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    Stradley Ronon
    Stevens & Young, LLP

 Suite 2600

 2005 Market Street

 Philadelphia, PA 19103-7018

 Telephone 215.564.8000

 Fax 215.564.8120

 www.stradley.com

Don E. Felice

dfelice@stradley.com

(215) 564-8794

January 18, 2024

Ms. Christina DiAngelo Fettig

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re: HC Capital Trust (“Registrant”)

                                  Sarbanes Oxley Review

Dear Ms. DiAngelo Fettig:

This correspondence is being provided to you
in response to your comments (“Staff Comments”) communicated during our conversations of November 29, 2023 and January 12,
2024 with respect to the Registrant’s filings on forms N-1A, N-CSR, N-PORT and N-CEN.

For your convenience, we have summarized our
understanding of the Staff Comments in bold typeface and set forth our response in the following italicized text.

With respect to Form N-1A:

1. You noted that, in the conditions related to the Registrant’s
                                       manager of managers exemptive order (the “Order”), it states that the Registrant will
                                       disclose in its prospectus: (1) that the primary investment adviser (the “Adviser”)
                                       has the ultimate responsibility, subject to oversight by the Board, to oversee the sub-advisers
                                       and recommend their hiring, termination and replacement; and (2) that notice of the hiring of
                                       a new sub-adviser (“Specialist Manager”) will be posted to the Trust’s website
                                       within 90 days of such hiring. You asked that Registrant point you to the relevant prospectus
                                       disclosure and confirm the address of the website on which required notices are posted.

    Response:
    The prospectus referenced disclosure
    is located on page 163 of the prospectus under the headings “Fund Management / Advisory Services / HC Capital Solutions.”
    While the disclosure does not use the exact wording set forth in the conditions, the Registrant

January 18, 2024

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believes that the substance is
appropriately conveyed. Notices regarding the hiring of a new Specialist Manager are posted within 90 days of such hiring, in the form
of an information statement, at www.hccapitalsolutions.com. Such information statements are removed
from the web site after the required time period has expired.

2. You noted that in the Principal Investment Strategy prospectus
                                       disclosure for the Short-Term Municipal Bond and Intermediate Term Municipal Bond Portfolios,
                                       it states that each portfolio will maintain an effective dollar-weighted average maturity within
                                       a specific range. You stated that such disclosure should just refer to the dollar-weighted average
                                       maturity instead and requested that such disclosures be adjusted accordingly going forward.

    Response:
    Registrant confirms that, going forward,
    this disclosure will be shortened to “dollar-weighted average maturity.”

3. You noted that The Institutional International Equity Portfolio
                                       had invested, as of June 30, 2023, a significant portion of its assets in PLC investment companies
                                       and inquired as to whether related disclosure should be added to the Principal Investments/Risks
                                       disclosures.

Response: Registrant notes that the Principal Investment Strategy
                                    disclosure currently states that “The Portfolio may invest in securities issued by other investment
                                    companies, including ETFs and closed-end funds, that invest in equity securities of issuers located
                                    in non-U.S. countries” and has Principal Risk disclosure related to investment companies. Registrant
                                    will consider whether additional risk disclosure with respect to additional subsets, such as PLC
                                    investment companies, is appropriate.

4. You noted that The Emerging Markets Portfolio had significant
                                       investments in swaps and inquired as to whether additional related Principal Investment Strategy
                                       disclosure should be added.

Response: As we discussed, the majority of the swap investments
                                    held by The Emerging Markets Portfolio as of June 30, 2023 were not traditional swaps, but rather
                                    instruments that were used to provide the returns of China A Shares that the Portfolio was not allowed
                                    to own directly. These positions were managed by one Hong Kong-based Specialist Manager. That Specialist
                                    Manager has since been terminated and those positions liquidated.

With respect to Form N-CSR:

1. In the Management Discussion of Fund Performance
                                            (the “MDFP”), you noted that most Portfolios include a footnote that explains
                                            that certain Specialist Managers are also under contract with respect to the Portfolio, but
                                            are not discussed as they were

 January
                                            18, 2024

Page 3

not allocated any assets to manage
during the period. You further noted that, for some Portfolios, the content of this footnote appears to be different from the equivalent
disclosure in the Notes to the Financial Statements.

    Response:
    Registrant states that the disclosure in the Notes to the
    Financial Statements is accurate. The discrepancies noted were due to an oversight in the drafting of the MDFP.

2. You noted that certain Portfolios had recently changed their
                                       benchmark indices and that, while there was the required disclosure regarding the reason for the
                                       change in the prospectus, that disclosure did not appear in the annual report. Additionally, you
                                       requested that, in the future, explanations of the reason for a benchmark change provide more
                                       detail as to why the new benchmark was more appropriate.

Response: The new indices were added into the June 30, 2023
                                    annual report, but had not yet been designated as the primary benchmarks. Note that the discussion
                                    in the MDFP for these Portfolios still refers to the original benchmark index. By the November 1,
                                    2023 prospectus, the decision to switch to the new indices as primary benchmarks had been made and
                                    the required disclosure was added. This disclosure will be included in the next applicable shareholder
                                    reports. The Registrant will seek to expand upon the basis for the changes going forward.

3. You noted that the schedule of investments for the Institutional
                                       International Equity and Corporate Opportunities Portfolios indicate significant investments in
                                       investment companies and that under Reg. S-X 12-12, fn 2, they should be categorized both by type
                                       of investment (investment companies) and by related industry, country or geographic location.
                                       You asked how this requirement is, or should be, satisfied.

Response: Going forward, the Registrant will subdivide listings
                                    of investment companies with categories such as “domestic equity,” “domestic fixed-income,”
                                    “international equity,” etc.

4. You noted that the schedules of investments for both of the
                                       Core Fixed Income and U.S. Government Fixed Income Securities Portfolios show that they invest
                                       in the Vanguard Short-Term Inflation Protected Securities ETF and stated that you would have expected
                                       that the ETF would also have been listed in Note 8 on page 316.

Response: The Registrant states that to
                                    the extent that there are similar ETF investment positions exceeding 25%, such will be disclosed
                                    accordingly in Note 8 in future reports.

5. You noted that the International Equity and Institutional International
                                       Equity Portfolios show significant foreign tax claims as receivables. You asked that the Registrant
                                       identify the countries to which these claims relate and how the Trust monitors collectability.
                                       You also inquired as to whether the Portfolios plan to enter

January 18, 2024

Page 4

into a closing agreement with the
IRS and whether the Portfolios have incurred professional fees related to these reclaims and, if so, how they are accounted for in the
financial statements.

Response: The Registrant states that the receivables in question
                                    primarily relate to Germany, Switzerland, Denmark and France. The
                                    Portfolios have incurred professional fees related to certain incremental EU reclaims beyond the
                                    regular reclaim receivables recorded at June 30, 2023 that are included within the disclosed Professional
                                    Fees on the Statement of Operations for the applicable Portfolios. The professionals hired
                                    to evaluate and process the claims are also primarily responsible for monitoring collectability and
                                    the status of claims and filing options are reviewed periodically with management. There are no current
                                    plans to enter into a closing agreement with the IRS.

6. In the Financial Highlights, you noted that funds with AFFE
                                       are required to have a footnote stating that the ratios of expenses and income do not reflect
                                       the proportionate share of the expenses and income of the underlying funds and that you did not
                                       see such a footnote.

Response: The Registrant
                                    states that, for funds with a deemed material AFFE of 0.05% or greater disclosed in the then current
                                    prospectus, a footnote has been included in the Financial Highlights reflecting the fact that the
                                    expense ratios do not include acquired fund fees and expenses of investment companies in which a
                                    portfolio invests. (see pages 282, 283, 285). In the event that AFFE had been below 0.05% during
                                    the last fiscal year, but had subsequently risen above that threshold, the footnote would be included.

7. With respect to The Catholic SRI Growth Portfolio, you noted
                                       that Item C in Form N-CEN states that there was an expense waiver in place but the terms of such
                                       waiver were not disclosed in the Notes to the Financial Statements.

Response: The Registrant states that the waiver was voluntary
                                    and that there were no contractual “terms.” The waived fees were reflected
                                    as "Expenses waived and/or reimbursed by Adviser" on the Statement of Operations and such
                                    amounts are not recoupable in subsequent periods. Note that the management fee paid to the primary
                                    investment adviser has subsequently been eliminated entirely.

8. In the tables on pages 294 and 295 of the Annual Report, with
                                       respect to the purchased options disclosure in column 3, you noted that there is no such entry
                                       in the Statement of Operations and suggested adding a footnote explaining that the activity is
                                       included in the “Securities” line item.

Response: The
                                    Registrant states that, going forward, as applicable, it will add a footnote to the Notes tables
                                    referencing the Statement of Operations line item that such purchased options activity is included
                                    within.

January 18, 2024

Page 5

9. Also in the tables on pages 294 and 295 of the Annual Report,
                                       you stated that you were unable to reconcile the amounts for The Corporate Opportunities Portfolio
                                       under “Equity Risk Exposure” to the Statement of Operations.

Response: The Registrant states that both the Statement
                                    of Operations disclosure and the Notes Equity Risk Exposure table are correct, but the Notes table
                                    Interest Rate Risk Exposure should have reflected (6,090) vs 4,584 to on a net basis (10,674 minus
                                    6,090) reflect the 4,584 presented on the Statement of Operations.

10. You asked that the Registrant verify if the first statement
                                        in the paragraph preceding Note 2.C on page 291, regarding valuation of Level 3 securities, is
                                        accurate for the current fiscal year.

Response: The Registrant states that the statement in question
                                    was applicable for private placement loan
                                    commitment Level 3 investments during the fiscal year, although there were no such remaining investments
                                    as of fiscal year-end. Such disclosure will no longer be reflected absent newly applicable Level
                                    3 investments.

With respect to Form N-CEN:

1. You noted that the auditor’s internal control reports
                                       for the periods June 30, 2021, April 30, 2023 and June 30, 2023 did not appear to be signed and
                                       requested that the form be refiled with signed reports.

Response: The requested signed reports will be filed.

2. You noted that Item C.2 indicates that there are two share
                                       classes outstanding, while there is currently only one share class registered.

Response: The Registrant had two registered share classes as
                                    of June 30, 2023, however only one was outstanding. The Advisors Class shares were removed from the
                                    registration statement that was effective as of November 1, 2023, so this will not be an issue going
                                    forward.

3. You requested an explanation of why some Portfolios with investments
                                       in derivatives did not check any boxes in Item C.7.N and you noted that under Item C.7.N, you
                                       expected to see Portfolios with derivatives activity to check box