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February 22, 2023

Via EDGAR

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Attn:
    Kimberly
A. Browning, Division of Investment Management

    Re:
    BBH Trust (the “Registrant”)

    Post-Effective Amendment No. 98

    (File Nos. 333-129342, 811-21829)

Dear Ms. Browning:

Listed below are the comments
of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) received on February 16, 2022,
relating to Post-Effective Amendment No. 98 to the Trust’s Registration Statement on Form N-1A filed on December 30, 2022, pursuant
to Rule 485(a) under the Securities Act of 1933, and the Trust’s responses thereto. Capitalized terms in the responses that are
not defined herein have the meaning given to them in Post-Effective Amendment No. 98.

Comments Related to All Funds

 1. Comment: Fee and Expense Tables

Please provide the Staff completed Fee
and Expense Tables for each Fund.

    Response:
    The Registrant confirms that the completed Fee and Expense Tables are included in Appendix A herein.

 2. Comment: Principal Investment Strategy and Principal Risks

Please update the fund’s principal
investment strategies and principal risk disclosure to accurately reflect the fund’s investments.

 Response: The Registrant confirms that the Funds’ principal investment
strategies and principal risk disclosure accurately reflects the Funds’ investments.

    Page 1 of 17

 3. Comment: Expense Table

Please
revise the second sentence of the preamble to the funds’ Item 3 Expense Table to be bold as required by Item 3 of Form N-1A.

 Response: The Registrant confirms that the requested revision has been made.

 4. Comment: Principal Investment Strategy

For funds that invest in foreign securities,
please include disclosure that indicates securities may be denominated in foreign currency.

 Response: The Registrant confirms that the requested disclosure has been added.

 5. Comment: Principal Investment Strategy

Please consider whether the inclusion
of principal risk disclosure related to environmental, social and governance (“ESG”) is appropriate. If a fund does not believe
the inclusion is appropriate, please disclose the reasoning to the Staff supplementally.

 Response: The Registrant represents that consideration of ESG is one of several factors that the Adviser considers
in its overall investment decision process. The Registrant does not believe that there are specific principal risks to disclose relating
to the Adviser’s consideration of ESG factors other than those already disclosed under Management Risk.

 6. Comment: Principal Investment Strategy

Please clarify whether each security
is subject to a review of ESG factors and provide a plain English description as to whether the securities are subject or not.

 Response: The Registrant confirms that the requested clarification has been made.

 7. Comment: Principal Investment Strategy

If a fund is investing in sectors on
a principal basis, please disclose the sectors in the Principal Investment Strategies and include attendant risk disclosure.

 Response: The Registrant represents that the Funds do not invest in specific sectors on a principal basis as the
Funds are actively managed and the Adviser’s investment process does not include specific allocations to particular sectors. As
such, the sector allocation and weighting of the Funds change over time and it would be inaccurate to disclose particular sectors as they
may or may not make up more than 25% of the portfolio at any given time.

    Page 2 of 17

 8. Comment:
                                            Principal Investment Strategies

Please revise the disclosure using open
ended terms to include only the types of securities in which the funds invest.

 Response: The Registrant confirms that open ended terms (i.e., “including”, “such as”, etc)
have been deleted. However, the Registrant respectfully declines to revise the term “may invest” as the Funds invest in a
variety of securities that are disclosed in the principal investment strategies and the composition of the portfolios change over time.
The Funds are actively managed and “may invest” accurately describes the portfolio management process of the Funds.

 9. Comment: Principal Investment Strategies

If a Fund has an invest policy related
to the 20% bucket under Rule 35d-1, please include disclosure related to the policy.

 Response: The Registrant confirms that the Funds do not have a specific investment strategy relating to their 20%
bucket, unless specifically described in the prospetus.

 10. Comment:
                                            Shareholder Information

Please provide the authority under the
federal securities laws or delete the sentence stating, “The Fund reserves the right to change the time its NAV is calculated if
the Fund closes earlier, or as permitted by the SEC.”

 Response: The Registrant confirms that the sentence has been deleted.

 11. Comment:
                                            Shareholder Information

Please delete the word “generally”
when referring to the determination of the market value of a security or alternatively please indicate when other methods may be used
for determining the market value of a security.

 Response: The Registrant confirms that “generally” has been deleted.

 12. Comment:
                                            Shareholder Information

Please include additional disclosure
related to the funds’ Board of Trustees’ adoption of policies and procedures related to the delegation of valuation policies
and procedures and their oversight responsibility.

 Response: The Registrant confirms that additional disclosure has been included as requested.

    Page 3 of 17

 13. Comment:
                                            Shareholder Information

Please revise the disclosure related
to the time in which orders are accepted to be in line with the requirements of Rule 22c-1 under the Investment Company Act of 1940.

 Response: The Registrant confirms that the requested revision has been made.

 14. Comment:
                                            Shareholder Information

Please revise the disclosure related
to the funds’ right to suspend redemptions to be in line with the requirements of Section 22(e) of the Investment Company Act.

 Response: The Registrant confirms that the requested revision has been made.

BBH Select Series – Large Cap Fund
Prospectus

 15. Comment:
                                            Principal Investment Strategy

In the Item 4 Principal Investment Strategies
section, please provide a brief description of the types of equity securities in which the fund invests.

 Response: The Registrant confirms that the requested disclosure has been added.

 16. Comment: Principal Investment Strategy

Please provide a definition of American
Depositary Receipt (“ADR”) and include attendant risk disclosure in the Principal Risk section. Additionally, please specify
the types of ADR in which the Fund invests.

 Response: The Registrant confirms that the requested disclosure regarding the types of ADR and a definition of ADRs
has been added. The Registrant represents that risk disclosure regarding ADRs is included under Foreign Investment Risk. The Registrant
notes that the term “Foreign Investment Risk” has been changed to “Non-U.S. Investment Risk” in connection with
the response to Comment 24 below.

 17. Comment: Principal Investment Strategy

In the Item 4 Principal Investment Strategies
section, please include the range of securities in which the fund may invest as stated in the Item 9 Principal Investment Strategies.

 Response: The Registrant confirms that the requested disclosure has been added.

    Page 4 of 17

 18. Comment: Principal Investment Strategy

Please include a definition of “essential
products and services”. Additionally, please provide the source of the definition and the elements of the test used by the fund.
Please include additional disclosure in the Item 4 Principal Investment Strategies and Principal Risk sections.

 Response: The Registrant has clarified the disclosure to state that the Fund invests in businesses that the Adviser
believes offer essential products and services. The Registrant respectfully declines to add a definition of essential products and services
as it is a subjective element of the qualitative analysis performed as part of the Adviser’s proprietary analytical process. The
Registrant represents that the risks corresponding to the Adviser’s investment process are disclosed under Management Risk.

 19. Comment: Principal Investment Strategy

Please include a definition of “loyal
customers” and please provide the source of the definition. Please include additional disclosure in the Item 4 Principal Investment
Strategies and Principal Risk sections.

 Response: The Registrant has clarified the disclosure to state that the Fund invests in businesses that the Adviser
believes have loyal customers. The Registrant respectfully declines to add a definition of loyal customers as it is a subjective element
of the qualitative analysis performed as part of the Adviser’s proprietary analytical process. The Registrant represents that the
risks corresponding to the Adviser’s investment process are disclosed under Management Risk.

 20. Comment: Principal Investment Strategy

Please include a definition of “leadership
in an attractive market niche or industry” and please provide the source of the definition. Please include additional disclosure
in the Item 4 Principal Investment Strategies and Principal Risk sections.

 Response: The Registrant has clarified the disclosure to state that the Fund invests in businesses that the Adviser
believes have leadership in an attractive market niche or industry. The Registrant respectfully declines to add a definition of leadership
in an attractive market niche or industry as it is a subjective element of the qualitative analysis performed as part of the Adviser’s
proprietary analytical process. The Registrant represents that the risks corresponding to the Adviser’s investment process are disclosed
under Management Risk.

    Page 5 of 17

 21. Comment: Principal Investment Strategy

Please include a definition of “sustainable
competitive advantage” and please provide the source of the definition. Please include additional disclosure in the Item 4 Principal
Investment Strategies and Principal Risk sections.

 Response: The Registrant has clarified the disclosure to state that the Fund invests in businesses that the Adviser
believes have a sustainable competitive advantage. The Registrant respectfully declines to add a definition of sustainable competitive
advantage as it is a subjective element of the qualitative analysis performed as part of the Adviser’s proprietary analytical process.
The Registrant represents that the risks corresponding to the Adviser’s investment process are disclosed under Management Risk.

 22. Comment: Principal Investment Strategy

Please include a definition of “managers
have high levels of integrity” and please provide the source of the definition. Please include additional disclosure in the Item
4 Principal Investment Strategies and Principal Risk sections.

 Response: The Registrant has clarified the disclosure to state that the Fund invests in businesses that the Adviser
believes have managers have high levels of integrity. The Registrant respectfully declines to add a definition of managers have high levels
of integrity as it is a subjective element of the qualitative analysis performed as part of the Adviser’s proprietary analytical
process. The Registrant represents that the risks corresponding to the Adviser’s investment process are disclosed under Management
Risk.

 23. Comment: Principal Investment Strategy

Please include a definition of “demonstrable
skills in operations,” and please provide the source of the definition. Please include additional disclosure in the Item 4 Principal
Investment Strategies and Principal Risk sections.

 Response: The Registrant has clarified the disclosure to state that the Fund invests in businesses that the Adviser
believes have demonstrable skills in operations. The Registrant respectfully declines to add a definition of demonstrable skills in operations
as it is a subjective element of the qualitative analysis performed as part of the Adviser’s proprietary analytical process. The
Registrant represents that the risks corresponding to the Adviser’s investment process are disclosed under Management Risk.

    Page 6 of 17

 24. Comment: Principal Investment Strategy

In the Item 4 Principal Risks section,
please provide a brief description of the types of equity securities in which the fund invests.

 Response: The Registrant confirms that the requested disclosure has been included.

 25. Comment: Principal Investment Strategy

Please include disclosure related to
how the fund determines that an issuer is considered “foreign.”

 Response: The Registrant confirms that to avoid confusion the disclosure has been revised to read “non-U.S.”
instead of “foreign”.

BBH Partner Fund – International Equity
Prospectus

 26. Comment: Principal Investment Strategies

Please clarify if the fund has a minimum
number of developed and emerging markets countries in which it must invest under its 80% net assets in international equity securities.
If the fund does not believe that additional disclosure is necessary, please indicate to the Staff the fund’s reasoning.

 Response: The Registrant confirms that the Fund does not have a minimum number of developed and emerging markets
countries in which it may invest for purposes of the 80% bucket. The Registrant confirms that additional disclosure has been included
to clarify that the Fund will invest in “multiple” developed and emerging markets countries.

 27. Comment: Principal Investment Strategies

Please specify in the Item 4 Principal
Investment Strategy what types of equity securities the fund invests and include attendant risk disclosure.

    Response:
    The Registrant confirms the addition of the requested disclosure.

 28. Comment: Principal Investment Strategies

Please clarify how the fund defines
a “developed market”.

    Response:
    The Registrant confirms that clarifying disclosure has been added.

 29. Comment: Principal Investment Strategies

Please clarify how the fund defines
a “emerging market”.

    Response:
    The Registrant confirms that clarifying disclosure has been added.

    Page 7 of 17

 30. Comment: Principal Investment Strategies

Please include disclosure in plain English
indicating the types of derivatives in which the fund may invest.

    Response:
    The Registrant confirms the addition of the requested disclosure.

 31. Comment: Principal Investment Strategies

Please provide disclosure in Items 4
and 9 related to the countries in which the fund principally invests and include attending risk disclosures. If the fund objects, please
supplementally describe the fund’s reasoning.

 Response: The Registrant respectfully declines to include disclosure related to specific countries in which the
Fund invests. The Fund is actively managed and the Adviser’s investment process does not include specific allocations to particular
countries. As such, the country allocation and weighting changes over time and it would be inaccurate to disclose particular countries
as they may or may not make up more than 25% of the portfolio at an given time.

 32. Comment: Principal Investment Strategies

Please confirm to the Staff whether
the fund includes derivatives in its 80% basket and that the market value of the derivatives is used in the calculation. If the fund does
include derivatives in its 80% basket, please confirm to the Staff that the fund uses mark-to-market value for the calculation.

 Response: The Registrant confirms that d