SecProbe.io

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April 12, 2023

EDGAR Operations Branch

Division of Investment Management

Securities and Exchange Commission

Attn: Ms. Christina DiAngelo
Fettig

100 F Street, N.E.

Washington, DC 20549

Capitol Series Trust
(the “Registrant”)

SEC File No. 811-22895

Dear Ms. Fettig:

Below please find our responses to your
comments with respect to the Registrant’s Registration Statement on Form N-14 (File No. 333-270510) (“Registration Statement”),
as filed with the U.S. Securities and Exchange Commission (the “SEC”) on March 13, 2023 (accession number 0001580642-23-001482)
related to the reorganization of the Hull Tactical US ETF (the “Target ETF”), a series of the Exchange Traded Concepts Trust
into the Hull Tactical US ETF (the “Acquiring ETF”), a series of the Capitol Series Trust (the “Reorganization”).

Proxy Statement/Prospectus

Comment 1: Confirm in correspondence any
repositioning of securities of the Target ETF in connection with the Reorganization, whether planned or forced.

Response to Comment 1: There will be no repositioning
of the securities of the Target ETF in connection with the Reorganization, either planned or forced. The entire portfolio of the Target
Fund will transition to the Acquiring Fund, and there will be no repositioning of the portfolio prior to the Reorganization As detailed
in the N-14, however, although the Target ETF and Acquiring ETF have the same investment objectives and substantially similar principal
investment strategies, HTAA has not been able to fully implement its options strategy as it relates to the Target Fund. That is because
the Target Fund’s Adviser, Exchange Traded Concepts, LLC and the ETC Trust have been reluctant to take on the derivatives risk management
oversight responsibilities associated with such investments. If the Plan is approved is approved by shareholders, HTAA intends to fully
implement the options component of its principal investment strategies as the Acquiring ETF Adviser, and the Acquiring ETF Adviser and
the Acquiring Trust will assume the derivatives risk management oversight responsibilities associated with these investments.

Comment 2: The fifth paragraph on the cover
page of the Proxy Statement/Prospectus indicates that the Target ETF and Acquiring ETF have “identical investment objectives and
principal investment strategies” while disclosure elsewhere indicates “substantially similar principal investment strategies.”
Please conform the disclosures for consistency, as appropriate.

Response to Comment 2: The subject
disclosure on the cover page of the Proxy Statement/Prospectus has been updated to reflect that the Target ETF and Acquiring ETF have
the same investment objectives and substantially similar principal investment strategies.

Comment 3: Please hyperlink the documents
incorporated by reference, as listed in the bullets on the second page of the cover page of the Proxy Statement/Prospectus. In addition,
please update the reference to the prospectus of the Target ETF to the most recent registration statement dated April 1, 2023.

Response to Comment 3:  The requested
changes have been incorporated into the Proxy Statement/Prospectus.

Comment 4: On page 4 of the Summary, related
to “Who will pay the costs associated with the Reorganization?,” please state that HTAA will pay the costs associated with
the Reorganization whether or not the Reorganization is consummated.

Response to Comment 4: The requested
change has been incorporated.

Comment 5: On page 5 of the Summary, related
to “What happens if the Reorganization is not approved?,” it states that in the event that the Reorganization does not take
place, the ETC Board will consider further actions to take. However, the disclosure on page 23 indicates that there are currently no other
proposed actions contemplated. Please conform the disclosure.

Response to Comment 5: The referenced
disclosure in the Summary has been updated to include the following statement: “Currently, there are no alternative actions contemplated
by the ETC Board for the Target ETF.”

Comment 6: Please remove the phrase “with
a different fiscal year end than the Target ETF” referenced under “What are the fees and expenses of the Target ETF and what
will the fees and expenses of the Acquiring ETF be after the Reorganization?” on page 15 of the Summary.

Response to Comment 6: The requested
change has been incorporated.

Comment 7: Please
complete the Expense Example hypothetical on page 16 of the Summary referenced under “What are the fees and expenses of the Target
ETF and what will the fees and expenses of the Acquiring ETF be after the Reorganization?”

Response to
Comment 7: The missing data has been included as follows:

Example

These examples are intended to help you compare the
cost of investing in the Target ETF Shares with the cost of investing in the Acquiring ETF Shares, both before and after the Reorganization.
The example assumes:

    ●
    You invest $10,000 in the Target ETF and in the Acquiring ETF for the periods shown;

    ●
    Your investment has a 5% return each year and the Funds’ operating expenses remain the same (except that any applicable fee waiver or expense reimbursement is reflected only through its expiration date);

    ●
    You reinvest all distributions and dividends without a sales charge;

 Although your actual costs may be higher or lower, based on these
assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    Target ETF – (with or without redemption at end of period)

    $97
    $303
    $525
    $1,166

    Pro Forma – Acquiring ETF (assuming the Reorganization is completed)*

    $97
    $303
    $525
    $1,166

Comment 8: The footnote to the Expense Example on
page 16 of the Summary states, “Pro forma numbers are estimated as if the Reorganization had been completed as of June 2, 2023,
and reflect the expense ratio for the period ended October 31, 2023, the Acquiring ETF’s new fiscal year end, and do not include
the estimated costs of the Reorganization.” The disclosure in the first paragraph of this section referenced under “What are
the fees and expenses of the Target ETF and what will the fees and expenses of the Acquiring ETF be after the Reorganization?” states
that the fees and expenses are based on the anticipated expenses of the Acquiring ETF during its first year of operations. Please conform
the disclosures.

Response to Comment 8: The referenced sentence
in the footnote to the Expense Example has been updated as follows (emphasis included to denote change): “Pro forma numbers are
estimated as if the Reorganization had been completed as of June 2, 2023, and reflect the expense ratio for the period ended October 31,
2023, the Acquiring ETF’s new fiscal year end and reflect the anticipated expenses of the Acquiring Fund during its first fiscal
period of operations, and do not include the estimated costs of the Reorganization.”

Comment 9: On page 17 of the Summary please include
the year-to-date return as of the most recent quarter end following the bar chart in the section related to “How do the performance
records of the ETFs compare?” consistent with the requirements of Form N-1A.

Response to Comment 9: The year-to-date return
as of the most recent quarter end has been included.

Comment 10: Please consider if it is appropriate to
expand the discussion under the fifth bullet point “The net assets of the Target ETF since its inception and the potential for the
Acquiring ETF to increase its assets over time compared to the Target ETF.,” on page 22 under the heading “Reasons for the
Reorganization” and modify accordingly.

Response to Comment 10: The subject disclosure
has been deleted.

Comment 11: The second sentence of the last paragraph
on page 22 states “The Board also noted that the Reorganization has the potential over time to lead to economies of scale that might
lead to lower annual fund operating expenses for the Acquiring ETF.” Please explain how the Reorganization would lead to lower expenses
of the Acquiring ETF or consider removing the subject disclosure.

Response to Comment 11. The subject disclosure
has been deleted.

Comment 12: The capitalization table data on page
24 under “Who will pay the expenses of the Reorganization?” needs to be completed and provided to the SEC prior to effectiveness
of the Proxy Statement/Prospectus. Please include the data in an N-14a filing, along with a delaying amendment. The SEC will review the
information and work with the Registrant on effectiveness of the Proxy Statement/Prospectus.

Response to Comment 12: The updated
capitalization table below has been included in the submission of a Form N-14a filing, along with a delaying amendment.

What are the capitalizations of the Funds and
what might the Acquiring ETF’s capitalization be after the Reorganization?

The following table sets forth as of March 29, 2023,
the capitalization of the Target ETF and the projected capitalization of the Acquiring ETF as adjusted to give effect to the proposed
Reorganization and assumes that the Reorganization is approved for the Target ETF. At the closing of the Reorganization, shareholders
of the Target ETF will receive the Acquiring ETF Shares based on the relative NAVs per shares of the Funds as of 4:00 p.m., Eastern time,
on the Closing Date.

    Target ETF
    Pro Forma- Acquiring ETF after Reorganization (estimated)

    Net Assets
    $25,018,729.69
    $25,018,729.69

    Total Shares Outstanding
    850,000
    850,000

    NAV per Share
    $29.43
    $29.43

Statement of Additional Information

Comment 13: In the Statement of Additional Information,
at page 3, please hyperlink the documents incorporated by reference, as listed in the bullets. In addition, please update the reference
to the prospectus of the Target ETF to the most recent registration statement dated April 1, 2023.

Response to Comment 13: The requested changes
have been incorporated into the Statement of Additional Information.

Part C

Comment 14: With regard to the Consent of the Independent
Registered Public Accounting Firm filed with Part C, please consider requesting the auditors include all name references included in the
Proxy Statement/Prospectus and file an updated consent.

Response to Comment 14: An updated Consent of the Independent Registered Public Accounting Firm is being filed with Form N-14/A submitted subsequently herewith.

If you have any additional questions, or need additional
information, please contact me by phone at 513-346-4152 or by e-mail at pleone@ultimusfundsolutions.com.
Alternatively, you may contact Thomas Sheehan, counsel to the Trust and its Independent Trustees, by phone at 207-632-0897 or by e-mail
at Thomas.Sheehan@practus.com.

    Sincerely,

    /s/ Paul Leone

    Mr. Paul Leone, Secretary

    Capitol Series Trust

    cc:

    Mr. Martin Dean, Chief Compliance Officer

    Ms. Tiffany Franklin, Assistant Secretary