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CORRESP
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David W. Freese

Partner

+1.215.963.5862

david.freese@morganlewis.com

October 19, 2023

FILED AS EDGAR CORRESPONDENCE

David P. Matthews, Esq	.

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: Form N-14 Filing for Bishop Street
Funds (File No. 333-274501)

Dear Mr. Matthews:

On behalf of our client, Bishop Street Funds (the
“Trust”), this letter responds to the comment you provided on behalf of the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “SEC”) 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 comment and
provided a response based on information provided by the Target Fund. Capitalized terms not defined herein should be given the meaning
provided in the Registration Statement.

 1. Comment.	 The Staff refers to the Trust’s response to Comment 19 in the Trust’s
prior Correspondence, filed on October 13, 2023, which states that broker non-votes will be counted as present for purposes of establishing
quorum at the Meeting. It is the Staff’s position that broker non-votes may not be counted as establishing quorum for a meeting
where only non-routine proposals are submitted to shareholders. Please remove references to broker non-votes being counted as establishing
quorum.

  Response. In
                                            response to this Comment, the referenced disclosure has been revised as follows:

   Morgan, Lewis & Bockius llp

   1701 Market Street

   Philadelphia, PA  19103-2921

   United States

    +1.215.963.5000

     +1.215.963.5001

David P. Matthews, Esq.

October 19, 2023

Page 2

Abstentions
[and broker non votes]
will be counted for purposes of determining whether a quorum is present at the
Meeting. Abstentions and broker non votes
will have the same effect as a vote “AGAINST” the Proposal because
an absolute percentage of affirmative votes is required to approve the Proposal.

Broker
non votes are proxies
from brokers or nominees
that indicate that they
have not received
voting instructions from the beneficial
owner or other
person entitled
to vote shares
on a particular matter for which the
brokers or nominees
do not have discretionary authority to vote,
such as the Proposal. A broker
non vote occurs when
a broker has not received
voting instructions from a shareholder
and is barred from voting the shares
without shareholder
instructions because the
proposal is non routine. The
Proposal is considered
“non routine” for purposes
of determining
broker non votes.—It
is the Funds' understanding
that because broker
dealers, in
the absence
of specific authorization from their
customers, will not have discretionary
authority to vote any shares
held beneficially
by their customers
on the single matter
expected
to be presented
at the Meeting
there are
unlikely to be
any broker non votes
at the Meeting.

Broker non-votes are inapplicable
for this Meeting because shareholders are being asked to approve a non-routine proposal for which brokers or nominees do not have discretionary
voting power.

* * * * * * * * * * * *

If you have any questions, need any additional information
or would like any clarification, please contact me at (215) 963-5862.

  Sincerely,

  /s/ David W. Freese

  David W. Freese

cc:	Michael Beattie, President, Bishop Street
Funds