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Financial Investors Trust

1290 Broadway, Suite 1000

Denver, Colorado 80203

February 28, 2025

VIA EDGAR

Ms. Soo Im-Tang

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. Im-Tang:

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 January
10, 2025 and February 24, 2025 regarding post-effective amendment No. 288 (“PEA 288”) to the Registrant’s
registration statement under the Securities Act of 1933, as amended (the “1933 Act”), and Post-Effective
Amendment No. PEA 289 under the Investment Company Act of 1940, as amended (the “Investment Company Act”), filed
pursuant to Rule 485(a) on November 27, 2025, with respect to ALPS Asset Allocation Growth & Income (the
“Fund”). Capitalized terms not otherwise defined herein shall have the meanings given to them in PEA 288.

In connection with this response letter, and on
or around February 28, 2025, 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 288 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

February 28, 2025

Page 2

Staff
Comments:

 1. Staff Comment: Please include the date of the prospectus in the New PEA.

Registrant’s Response:
Comment complied with.

 2. Staff Comment: Please provide a completed fees and expenses table at least five business
days prior to the effectiveness of the New PEA.

Registrant’s Response:
Comment complied with. A completed fees and expenses table is attached hereto as Exhibit A.

 3. Staff Comment: The discussion of the Fund’s principal investment strategies refers
to ETFs advised by the Adviser. Please disclose the percentage of the Fund that may be invested in ETFs advised by the Adviser.

Registrant’s Response:
The Fund does not have a limit on the portion of its portfolio that may be invested in AAI ETFs. The following language has been added
to the final paragraph of the discussion of the Fund’s principal investment strategies.

“The portion of the Fund’s
portfolio invested in AAI ETFs will vary from time to time. There is no minimum or maximum amount of the Fund’s portfolio that may
be invested in AAI ETFs at any given time.”

 4. Staff Comment: The discussion of the Fund’s principal investment strategies includes
that “[t]he Fund also seeks, under normal market conditions, a target asset allocation, on a look-through basis, of 60% to equities
and 40% to fixed-income securities…” Please disclose the specific types of equities and fixed-income securities in which
the Fund may invest, including both direct investments and indirect investments through underlying ETFs. In addition, disclose in the
discussion of the Fund’s principal risks the risks associated with investing in such securities.

Registrant’s Response:
Based on information from the Adviser, the equity securities in which the Fund will indirectly invest through its investments in underlying
ETFs include listed domestic and international common and preferred stock. With respect to the Fund’s indirect investments in fixed
income securities, the Fund will invest in domestic and international government, corporate, and high-yield bonds as well as U.S. municipal
bonds. The second paragraph of the discussion of the Fund’s principal investment strategies has been revised as follows:

“The Fund is designed for investors
seeking current income and capital appreciation while also seeking to manage risk. The Fund will typically have an allocation to global
equities and therefore, investors in this Fund should be able to assume a certain degree of portfolio volatility. Variations of up to
20% in the target asset allocation between equities and fixed income securities are permitted. Therefore, under normal conditions, the
equity/fixed income allocation in the Fund may range from 40%/60% to 80%/20% instead of the 60%/40% target. The Fund is expected to invest
between 40% and 80% of its assets primarily in ETFs with exposure to a globally diversified basket of equities (which may include common
and preferred stock of issuers located in emerging markets). The balance of the Fund is expected to be invested primarily in various
other income-paying ETFs, the assets of which may include corporate debt. The fixed income ETFs included in the portfolio may hold fixed
income instruments, including government bonds, corporate bonds, and U.S. municipal bonds, of any credit quality, including
“junk” bonds, and of any duration. The Adviser may tactically depart from the targeted allocations when certain sectors appear
to be over- or under-valued. The equity issuers to which the Fund will have exposure may be issuers of any market capitalization.”

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U.S. Securities and Exchange Commission

Division of Investment Management

February 28, 2025

Page 3

 5. Staff Comment: The Staff notes that the Fund is expected to invest its assets in ETFs with
exposure to “a globally diversified basket of equities.” As of November 30, 2024, the Fund was only invested in the U.S. Explain
how the Fund’s investments as of November 30, 2024 is consistent with the Fund’s principal investment strategies, including to the extent appropriate, how such U.S. investments promote
global diversification. If the Fund
expects to invest primarily in the U.S. or a specific country or region, please modify the disclosure accordingly.

Registrant’s Response:
Based on information from the Adviser, the Fund’s exposure to international securities is achieved through its investments in underlying
ETFs listed on U.S. exchanges. Accordingly, the first paragraph of the discussion of the Fund’s principal investment strategies
has been revised as follows:

“ALPS Advisors, Inc. (the
“Adviser” or “AAI”) seeks to achieve the Fund’s investment objective by strategically
investing in, and tactically adjusting allocations to, exchange-traded funds (“ETFs”) that, under normal market
conditions, are expected to consist of ETFs advised by the Adviser (“AAI ETFs”), as well as unaffiliated ETFs. The
ETFs in which the Fund may invest consist of ETFs that are listed on U.S. exchanges and may have exposure to international
securities. The Fund also seeks, under normal market conditions, a target asset allocation, on a look-through basis, of 60%
to equities and 40% to fixed-income securities, subject to the variations described below. The Fund’s strategic allocation
refers to the Adviser’s long-term, macro-view targeted allocation of asset class exposure that takes into consideration the
Fund’s particular investment objective and risk limitations. The Fund’s tactical adjustments refer to the
Adviser’s periodic modifications of the Fund’s allocation in response to prevailing market conditions, to seek to
emphasize asset classes that are perceived to have a higher probability of relative outperformance.”

 6. Staff Comment: The discussion of the Fund’s principal investment strategies includes
that the Fund’s exposure to ETFs with exposure to a globally diversified basket of equities may include securities of issuers in
emerging markets. Please define or describe the factors used by the Fund to determine whether an issuer is located in an emerging market.

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U.S. Securities and Exchange Commission

Division of Investment Management

February 28, 2025

Page 4

Registrant’s Response:
Comment complied with. The following information has been added to the fourth paragraph in the discussion of the Fund’s principal
investment strategies:

“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 final paragraph in the discussion of the Fund’s principal investment
strategies includes a list of ETFs in which the Fund may invest at least 25% of its portfolio holdings. Please supplementally explain
the significance of these ETFs. Are these AAI ETFs?

Registrant’s Response:
Registrant confirms that the ETFs listed in the final paragraph of the discussion of the Fund’s principal strategies are AAI ETFs.

 8. Staff Comment: The “Affiliated ETF Risk” includes the below language. If accurate,
please clarify if the Fund only does not pay advisory fees with respect to ETFs advised by the Adviser. As currently included, this disclosure
could be interpreted to mean that the Fund does not pay an advisory fee.

“To seek to mitigate risks of
conflicts of interest arising from investments in affiliated investment companies, the Fund has adopted an expense structure under which
the Fund does not pay advisory fees to the Adviser.”

Registrant’s Response:
Pursuant to the investment advisory agreement between the Trust, on behalf of the Fund and the Adviser (the “Advisory Agreement”),
the Adviser does not receive a management fee from the Trust for its services under the Advisory Agreement. Historically, the Fund limited
its investments in ETFs advised by the Adviser, and because the Adviser received advisory fees from such underlying ETFs, the Adviser
did not charge an advisory fee to the Fund under the Advisory Agreement. While the Fund’s investment strategy has expanded to allow
for investments in unaffiliated ETFs, the Advisory Agreement has remained unchanged. Accordingly, Registrant respectfully declines to
revise the above-referenced disclosure.

 9. Staff Comment: Please consider including in the discussion of the Fund’s principal
risks the risk that when all or a portion of an ETF’s underlying securities trade in a market that is closed while the market in
which such ETF’s shares are listed is open, there can be changes between the close of the foreign market and the ETF domestic market
trading day. In addition, note that this could in turn lead to a difference between the value of the ETF’s shares and the value
of the underlying shares.

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U.S. Securities and Exchange Commission

Division of Investment Management

February 28, 2025

Page 5

Registrant’s Response:
Comment complied with. The following information has been added to “ETF Investment Risk” in the discussion of the Fund’s
principal risks:

“Where all or a portion of an
underlying ETF’s underlying securities trade on a foreign market, there may be differences between the price of the underlying ETF’s
shares and the shares of the underlying securities due to differences in the opening and closing times of such foreign markets.”

 10. Staff Comment: The “Allocation Risk” includes reference to “AAI.”
Please define this term.

Registrant’s Response:
Comment complied with.

 11. Staff Comment: Please include in the “Fixed Income Securities Risk” (or elsewhere
in the discussion of the Fund’s principal risks) reference to the current market conditions that may impact the fixed income securities
in which the Fund invests, including the high-interest rate environment and the impact of inflation of debt instruments.

Registrant’s Response:
Registrant respectfully notes that the “Interest Rate Risk” included in the discussion of the Fund’s principal risks
includes information about the impact on fixed income securities when interest rates rise. In light of the Staff’s comment, however,
Registrant has revised the “Interest Rate Risk” in the summary section of the Fund’s Prospectus as follows to provide
additional emphasis with respect to the impact of rising interest rates:

“Interest Rate Risk. The
fixed-income securities in which an underlying ETF may invest may be of any credit quality or duration. Duration is a weighted measure
of the length of time a bond will pay out and takes into account interest payments that occur throughout the course of holding the bond.
In general, the longer the bond’s duration, the more its price will drop as interest rates go up. When interest rates rise,
tThe value of the underlying ETF’s investments in fixed-income securities will generally decrease when
interest rates rise, which means the Fund’s NAV will likewise decrease.”

Additionally, the “Fixed Income
Securities Risk has been revised as follows:

“Fixed Income Securities Risk.
The Fund’s investments, through an underlying ETF, in fixed-income securities and positions in fixed-income derivatives may decline
in value because of changes in interest rates. As nominal interest rates rise, the value of fixed-income securities and any long positions
in fixed-income derivatives held by the Fund are likely to decrease, whereas the value of its short positions in fixed-income derivatives
is likely to increase. Additionally, the Fund’s investments in fixed income securities may underperform due to inflation (or
the expectation of inflation). Inflation may reduce the intrinsic value of increases in the value of the Fund. Inflation risk is the risk
that the value of assets or income from investments will be less in the future as inflation decreases the value of money. As inflation
increases, the value of the Fund’s assets can decline.”

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U.S. Securities and Exchange Commission

Division of Investment Management

February 28, 2025

Page 6

 12. Staff Comment: The “Small-, Mid-, and Large-sized Companies Risk” includes the
below information. Please clarify or provide examples of “emerging products.”

“The Fund’s investments,
through an underlying ETF, in securities issued by small- and mid-sized companies, which can include companies offering emerging products
or services, may involve greater risks than are customarily associated with larger, more established companies.”

Registrant’s Response:
Registrant has revised the above referenced disclosure to remove the reference to “emerging products or services.”

 13. Staff Comment: The “Limited Investments Risk” includes that the Fund may invest
in a limited number of ETFs. Please supplementally explain if there is a minimum number of ETFs in which the Fund must be invested at
any time.

Registrant’s Response:
Registrant confirms that there is no minimum number of ETFs in which the Fund must be invested at any time.

 14. Staff Comment: The “Underwriting Commissions – Class C Shares”
section of the SAI includes reference to “APSD.” Please define this term.

Registrant’s Response:
Comment complied with.

 15. Staff Comment: The table on page 66 of the SAI showing shareholders that own 5% or more
of the Fund’s share classes includes duplicative entries for the Fund’s Class C shares.

Registrant’s Response:
The above referenced table has been updated in the New PEA.

* * * * *

If you have any questions or further comments,
please contact Peter H. Schwartz, counsel to the Registrant, at (303) 892-7381.

    Very truly yours,

    /s/ Brendan Hamill

    Brendan Hamill

    Secretary of Financial Investors Trust

 cc: Peter H. Schwartz, Esq., Davis Graham & Stubbs LLP

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U.S. Securities and Exchange Commission

Division of Investment Management

February 28, 2025

Page 7

Exhibit A

FEES AND EXPENSES OF THE FUND

This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to
financial intermediaries, which are not reflected in the tables and examples below. Y