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Blank Rome LLP

1271 Avenue of the Americas

New York, NY 10020

(212) 885-5000 (Phone)

(212) 885-5001 (Facsimile)

www.blankrome.com

June 6, 2023

VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Rebecca Marquigny, Esq.

    Re:

    RiverPark Funds Trust (Registration No. 333-167778/811-22431)

    Response to Examiner Comments on Post-Effective

    Amendment No. 35

Dear Ms. Marquigny:

On behalf of our client, RiverPark Funds Trust (the " Registrant "),
this letter responds to the comments provided on behalf of the staff (the "Staff") of the Securities and Exchange Commission
(the "SEC") via telephone on May 1, 2023, regarding the Post-Effective Amendment No. 35 (“PEA No. 35”) to the registration
statement on Form N-1A for the Registrant. PEA No. 35 seeks to register shares of Riverpark/Next Century Growth Fund, a new series of
the Registrant (the “Fund”).

Pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the
“1933 Act”), PEA No. 35 would have become effective on May 28, 2023. On May 26, 2023, the Registrant filed a BXT filing to
designate a new effective date of June 15, 2023 for PEA No. 35. The Registrant expects to file Post-Effective Amendment No. 37 on or before
June 14, 2023, which will become effective on June 15, 2023 and which will reflect changes made in response to the Staff’s comments,
as set forth below, and certain other non-material clarifying and conforming changes.

Capitalized terms used in this response letter, but not defined herein,
shall have the same meaning as in PEA No. 35. The section and page references that we refer to in the Trust’s responses are references
to the filed version of the PEA No. 35. Unless otherwise defined in this letter, capitalized terms have the meanings given in the PEA
No. 35.

General

 1. Comment: Please reply in writing to each comment via EDGAR correspondence filed at least five days before the effective date
or 485(b) filing to allow for Staff review and response, as necessary. When a comment is relevant to disclosure found elsewhere in the
filing, the staff expects that the comment and its response will be applied. If corresponding changes will not be made throughout the
disclosure, please identify and explain any exceptions. Where a reply contemplates revised disclosure, include the proposed new language
in the correspondence. Your response letter should also provide updated pages where required material information is missing or bracketed
in the filing made pursuant to Rule 485(a) (e.g., fee table and expense example figures).

Response:  The Registrant hereby confirms
that it will comply with the foregoing instructions. The final fee table and expense example figures are provided in Appendix A
attached hereto.

    June 6, 2023

Page 2

Prospectus

Fees and Expenses of the Fund

 2. Comment: Per Item 3 of Form N-1A, bold the third sentence of the first paragraph.

Response:  The referenced sentence has
been bolded.

 3. Comment: Consider removing the Shareholder Fees table if the Fund will not be charging any of the fees included in the table.

Response:  The Shareholder Fees Table
has been removed.

 4. Comment: Consider deleting the “Distribution and Service (12b-1) Fees” row of the Annual Portfolio Operating Expenses
table, if the Fund will not be charging such fees.

Response:  The “Distribution and
Service (12b-1) Fees” row of the Annual Portfolio Operating Expenses table has been deleted.

 5. Comment: The prospectus indicates that the Fund may invest in other investment companies. If acquired fund fees and expenses
will exceed 1 basis point of the Fund’s net assets, please disclose these expenses in a separate line item in the Annual Portfolio
Operating Expenses table.

Response:  Initially the Fund will not
be investing in other investment companies, and the mention of such investments has been removed from the Principal Investment Strategies
section of the prospectus to make that clearer. If that situation should change, acquired fund fees and expenses will be disclosed in
a separate line item in the Annual Portfolio Operating Expenses table.

 6. Comment: Please supplementally explain the assumptions upon which the estimate of “Other Expenses” was made and
how the Registrant determined such estimate was reasonable.

Response:  The Registrant supplementally
advises that the Other Expenses estimate is based on an estimated expense level of $40,000 and an AUM level of $8,000,000, which the Registrant
currently believes is an attainable level of AUM for the Fund in its initial year of operations.

 7. Comment: In the last sentence of footnote 3 to the Annual Portfolio Operating Expenses table, please clarify that recoupment
is not permitted in two circumstances (not just the one identified in clause (2) of such sentence) as recoupment is also prohibited if
it would cause the annual expense limitation in effect at the time of the recoupment to be exceeded.

Response:  The requested clarification
has been made – the last sentence has been revised to read as follows:

“The Fund has agreed to repay
the Adviser in the amount of any fees waived and Fund expenses reimbursed, subject to certain limitations that: (1) the repayment is
made only for fees waived or expenses reimbursed not more than three years prior to the date of repayment; and (2) the repayment may
not be made if it would cause the Fund’s operating expenses to exceed the lesser of: (a) the annual expense limitation in effect
at the time of the fee waiver or expense reimbursement or (b) the annual expense limitation in effect at the time of the repayment.”

    June 6, 2023

Page 3

Principal Investment Strategies

 8. Comment: Please specifically state the dollar value of the market capitalization of the largest constituent in the Russell
2000® Index as of a date reasonably close to the anticipated effective date of the prospectus.

Response:  The following sentence has
been added at the end of the first paragraph of the Principal Investment Strategies section on page 2 of the prospectus:

“As
of May 31, 2023, the market capitalization of the largest company in the Russell 2000® Index on a rolling three-year basis was $29.1
billion.”

 9. Comment: Reference is made to the second and third paragraphs of the Principal Investment Strategies section on page two of
the prospectus. Please revise these paragraphs to include disclosure regarding how the sub-adviser identifies, evaluates and selects fund
holdings. In this regard, discuss the relevant matrix considered, the time periods over which they are evaluated, any baseline eligibility
criteria and any relevant exclusionary factors in concrete practical terms, explaining how the Sub-Adviser determines a company is likely
to "sustain above average revenue and earnings growth over time."

Response:  The Principal Investment Strategies
section has been modified as provided in Appendix B hereto. Specifically, three paragraphs have been added to include additional
disclosure regarding how the Sub-Adviser identifies, evaluates and selects Fund holdings.

 10. Comment: Please add disclosure to the Principal Investment Strategies section to describe the Sub-Adviser's portfolio construction
method, including constraints, allocation considerations and the process for making individual buy and sell decisions. In this regard,
clearly and concisely explain how the Sub-Adviser builds a stable portfolio profile maintained by the Sub-Adviser’s portfolio turnover
decisions.

Response:  The Principal Investment Strategies
section has been modified in response to this comment. Please see Appendix B hereto.

    June 6, 2023

Page 4

 11. Comment: The staff notes that the disclosure in both the Principal Investment Strategies and the Principal Investment Risks
sections is excessively reliant on the word "may" - please revise the disclosure to focus on what the Fund intends to invest
in, which should be described in clear, concise and definitive language. In this regard:

 · If an instrument, transaction type or investment technique (ie, IPO, PIPE, SPAC, ADR and any other specified investment) is
not principal, relocate it to another location.

 · Explain how the Sub-Adviser determines the type of instrument best suited in any given situation - where a type of instrument is identified
as principal (ie, a SPAC, IPO, PIPE, etc), explain its strategic role in achieving the Fund's objective (long term capital appreciation).
If the Fund does not rely on a specified instrument type for achieving its objective - state why it is otherwise principal (for example,
is it risk mitigating?) or alternatively relocate the corresponding references to such instruments to a location that includes the non-principal
strategies the Fund can employ.

Response:  The Principal Investment Strategies
section has been modified as provided in Appendix B hereto. Specifically, those instruments, transaction types and investment techniques
that are not principal to the Fund’s investment strategy have been deleted from the Principal Investment Strategies section.

 12. Comment: Reference is made to the last sentence of the fourth paragraph of the Principal Investment Strategies section. Please
explain specifically what “tied economically” means as used in the sentence and state any asset percentage or other limits
on the Fund’s derivative holdings.

Response:  The referenced sentence has
been deleted as derivatives are not part of the principal investment strategy of the Fund.

 13. Comment: Reference is made to the first sentence of the fifth paragraph of the Principal Investment Strategies section. Please
clarify the Fund's strategy with respect to foreign investments and disclose any criteria limiting the Fund’s foreign-currency denominated
investments (such as a net asset percentage limit). In addition, if the Fund will invest in unsponsored depositary instruments, affirmatively
disclose this (noting that ADRs are “sponsored & unsponsored”).

Response:  The referenced sentence has
been deleted as foreign investments and ADRs are not part of the principal investment strategy of the Fund.

 14. Comment: Reference is made to the last sentence of the fifth paragraph of the Principal Investment Strategies section. Explain
how the Sub-Adviser applies a “bottom up” growth analysis in selecting investment companies and ETFs to invest in.

Response:  The referenced sentence has
been deleted as investments in other investment companies and ETFs are not part of the principal investment strategies of the Fund.

    June 6, 2023

Page 5

 15. Comment: Reference is made to the sixth paragraph of the Principal Investment Strategies section. The basis for the portfolio's
sector distribution in "significant positions in particular sectors" is unclear. Please explain how the Sub-Adviser makes sector
allocation decisions (eg, by evaluating sector growth? if so, based on what criteria and what metrics?). If the Fund does not employ
a sector strategy, say this directly and explain the portfolio's sector distribution in terms of the growth strategy's practical impact
(ie, identify which sectors are likely to be invested in based on growth-strategy). If the Sub-Adviser anticipates a significant
investment in a particular sector at the time of launch, so state.

Response:  The Principal Investment Strategies
section has been modified as provided in Appendix B hereto. Specifically, the fourth paragraph of the updated Principal Investment
Strategies includes additional disclosure regarding sector allocation.

 16. Comment: Reference is made to the last paragraph of the Principal Investment Strategies section. Please explain what is meant
by "constructed with the overall goal of mitigating risk.” Does it apply to individual purchase and sale decisions? How and
to what extent does it influence the fund's overall risk profile? For clarity, please revise or supplement the disclosure as necessary.

Response:  The referenced paragraph has
been deleted from the Principal Investment Strategies section. Please see Appendix B hereto.

Principal Risks

 17. Comment: The staff notes that the Principal Risks disclosed pursuant to Item 4(b) of Form N-1A (beginning on page 3 of the
prospectus) do not align with those disclosed pursuant to Item 9(c) of Form N-1A (beginning on page 6 of the prospectus). In addition,
some principal risks are not apparent consequences of the primary strategy disclosed pursuant to Items 4(a) and 9(b) of Form N-1A. Accordingly,
please review the related strategy sections and revise to provide appropriate support for each principal risk.

Response:  The Principal Risks section
has been modified as provided in Appendix C hereto. As indicated in the responses to Items 9 through 16 above, the Principal Investment
Strategies section has been modified as provided in Appendix B hereto. The Registrant believes that the disclosure in the updated
Principal Investment Strategies section aligns with the disclosure in the updated Principal Risks section.

 18. Comment: If the Fund is advised by or sold through an insured depository institution, include the statement required by item
4(b)(1)(iii) of Form N-1A.

Response:  The Fund is not advised by
or sold through an insured depository institution.

    June 6, 2023

Page 6

 19. Comment: Reference is made to the first sentence of “Equity Securities Risk” which provides that “[t]he Fund
may invest in equity securities, securities with exposure to equity securities or indices comprised of equity securities.” The strategy
section does not mention investing in indices - please move this sentence to strategy section - or remove reference to investments in
indices.

Response:  The reference to investing
in indices has been deleted.

 20. Comment: Reference is made to the first sentence of “Growth Stock Risk” which provides that “[t]he Fund may
invest in growth stocks.” Please substitute the word will for may - or supplementally explain why such a change is incorrect or
inappropriate.

Response:  The word “may”
has been changed to “will.”

 21. Comment: Please delete the words “from time to time” from the first sentence of “Focus Risk.”

Response:  The words “from time
to time” have been deleted.

 22. Comment: The staff notes that if “Portfolio Turnover Risk” is significant enough to be included as a principal
risk, it should correspondingly be highlighted as a strategy in the Principal Investment Strategies section.

Response:  The Registrant advises that
short term trading is not a principal investment strategy of the Fund, and, accordingly, “Portfolio Turnover Risk” has been
moved to the Non-Principal Risks section.

 23. Comment: Please add risk disclosure in the Principal Risks section beginning on page 3 of the prospectus for the following
types of investments (which are included in the Principal Investment Strategies section): PIPEs; IPOs; SPACs; Foreign Securities; ADRs;
investments in other investment companies; ETFs; and convertible securities (which should include specific risks with respect to preferred,
warrants and debentures).

Response:  The Registrant advises that
disclosure regarding the referenced types of investments has been removed from the updated Principal Investment Strategies section as
shown in Appendix B hereto. As such, risk disclosure has not been added to the Principal Risks section for these types of investments.

    June 6, 2023

Page 7

 Performance

 24. Comment: Please add preamble disclosure conforming to language and substance required by Item 4(b)(2)(i) of Form N-1A before
the paragraph currently included in the Performance section.

Response:  The following has been inserted
after the first sentence of the paragraph currently included in the Performance section:

“Once the Fund has completed
a full calendar year of operations, a bar chart and table will be included that will provide some indication o