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1271 Avenue of the Americas
|New York, NY 10020

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September 11, 2025

VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Samantha A. Brutlag

Re:       Two Roads Shared Trust (Registration No. 333-182417/811-22718)

    Response to Examiner Comments on Post-Effective

    Amendment No. 415

Dear Ms. Brutlag:

This letter summarizes the Staff’s comments
provided during our telephone conference call on August 19, 2025, regarding the Post-Effective Amendment to the Registration Statement
on Form N-1A (“PEA No. 415”) for Liberty One Spectrum ETF (the “Spectrum ETF”), Liberty One Defensive Dividend
Growth ETF (the “Defensive Dividend Growth ETF”) and Liberty One Tactical Income ETF (the “Tactical Income ETF”)
(each a “Fund” and, collectively, the “Funds”), three new series of Two Roads Shared Trust (the “Registrant”).

Pursuant to Rule 485(a) under the Securities Act of
1933, as amended (the “1933 Act”), PEA No. 415 is scheduled to be automatically effective on September 16, 2025. The Registrant
expects to file a Post-Effective Amendment on or before September 16, 2025, which will become effective on September 16, 2025, to 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. 415. The section and page references that we refer to in the Registrant’s
responses are references to the filed version of the PEA No. 415.

Prospectus

 1. Comment: Please explain the meaning of the ticker “RDMI”
for the Tactical Income ETF.

Response: The Registrant has changed
the Fund’s ticker to “LOTI.”

 2. Comment: The below sentence from each Fund’s ETF Structure
Risk disclosure only applies if a Fund is investing in foreign securities. Please remove this sentence from the disclosure or update each
Fund’s investment strategy, as applicable, if a Fund will invest in foreign securities.

“When all or a portion of an ETF’s
underlying securities trade in a market that is closed when the market for the Fund’s shares is open, there may be changes from
the last quote of the closed market and the quote from the Fund’s domestic trading day, which could lead to differences between
the market value of the Fund’s shares and the Fund’s NAV.”

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Response: The Registrant has made
the requested change to the disclosure:

The Fund is structured as an ETF and as
a result is subject to special risks. Shares are not individually redeemable and may be redeemed by the Fund at NAV only in large blocks
known as “Creation Units.” An investor may incur brokerage costs purchasing enough shares to constitute a Creation Unit. Trading
in shares on the exchange on which the Fund is listed may be halted due to market conditions or for reasons that, in the view of the exchange,
make trading in shares inadvisable, such as extraordinary market volatility. There can be no assurance that shares will continue to meet
the listing requirements of the exchange. An active trading market for the Fund’s shares may not be developed or maintained. If
the Fund’s shares are traded outside a collateralized settlement system, the number of financial institutions that can act as authorized
participants that can post collateral on an agency basis is limited, which may limit the market for the Fund’s shares. The market
prices of shares will fluctuate in response to changes in NAV and supply and demand for shares and will include a “bid-ask spread”
charged by the exchange specialists, market makers or other participants that trade the particular security. Shares may trade at a discount
or premium to NAV. If a shareholder purchases shares at a time when the market price is at a premium to the NAV or sells shares at a time
when the market price is at a discount to NAV, the shareholder may sustain losses if the shares are sold at a price that is less than
the price paid by the shareholder for the shares. There may be times when the market price and the NAV vary significantly. For example,
in times of market stress, market makers may step away from their role market making in shares of ETFs and in executing trades, which
can lead to differences between the market value of the Fund’s shares and the Fund’s NAV. When
all or a portion of an ETFs underlying securities trade in a market that is closed when the market for the Fund’s shares is open,
there may be changes from the last quote of the closed market and the quote from the Fund’s domestic trading day, which could lead
to differences between the market value of the Fund’s shares and the Fund’s NAV. In stressed market conditions,
the market for the Fund’s shares may become less liquid in response to the deteriorating liquidity of the Fund’s portfolio.
This adverse effect on the liquidity of the Fund’s shares may, in turn, lead to differences between the market value of the Fund’s
shares and the Fund’s NAV.

 3. Comment: Each of the Funds includes “Geographic Risk”
in its principal risks which suggests it may invest in foreign markets and other countries, which is different from its investment strategy.
Please edit or remove this risk disclosure or update each Fund’s investment strategy, as applicable, if a Fund will invest in foreign
securities.

Response: The Registrant believes
this risk is appropriate to include in the principal risk section. In the Adviser’s view, because many of the U.S.-based companies
the Funds will invest in sell products and services internationally, the Funds may potentially have some specific country risk. The Registrant
has revised such risk disclosure in response to the Staff’s comment to clarify as follows:

Geographic Risk. The risk that if
the Fund invests a significant portion of its total assets in certain issuers within the same geographic region, an adverse economic,
business or political development or natural or other event, including war, terrorism, natural and environmental disasters, epidemics,
pandemics and other public health crises, affecting that region may affect the value of the Fund’s investments more than if the
Fund’s investments were not so focused. The Fund may invest without limitation in a particular country
or region or may be exposed to the risks of a specific country as a result of its investments
in U.S.-based companies with operations or markets in other countries.

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In addition, the Registrant added the
following risk disclosure to each section:

Foreign Exposure Risk. Although
the Fund may invest in securities of companies listed on U.S. securities exchanges, the international operations of
those companies may create exposure to foreign markets where such companies operate. The international operations
of many companies expose them to risks associated with political, social or economic events in other countries or regions, which
may include instability and changes in economic and political conditions, foreign currency fluctuations, changes in foreign regulations,
tariffs and trade disputes, competition from subsidized foreign competitors with lower production costs and other risks inherent
to international business.

 4. Comment: The Spectrum ETF and Defensive Dividend Growth ETF include
risk disclosure for U.S. government securities, but the investment strategy discussion does not reference investments in treasuries or
other U.S. agency securities. Please remove such risk disclosure or update each Fund’s investment strategy, as applicable.

Response: The risk disclosure has
been removed in response to the Staff’s comment.

 5. Comment: For the Tactical Income ETF, if the Fund will not be invested
in other investment companies that utilize equity options, derivatives, currencies, leverage, or in inverse ETFs, please update the Fund’s
Investment Companies/Exchange-Traded Funds Risk accordingly.

Response: The risk disclosure has
been updated in response to the Staff’s comment as follows:

Investment Companies/Exchange-Traded
Funds Risk. When the Fund invests in other investment companies (including open-end mutual funds, closed-end funds or ETFs) it will
bear additional expenses based on its pro rata share of other investment company’s operating expenses, including the management
fees of unaffiliated funds in addition to those paid by the Fund. The risk of owning an investment company generally reflects the risks
of owning the underlying investments held by the investment company. The Fund may also incur brokerage costs when it purchases and sells
shares of investment companies. Additionally, a Fund will be indirectly exposed to the risks of the portfolio
assets held by the other investment company, which may include, but is not limited to, those of equity options, derivatives, currencies,
index, leverage, and replication management. Each Fund may invest in inverse ETFs, which may result in increased volatility and will magnify
the Funds’ losses or gains. During periods of market volatility, inverse ETFs may not perform as expected.

 6. Comment: Please conform the Spectrum ETF’s principal investment
objective to be consistent under Item 2 and Item 9.

Response: The Registrant has updated
the disclosure as requested under Item 9 as follows:

Investment Objective: The Liberty
One Spectrum ETF (the “Fund”) seeks to provide current income and the positions or opportunity
for capital appreciation to product a total return capital appreciation and to provide current
income. There is no guarantee that the Fund will achieve its investment objective. The Fund’s investment objective
may be changed by the Fund’s Board of Trustees upon 60 days’ prior written notice to shareholders.

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 7. Comment: Please conform the Defensive Dividend Growth ETF’s
principal investment objective to be consistent under Item 2 and Item 9.

Response: The Registrant has updated
the disclosure as requested under Item 9 as follows:

Investment Objective: The Liberty
One Defensive Dividend Growth ETF (the “Fund”) seeks to provide current income and the opportunity
for capital appreciation to produce a total return capital appreciation and to provide current
income. There is no guarantee that the Fund will achieve its investment objective. The Fund’s investment objective
may be changed by the Fund’s Board of Trustees upon 60 days’ prior written notice to shareholders.

 8. Comment: In the section “Principal and Other Risk Factors,”
please clearly indicate which risks are non-principal risks or move them to the SAI.

Response: The Registrant has added
the following explanatory disclosure in the paragraph above the risk table:

“The table below notes the principal
risks identified under “Principal Risk Factors” in each Fund’s summary.”

 9. Comment: Under the “Management” section of the Prospectus,
please identify any other titles each Portfolio Manager may have had while working for the Investment Adviser in the last five years.

Response: Additional disclosure
has been added, as applicable.

Statement of Additional Information

 10. Comment: The SAI states that both the Spectrum ETF and Tactical Income
ETF are “diversified” series of the Trust. Please confirm this disclosure and update as necessary.

Response: The Registrant has revised
the disclosure as follows:

“Spectrum ETF and
Tactical Income ETF are each is a “diversified” series of the Trust, meaning that Spectrum ETF and
Tactical Income ETF are is subject to diversification requirements of the Investment
Company Act of 1940 (the “1940 Act”), which generally limit investments, as to 75% of a fund’s total assets, to no more
than 5% in securities in a single issuer and 10% of an issuer’s voting securities. Defensive Dividend Growth ETF and
Tactical Income ETF is are each a “non-diversified”
series of the Trust.”

 11. Comment: Please include a diversification policy under the “Investment
Restriction” section.

Response: The Registrant has added
the following disclosure:

“8. Diversification. With respect
to 75% of its total assets, Spectrum ETF may not purchase any security (other than U.S. Government Securities or securities of other investment
companies) if as a result: (i) more than 5% of the Fund’s total assets immediately after, and as the result of, such purchase would
be invested in the securities of any one issuer, or (ii) the Fund would hold more than 10% of the outstanding voting securities of a single
issuer.”

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 12. Comment: Under the “Investment Restrictions” section
at the top of page 19 discussing the Fund’s review of the holdings of underlying funds for the purpose of evaluating industry concentration,
please clarify this language to reflect that the Funds will consider the investment of all investment companies in which it invests.

Response: The Registrant has revised
the disclosure as follows:

“With respect to the fundamental
policy relating to concentration set forth in fundamental investment restriction #5 above, if a Fund invests in one or more investment
companies that concentrates its investments in a particular industry, that Fund will examine its other
all look through to the underlying holdings of the investment companies
company in which the Fund is invested holdings
to ensure that such Fund is not indirectly concentrating its investments in a particular industry.”

We trust that the foregoing is responsive to your
comments. Please feel free to contact the undersigned at 212-885-5147 if you have any questions.

Sincerely yours,

	/s/ Stacy H. Louizos

Stacy H. Louizos

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