SecProbe.io

CORRESP
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David W. Freese

Partner

+1.215.963.5862

david.freese@morganlewis.com

October 13, 2023

FILED AS EDGAR CORRESPONDENCE

Mindy Rotter, Esq., CPA

David P. Matthews, Esq	.

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 Re: Response Letter to Comments on Form N-14 for Bishop Street
Funds (File No. 333-274501)

Dear Ms. Rotter and Mr. Matthews:

On behalf of our client, Bishop Street Funds
(the “Trust”), this letter responds to the comments you provided on behalf of the staff (the “Staff”) of the
U.S. Securities and Exchange Commission (the “SEC”) via telephone, regarding the Trust’s registration statement on
Form N-14 (the “Registration Statement”), filed on September 13, 2023, with respect to the reorganization (the
“Reorganization”) of the Hawaii Municipal Fund (the “Target Fund”), a series of Lee Financial Mutual Fund,
Inc. (the “Target Company”), into the Hawaii Municipal Bond Fund (the “Acquiring Fund”, and together with the
Target Fund, the “Funds”), a series of the Trust.

Below, we have briefly summarized your comments and
questions, and provided responses based on information provided by the Trust, Bishop Street Capital Management (“Bishop Street”),
the Target Company and Lee Financial Group Hawaii, Inc. (“Lee Financial”), as appropriate. Capitalized terms not defined herein
should be given the meaning provided in the Registration Statement. To the extent comments received from the Office of the Chief Accountant
and the Disclosure Review Office are the same, they are provided in response to the comments under the Office of the Chief Accountant
section only to avoid duplication.

Comments from the Office of the Chief Accountant

 1. Comment. Please consider disclosing the estimated reorganization costs that Bishop
                                                                 Street and Lee Financial each expects to pay in the “Summary of Key Information” section of the Proxy
                                                                 Statement/Prospectus and the “Supplemental Financial Information” section of the Statement of Additional Information
                                                                 (“SAI”). Please also supplementally disclose these estimated reorganization costs.

   Morgan, Lewis & Bockius llp

   1701 Market Street

   Philadelphia, PA  19103-2921

   United States

    +1.215.963.5000

     +1.215.963.5001

Mindy Rotter,
Esq., CPA

David P. Matthews, Esq.

October 13, 2023

Page 2

Response. The Trust respectfully declines to disclose Bishop Street’s and Lee
Financial’s respective reorganization costs in the Proxy Statement/Prospectus and SAI because such disclosures are not required
by Form N-14 and shareholders will not bear such costs. While it cannot be determined with certainty, Bishop Street and Lee Financial
expect their collective Reorganization costs will be less than $250,000.

 2. Comment. Please supplementally confirm that the fees presented in the
                                                                                     “Comparison of Fund Fees and Expenses” section of the Proxy Statement/Prospectus represent current fees in accordance
                                                                                     with Item 3 of Form N-14.

Response. The
Target Company and the Trust each confirm that the fees presented in the “Comparison of Fund Fees and Expenses” section of
the Proxy Statement/Prospectus represent current fees in accordance with Item 3 of Form N-14.

 3. Comment. The disclosure under the heading “Summary of Key Information - How do
the Funds’ fees and expenses compare? - Expense Limitation Agreement with Respect to the Acquiring Fund” notes that Lee Financial
does not have a contractual expense limitation agreement in place with the Target Fund. Please supplementally confirm that Lee Financial
has no right to recoup the fees waived and expenses reimbursed  with respect to the Target Fund after the Reorganization.

Response. Lee
Financial supplementally confirms that it has no right to recoup the fees waived and expenses reimbursed with respect to the Target Fund
after the Reorganization.

 4. Comment. Please revise the capitalization table in the “Other Matters” section
of the Proxy Statement/Prospectus via a Rule 497 filing to include the total net assets of the Acquiring Fund, inclusive of both Class
A Shares and Class I Shares, as of August 18, 2023. Please also supplementally provide this revised disclosure.

Response. The Trust has included a new, second footnote to the capitalization table stating: “The total net assets of the Acquiring Fund,
inclusive of both Class A Shares and Class I Shares, was $107,954,070 as of August 18, 2023.”

 5. Comment. Please supplementally disclose the approximate percentage of the Target Fund’s
portfolio that will be sold due to portfolio repositioning in connection with the Reorganization. Please also supplementary discuss whether
such repositioning is voluntary or forced.

Mindy Rotter, Esq., CPA

David P. Matthews, Esq.

October 13, 2023

Page 3

Response.
During the time since the Registration Statement was filed, the Target
Fund has determined that no portfolio repositioning will occur prior to the close of the Reorganization. Accordingly, the related disclosure
in the Registration Statement has been deleted.

 6. Comment. In the “Supplemental Financial Information” section of the Statement
of Additional Information, please disclose via a Rule 497 filing that the Acquiring Fund is the performance survivor of the Reorganization.
Please also supplementally provide this revised disclosure.

Response. The
final sentence of the “Supplemental Financial Information” section has been revised to read: “The Acquiring Fund will
be the accounting survivor and the performance survivor of the Reorganization.”

Comments from
the Disclosure Review Office

 7. Comment. We note that both Funds invest in Hawaii municipal securities and are aware
of the devasting impact that resulted from the wildfires in Maui, Hawaii. It seems possible that both Funds may have, or have had, material
investment exposure impacted by the wildfires. Please supplementally: (i) describe to what extent the Funds have been impacted by the
wildfires with respect to liquidity, valuation and risk/return profiles; and (ii) discuss whether each Fund’s respective board of
trustees or directors (as applicable) and adviser considered the impact of the wildfires in deciding to approve and recommend the Reorganization.

Response.
The meeting of the Target Company Board where the Target Company Board considered the approval of the Reorganization occurred before
the wildfires. Accordingly, the wildfires were not a consideration of the Target Company Board in approving the Reorganization. Lee
Financial does not believe that the impact of the Maui, Hawaii wildfires to the Target Fund’s portfolio have been material.
Liquidity has not been impacted and Lee Financial believes valuations have been reflective of the then current market conditions.
Lee Financial notes that the Target Fund continues to hold Hawaiian Electric bonds but such holdings have been decreased to reduce
its risk.

At its meeting at which it approved the
Reorganization, the Acquiring Trust Board asked representatives of Bishop Street whether, as of such date, the wildfires materially impacted
the market for Hawaiian bonds and were informed that the market had not been materially impacted as of such date. The Acquiring Trust
Board took this information in account within the total mix of information it considered when determining whether to approve and recommend
the Reorganization. During the time after that meeting, Bishop Street determined to sell all of the Acquiring Fund’s holdings in
Hawaiian Electric, based on the impact of the wildfires on that holding that had occurred after the meeting.

 8. Comment. In the “Introduction” section of the Proxy Statement/Prospectus,
please include a statement that Target Fund shareholders will receive Class A shares of the Acquiring Fund and explain any differences
in the value per share as compared to the Target Fund. Alternatively, please include a statement that directs investors to a different
section of the Proxy Statement/Prospectus containing this disclosure.

Response. The requested change has been made.

Mindy Rotter,
Esq., CPA

David P. Matthews, Esq.

October 13, 2023

Page 4

 9. Comment. On page (vii) of the Proxy Statement/Prospectus, please hyperlink each
document that is incorporated by reference and provide each document’s respective file number under the Securities Act of 1933,
as applicable.

Response. The requested changes have been made.

 10. Comment. In the “Summary of Key Information” section of the Proxy Statement/Prospectus,
please include, where appropriate, a description or comparison of the relative total assets under management of all classes of the Target
Fund and Acquiring Fund.

Response. The requested change has been made.

 11. Comment. In the “Summary of Key Information” section of the Proxy Statement/Prospectus,
under the “What are the reasons for the proposed Reorganization?” heading, please: (i) expand the disclosure to address references
to “changing investment landscape, various economic factors and escalating costs” in the shareholder letter from Terrence
K.H. Lee, Chief Executive Officer of Lee Financial; and (ii) address the reasons why Lee Financial will seek to liquidate the Target Fund
or search for a new reorganization partner if the Reorganization is not approved.

Response. The requested changes have been made.

 12. Comment. In the “Summary of Key Information” section of the Proxy Statement/Prospectus,
under the “How do the Funds’ investment objectives, principal investment strategies and principal risks compare?” heading:

      (i). Please specifically discuss the impact on performance and taxation
attributable to investments by the Acquiring Fund in non-Hawaiian bonds and instruments that pay income subject to the federal alternative
minimum tax, differences between the Target Fund’s and Acquiring Fund’s respective concentration policies, and the Target
Fund’s investments primarily in investment grade bonds versus the Acquiring Fund’s investments only in investment grade bonds.

Response. The
Trust notes that to the extent that the differences between the Target Fund's and Acquiring Fund's respective principal investment strategies
noted in this Comment impacted the performance or taxation of the Acquiring Fund or Target Fund, such impact would have depended on a
variety of factors and prevailing market conditions during the times when the Funds held different types or amounts of investments. In
response to this Comment, the Trust has added the following disclosure in the referenced section: “These differences in the principal
investment strategies of the Acquiring Fund relative to the Target Fund, among other reasons, may cause the Acquiring Fund to have a
different risk/return profile relative to the Target Fund.”

The Trust further notes that the current
disclosure in the section titled “Summary of Key Information - How do the performance records of the Funds compare?” explains
that the differences in performance between the Funds over time can be principally attributed to differences in expenses and portfolio
duration. In response to this Comment, the Trust also has expanded upon this discussion and has further noted that other factors, such
as the Acquiring Fund's principal investment strategy to invest in non-Hawaiian municipal bonds, may also have contributed to the differences
in the performance of the Funds.

      (ii). Please define “investment grade.”

Response. The
requested change has been made.

Mindy Rotter,
Esq., CPA

David P. Matthews, Esq.

October 13, 2023

Page 5

 13. Comment. In the “Summary of Key Information” section of the Proxy Statement/Prospectus,
please conform the statement that current annual operating expenses of Investor Class Shares of the Target Fund are lower than the current
annual operating expenses of Class A Shares of the Acquiring Fund with the statement that the Target Fund’s expense ratio has been
historically higher than that of the Acquiring Fund.

Response. The requested change has been made. References to annual operating expenses
have been clarified as “gross” or “net” as appropriate.

 14. Comment. In the “Summary of Key Information” section of the Proxy Statement/Prospectus,
under the “Expense Limitation Agreement with Respect to the Acquiring Fund” subheading, please include a statement that the
Acquiring Fund’s expense limitation agreement is not currently extended beyond April 30, 2024, and that the annual operating expenses
of the Acquiring Fund will exceed those of the Target Fund if the expense limitation agreement is not extended beyond April 30, 2024.

Response. The noted disclosure has been revised to state that the expense limitation
agreement “will automatically renew unless terminated in accordance with its terms” rather than “may be extended.”
In response to this Comment, the following additional disclosure has been added: “If this agreement is terminated, the Acquiring
Fund’s gross operating expenses beginning April 30, 2024 are likely to exceed the current gross operating expenses of the Target
Fund. Bishop Street has no current intention of terminating this agreement.”

 15. Comment. In the “Summary of Key Information” section of the Proxy Statement/Prospectus,
under the “Who will pay the costs of the Reorganization?” heading, please quantify the estimated amount of repositioning costs
to be incurred in dollars and as a percentage of the Target Fund’s total net assets.

Response. As noted in response to Comment 5, during the time since the Registration
Statement was filed, the Target Fund has determined that no portfolio repositioning will occur prior to the close of the Reorganization.
Accordingly, the related disclosure in the Registration statement has been deleted.

 16. Comment. In the “Additional Information About the Funds” section of
the Proxy Statement/Prospectus, please revise the comparative disclosures to highlight more prominently material differences between the
Funds. The revised disclosure should allow investors to easily understand how the nature of their investment will change if the Reorganization
is approved.

Mindy Rotter,
Esq., CPA

David P. Matthews, Esq.

October 13, 2023

Page 6

Response. The requested changes have been made, except that the first paragraphs
under the sections titled “Comparison of Principal Investment Strategies” and “Comparison of Principal Risks of Investing
in the Funds” continue to just refer the reader to corresponding discussions under the “Summary of Key Information”
sections. The Trust believes that this approach provides a concise and appropriate mechanism to summarize the relevant disclosure for
shareholders.

 17. Comment. Please supplementally describe: (i) how the Acquiring Fund will disclose
a waiver of front-end sales loads for some, but not all Class A shareholders; and (ii) why a selective waiver of front-end sales charges
is appropriate.

Response. The Trust intends to file a supplement to the Acquiring Fund’s prospectus
that discloses that the Acquiring Fund will waive all front-end sales charges for legacy shareholders of the Target Fund that receive
Acquiring Fund shares in the Reorganization. The Trust notes that it does not consider such waiver to be a “selective” waiver,
but rather to be an elimination of a sales load to a disclosed class of investors as contemplated by Rule 22d-1 under the 1940 Act.

 18. Comment. In the “Additional Information About the Funds” section of
the Proxy Statement/Prospectus, under the “Comparison of Performance Records” heading, please expand the discussion to address
the reasons for the Target Fund’s outperformance as compared to