cohen

Stephen T. Cohen