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May 15, 2023

EDGAR Operations Branch

Division of Investment Management

Securities and Exchange Commission

Attn: Ms. Christina DiAngelo
Fettig

and Ms. Karen Rossotto

100 F Street, N.E.

Washington, DC 20549

Capitol Series Trust
(the “Registrant”)

SEC File No. 811-22895

Dear Ms. Fettig
and Ms. Rossotto:

Below please find our responses to your
comments of April 13, 2023 and April 14, 2023 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) and the subsequent filing of the Registration Statement on Form N-14/A on April 12, 2023
(accession number 0001580642-23-002066) 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”). In this response, we note that Registrant previously responded to comments Ms. Fettig provided
on March 29, 2023 with respect to Registrant’s original N-14 filing, and that such responses were incorporated into Registrant’s
April 12, 2023 N-14/A filing. We also note that Ms. Rossotto’s comments of April 14, 2023 related to the original N-14 filing of
March 13, 2023 and not the N-14/A filing on April 12, 2023, and in certain instances concerned matters that had been addressed or language
that had been modified in our N-14/A filing. We will endeavor to identify such situations in this response.

Proxy Statement/Prospectus

Comment 1: Several occurrences in the Form
N-14 Proxy Statement/Prospectus indicate that the Target ETF and Acquiring ETF have “identical principal investment strategies and
risks” while disclosure elsewhere indicates “substantially similar principal investment strategies and risks.” Please
conform the disclosures for consistency, including on pages 1, 2, 3, 7, 8 and 22, as appropriate.

Response to Comment 1: All occurrences in the
Proxy Statement/Prospectus have been updated to reflect that the Target ETF and Acquiring ETF have identical investment objectives and
substantially similar principal investment strategies and risks, including with regard to the referenced pages.

Comment 2: With regard to the disclosure
presented in the section titled “Important Shareholder Information,” please include detail describing why the reorganization
is occurring.

Response to Comment 2: The following disclosure has
been added as the fourth paragraph to the referenced section: “The Reorganization is proposed for
three primary reasons: (1) to enable HTAA, LLC, which currently serves as the subadviser to the Target ETF (“Target ETF Subadviser”),
to serve as the investment adviser to the Acquiring ETF (“Acquiring ETF Adviser”) in a single adviser fund structure; (2)
subject to the approval of the Board of Acquiring Trust, to enable HTAA to fully implement its options

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strategy, which it has been unable to do in its role
as the Target ETF Subadviser. including investments through sophisticated trading strategies in S&P 500 Index-related options and
equity options; and (3) to create the opportunity for HTAA to implement an effective derivatives risk management program (“DRMP”),
tailored to a single-adviser fund structure rather than a subadvisory fund structure, with transparency to monitor the portfolio and trades
verify compliance with applicable derivative limitations on an intraday basis, and supported by an administrator with extensive DRMP experience
and the necessary tools to support both the Adviser and the Acquiring Trust’s Board in fulfilling their DRMP responsibilities.

Comment 3: The last paragraph in the section
titled “Important Shareholder Information,” states that shares may be voted by telephone “if eligible.” Please
explain what is meant by “if eligible.”

Response to Comment 3:  The subject
disclosure has been deleted in the Registrant’s filing on Form N-14/A on April 12, 2023 (accession number 0001580642-23-002066).

Comment 4: The Notice of Meeting includes
the following: “Proxy card instructions may be revoked at any time before they are exercised by submitting a written notice of revocation
or a subsequently executed proxy card or by attending the Meeting and voting in person.” Please describe the process for how a vote
can be revoked if voting occurs by telephone or the internet.

Response to Comment 4: The following
disclosure has been substituted for the quoted sentence: “If you have authorized a proxy to vote on the proposed reorganization,
whether by mail, by telephone, or through the internet, you may revoke such authorization at any time before it is exercised by: (1) sending
in another proxy card with a later date; (2) sending a written notice the Secretary of the Target ETF expressly revoking your proxy, or
(3) attending the Meeting and voting in person. Please remember that since your voting instructions are processed in the order in which
they are received, your last vote received will be the one that counts”.

Comment 5: On page 1 of the Summary, related
to “Why is the Reorganization Being Proposed?,” please include details regarding the considerations of the Board of the Target
ETF in approving the reorganization, including with regard to implementation of the options component of the Target ETF’s principal
investment strategy, given the statement “…the ETC Trust have been reluctant to take on the derivatives risk management oversight
responsibilities associated with such investments.” In an appropriate location, please also address the considerations of the Board
of the Acquiring ETF with regard to implementing a derivatives risk management program in light of the options strategy to be implemented
in the Acquiring ETF.

Response
to Comment 5: The Registrant wishes to inform the staff that the referenced quoted disclosure on page 1 of the Summary reflected
the views of HTAA and was included in the Registration Statement by the Registrant without first consulting the adviser to the Target
ETF, Exchange Traded Concepts, LLC (the “Target ETF Adviser”). It was subsequently removed from the Registration Statement
by pre-effective amendment filed on April 12, 2023 and was replaced with alternative disclosure.1 The Target ETF Adviser

1 The
alternative disclosure (as modified to reflect a consistent description of the comparative investment objectives and principal investment
strategies of the Target ETF and Acquiring ETF in response to Comment 1 above) read as follows:

The Reorganization is being proposed
to enable HTAA LLC, which serves as the subadviser to the Target ETF (“HTAA” or “Target ETF Subadviser”) to serve
as the adviser to the Acquiring ETF (“Acquiring ETF Adviser”) if shareholders approve the Plan, to fully implement the options
component of the ETFs’ principal

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and ETC Trust have implemented and continue
to maintain and operate a robust derivatives risk management program (“DRMP”), actively administered by the program’s
derivatives risk manager and overseen by the Board of Trustees, including Independent Trustees.

We offer a brief history of the evolution
of the Target ETF’s investment strategy that has been developed by HTAA LLC, the Target ETF's sub-adviser, to provide greater context
for one of the reasons that the Reorganization is being proposed. Prior to the Fund’s commencement of operations in 2015, the Target
ETF Adviser engaged HTAA to develop and implement the Target ETF’s investment strategy, with the Target ETF Adviser retaining responsibility
for carrying out HTAA’s investment decisions by trading the Target ETF’s portfolio. Over time, HTAA refined and modified the
Target ETF’s strategy. In this regard, at the recommendation of HTAA in late 2020, the Target ETF’s strategy was enhanced
to allow investment in S&P 500 Index-related options (see prospectus supplement dated December 29, 2020 and subsequent post-effective
amendment to the Target ETF’s registration statement that became effective on April 1, 2021). Shortly thereafter, based on the recommendation
of the Target ETF Adviser and HTAA, portfolio trading responsibilities were transitioned to HTAA (see prospectus supplement dated September
9, 2021). Thereafter, the Target ETF’s strategy was further modified to allow investment in equity options, in addition to S&P
500 Index-related options (see supplement dated January 31, 2022 and subsequent post-effective amendment to the Target ETF’s registration
statement that became effective on April 1, 2022).

The Target ETF Adviser notes that, at the
time the Target ETF’s strategy was changing to permit investment in equity options in early 2022, it was in the process of preparing
to comply with Rule 18f-4 requirements and structuring a DRMP. The DRMP designed by the Target ETF Adviser for the Target ETF meets the
various conditions of and operates in compliance with Rule 18f-4. At no time was the Target ETF Adviser concerned with its ability to
operate its DRMP with respect to the Target ETF or comply with Rule 18f-4.

However, as options investments would be
becoming a larger overall component of the Target ETF’s strategy and would have been effected through increasingly sophisticated
trading strategies, the Target ETF Adviser did not believe it would have adequate intraday transparency into the Target ETF’s portfolio
to monitor it in real-time. The Target ETF Adviser, therefore, determined as a business matter that HTAA’s enhanced options program
for the Target ETF needed further evaluation before it could be implemented. The Target ETF Adviser and HTAA, therefore, agreed that HTAA
would postpone implementation.

While the Target ETF Adviser was conducting
its evaluation, HTAA independently sought another shared trust that would permit it to promptly implement the options strategy. Once satisfied
that CST would permit HTAA to do so and confirming that, like ETC Trust, CST possessed the necessary infrastructure and expertise to support
the Target ETF, HTAA recommended to the Target ETF Adviser and the ETC Trust Board that the Target ETF be reorganized into a new series
of CST. In response, HTAA and ETC Trust

investment strategies. As discussed in greater detail below, although the stated investment objective
the Target ETF and Acquiring ETF are identical, and the principal investment strategies of the Target ETF and Acquiring ETF are substantially
similar, HTAA has not been able to fully implement its options strategy as it relates to the Target ETF. If the Plan is approved by shareholders,
HTAA intends to fully implement the options component of its principal investment strategies as the Acquiring ETF Adviser.

Registrant has further modified this disclosure by
adding the following sentence at the end of the preceding paragraph. “The fact that the options strategy was not fully implemented
in the Target ETF and may be fully implemented in the Acquiring ETF may impact the fund’s performance and risk profile as it transitions
to the Acquiring Trust.”

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conducted due diligence on CST and presented
information to the ETC Trust Board for its consideration of the proposed reorganization. Further, the ETC Trust Board and the Target ETF
Adviser had an opportunity to meet with representatives of CST and HTAA to further discuss the operations, practices and procedures of
CST and the support that the Target ETF would receive as a series of CST. After evaluating all of this information, the Target ETF Adviser
and Board of ETC Trust both concluded that the operation of the Target ETF as a series of CST would be in the best interests of shareholders.

In determining to approve the Reorganization,
including with regard to implementation of the options component of the Target ETF’s principal investment strategy following the
Reorganization, the Independent Trustees of the Target ETF also considered the following related to the Acquiring Trust’s capabilities
to support HTAA’s DRMP:

 · The Acquiring ETF’s Chief Compliance Officer and the Acquiring ETF’s
counsel assured the Target ETF’s Independent Trustees that CST has options experience and portfolio management and monitoring capabilities
that comply with Rule 18f-4 and monitor risks; and also employs an outside expert consultant;

 · The Acquiring Trust makes use of an affiliate of Confluence in the operation
of its Rule 18f-4 derivatives risk management program;

 · The Acquiring Trust appears to have a capable and experienced Board; and
the Target ETF’s Independent Trustees reviewed the experience of each; and

 · The Target ETF’s Independent Trustees asked questions and were provided
with a due diligence response that included addressing follow-up questions.

Details regarding the considerations of the Board
of the Target ETF in approving the reorganization are included in the Summary under the new heading “Why is the Reorganization
Being Proposed, and Why Did the Board of the Target ETF Approve the Plan of Reorganization?

With respect to the staff’s request
that Registrant address the considerations of the Board of the Acquiring ETF with regard to implementing a derivatives risk management
program in light of the options strategy to be implemented in the Acquiring ETF, Registrant has added the following language to the Q
& A section of the filing, immediately following the Question “Will there be changes to the Board of Trustees and service
providers for the Acquiring ETF?”

What Did the Board of the Acquiring
ETF Consider With Regard to the Implementation of Derivatives Risk Management Program in Light of the Options Strategy to be Implemented
in the Acquiring ETF?

The Board and Officers of Capitol Series
Trust (“Acquiring Trust or “CST”) considered the implementation of a DRMP in connection with HTAA’s full implementation
of its options strategy post-reorganization on three separate occasions. The first of these occurred at a special telephonic meeting of
the Board held on November 17, 2022 (“Special Meeting”) that was attended by all of the Acquiring Trust’s Trustees and
Officers, by Trust counsel, and by representatives of HTAA. The purpose of the Special Meeting was to consider resolutions to authorize
the drafting of an N-14 proxy statement to reorganize the Target ETF into CST and to approve the filing of an amendment to the Acquiring
Trust’s registration statement to add Hull

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Tactical ETF as a new series of CST, with
HTAA serving as the Fund’s adviser, rather than the subadvisory role that it has with the Target ETF. At the meeting, Matthew Miller,
President to the Trust, provided a brief overview of the Hull ETF and the investment strategy used by HTAA to manage the Hull Tactical
ETF. He also informed the Board that one of the reasons that HTAA sought to move the Hull ETF to CST was that it had not been able to
fully employ its options trading strategy in the ETC subadvised fund, but intends to do so when it transitions to CST.

Mr Miller then introduced Petra Bakosova,
CEO of HTAA and portfolio manager of the Target ETF, and William Raj, HTAA’s Operations Manager. Referring the Trustees to presentation
materials that HTAA had disseminated to the Board, she then:

 · Provided background information about HTAA, noting
that the firm is an SEC-registered investment advisor focused on quantitative asset management that was founded in 2013 by Blair Hull,
who serves as HTAA’s Chairman and is its majority owner through his interest in HTAA Holdings LLC HTAA’s parent company. She
also noted that prior to founding HTAA, LLC, Mr. Hull was the founder of Hull Trading Company and served as the firm’s Chairman
and CEO until selling it to Goldman Sachs in 1999. She noted that at its peak, Hull Trading Company traded on 28 exchanges in nine countries
and moved nearly a quarter of the entire daily market volume on some markets, executed over 7% of the i