SecProbe.io

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            Stradley Ronon Stevens & Young, LLP

            2000 K Street, N.W., Suite 700

            Washington, D.C. 20006

            Telephone  202-822-9611

            Fax  202-822-0140

            www.stradley.com

    Cillian M. Lynch

    (202) 419-8416

    clynch@stradley.com

    January 24, 2023

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Investment Management

    100 F Street, N.E.

    Washington, D.C. 20549-9303

              Attention:

              Ms. Alison White, Esquire

              Re:

              GuideStone Funds

              File Nos. 333-53432, 811-10263

    Dear Ms. White:

    On behalf of GuideStone Funds (the “Registrant”) below you will find the Registrant’s responses to the comments
      conveyed by you on December 1, 2022, with regard to Post-Effective Amendment No. 91 (the “Amendment”) to the Registrant’s registration statement on Form N-1A.  The Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on
      November 10, 2022, pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), and Rule 485(a)(2) under the Securities Act of 1933, as amended (the “Securities Act”).

    Below we have provided your comments and the Registrant’s response to each comment.  These responses will be
      incorporated into a post-effective amendment filing to be made pursuant to Rule 485(b) of the Securities Act (the “485(b) Filing").  Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration
      Statement.

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        general comments

        1) Comment:  Please disclose how each Fund intends to measure and monitor whether it is achieving its ESG-related impacts, and over what time periods.  The disclosure should include the specific metrics or key performance indicators that
            each Fund will use to assure that each investment aligns with its impact investing mandate.  Please also consider walking us through an example in correspondence, to help us to better understand the process.

        Response:  Registrant respectfully declines to revise its disclosure as Form N-1A does not contain a requirement to disclose how a Fund intends to measure and monitor whether it is achieving its ESG-related impacts.
            Registrant is aware that the SEC has recently proposed amendments to form N-1A requiring disclosure of information about a Fund’s implementation of ESG factors in its principal investment strategies.  If such amendments are adopted as proposed,
            or if the SEC otherwise releases a publicly available position specifically requiring ESG-related disclosure, Registrant will amend its disclosure accordingly.

        2) Comment:  Please disclose whether and where the Funds will disclose their progress on achieving their stated impacts.  If the Funds will not publicly disclose this information, explain to us why that is appropriate.

        Response:  Registrant directs the Staff to its response to Comment 1 above.

        3) Comment:  Each Fund’s name includes the word “impact”.  We believe this word suggests a type of investment and, therefore, each Fund should include an 80% names rule policy that covers the term.

        Response:  Registrant respectfully disagrees that the word “impact” suggests a type of investment that requires an 80% names rule policy to cover the term.  Rule 35d-1 under the 1940 Act (the “Names Rule”) requires
            that an “investment company with a name that suggests that the company focuses its investments in a particular type of investment (e.g., the ABC Stock Fund or XYZ Bond Fund) or in investments in a particular industry . . . invest at least 80%
            of its assets in the type of investment suggested by the name.”  Unlike the terms “stocks” and “bonds”, the term “impact” does not refer to a particular type of investment, and further, it does not connote investments in any given industry.
            Rather, Registrant submits that the term “impact” is similar to terms such as “growth” and “value” that the SEC has stated connote types of investment strategies as opposed to types of investments.  Registrant is aware that the SEC has recently
            proposed amendments to the Names Rule.  If such amendments are adopted as proposed, or the SEC otherwise releases a publicly available position clarifying how terms such as “impact” are to be treated for purposes of a fund’s 80% policy,
            Registrant will amend its disclosure accordingly.

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        4) Comment:  Please explain in the filing how each Fund will apply its impact investing criteria to: (1) municipal bonds; (2) obligations issued or guaranteed by the U.S. government, its agencies and instrumentalities; and (3) obligations
            issued or guaranteed by foreign governments.  With regard to the third category, it is unclear how securities issued by foreign governments can meet the Fund's impact criteria.

        Response:  Registrant has added the following as the fourth bullet point under each Fund’s “Principal Investment Strategies” section:

        When selecting investments, the Adviser and/or Sub-Adviser may consider whether investments promote impact goals, including, but not
          limited to, decent work and economic growth, good health and well-being, quality education, reduced inequalities, affordable and clean energy and responsible consumption and production.

        Registrant also directs the Staff to its response to Comment 19.

        prospectus

        5) Comment:  Please disclose in the prospectus how the Funds will approach relevant ESG proxy issues for their portfolio companies.  Alternatively, explain in correspondence why you believe that such disclosure is not required.

        Response:  Registrant respectfully declines to add additional disclosure as it believes its current disclosure is satisfactory and consistent with the requirements of Form N-1A.  Registrant notes that it has included
            its proxy voting policies and procedures the Funds use to determine how to vote proxies relating to portfolio securities consistent with Item 17(f) of Form N-1A.  Consistent with its fiduciary duty to the Funds, Registrant has delegated its
            proxy voting duties to the sub-advisers (each, a “Sub-Adviser”) of each Fund, whose proxy voting policies are also included or otherwise described in the Statement of Additional Information (“SAI”).  Each Sub-Adviser may consider ESG proxy
            issues for the Funds’ portfolio companies as a consideration in any vote, consistent with their own fiduciary duties to the Funds.

        6) Comment:  Please confirm the fee waiver disclosed in the “Annual Fund Operating Expenses” table is reflected in the “Expense Example” table for each Fund only for the period it is in place.

        Response:  Registrant confirms the fee waiver disclosed in the “Annual Fund Operating Expenses” table is reflected in the “Expense Example” table for each Fund only for the period it is in place.

        7) Comment:  Please show the shareholder servicing fees in the “Annual Fund Operating Expenses” tables for Investor Class shares of each Fund as a separate line item pursuant to Instruction 3(b) to Item 3 of Form N-1A.

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        Response:  Instruction 3(b) to Item 3 of Form N-1A states “Under an appropriate caption or a subcaption of “Other Expenses,” disclose the amount of any distribution or similar
              expenses deducted from the Fund’s assets other than pursuant to a rule 12b-1 plan” (emphasis added).  Instruction 3(c) to Item 3 of Form N-1A further provides that ‘“Other Expenses” include all expenses not otherwise disclosed in the
            table that are deducted from the Fund’s assets or charged to all shareholder accounts.”  As disclosed in the prospectus and SAI under the heading “Shareholder Servicing Arrangements”, the Funds’ Service Plan authorizes the Investor Class to pay
            shareholder “service” fees.  The SAI, as revised for the 485(b) filing, further states:

        Service activities include, but are not limited to, such services as answering shareholder inquiries; establishing and maintaining
          shareholder accounts; providing account statements and documents; delivering reports and other communication from a Fund, as may be required by applicable law and regulation; aggregating and processing purchase and redemption orders; processing
          dividend payments; monitoring shareholder compliance with applicable frequent trading policy; cooperating with the Trust to facilitate implementation of its anti-money laundering program; and providing such other related personal and/or elective
          services as the shareholder may request.

        Conversely, activities undertaken by a distributor, as provided by Rule 12b-1(a)(2) under the 1940 Act, are those “primarily intended to
          result in the sale of shares … including … advertising, compensation of underwriters, dealers, and sales personnel, the printing and mailing of prospectuses to other than current shareholders, and the printing and mailing of sales literature[.]”
          The “service” activities provided under the Service Plan are routine services related to the maintenance of shareholder accounts and are not “intended to result in the sale of shares” or otherwise “similar” to expenses arising from “distribution”
          activities, and therefore Registrant submits that Instruction 3(b) does not apply.  Registrant notes this position is consistent with the practices of various other mutual funds.  As such, respectfully declines to add a separate line item to the
          “Annual Fund Operating Expenses” tables as it believes including its shareholder servicing fees in the “Other Expenses” caption for each Fund is consistent with the requirements of Instructions 3(b)-(c) of Item 3 of Form N-1A.  Registrant notes
          the above discussion reflects disclosure updates that will be made in the 485(b) Filing to reflect amendments to the Service Plan which are not material to this response.

        8) Comment:  Since the “other expenses” as disclosed in the “Annual Fund Operating Expenses” table are different for the two classes of each Fund, please briefly explain what would cause such difference (aside from shareholder servicing
            fees) and advise where in the prospectus such differences are disclosed.  In addition, please explain in correspondence how such differences are consistent with Rule 18f-3 under the 1940 Act.

        Response:  Registrant notes that the primary item that causes “Other expenses” to vary among the Institutional Class and the Investor Class of the Fund is a 0.25% shareholder

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        servicing fee that is borne by the Investor Class of the Funds, as referenced by the Staff.  This is disclosed on page 46 of the prospectus
          and page 68 of the SAI under “Shareholder Servicing Arrangements.”  In addition, the transfer agency fees and expenses borne by the Investor Class are expected to be higher than those borne by the Institutional Class, especially due to the fact
          that the Institutional Class assets under management are expected to be more than the Investor Class assets under management for each Fund.

        In addition, the Rule 18f-3 Plan approved by the Board of Trustees (the “Trustees”) of the Funds provides that the following types of
          expenses specific to each class shall be allocated to such class: (i) transfer agency costs; (ii) SEC and blue sky registration or qualification fees; (iii) printing and postage expenses related to printing and distributing materials such as
          shareholder reports, prospectuses and information statements to current shareholders of a particular class or to regulatory authorities with respect to such class; (iv) audit or accounting fees or expenses relating solely to such class; (v) the
          expenses of administrative personnel and services as required to support the shareholders of such class; (vi) litigation or other legal expenses relating solely to such class; (vii) Trustees’ fees and expenses incurred as a result of issues
          relating solely to such class; and (viii) other expenses subsequently identified and determined to be properly allocated to such class (provided that in no event shall these include advisory or custodial fees, tax return preparation fees or other
          expenses related to the management of the Funds’ assets).  On page 67 of the SAI, under “Shares of Beneficial Interest,” the Funds disclose that expenses allocated to a Class will be borne by such Class.  The Rule 18f-3 Plan will be filed as
          Exhibit (n) to Item 28 of the Registration Statement with the 485(b) Filing.

        As required by Rule 18f-3(a)(1)(i) under the 1940 Act, each class has a different arrangement for shareholder services, and pays all of the
          expenses of that arrangement (i.e., the 0.25% shareholder servicing fee applicable to the Investor, and not the Institutional, Class).  Rule 18f-3(a)(1)(ii) permits each class to pay a different share of
          other expenses, not including advisory or custodial fees or other expenses related to the management of the company’s assets, if these expenses are actually incurred in a different amount by that class, or if the class receives services of a
          different kind or to a different degree than other classes.

        9) Comment:  With respect to the disclosure under the “Principal Investment Strategies” section for each Fund, it is unclear how investments in nonprofit organizations provide financial returns; are these investments, or donations?  If
            they are investments, how are they evaluated?  If they are donations, how does the Adviser consider these investments from a fiduciary perspective?  Please provide some examples of investments in nonprofits the Registrant has made in the past
            for other impact funds, if any.

        Response:  The Funds invest in corporate bonds issued by nonprofit organizations.  Registrant respectfully directs the Staff to its semi-annual report for the reporting period ended June
            30, 2022, filed with the SEC on September 1, 2022, which discloses various investments in nonprofit organizations made by the Global Impact Fund.  “BlueHub Loan

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         Fund, Inc.” and “Preservation Of Affordable Housing, Inc.” are examples of two such issuers.

        10) Comment:  Given the Funds may invest in the GuideStone Funds Money Market Fund, should there be a line in the “Annual Fund Operating Expenses” table of each Fund for acquired fund fees and expenses
            (“AFFE”)?  Please advise or revise.

        Response:  Each Fund’s investments in the Guidestone Funds Money Market Fund is expected to be less than 0.01% of such Fund’s average daily net assets during its initial fiscal period and, accordingly, the amount of
            AFFE has been included in the “Other Expenses” line of the Fund’s “Annual Fund Operating Expenses” table as permitted by Instruction 3(f)(i) of Item 3 of Form N-1A.

        11) Comment:  The Impact Bond Fund’s “Principal Investment Strategies” section provides, under the same bullet point, that the Fund invests primarily in “The U.S. government, its agencies and instrumentalities, banks and corporations.”
            Please consider separating banks and corporations into their own bullet points.

        Response:  Registrant has revised its disclosure consistent with the Staff’s instru