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  Troutman Pepper Hamilton Sanders LLP

3000 Two Logan Square, Eighteenth and Arch Streets

Philadelphia, PA 19103-2799

troutman.com

John P. Falco

john.falco@troutman.com

June
8, 2023

Via
EDGAR

Division
of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington,
D.C. 20549

Attn:
Ms. Megan F. Miller

    Re:
    Third
    Avenue Trust

    File Nos. 333-20891 and 811-08039

Dear
Ms. Miller:

On
behalf of Third Avenue Trust (“the Trust”), this letter is being provided to the Commission to respond to supplemental comments
provided orally by the Commission’s Staff (the “Staff”) on May 16, 2023 in connection with the Staff’s review,
pursuant to Section 408 of the Sarbanes-Oxley Act of 2002, of the Trust’s Form N-CSR filing submitted to the Commission via EDGAR
on January 6, 2023 (each a “2022 Report” and, together, the “2022 Reports”) including the annual reports to shareholders
of the Third Avenue Value Fund, Third Avenue Small-Cap Value Fund, Third Avenue Real Estate Value Fund and Third Avenue International
Real Estate Value Fund and the Trust’s Form N-CEN filing for the fiscal year ended October 31, 2022 submitted to the Commission
via EDGAR on January 12, 2023.

The
Trust appreciates the opportunity to address the Staff’s supplemental comments. Set forth below are the Staff’s supplemental
comments with respect to the Third Avenue Small-Cap Value Fund’s (the “Fund”) 2022 Report followed by the Trust’s
response to the comments.

*          *          *

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 2

 1. With
                                            respect to the distribution of realized gains from Central Securities Corporation, please
                                            explain in correspondence how the distribution was accounted for in the current year and
                                            prior year. Please provide a Staff Accounting Bulletin No. 99 (“SAB 99”) analysis.

Response:
The Fund received capital gain distributions from Central Securities Corporation (“CSC”) of $314,723, $111,121, and $11,121
in 2022, 2021, and 2020, respectively. The distributions represent 0.19%, 0.11% and 0.02% of net assets, respectively, which Fund management
concludes are immaterial as these amounts are below 0.50% of net assets. The capital gain distributions were inadvertently reported as
income within “Dividends – unaffiliated issuers” in the Fund’s Statement of Operations rather than “Distributions
of realized gains by underlying investment companies.” This resulted in an overstatement of investment income of 14%, 5% and 1%,
respectively.

Fund
management’s SAB 99 analysis follows below.

Impact
Analysis

(a)
Impact to Shareholders

The
impact of the incorrect classification of income (between dividend income and long-term capital gain) had no effect on the Fund’s
net assets, net asset value (“NAV”) or shareholder performance. From a tax perspective, shareholders of the Fund were not
impacted by the classification of CSC’s distributions as income (rather than realized gain) because all calendar year 2022 income
distributions to shareholders were reported as qualified dividend income, and, consequently, are taxed at the long-term capital gain
rates that such distributions would be taxed at if such amounts were reported as long-term capital gain distributions. The classification
error would not have caused a shareholder to reach a different conclusion or act differently because the total distribution and the corresponding
taxes paid would have been the same regardless of the classification. Therefore, there was no impact to shareholders’ taxable distributions.

(b)
Financial Statement Impact

The
issue was identified after the issuance of the Fund’s October 31, 2022 financial statements. When reviewing the Fund’s annual
report, Fund management determined the following Statement of Operations accounts would be affected due to a reclassification of income:

    Journal
    Entry

    Debit

    Credit

    Dividend
    income

    $ 314,723.00

    Realized
    gain / loss on investments - investment companies

    $ 314,723.00

    Audited
 10/31/2022
 Annual Report

    Updated
 Balance

    Dividends
    - unaffiliated issuers

    $ 2,000,917

    $ 1,686,194

    Total
    investment income

    $ 2,235,142

    $ 1,920,419

    Net
    investment income

    $ 346,964

    $ 32,241

    Net
    realized gain on investments - investment companies

    $ -

    $ 314,723

    Net
    gain/(loss) on investments, options and foreign currency transactions

    $ 2,221,340

    $ 2,536,063

    Net
    increase/(decrease) in net assets resulting from operations

    $ 2,568,304

    $ 2,568,304

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 3

Below
is the impact to the Fund’s financial highlight per share calculations and net investment income ratio:

    Audited
 10/31/2022
 Annual Report

    Updated
 Balance

    Investor
    Class

    Per
    share:

    Net
    investment loss

      (0.01 )

      (0.04 )

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      0.25

      0.28

    Total
    from investment operations

      0.24

      0.24

    Ratio
    of net investment income to average net assets

      -0.03 %

      -0.21 %

    Institutionals
    Class

    Per
    share:

    Net
    investment loss

      0.04

      0.00

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      0.26

      0.30

    Total
    from investment operations

      0.30

      0.30

    Ratio
    of net investment income to average net assets

      0.22 %

      0.02 %

    Z
    Class

    Per
    share:

    Net
    investment loss

      0.06

      0.02

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      0.26

      0.30

    Total
    from investment operations

      0.32

      0.32

    Ratio
    of net investment income to average net assets

      0.30 %

      0.12 %

No
adjustments were made to the current year (11/01/2022 – present) general ledger pertaining to the prior year error (11/01/2021
– 10/31/2022).

Although
the capital gain distribution was not reported into realized gain/(loss), Fund management considers these amounts immaterial to the users
of the financial statements and financial highlights in the Fund’s 2022 Report.

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 4

(c)
Tax Impact

Within
the Fund’s 2022 Report footnotes, only the tax character of distributions and accumulated undistributed earnings would need to
be updated. The components of net assets would remain the same since the error is within retained earnings. See below comparison:

    Tax
    character of dividends and distributions paid during the year ended 10/31/2022

    Audited
 10/31/2022
 Annual Report

    Updated
 Balance

    Ordinary
    income

    $ 505,276

    $ 329,732

    Net
    capital gains

    $ 13,422,778

    $ 13,598,322

    Total

    $ 13,928,054

    $ 13,928,054

(d)
Prior Year Impact

The
Fund initially purchased CSC in March 2020. To date, the Fund has made no additional purchases or sales of CSC. Below is a listing of
the distributions received by the Fund in 2020 and 2021:

    2020

    % of
 Net Assets

    Ordinary
    Income Distribution

      11,121

      0.01 %

    Capital
    Gain Distribution

      11,121

      0.01 %

    Total
    Distribution

      22,242

      0.02 %

    Net
    Assets

      134,829,456

    2021

    % of
 Net Assets

    Ordinary
    Income Distribution

      77,847

      0.04 %

    Capital
    Gain Distribution

      111,121

      0.06 %

    Total
    Distribution

      188,968

      0.11 %

    Net
    Assets

      174,057,350

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 5

Below
is the impact to the Fund’s financial highlight per share calculations and net investment income ratio in 2020 and 2021:

    2021

    Audited

10/31/2021
 Annual Report

    Updated

Balance

    Investor
    Class

    Per
    share:

    Net
    investment loss

      (0.05 )

      (0.06 )

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      6.48

      6.49

    Total
    from investment operations

      6.43

      6.43

    Ratio
    of net investment income to average net assets

      -0.24 %

      -0.31 %

    Institutionals
    Class

    Per
    share:

    Net
    investment loss

      0.02

      0.00

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      6.61

      6.63

    Total
    from investment operations

      6.63

      6.63

    Ratio
    of net investment income to average net assets

      0.08 %

      0.01 %

    Z
    Class

    Per
    share:

    Net
    investment loss

      0.03

      0.02

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      6.65

      6.66

    Total
    from investment operations

      6.68

      6.68

    Ratio
    of net investment income to average net assets

      0.15 %

      0.09 %

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 6

 2020

    Audited

10/31/2020
 Annual Report

    Updated

Balance

    Investor
    Class

    Per
    share:

    Net
    investment loss

      (0.06 )

      (0.06 )

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      (2.40 )

      (2.40 )

    Total
    from investment operations

      (2.46 )

      (2.46 )

    Ratio
    of net investment income to average net assets

      -0.37 %

      -0.37 %

    Institutionals
    Class

    Per
    share:

    Net
    investment loss

      -0.02

      -0.02

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      -2.46

      -2.46

    Total
    from investment operations

      (2.48 )

      (2.48 )

    Ratio
    of net investment income to average net assets

      -0.12 %

      -0.12 %

    Z
    Class

    Per
    share:

    Net
    investment loss

      0.00

      0.00

    Net
    gain/(loss) on investment transactions (both realized and unrealized)

      -2.46

      -2.46

    Total
    from investment operations

      (2.46 )

      (2.46 )

    Ratio
    of net investment income to average net assets

      -0.02 %

      -0.02 %

The
Fund recorded the total distribution in ordinary income. Although the capital gain distribution was not reported into realized gain/(loss),
Fund management considers these amounts immaterial to the users of the financial statements and financial highlights in the Fund’s
2020 and 2021 annual reports.

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 7

Materiality
Assessment

In
evaluating the materiality of the misstatement, Fund management considered SAB 99.

 ● Whether
                                            the misstatement arises from an item capable of precise measurement or whether it arises
                                            from an estimate and, if so, the degree of imprecision inherent in the estimate.

 ○ Fund
management’s response: The error only occurred within one investment type and one holding (closed end/investment companies)
and not a larger investment class. Further, Fund management reviewed the purchase and sales journal for each of the Trust’s series
for the year 11/01/2021 – 10/31/2022 and noted that no other investment companies paid capital gain distributions during such year.
Additionally, the error amount is a known amount obtained through publicly available information from CSC (ordinary income and long-term
capital gain characteristics).

 ● Whether
                                            the misstatement masks a change in earnings or other trends.

 ○ Fund
management’s response: There was no impact to the Fund’s NAV per share or net assets, as this was an error between income
accounts. Neither shareholder investment value nor cost basis are impacted. Shareholder transactions (purchases/redemptions) were unaffected.
There was no impact to the Fund’s total return. There was no impact to the taxability of the Fund’s distributions.

 ● Whether
                                            the misstatement hides a failure to meet analysts’ consensus expectations for the enterprise.

 ○ Fund
management’s response: The investment strategy of the Fund is focused on acquiring equity securities of well-financed small
companies at a discount to what the Fund believes is their intrinsic value. The Fund’s investment strategy was not affected by
the misstatement described above.

 ● Whether
                                            the misstatement changes a loss into income or vice versa.

 ○ Fund
management’s response: The per share “Total from investment operations” in the Fund’s financial highlights
remained unchanged. Only certain per share components would be updated due to this error, however, not in total. The ratio of net investment
income remains as a positive (Institutional and Z Class) or negative (Investor Class) before and after the error was identified.

 ● Whether
                                            the misstatement concerns a segment or other portion of the registrant’s business that
                                            has been identified as playing a significant role in the registrant’s operations or
                                            profitability.

 ○ Fund
management’s response: Not applicable.

 ● Whether
                                            the misstatement affects the registrant’s compliance with regulatory requirements.

 ○ Fund
management’s response: The misstatement does not affect the Fund’s compliance with regulatory requirements.

Division of Investment Management

U.S. Securities and Exchange Commission

June 8, 2023

Page 8

 ● Whether
                                            the misstatement affects the registrant’s compliance with loan covenants or other contractual
                                            requirements.

 ○ Fund
management’s response: Not applicable.

 ● Whether
                                            the misstatement has the effect of increasing management’s compensation – for
                                            example, by satisfying requirements for the award of bonuses or other forms of incentive
                                            compensation.

 ○ Fund
management’s response: The advisory fee is calculated using net assets and a contractual rate. This misstatement did not impact
net assets; therefore, the advisory fee was not impacted.

 ● Whether
                                            the misstatement involves concealment of an unlawful transaction.

 ○ Fund
management’s response: The error was unintentional. There was no fraud committed or intent to cause fraud.

In
conclusion, the Fund did not receive any other distributions from investment companies during 2022, 2021 and 2020 other than from CSC
and the Fund confirms that the distribution from CSC was not material to the “Net increase in net assets resulting from operations”
line item in the Fund’s financial statements for the years ended October 31, 2022, October 31, 2021, and October 31, 2020.

 2. Please
                                            confirm that the Fund’s auditors reviewed the Trust’s correspondence submitted
                                            to the Staff on May 10, 2023.

Response:
Confirmed, the Fund’s auditors reviewed the Trust’s correspondence submitted to the Staff on May 10, 2023. Additionally,
the Fund’s auditors have reviewed this correspondence.

 3. Please