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Financial Investors Trust

1290 Broadway, Suite 1000

Denver, Colorado 80203

October 30, 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 October
7, 2024 and supplemental comments received on October 18, 2024 regarding post-effective amendment No. 275 (“PEA 275”) to the Registrant’s registration statement under
the Securities Act of 1933, as amended (the “1933 Act”), and Post-Effective Amendment No. PEA 276 under the Investment
Company Act of 1940, as amended (the “Investment Company Act”), filed pursuant to Rule 485(a) on August 20, 2024,
with respect to the Emerald Growth Fund (the “Fund”). Capitalized terms not otherwise defined herein shall have the
meanings given to them in PEA 275.

In connection with this response letter,
and on or around October 30, 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 275 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 30, 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 275 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 275 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.

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

    2

    U.S. Securities and Exchange Commission
 Division of Investment Management
 October 30, 2024

Page 3

General Comments

 1. Staff Comment: The Fund’s
                                            fees and expenses table includes “shareholder services fees” as a sub-caption
                                            under “Other Expenses.” Where are these fees described in the prospectus? If
                                            not already described, please add associated disclosure. What agreement governs the shareholder
                                            services fees? If not already filed, file a copy of the relevant agreement as an exhibit
                                            to the Fund’s registration statement.

Registrant’s Response:
The Shareholder Services Plan for Class C shares is discussed in the “Distribution and Services (12b-1 Plan) and Shareholder Services
Plan for Class C Shares” section of the Fund’s prospectus. The Shareholder Services Plans for the Institutional Class and
Investor Class shares are discussed in the “Shareholder Services Plan for Institutional Class and Investor Class Shares”
section of the Fund’s prospectus. Class A of the Fund does not have a shareholder services plan.

The Class C Shareholder Services Plan dated
December 13, 2011 and the Amended and Restated Shareholder Services Plans for the Investor Class and Institutional Class, each dated
March 11, 2016, have previously been filed as exhibits to the Fund’s registration statement. Registrant notes that the hyperlink
contained in Exhibit (m)(20) to PEA 275 inadvertently included a hyperlink to the Institutional Class Shareholder Services Plan instead
of the Investor Class Shareholder Services Plan. The hyperlinks and exhibit references will be updated in the New PEA.

The Investor Class Shareholder Services
Plan can be found at the following link:

https://www.sec.gov/Archives/edgar/data/915802/000139834416011997/fp0019019_ex9
928m25.htm.

The Institutional Class Shareholder Services
Plan was filed as Exhibit (m)(26) to Post- Effective Amendment No. 174 to the Trust’s Registration Statement, and can be found
at the following link:

https://www.sec.gov/Archives/edgar/data/915802/000139834416011997/fp0019019_ex9
928m26.htm.

 2. Staff Comment: Footnote 2 to
                                            the Fund’s fees and expenses table includes a discussion of the Adviser’s agreement
                                            to waive and/or reimburse the Fund for certain fees and expenses under the Fund’s expense
                                            agreement (the “Prior Expense Agreement”). Will this agreement be split
                                            into separate agreements? If yes, revise the footnote disclosure accordingly. Include the
                                            length of the applicable expense agreement and state that such expense agreement will be
                                            in place for at least one year from the date of the prospectus.

    3

    U.S. Securities and Exchange Commission
 Division of Investment Management
 October 30, 2024

Page 4

Additionally, disclose under what circumstances
the expense agreement(s) may be terminated and by whom.

Registrant’s
Response: Registrant confirms that the Adviser’s agreement to permanently waive and/or reimburse the Fund for any
acquired fund fees and expenses (“AFFE”) incurred by the Fund in connection with the Fund’s investment in
exchange-traded funds (“ETFs”) advised or sub-advised by the Adviser will be moved to a separate expense
agreement between the Trust, on behalf of the Fund, and the Adviser (the “AFFE ELA”). The remaining provisions in
the Prior Expense Agreement will be covered in a separate expense agreement between the Trust, on behalf of the Fund, and the
Adviser (the “New ELA,” and together with the AFFE ELA, the “Expense Agreements”). As
reflected in the New PEA, the Adviser will be waiving AFFE incurred by the Fund in connection with its investments in ETFs advised
or sub-advised by the Adviser pursuant to the AFFE ELA. While the New ELA will be in effect and triggered as of the date of the
prospectus and statement of additional information, the New ELA is not triggered at the Fund’s current asset levels.
Accordingly, Footnote 2 to the Fund’s fees and expenses table has been replaced with the below. Additionally, information
regarding the New ELA has been added to the “Management” section of the Fund’s prospectus.

“(2) [Pursuant to a written
agreement (the “AFFE Agreement”), Emerald Mutual Fund Advisers Trust (“Emerald” or the
“Adviser”) has agreed to waive and/or reimburse the Fund’s Class A, Class C, Institutional Class, and Investor
Class shares for any acquired fund fees and expenses incurred by the Fund in connection with the Fund’s investment in any
exchange-traded funds advised or sub-advised by the Adviser. The amount of such waived fees shall not be subject to recapture by the
Adviser. The AFFE Agreement has no termination date. Prior to August 31, 2026, and thereafter, this waiver may not be modified
or discontinued without the approval of the Fund's Board of Trustees.”

 3. Staff Comment: The Staff notes
                                            that if one or both of the Expense Agreements is not triggered because the Fund’s total
                                            annual operating expenses are below the applicable waiver threshold or the Fund is not invested
                                            in ETFs advised by the Adviser, information related to the applicable Expense Agreement should
                                            not be disclosed in the Fund’s fees and expenses table or expense example.

Registrant’s Response:
As described in the response to Staff Comment 2, the New ELA is not triggered at the Fund’s current asset levels and is not included
in the Fund’s fees and expenses table or expense example. As the Adviser is waiving amounts pursuant to the AFFE ELA, information
related to the AFFE ELA is included in the fees and expenses table and expense example.

 4. Staff Comment: Please confirm
                                            that the Fund’s expense example will take into account the Fund’s Expense Agreements
                                            during the applicable periods in which such Expense Agreement will be in effect.

    4

    U.S. Securities and Exchange Commission
 Division of Investment Management
 October 30, 2024

Page 5

Registrant’s Response:
As described in the response to Staff Comments 2 and 3, the New ELA is not triggered at this time and the Fund’s expense example,
as reflected in the New PEA, does not take into account the New ELA. Because the AFFE ELA will be in effect in perpetuity, in accordance
with Instruction 4(a) to Item 3 of Form N-1A, the expense example information for the one-, three-, five-, and ten-year periods reflects
adjustments to reflect amounts to be waived under the AFFE ELA.

 5. Staff Comment: Update the preamble
                                            to the Fund’s expense example to include disclosure regarding the components of the
                                            Expense Agreements.

Registrant’s Response:
Comment complied with. The preamble to the Fund’s expense example has been updated as follows:

“This
example is intended to help you compare the costs of investing in the Fund with the cost of investing in other mutual funds. The example
assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods.
[This example reflects the expense waiver, which has no termination date, for the AFFE Agreement. the net
operating expenses with expense waivers through the current term of the Expense Agreement, which ends on August 31, 2026.]
The example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same.”

 6. Staff Comment: The discussion
                                            of the Fund’s principal investment strategies includes that the Fund will invest in
                                            U.S. and foreign companies. Disclose how the Fund determines a company is a foreign company
                                            (for example, by reference to an index or an economic tie test). The Staff would not object
                                            to including this disclosure in the discussion of the Fund’s principal investment strategies
                                            provided in response to Item 9 of Form N-1A.

Registrant’s Response:
The discussion of the Fund’s principal investment strategies provided in response to Item 9 of Form N-1A has been revised to include
the following language:

“With
respect to foreign securities, the Adviser considers a company to be economically tied to a country if at least one of the following
attributes exists: the company (1) is organized in such country, (2) is headquartered in such country, (3) has its primary stock exchange
listing in a market located in such country, or (4) during the company’s most recent fiscal year, derived at least 50% of its revenues
or profits from goods produced or sold, investments made, or services performed in such country or has at least 50% of its assets in
such country.”

 7. Staff Comment: The Staff notes
                                            that “securities convertible into common or preferred stocks” was removed from
                                            the first paragraph in the discussion of the Fund’s principal investment strategies,
                                            but the Item 9 “Equity Securities Risk” includes reference to the Fund investing
                                            in “convertible preferred stocks and securities with values that are tied to the price of stocks, such as rights, warrants,
and convertible debt securities.” Please harmonize the disclosure across the discussions of the Fund’s principal investment
strategies and principal risks.

    5

    U.S. Securities and Exchange Commission
 Division of Investment Management
 October 30, 2024

Page 6

Registrant’s Response:
Comment complied with. The Fund’s Item 9 “Equity Securities Risk” has been revised to remove discussions of the Fund
investing in convertible preferred stocks and securities with values that are tied to the price of stocks, such as rights, warrants,
and convertible debt securities.

 8. Staff Comment: The first paragraph
                                            in the discussion of the Fund’s principal investment strategy includes that, “[u]nder
                                            normal conditions, the Fund invests in equity securities of U.S. and foreign companies, primarily common
stocks and preferred stocks.” Replace “primarily” with “principally” for conformity with the requirements
of Item 4 and Item 9 of Form N-1A.

Registrant’s Response:
Comment complied with.

 9. Staff Comment: In the second
                                            paragraph in the discussion of the Fund’s principal investment strategies, revise the
                                            bolded terms in the below to be in plain English.

“The Fund utilizes a fundamental approach
to choosing securities: the research staff of Emerald conducts company-specific research analysis to identify companies whose earnings
growth rate exceeds that of their peer group. Companies with perceived leadership positions and competitive
advantages in niche markets that do not receive significant coverage from other institutional investors are favored.”