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CORRESP
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Financial
Investors Trust

1290
Broadway, Suite 1000

Denver,
Colorado 80203

October 4, 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 14,
2024 and supplemental comments received on September 18, 2024 and September 24, 2024, regarding post-effective amendment No. 268
(“PEA 268”) to the Registrant’s registration statement under the Securities Act of 1933, as amended (the
“1933 Act”), and Post-Effective Amendment No. PEA 269 under the Investment Company Act of 1940, as amended (the
“Investment Company Act”), filed pursuant to Rule 485(a) on June 28, 2024, with respect to the ALPS Balanced
Opportunity Fund (the “Fund”). Capitalized terms not otherwise defined herein shall have the meanings given to
them in PEA 268.

In connection with this response letter, and on or
around October 4, 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 (the “New PEA”), which is expected to include (i) changes to PEA 268 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

October 4, 2024

Page
2

Staff
Comments:

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 268 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 268 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.

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U.S.
Securities and Exchange Commission

Division
of Investment Management

October 4, 2024

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3

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

General
Comments

 1. Staff
                                         Comment: The Staff notes that the Fund materially changed its investment strategy
                                         and Smith Capital Investors, LLC (“Smith”) will no longer serve as
                                         the Fund’s investment sub-adviser, resulting in a transition in the prior managerial
                                         structure of the Fund. Please supplementally inform the Staff why the Board of Trustees
                                         of the Trust (the “Board”) believes these changes are consistent with
                                         its fiduciary obligations to the Fund and in the best interests of the shareholders,
                                         who did not vote for these changes. Additionally:

 a. explain
                                         in detail the information the Board considered and how the Board weighed the information
                                         in arriving at its decision;

 b. explain
                                         in detail why the Board concluded that this approach was better than other alternatives,
                                         such as liquidating the Fund and launching a new fund; and

 c. support
                                         such explanations with data (e.g., that the Board considered the cost savings associated
                                         with the approach of updating the Fund’s strategy and terminating the sub-adviser
                                         against the costs of liquidating the Fund and launching a new fund).

Registrant’s
Response: In connection with its meeting held on June 11-12, 2024, the Board, which is comprised solely of Trustees who
are not considered to be “interested person[s]” of the Registrant under the Investment Company Act (the “Independent
Trustees”), considered and approved, the following changes relating to the Fund as reflected in PEA 268 (collectively,
the “Changes”): the changes to the Fund’s name; the termination of the Sub-Advisory Agreement dated June
17, 2020 between the Adviser and Smith with respect to the Fund; and the changes to the Fund’s investment strategies whereby
the Fund would now invest as a principal investment strategy in underlying exchange-traded funds that are advised by the Adviser
(each, an “Underlying ETF”) to gain fixed income exposure as opposed to making such investments directly. In consideration of the Changes, the Trustees reviewed information provided by ALPS Advisors Inc., the Fund’s adviser
(the “Adviser”), in advance of the meeting, including a presentation discussing from the Adviser.

As
part of its review, the Trustees considered the Adviser’s rationale for the Changes, including, among other factors, potential
efficiencies to the Fund from investing its Fixed Income Sleeve (as defined below) in Underlying ETFs advised by the Adviser.
The Board considered that the proposed changes to the Fund’s principal investment strategies, while material and requiring
a filing pursuant to Rule 485(a) under the Securities Act of 1933, did not change the Fund’s investment objective or strategy
of normally investing 60% of its assets in equity securities (the “Equity Sleeve”) and, on a look-through basis,
40% of its assets in fixed-income securities and cash equivalents (the “Fixed Income Sleeve”). Furthermore,
the Board also noted that, while the Adviser proposed investing the Fixed Income Sleeve in Underlying ETFs, the Underlying ETFs
will invest in similar fixed income securities as those in which the Fund currently invests.

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U.S.
Securities and Exchange Commission

Division
of Investment Management

October 4, 2024

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4

In
addition, the Board received and considered information regarding the portfolio transition, including the estimated time to transition
the Fund’s portfolio and the tax implications associated with repositioning the Fund’s portfolio. The Board also
considered that the Adviser has agreed to waive fees and/or reimburse the Fund for any acquired fund fees and expenses (“AFFE”)
incurred by the Fund in connection with the Fund’s investments in ETFs advised by the Adviser.

The Board considered various alternatives
to the Changes, including the terms under which Smith would potentially remain as a sub-adviser to the Fund and the capability and willingness
of the Adviser to invest the fixed income portion of the Fund directly into particular fixed income instruments. The Board concluded
that the Changes were, given the alternatives, in the best interests of the Fund and the Fund’s shareholders. The Board did not
consider liquidating the Fund or launching a new series of the Trust as alternatives to the Changes.

In
evaluating the Changes, the Trustees considered their duties under the 1940 Act, as well as under the general principles of state
law, and the standards used by courts in determining whether investment company boards have fulfilled their duties. To assist
the Trustees in their deliberations, the Trustees consulted with their independent legal counsel, including in executive session.
In considering the approval of these changes, the Trustees reviewed and evaluated the information and factors they believed to
reasonably be necessary and appropriate in light of legal advice furnished to them by their independent legal counsel and through
the exercise of their own business judgment. Individual Trustees may have weighed certain factors or information differently,
and the Board did not consider any single factor or information controlling in reaching its decision. The Board, in exercising
its fiduciary duties, does not dictate to an investment adviser how to achieve the optimal return for shareholders or what investments
to make, but rather relies on the expertise of the Adviser to manage the Fund’s assets. With regard to the Fund, the Board
considered the Adviser’s expertise and gave deference to the Adviser’s recommendation that the Changes would be beneficial
to Fund shareholders.

Based on the information presented, and
other information and factors deemed relevant to each Trustee in the exercise of his or her business judgment, the Trustees concluded
that the Changes were in the best interest of the Fund and the Fund’s shareholders and the Trustees approved the Changes.

 2. Staff
                                         Comment: Please explain why the Adviser feels the Changes are consistent with
                                         its fiduciary duties to the Fund.

Registrant’s
Response: The Adviser believes that the Changes are in the Fund’s best interest as the Fund will gain trade execution
and tax efficiencies by attaining the fixed income exposure through an Underlying ETF. Any AFFE associated with the Fund’s
investment in ETFs advised by the Adviser will be reimbursed to the Fund by the Adviser.

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U.S.
Securities and Exchange Commission

Division
of Investment Management

October 4, 2024

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5

 3. Staff
                                         Comment: Has the Trust and the Fund notified shareholders of the Changes? If
                                         notice was provided, please provide the Staff a copy of the notice and indicate when
                                         the notice was transmitted. If notice was not provided, when and how will the Trust and
                                         Fund provide such notice?

Registrant’s
Response: Shareholders will be notified of the Changes by receiving a copy of the revised prospectus or summary prospectus,
as appropriate, once those materials are effective.

 4. Staff
                                         Comment: What is the composition of the Fund’s shareholder base (e.g.,
                                         affiliated vs. unaffiliated, retail vs. institutional, and domestic vs. foreign)?

Registrant’s
Response: The Adviser has indicated that, as of August 1, 2024, 100% of the Fund is owned by domestic retail shareholders.
Of such shareholders, 19% are affiliated with the Fund.

 5. Staff
                                         Comment: Please supplementally explain why making the Changes in a post-effective
                                         amendment to the Trust’s registration statement pursuant to Rule 485(a)(1) (allowing
                                         for effectiveness 60 days after filing the post-effective amendment) as opposed to a
                                         post-effective amendment to the Trust’s registration statement pursuant to Rule
                                         485(a)(2) to add a new series of the Trust (allowing for effectiveness 75 days after
                                         filing the post-effective amendment) is consistent with the text and policy of Rule 485(a).
                                         Please also explain why Registrant believes this does not provide an unfair advantage
                                         over other registrants that go effective 75 days after the date of filing pursuant to
                                         Rule 485(a)(2).

Registrant’s
Response: As detailed in response to Staff Comment 1, while the Fund will no longer have a sub-adviser and a portion of
the Fund’s assets will be invested in Underlying ETFs instead of directly, Registrant does not believe the Changes are material
enough to warrant the launch of a new series of the Trust to implement. The Fund will maintain the same investment
adviser and while the Fund’s investment in fixed income securities will be accomplished through investments in Underlying
ETFs, currently expected primarily to be the ALPS | Smith Core Plus Bond ETF (“SMTH”), the Fund’s investment objective and strategy to invest at least 60% of its assets the Equity Sleeve and, on a
look-through basis and 40% of its assets in the Fixed Income Sleeve is not changing. Additionally, SMTH is advised by the
same investment adviser, sub-advised by Smith, and invests in fixed income securities that are similar to the fixed income securities
the Fund currently holds directly.

After
analyzing the materiality of the Changes in light of the above circumstances, Registrant believes that including the Changes in a post-effective
amendment to the Trust’s registration statement filed under Rule 485(a)(1) is appropriate. Registrant also notes that Post-Effective
Amendment No. 276 to the Trust’s Registration Statement, filed with the Commission on August 26, 2024, delayed the effectiveness
of PEA 268 to September 12, 2024 (Accession No. 0001398344-24-015518) (“PEA 276”), and Post-Effective Amendment No.
278 to the Trust’s Registration Statement, filed with the Commission on September 11, 2024, further delayed the effectiveness of
PEA 268 to September 20, 2024 (Accession No. 0001398344-24-017810) (“PEA 278”). The delay in the effectiveness of
PEA 268 means that PEA 268 would go effective 84 days from the date PEA 268 was filed, nine days longer than the period in which the
filing would have gone effective if filed pursuant to Rule 485(a)(2). While Registrant does not believe that an unfair advantage would
have been given to the Fund by filing the changes under Rule 485(a)(1), the filing of PEAs 276 and 278 removes any potential perceived
advantage to the Fund over a fund that filed under Rule 485(a)(2).

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U.S.
Securities and Exchange Commission

Division
of Investment Management

October 4, 2024

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