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SEC Response Letter

 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

February 21, 2020

 Via
Edgar

 Ms. Kathy Churko

Ms. Kate Whiting

 U.S.
Securities and Exchange Commission

 Division of Investment Management

100 F Street, N.E.

 Washington,
D.C. 20549

Re:
 HC Capital Trust (“Registrant”)

 File Nos.: 33-87762 and
811-08918

 Dear Ms. Churko and Ms. Whiting:

This correspondence is being provided to you in response to your comments communicated during two separate telephone
conversations on February 10, 2020 with respect to the Registrant’s filing on Form N-14 dated January 14, 2020.

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.

1.
 You requested that all information that was still missing in the preliminary filing be completed.

Response:
 The disclosure will be revised as requested.

2.
 In the Introduction, you requested that the statement that “If shareholders of a Target Portfolio do
not approve a Reorganization, no Reorganization will occur and the Board will consider what further action is appropriate for the Portfolios” be revised to improve clarity.

 February 21, 2020

 Page
 2

Response:
 The disclosure will be revised as requested.

3.
 On Page 1, under “What are the reasons for the proposed Reorganization?”, you requested that
the statement that the Reorganization would reduce overall costs be clarified in light of the fact that advisory fees for some of the Portfolios would increase.

Response:
 The disclosure will be revised as requested.

4.
 On Page 2, you requested that the statement that “As a result, the risks of owning shares of the
Acquiring Portfolio are similar to the risks of owning shares of each Target Portfolio, although the risks of the Portfolios may not be exactly the same” be clarified.

Response:
 The disclosure will be revised as requested.

5.
 With respect to the expense tables on page 3. You requested that:

(a)
 Registrant confirm that the tables represent current fees;

Response: The disclosure will be updated to reflect more current fees based on a February, 2020 supplement.

(b)
 A footnote be included noting that HC Advisors Shares have been fully redeemed and amounts shown are
estimates;

 Response: The disclosure will be revised as requested.

(c)
 Registrant explain why the fees shown here with respect to The Institutional Small Capitalization –
Mid Capitalization Portfolio differ from those in the Financial Highlights tables.

 Response:
The fees here differ from those in the Financial Highlights table as a result of updated allocations of Portfolio assets among the various Specialist Managers.

6.
 With respect to the “Board Considerations in Approving the Reorganization” disclosure on Page
15, you asked whether there were any additional reasons that the Advisor was recommending the Reorganization, such as declining assets in one or more Portfolios.

Response:
 As we discussed, the Trust Portfolios are exclusively available to clients of the Advisor, which uses the
Portfolios as asset allocation tools for such clients to allow them exposure to the advisory services of the various Specialist Managers.

 February 21, 2020

 Page
 3

 The reasons presented in the disclosure were the only reasons underlying the Advisor’s
recommendation.

7.
 Also in the “Board Considerations …” section, you requested that:

(a)
 Registrant note that while, as stated, “U.S. equity securities tend to have similar risk
characteristics across styles,” the various Portfolios have performed differently;

Response:
 The disclosure will be revised as requested.

(b)
 As noted previously, clarify the fact that the referenced “reduction in costs” does not refer
to the advisory fees, which are expected to increase;

Response:
 The disclosure will be revised as requested.

(c)
 Note whether the Board considered other alternatives.

Response:
 The disclosure will be revised as requested.

8.
 With respect to the “Costs of the Reorganization,” you requested that the method for the
allocation of costs among the Portfolios be disclosed.

Response:
 The disclosure will be revised as requested.

9.
 With respect to the Capitalization table on Page 20, you requested that adjustments be made for shares
and net assets.

Response:
 The disclosure will be revised as requested.

10.
 With respect to Note 1 in the Pro Forma Financial Information, you requested that Registrant confirm that
there will be no Portfolio repositioning related to the Reorganizations.

Response:
 Registrant confirms that there will be no Portfolio repositioning related to the Reorganizations,
although all each of the Portfolios will continue to conduct transactions in the regular course of their business in the period leading up, to and immediately subsequent to, the Reorganizations.

11.
 You noted that Net Assets presented in Note 2 in the Pro Forma Financial Information have been adjusted
for expected expenses of the Reorganizations and requested that the same adjustments be made to the Capitalization table.

 February 21, 2020

 Page
 4

Response:
 The disclosure will be revised as requested.

12.
 With respect to Note 3 in the Pro Forma Financial Information, “Pro Forma Adjustments,” you
asked whether there were any significant changes being made to any of the existing contracts.

Response:
 No material changes will be made to any existing contracts with Trust service providers as a result of
the Reorganizations.

13.
 You asked that Registrant confirm that the Acquiring Portfolio will be the performance survivor as well
as the accounting survivor.

Response:
 Registrant confirms that the Acquiring Portfolio will be the performance survivor as well as the
accounting survivor.

 Very truly yours,

/s/ Don E. Felice

 Don E. Felice