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RBC Funds Trust

 1900 K Street, NW

 Washington, DC 20006-1110

+1 202 261 3300 Main

 +1 202 261 3333 Fax

www.dechert.com

 STEPHEN T. COHEN

stephen.cohen@dechert.com

 +1 202 261 3304 Direct

 December 8, 2022

VIA EDGAR

 Kimberly Browning

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

 Washington,
D.C. 20549-0504

Re:
 RBC Funds Trust (the “Trust” or “Registrant”)

 File Nos.: 333-111986;
811-21475

 Dear Ms. Browning:

We are writing in response to comments provided telephonically on November 3, 2022 with respect to Post-Effective
Amendment No. 164 filed on Form N-1A on September 30, 2022 for the Trust under the Securities Act of 1933, as amended (“Securities Act”), and the Investment Company Act of 1940, as amended
(“1940 Act”). The Trust has considered your comments and has authorized us to make the responses and changes discussed below to the registration statement on its behalf. Capitalized terms used but not defined in this letter have the
meanings given to them in the Fund’s registration statement.

 Summary Prospectus - All Funds

Comment 1.
 In accordance with Form N-1A, please revise each Fund’s Fees
and Expenses of the Fund disclosure to bold the second sentence of the disclosure and provide a cross reference to the SAI in the last sentence of the disclosure.

Response 1. The Trust has revised each Fund’s Fees and Expenses of the Fund disclosure to state the following:

 This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund. You may pay
other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below. You may qualify for sales charge discounts on purchases of Class A shares of the Fund if you and
your family invest, or agree to invest in the future, at least $25,000 in Class A shares of the RBC Funds. More information about these and other discounts is available from your financial intermediary and under the subheading “Reducing
the Initial Sales Charge on Purchases of Class A Shares” on page […] of this Prospectus.

 The Funds do not have a corresponding disclosure in the SAI and therefore a
cross reference to the SAI is not provided.

Comment 2.
 If the Funds will invest in other investment companies, please add “Acquired Fund Fees and
Expenses” as a separate line item of the fee table, as applicable.

 Response 2. The
Trust confirms that each Fund’s estimated AFFE is not expected to exceed 0.01% of the Fund’s average net assets, and, therefore, a line for AFFE is not necessary in the fees and expenses table.

Comment 3.
 If the Funds will engage in short selling, please confirm that expenses such as dividends paid on stocks
sold short are included in the “Other Expenses” line item of the fee table or include such expenses as a separate line item in the fee table.

Response 3. The Trust confirms that the Funds will not engage in short selling.

Comment 4.
 Please confirm that each Fund’s strategies and risks in Item 4 summarize and align with the strategy
and risk disclosures in Item 9.

 Response 4. Notwithstanding the changes discussed below,
the Trust confirms that each Fund’s strategies and risks in Item 4 summarize and align with the strategy and risk disclosures in Item 9.

Comment 5.
 Please remove vague phrases throughout the registration statement, including “such as” and
“but [are] not limited to”.

 Response 5. The Trust has made the requested changes.

Comment 6.
 If the Funds will invest in contingent convertible securities, please add related disclosure and provide
the amount the Funds will invest in contingent convertible securities.

 Response 6. The
Trust confirms that the Funds will not principally invest in contingent convertible securities.

Comment 7.
 Please add risks related to the Funds’ investments in depositary receipts and clarify whether the
Funds may invest in sponsored and/or unsponsored depositary receipts.

 Response 7. The Trust
has added the following Depositary Receipts Risk disclosure to Item 4 and Item 9 of Form N-1A as set forth below:

 Summary Risk:

Depositary Receipts Risk. Depositary receipts, such as American depositary receipts (“ADRs“), global
depositary receipts (“GDRs“), and European depositary receipts (“EDRs“), may be issued in sponsored or un-sponsored programs. They may be traded in the over-the-counter (“OTC”) market or on a regional exchange, or may otherwise have limited liquidity. The prices of depositary receipts may differ from the prices of securities upon which they are
based. In a sponsored program, a security issuer has made arrangements to have its securities traded in the form of depositary receipts. In an un-sponsored program, the issuer may not be directly involved in
the creation of the program. Holders of unsponsored depositary receipts generally bear all the costs of the facility. The depository usually charges fees upon deposit and withdrawal of the underlying securities, the conversion of dividends into U.S.
dollars or other currency, the disposition of non-cash distributions, and the performance of other services. Depositary receipts involve many of the same risks as direct investments in foreign securities.
These risks include: fluctuations in currency exchange rates, which are affected by international balances of payments and other economic and financial conditions; government intervention; and speculation. With respect to certain foreign countries,
there is the possibility of expropriation or nationalization of assets, confiscatory taxation, political and social upheaval, and economic instability. Investments in depositary receipts that are exchange traded or OTC may also subject the Fund to
liquidity risk. This risk is enhanced in connection with OTC depositary receipts.

 Item 9 Principal Risks:

 Depositary Receipts Risk. Investments in securities of foreign companies in the form of American
depositary receipts (“ADRs”), Global depositary receipts (“GDRs”), and European depositary receipts (“EDRs”) are subject to certain risks. ADRs typically are issued by a U.S. bank or trust company and evidence ownership
of underlying securities issued by a foreign corporation. EDRs and GDRs typically are issued by foreign banks or trust companies, although they may be issued by U.S. banks or trust companies, and evidence ownership of underlying securities issued by
either a foreign or U.S. corporation. Where the custodian or similar financial institution that holds the issuer’s shares in a trust account is located in a country that does not have developed financial markets, a Fund could be exposed to the
credit risk of the custodian or financial institution and greater market risk. In addition, the depository institution may not have physical custody of the underlying securities at all times and may charge fees for various services, including
forwarding dividends and interest and corporate actions. A Fund would be expected to pay a share of the additional fees, which it would not pay if investing directly in the foreign securities. A Fund may experience delays in receiving its dividend
and interest payments or exercising rights as a shareholder.

 Depositary receipts may be issued in sponsored or un-sponsored programs. In a sponsored program, a security issuer has made arrangements to have its securities traded in the form of depositary receipts. In an un-sponsored
program, the issuer may not be directly involved in the creation of the program. Although the U.S. regulatory requirements applicable to ADRs generally are similar for both sponsored and un-sponsored programs,
in some cases it may be easier to obtain financial and other information from an issuer that has participated in the creation of a sponsored program. To the extent the Fund invests in depositary receipts of an
un-sponsored program, there may be an increased possibility the Fund would not become aware of and be able to respond to corporate actions such as stock splits or rights offerings involving the foreign issuer
on a timely basis, as the issuers of unsponsored depositary receipts are not obligated to disclose information that is considered material in the U.S.

Depositary receipts involve many of the same risks as direct investments in foreign securities. These risks include:
fluctuations in currency exchange rates, which are affected by international balances of payments and other economic and financial conditions; government intervention; and speculation. With respect to certain foreign countries, there is the
possibility of expropriation or nationalization of assets, confiscatory taxation, political and social upheaval, and economic instability. Investments in depositary receipts that are traded over the counter may also subject a Fund to liquidity risk.

Comment 8.
 Please confirm whether each Fund will invest in Brazil bonds issued in Brazilian Real.

 Response 8. The Trust confirms that the Funds will not invest in Brazil bonds issued in
Brazilian Real, and the references to such investments have been removed.

Comment 9:
 Each Fund includes “Geographic Focused Risk” and “Market Risk” as principal risks.
Please state whether the Funds have any allocation policies with respect to geographic regions, countries or sectors. If so, please clarify.

Response 9. Each Fund has revised its principal investment strategies to clarify the Fund’s allocation policies
with respect to geographic regions, countries and sectors.

Comment 10.
 Please confirm whether the Funds will use derivatives for its principal investment strategies and if so,
please add corresponding disclosure detailing the types of derivatives and any related risk disclosure.

Response 10. The Trust confirms that the Funds will not use derivatives for its principal investment strategies and
the references to such investments have been removed.

Comment 11.
 Given that each Fund includes ESG as a part of its principal investment strategies, please consider
adding a corresponding principal risk disclosure. If a corresponding principal risk disclosure will not be added, please explain why not.

Response 11. The consideration and integration of ESG factors is part of the
Sub-Advisor’s investment process for managing the Funds and is not a principal investment strategy of the Funds. In contrast to funds where it may be appropriate to include ESG risk, the Funds do not seek
to invest a certain percentage of their assets in companies that meet ESG goals. Accordingly, the Trust does not believe that adding ESG Risk as a principal risk disclosure is appropriate.

Comment 12.
 Each Fund’s principal investment strategies states, “[c]ompanies with business models that have
‘very high’ ESG risks are restricted from investment because the Sub-Advisor views such investments as unlikely to be sustainable in the long term.” Please define “very high” and
clarify what is meant by the term “restricted”.

 Response 12. The Funds have
removed the statement referenced above from their Item 4 principal investment strategies and Item 9 disclosures.

Comment 13.
 Please clarify what is meant by “ESG checklists” in plain English.

Response 13. The Funds have removed the statement referenced above from their Item 4 principal investment strategies
and revised the disclosure in each Fund’s Item 9 disclosure to state the following (new language underlined):

 The Sub-Advisor’s ESG integration approach incorporates proprietary ESG checklists (i.e., scorecards that evaluate companies on a range of ESG matters), internal research, analysis and discussion, and ESG
data from third party providers. The Sub-Advisor employs a fundamental investment process that considers a wide range of factors, and no one factor or consideration is determinative.

Comment 14.
 In plain English, please clarify the following sentence: “ESG engagements are undertaken to gain
insight and/or influence (or identify the need to influence) involving ESG practices and/or improve ESG disclosure, to the extent possible.”

Response 14. The Funds have removed the statement referenced above from their Item 4 principal investment strategies
and revised the disclosure in each Fund’s Item 9 disclosure to state the following:

 The Sub-Adviser may undertake ESG engagement to seek to gain insight regarding a company’s ESG practices and/or improve a company’s ESG disclosure. For example, the
Sub-Advisor may engage with management of certain companies regarding corporate governance practices as well as what the Sub-Advisor deems to be materially important
environmental and/or social issues facing a company.

Comment 15.
 Each Fund’s principal investment strategies states, “[t]he
Sub-Advisor also votes all proxies in accordance with its fiduciary duty”. Please add a cross reference to that discussion to Appendix B – Proxy Voting Guidelines.

Response 15. The Funds have made the requested change to the Item 9 disclosure.

Comment 16.
 For each Fund, please explain how the Advisor and/or Sub-Advisor
decides to sell securities.

 Response 16. The Trust has added the following disclosure to
each Fund’s principal investment strategies:

 The Sub-Advisor may sell
securities for a number of reasons such as a change in the business model, a more attractive opportunity arises, portfolio construction benefits and less perceived potential upside.

Comment 17.
 Please enhance the Equity Market Risk disclosure to identify the types of equity securities and disclose
the rights of holders of common and preferred stock.

 Response 17. The Funds have revised
the Equity Market Risk disclosure to state the following (new language underlined):

 Summary Risk:

Equity Market Risk. Equity securities represent an ownership interest, or the right to acquire an ownership
interest, in an issuer. The values of equity securities, including common stocks, preferred stocks, convertible securities, depositary receipts, participation notes, warrants, rights and initial public offerings, may decline due to general
market conditions which are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor
sentiment generally. Common stocks are generally exposed to greater risk than other types of securities, such as preferred stock and debt obligations, because common stockholders generally have inferior rights to receive payment from issuers.

 Item 9 Principal Risks:

Equity Market Risk (All Funds). Equity securities represent an ownership interest, or the right to acquire
an ownership interest, in an issuer. The values of equity securities may decline due to general market conditions which are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the
general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. They may also decline due to factors which affect a particular industry or

industries, such as labor shortages or increased production costs and competitive conditions within an industry. Equity securities generally have greater price volatility than fixed income
securities. Common stocks are generally exposed to greater risk than other types of securities, such as preferred stock and debt obligations, because common stockholders generally have inferior rights to receive payment from issuers.

Comment 18.
 Please revise the Derivatives Risk disclosure to discuss each Fund’s investments in derivatives in
lieu of providing boilerplate language.

 Response 18. As noted in response to Comment 10
above, the Funds have removed the Derivatives Risk disclosure.

 Summary Prospectus - RBC Emerging Markets
ex-China Equity Fund

Comment 19.
 If the Fund’s investments in derivatives will include
“over-the counter” and “excha