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CORRESP
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Financial
Investors Trust

1290
Broadway, Suite 1000

Denver,
Colorado 80203

August
28, 2024

VIA
EDGAR

Ms.
Kimberly Browning

Division
of Investment Management

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

Re: Financial
                                         Investors Trust (the “Registrant”)

  File
                                         Nos. 33-72424, 811-8194

Dear
Ms. Browning:

On
behalf of the Registrant, set forth below are the Registrant’s responses to certain comments received from the staff of the
Division of Investment Management on August 5, 2024 and supplemental comments received on August 26, 2024, regarding post-effective
amendment No. 267 (“PEA 267”) to the Registrant’s registration statement under the Securities Act of 1933,
as amended (the “1933 Act”), and Post-Effective Amendment No. PEA 268 under the Investment Company Act of 1940,
as amended (the “Investment Company Act”), filed pursuant to Rule 485(a) on June 20, 2024, with respect to the
Seafarer Overseas Growth and Income Fund and Seafarer Overseas Value Fund (each, a “Fund” and collectively, the
“Funds”). Capitalized terms not otherwise defined herein shall have the meanings given to them in PEA
267.

In
connection with this response letter, and on or around August 28, 2024, the Registrant anticipates filing, pursuant to Rule 485(b),
a new post-effective amendment to the Registrant’s registration statement under the 1933 Act, which is expected to include
(i) changes to PEA 267 in response to the Staff’s comments, (ii) certain other non-material information; and (ii) certain
other required exhibits.

U.S.
Securities and Exchange Commission

Division
of Investment Management

August
28, 2024

Page
2

Staff
Comments (AUGUST 5, 2024):

Preliminary
Comments

 A. Staff
                                         Comment: Please acknowledge that Registrant has reviewed the SEC’s public
                                         announcement from 2016 and that the Registrant is responsible for all disclosures in
                                         the Fund’s registration statement.

Registrant’s
Response: Registrant understands, in accordance with the SEC’s public announcement from 2016, that Fund management
and the Registrant are responsible for the accuracy of the disclosures in the Fund’s registration statement.

 B. Staff
                                         Comment: The Staff comments are universal and may apply to multiple sections
                                         of the Registration statement.

Registrant’s
Response: Registrant acknowledges that comments are universal and may apply to multiple sections of the Registration statement.

 C. Staff
                                         Comment: Supplementally confirm to the Staff that any areas of the registration
                                         statement that are not complete in PEA 267 will be completed in the subsequent post-effective
                                         amendment to the registration statement with respect to the Fund.

Registrant’s
Response: Registrant confirms that any information not completed in PEA 267 will be completed in the subsequent post-effective
amendment to the registration statement with respect to the Fund.

 D. Staff
                                         Comment: Please provide a copy of any changes to the registration statement at
                                         least five business days prior to the date of effectiveness.

Registrant’s
Response: Comment complied with.

 E. Staff
                                         Comment: Should the Registrant decline a Staff comment, please supplementally
                                         explain the rationale for declining the comment and cite to any applicable laws, regulations,
                                         rules, etc.

Registrant’s
Response: To the extent Registrant has declined a Staff comment, Registrant has included the rationale for declining the
comment, including, any applicable citations.

 F. Staff
                                         Comment: The Staff notes that any comments that are being provided for the Registrant’s
                                         consideration will be specifically identified as such in the applicable comment.

    1

U.S.
Securities and Exchange Commission

Division
of Investment Management

August
28, 2024

Page
3

Registrant’s
Response: Registrant acknowledges the Staff’s comment.

General
Comments

 1. Staff
                                         Comment: The cover page includes the below information. Explain supplementally
                                         to the Staff why the bolded/underlined language is included.

“As
with all mutual funds, neither the Securities and Exchange Commission nor the Commodity Futures Trading Commission
has approved or disapproved these securities or passed upon the accuracy or adequacy of this Prospectus. Any representation to
the contrary is a criminal offense.”

Relatedly,
page 8 of the Statement of Additional Information (the “SAI”) includes the below information. Please update
this disclosure to explain the Adviser’s current status.

“The
Adviser intends to either: (i) comply with the requirements of the CEA by operating the Fund in a manner consistent with the restrictions
of Rule 4.5, including filing a notice of eligibility of exemption from registration in accordance with applicable procedures
and deadlines; (ii) comply with the requirements of the CEA by registering as a CPO with the CFTC and the National Futures Association;
or (iii) operate the Fund in a manner such that the Fund will not be a “commodity pool” under the CEA.”

Registrant’s
Response: Registrant notes that the language on the cover page has been revised to remove the reference to the Commodity
Futures Trading Commission.

On
an annual basis, each Fund claims an exclusion from the definition of a commodity pool operator (“CPO”) and is therefore
not subject to registration or regulation as a CPO. Accordingly, the information on page 8 of the SAI has been revised as follows:

“The
Adviser intends to either: (i) comply complies with the requirements of the CEA by operating the
Fund in a manner consistent with the restrictions of Rule 4.5, including filing a notice of eligibility of exemption from registration
in accordance with applicable procedures and deadlines; (ii) comply with the requirements of the CEA by registering
as a CPO with the CFTC and the National Futures Association; or (iii) operate the Fund in a manner such that the Fund will not
be a “commodity pool” under the CEA.”

 2. Staff
                                         Comment: In the preamble to each Fund’s fees and expenses table, please
                                         bold the following language, “[y]ou may pay other fees, such as brokerage commissions
                                         and other fees to financial intermediaries, which are not reflected in the tables and
                                         examples below.”

Registrant’s
Response: Comment complied with.

    2

U.S.
Securities and Exchange Commission

Division
of Investment Management

August
28, 2024

Page
4

 3. Staff
                                         Comment: Footnote (1) to the fees and expenses table for the Seafarer Overseas
                                         Growth and Income Fund (the “Growth & Income Fund”) includes that the
                                         Fund’s Total Annual Fund Operating Expenses have been restated to reflect current
                                         fees. Please explain supplementally to the Staff the nature of the restated fees. See
                                         Instruction 3(d)(iii) to Item 3 of Form N-1A.

Registrant’s
Response: The Funds accrue daily Shareholder Servicing Fees of 0.15% and 0.05% for the Investor Class and Institutional
Class, respectively. Under the terms of the Shareholder Services Plans, each Plan will cause the Funds to pay an aggregate fee,
not to exceed on an annual basis 0.15% and 0.05% of the average daily net asset value of the Investor and Institutional share
classes, respectively. Such payments will be made on assets attributable to or held in the name of a Participating Organization,
on behalf of its clients as compensation for providing service activities pursuant to an agreement with the Participating Organization.
Participating Organizations may charge less than the maximum fees described above, and therefore the Funds may pay less than those
maximum fees.

During
the fiscal year ended April 30, 2024, the Funds did not utilize the maximum Shareholder Servicing Fees under the Plans. The fees
and expenses table in the prospectus has been restated to reflect the maximum Shareholder Servicing Fees that could be utilized
by the Funds.

 4. Staff
                                         Comment: The preamble to the expense example for the Growth & Income Fund
                                         includes, “[t]his example assumes you purchase your shares on August 31, 2024,
                                         and reflects the net operating expenses with expense waivers through the current term
                                         of the Expense Agreement, which ends on August 31, 2025.” The Staff notes that
                                         the Fund’s fees and expenses table does not include reference to waived fees. If
                                         no fees are being waived, remove the above referenced language from the preamble to the
                                         Fund’s expense example.

Registrant’s
Response: The above referenced language has been removed from the preamble to the Growth & Income Fund’s expense
example.

 5. Staff
                                         Comment: The final sentence in the first paragraph of the discussion of the Growth
                                         & Income Fund’s principal investment strategies includes that under normal
                                         market conditions, the Growth & Income Fund invests “at least 80% of its total
                                         assets in dividend-paying common stocks, preferred stocks, convertible securities,
                                         and debt obligations of foreign companies (which the Fund regards as companies located
                                         outside the U.S.), foreign governments and their agencies, where “total assets”
                                         means net assets, plus the amount of any borrowings for investment purposes”
                                         (the “80% Test”). Including that “total assets” means “net
                                         assets” is potentially confusing. For purposes of plain English, please revise
                                         “total assets” to “net assets” in the Fund’s 80% Test.

    3

U.S.
Securities and Exchange Commission

Division
of Investment Management

August
28, 2024

Page
5

Registrant’s
Response: Comment complied with. The 80% Test has been revised as follows:

“Under
normal market conditions, the Fund seeks to achieve its investment objective by investing at least 80% of its total net assets (plus
the amount of any borrowings for investment purposes) in dividend-paying common stocks, preferred stocks, warrants,
convertible securities, and debt obligations of foreign companies (which the Fund regards as companies located outside the
U.S.), foreign governments and their agencies, where “total assets” means net assets, plus the amount
of any borrowings for investment purposes.”

 6. Staff
                                         Comment: The Staff notes that the Growth & Income Fund’s 80% Test includes
                                         reference to investments in convertible securities. If the Fund invests or expects to
                                         invest in contingent convertible securities (“CoCos”), the Fund should consider
                                         what, if any, disclosure is appropriate. The type and location of such disclosure will
                                         depend on, among other items, the extent to which the Fund invests in CoCos and the characteristics
                                         of the CoCos (e.g., credit quality and triggers). If investments in CoCos are a principal
                                         investment strategy of the Fund, a description of CoCos should be included in the discussion
                                         of the Fund’s principal investment strategies and attendant risk disclosure should
                                         be added to the discussion of the Fund’s principal risks. In addition, supplementally
                                         confirm to the Staff whether the Fund currently invests in CoCos and the amount of the
                                         Fund that is currently invested in CoCos.

Registrant’s
Response: Based on information from the Adviser, the Growth & Income Fund does not currently hold CoCos, nor is it
expected that the Fund will invest in CoCos in the future. Accordingly, associated disclosure has not been added to the Fund’s
prospectus.

 7. Staff
                                         Comment: Please clarify if the Growth & Income Fund’s 80% Test is a
                                         fundamental policy of the Fund. If a non-fundamental policy, include disclosure that
                                         shareholders of the Growth & Income Fund will receive sixty days' notice prior to
                                         any changes to the Fund’s 80% Test.

Registrant’s
Response: Registrant confirms that the Growth & Income Fund’s 80% Test is not a fundamental policy of the Fund.
Additionally, Registrant respectfully notes that the below language is included in the “Investment Objectives and Principal
Investment Strategies” section of the Funds’ prospectus. Accordingly, no changes have been made in response to the
Staff’s comment.

“The
Funds’ Board of Trustees (the “Board”) may change a Fund’s investment objective or a Fund’s principal
investment strategies without a shareholder vote. The Funds will notify you in writing at least sixty (60) days before making
any such change.”

    4

U.S.
Securities and Exchange Commission

Division
of Investment Management

August
28, 2024

Page
6

 8. Staff
                                         Comment: The Growth & Income Fund’s 80% Test includes reference to
                                         debt obligations. In the discussion of the Fund’s principal investment strategies,
                                         please specify the types of debt obligations that will be used for purposes of the Fund’s
                                         80% Test and add attendant risk disclosure to the discussion of the Fund’s principal
                                         risks. See Items 4 and 9 of Form N-1A.

Registrant’s
Response: The following information has been added at the end of the first paragraph in the discussion of each Fund’s
principal investment strategies:

“For
this purpose, the debt obligations in which the Fund may invest include corporate, government, agency, and convertible bonds.”

Registrant
notes that the penultimate paragraph in the discussion of each Fund’s principal investment strategies includes, “[t]he
Fund may invest in convertible securities and debt obligations of any quality or duration. Such debt obligations may include investments
in below investment grade debt, also known as ‘junk bonds.’”

Additionally,
the discussion of each Fund’s principal risks includes “Fixed Income Securities Risk,” which addresses the risks
associated with such investments.

 9. Staff