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Blank Rome LLP

1271 Avenue of the Americas

New York, NY 10020

(212) 885-5000 (Phone)

www.blankrome.com

September 18, 2023

VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention:	   Ms. Christina DiAngelo-Fettig

Mr. David Matthews

	Re:	                 Centaur Mutual Funds Trust

Registration Statement on Form N-14

File No. 333-273612

Dear Ms. DiAngelo-Fettig and Mr. Matthews:

This letter is in response to the comments provided
by the staff of the U.S. Securities and Exchange Commission (the “Staff”) via telephone on August 23, 2023 and September 6,
2023, relating to the registration statement on Form N-14 (the “Registration Statement”) filed on August 2, 2023, relating
to the proposed reorganization of Ziegler FAMCO Hedged Equity Fund (the “Acquired Fund”), a series of Trust for Advised Portfolios
(“TAP”), into DCM/INNOVA High Equity Income Innovation Fund (the “Acquiring Fund”), a series of Centaur Mutual
Funds Trust (“Centaur Trust” or the “Registrant”). The Acquired Fund and the Acquiring Fund are referred to herein
as the “Funds.” Please see the Registrant’s responses to such comments below, which the Registrant has authorized Blank
Rome LLP to make on its behalf.

Responses to all of the comments are included below
and, as appropriate, will be incorporated into Pre-Effective Amendment No. 1 to the Registration Statement. Capitalized terms not otherwise
defined in this letter have the meanings assigned to them in the Registration Statement.

Accounting
Comments

General

 1. Comment: Please confirm that that the pre-effective amendment to the Registration Statement to
be filed will contain updated auditor’s consents.

Response: The Registrant confirms that
updated auditor’s consents will be filed with the pre-effective amendment to the Registration Statement.

September 18, 2023

Page 2

QUESTIONS AND ANSWERS RELATING TO THE REORGANIZATION

 2. Comment: The Staff notes the response to the fourth question on page vi (“Why is the
Reorganization occurring?”) focuses on economies of scale, which is generally applicable to most reorganizations. If applicable,
please provide additional detail regarding the reasons for merging these two funds.

Response: The following has been added
after the third sentence of the referenced response:

Before recommending the Reorganization to the TAP Board of
Trustees, ZCM considered other strategic options for the Acquired Fund, including its dissolution, which would have resulted in the cessation
of an investment strategy that has served the Acquired Fund’s shareholders well and would likely have resulted in the realization
of long-term capital gains and the taxation associated with such. As noted below, the principal investment strategies of the Acquired
Fund and the Acquiring Fund are similar in all material respects. As such, the Reorganization will allow the Acquired Fund shareholders
to continue to be invested in an open-end mutual fund with an investment strategy that is similar in all material respects.

 3. Comment: Please revise the last sentence of the second paragraph of the response to the third
question on page viii (“What are the primary differences between the objectives, principal investment strategies and principal
risks of the Acquired Fund and the Acquiring Fund?”).

Response: The referenced sentence has
been revised as follows:

Both Funds primarily invest in equity securities and under
their investment strategies and both Funds are able to engage in options transactions.

 4. Comment: Reference is made to the first paragraph of the response to the first question on page
ix (Will the Reorganization result in new or higher fees for shareholders?). Please add disclosure that the pro-forma gross
expense ratio for the combined Funds is higher than the gross expense ratio for the Acquired Fund.

Response: The first sentence of the
referenced paragraph has been revised as follows:

The Reorganization is expected to result in substantially the
same net expense ratio for shareholders of the Acquired Fund, although the advisory fee for the Acquiring Fund is higher than that of
the Acquired Fund and, as shown in the Fees and Expenses table on page 13 of the Combined Proxy Statement
and Prospectus, the gross expense ratio (before fee reductions and/or expense reimbursements) for shareholders of the Acquired Fund will
decrease from 1.46% to 1.38%.

September 18, 2023

Page 3

 5. Comment: Reference is made to the last sentence of the first paragraph of the response to the
first question on page ix (“Will the Reorganization result in new or higher fees for shareholders?”). What is the basis
for stating “ . . . it is anticipated that, after the closing of the Reorganization, the Acquiring Fund’s operating expenses
will not include AFFEs”? Please disclose supplementally whether there is any current or anticipated repositioning of the Acquired
Fund’s portfolio in this regard and, if so, consider adding disclosure regarding such repositioning to the response.

Response: The Registrant supplementally
advises that, in response to Comment #13 below, the Fees and Expenses table included in the Registration Statement has been updated. The
original Fees and Expense table, which was based on the Acquiring Fund’s financial information for the fiscal year ended October
31, 2022, showed AFFEs of 0.03% for the Acquiring Fund. The updated Fees and Expenses table (provided in Appendix A hereto), which
is based on the Acquiring Fund’s financial information for the semi-annual period ended April 30, 2023, shows AFFEs of 0.00% for
the Acquiring Fund, which reflects a decrease in underlying funds held by the Acquiring Fund during the semi-annual period ended April
30, 2023. DCM has advised the Registrant that it has modeled a pro forma portfolio for the Acquiring Fund after the closing of
the Reorganization. The pro forma portfolio does not include these underlying funds. Very soon after the Reorganization, DCM will
transform the Acquiring Fund’s portfolio to reflect the pro forma portfolio. Accordingly, (i) the Pro forma Combined
column of the updated Fees and Expenses table provided in Appendix A hereto shows AFFEs of 0.00% and (ii) references throughout
the Registration Statement to the fact that “. . . the Acquiring Fund’s operating expenses currently include AFFEs”
have been deleted.

 6. Comment: Reference is made to the response to the last question on page ix (“Who will
pay for the Reorganization?”). Please disclose if DCM will pay the Reorganization costs whether or not the Reorganization is
consummated. In addition, please add a statement that any repositioning costs will be paid by the Funds.

Response: The following has been added
to the referenced response:

DCM will pay the costs solely and directly relating to the
Reorganization whether or not the Reorganization is consummated. Any costs related to the repositioning of the portfolios of the Acquired
Fund or the Acquiring Fund will be paid by the Acquired Fund or the Acquiring Fund, as applicable. Currently, costs (including brokerage
and tax) of the Acquired Fund’s portfolio repositioning prior to the Reorganization are expected to be approximately $3,600 and
will be borne by the Acquired Fund.

 7. Comment: Reference is made to the response to the first question on page x (“Will the
Reorganization result in any U.S. federal income tax liability to me?”).

 · Will there be costs associated with the Acquired Fund’s closing out of put options? Are those
costs included in (or in addition to) the approximate $12,500 in portfolio transaction costs noted later in the paragraph?

September 18, 2023

Page 4

 · The sixth sentence notes that up to $5 million in Acquiring Fund assets may be sold and/or rebalanced
following the completion of the Reorganization. Will these sales/rebalances happen because of the Reorganization? Will the assets that
are sold/rebalanced be assets of the Acquired Fund or the Acquiring Fund?

 · The penultimate sentence of the referenced response notes that there is not expected to be any material
impact to shareholders due to the receipt of capital gains distributions. Please revise this disclosure to include the estimated capital
gains as a per share amount and as a total amount.

Response: The Registrant advises as
follows:

 · It is anticipated that the total transaction costs associated with closing the put options will be no
more than $140. This does not include changes in the value of the contracts, which could be a gain or a loss. Because the put options
contracts will be closed at the time of the Reorganization, this expense is not included in the approximately $12,500 in post-Reorganization
transaction costs noted later in the paragraph.

 · The potential transactions described are post-Reorganization, and therefore all assets will be part
of the Acquiring Fund. In terms of the pre-Reorganization source of the assets, it will be a mix of Acquiring Fund assets and Acquired
Fund assets, with the purpose being to bring the two portfolios more closely into alignment with each other.

 · The Registrant does not expect any capital gains distributions. The estimated distribution is $0.00.
The penultimate sentence of the referenced response has been revised as follows:

For tThe
transactions executed as a result of the Reorganization, there is are
not expected to be any material impact to shareholders due to the receipt of require
any capital gain distributions.

 8. Comment: Reference is made to the response to the fourth question on page x (“What will
happen if shareholders do not approve the Reorganization?”). Please disclose other actions (in addition to liquidating) that
may be taken with respect to the Acquired Fund if the shareholders do not approve the Reorganization.

Response: The Registrant confirms that
ZCM has advised that, given the relatively small size of the Acquired Fund and the lack of prospects for any future meaningful asset growth,
ZCM has informed the TAP Board that it will likely recommend the liquidation of the Acquired Fund if the shareholders of the Acquired
Fund do not approve the Reorganization. As such, no disclosure has been added to the Registration Statement regarding other actions that
may be taken with respect to the Acquired Fund if the shareholders do not approve the Reorganization.

COMBINED PROXY STATEMENT AND PROSPECTUS

Cover (beginning on page xii)

 9. Comment: Please include live hyperlinks to the documents incorporated by reference into the Combined
Proxy Statement and Prospectus on page xiii.

September 18, 2023

Page 5

	Response: The Registrant confirms
hyperlinks will be included for the referenced documents.

Summary (beginning on page 1)

 10. Comment: Please add disclosure to the first sentence of the sixth bullet point under the fifth
paragraph on page 1 to indicate that AFFEs are excluded from the total annual fund operating expenses.

Response: The referenced sentence has
been revised as follows:

The total annual fund operating expenses (excluding
acquired fund fees and expenses (“AFFEs”)) borne by shareholders are expected to remain the same for a period of
at least two years after the closing of the Reorganization.

 11. Comment: The last sentence on page 1 refers to securities transactions conducted in advance of
the Reorganization. Please advise whether these transactions are in connection with the Reorganization. If applicable, add disclosure
indicating that the transactions are ordinary course.

Response: The Registrant advises that
the referenced sentence relates to transactions conducted in the ordinary course of managing the Acquired Fund. As such, the referenced
sentence has been revised as follows:

However, any securities transactions conducted in
the ordinary course in advance of the Reorganization may generate capital gains for the Acquired Fund based on market prices
of the securities sold, which may result in taxable distributions to shareholders of the Acquired Fund prior to or on the date of the
Reorganization.

Summary - Board Considerations (beginning
on page 2)

 12. Comment: The penultimate paragraph on page 2 states that “…the Reorganization is
not expected to change the way the Acquired Fund’s assets are managed in any material respect.” Please confirm this is accurate
in light of the closing out of the Acquired Fund’s put options.

Response: The Registrant advises that
this disclosure is accurate. Pursuant to the investment strategies of the Acquired Fund, options positions are normally closed out at
the end of the month. The closing of the put positions is consistent with the Acquired Fund’s investment strategies.

Proposal – Comparison of the
Acquired Fund and the Acquiring Fund – Comparison of Fees and Expenses (beginning on page 13)

 13. Comment: Please update the information provided in the fee table on page 13 so that it reflects
“current fees” in accordance with Item 3 of Form N-14.

September 18, 2023

Page 6

	Response: As requested, the fee
table on page 13 has been updated so that all data is as of April 30, 2023. The updated fee table is provided in Appendix A hereto.

 14. Comment: Please note that the Acquiring Fund’s expense limitation agreement referenced
in footnote 2 to the fee table must be in effect for at least one year from the date of the prospectus.

Response: The Registrant confirms that
the referenced expense limitation agreement will be in effect for at least one year from the date of the Combined Proxy Statement and
Prospectus.

 15. Comment: Reference is made to the Acquired Fund’s expense limitation agreement referenced
in footnote 3 to the fee table. Please supplementally confirm that any previously waived fees or paid expenses subject to recapture pursuant
to such agreement will not be carried over to the Acquiring Fund post-Reorganization.

Response: The Registrant supplementally
confirms that any previously waived fees or paid expenses subject to recapture pursuant to the Acquired Fund’s expense limitation
agreement will not be carried over to the Acquiring Fund post-Reorganization.

 16. Comment: The Staff notes that the last sentence of footnote 4 discloses that it is anticipated
that, after the closing of the Reorganization, the Acquiring Fund’s operating expenses will not include AFFEs. If that is the case,
consider whether AFFEs should be included in the pro-forma column of the fee table.

Response: The Registrant advises that
the Pro forma Combined column of the updated Fees and Expenses provided in Appendix A hereto shows AFFEs of 0.00%.

Proposal – Comparison of the
Acquired Fund and the Acquiring Fund – Comparison of Valuation Policies (page 21)

 17. Comment: Reference is made to the last paragraph on page 21. If there are differences in the
valuation procedures of the Acquired Fund and the Acquiring Fund, please expand the disclosure to describe those differences.

Response: The Registrant advises that
there are no differences in the valuation procedures of Acquired Fund and the Acquiring Fund. The disclosure in the referenced paragraph
will be modified as follows to be more definitive:

Based on the portfolio holdings as of the date of this Combined
Proxy Statement and Prospectus, it is not anticipated that the valuation of the Acquired
Fund’s portfolio securities under the Acquired Fund’s valuation procedures will not
be materially different than the valuation of the portfolio securities under the Acquiring Fund’s valuation procedures.

Information about the Reorganization
– Portfolio Transitioning (page 24)

September 18, 2023

Page 7

 18. Comment: Reference is made to the last sentence of the first paragraph under “Portfolio
Transitioning” on page 24, which provides that it is not possible to estimate the gain or loss to be recognized in connection with
the transition of the Acquired Fund’s portfolio. Please confirm the accuracy of this sentence. In addition, please u