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CAPITOL SERIES TRUST

225 Pictoria Drive, Suite 450

Cincinnati, Ohio 45246

August 24, 2023

VIA EDGAR

Ms. Karen L. Rossotto

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: Capitol Series Trust (the “Registrant”)

File Nos. 333-191495 and 811-22895

Dear Ms. Rossotto:

On behalf of the Registrant, set forth below are the
Registrant’s responses to comments received from the staff of the Division of Investment Management regarding post-effective amendment
No. 138 (“PEA 138”) to the Registrant’s registration statement under the Securities Act of 1933, as amended (the “Securities
Act”), and Post-Effective Amendment No. PEA 139 under the Investment Company Act of 1940, as amended (the “Investment
Company Act”), filed pursuant to Rule 485(a) on June 29, 2023 with respect to Canterbury Portfolio Thermostat Fund.

In connection with this response letter, on August
28, 2023, the Registrant anticipates filing, pursuant to Rule 485(b), post-effective amendment No. 141 to the Registrant’s registration
statement under the Securities Act (“PEA 141”), which is expected to include (i) changes to PEA 138 in response to the Staff’s
comments, (ii) certain other non-material information; and (iii) certain other required exhibits.

Set forth in the numbered paragraphs below are the
oral comments on PEA 138 that the Staff communicated to Registrant on August 14, 2023, followed by Registrant’s responses to such
comments.

Ms. Karen L. Rossotto

U.S. Securities and Exchange Commission

Division of Investment Management

August 24, 2023

Page 2

 1. Staff Comment: As an overriding
                                            comment, the staff notes that the Fund’s investment strategy is somewhat vague. Please
                                            attempt to clarify the investment strategy, and how the fund will employ that strategy to
                                            achieve its investment objective. Please also explain what the investment strategy was, and
                                            how it is changing in connection with the filing of PEA 138 and PEA 141.

□ Registrant’s Response: Registrant
will attempt to clarify the Fund’s investment strategy throughout the prospectus in response to the staff’s comments. In
terms of how the investment strategy is changing in connection with the filing of PEA 138 and PEA 141, as noted in the first paragraph
of the prospectus under the heading “Principal Investment Strategies”, the Fund, which until now has been structured as a
fund of ETFs, will prospectively under normal circumstances continue to invest more than 50% of the Fund’s portfolio in ETFs, but
will also have the ability to invest up to 50% of the Fund’s assets in listed securities of individual issuers, some of which may
also be held by the underlying ETFs in which Fund invests.

 2. Staff Comment:  In the Investment Objective and the first
                                            sentence of the Principal Investment Strategies on page 2 of the Prospectus, please clarify
                                            in plain English what you mean by “risk-adjusted growth”?

□ Registrant’s Response: Risk-adjusted
growth is defined as the return of an investment or “growth” relative to risk or “volatility” experienced. We
define risk as volatility and drawdown. So, in plain English, the fund seeks to grow investments with lower volatility/fluctuations,
or greatest return for a given level of risk (i.e., standard deviation).

 3. Staff Comment: In the section Principal Investment Strategies,
                                            last paragraph, 5th line, please describe in the disclosure what an “alternative security”
                                            is.

□ Registrant’s Response:
An alternative security is any liquid traded security that is not a traditional stock or bond. We define an “Alternative
Security” as an ETF that is invested in commodities, currencies, or is a 1x inverse fund. The fund does not invest in alternative
securities that are not ETFs.

4.
Staff Comment: In the section Principal Investment Strategies, please describe with specificity the types of securities
the fund will invest in and with respect to equity securities, describe the market capitalization of the equity securities the fund will
invest in.

□ Registrant’s Response:
 Given that the fund has a “go-anywhere” strategy, it is unconstrained with respect to market capitalization, investment
style (such as growth or value), or geography (whether domestic, international or emerging markets). While the Fund has the authority
to invest directly in any security which its underlying ETFs are eligible to invest in, the Fund currently intends to achieve exposure
to fixed income, currencies, commodities, and inverse securities exclusively through investments in ETFs when needed as a risk management
tool.

Ms. Karen L. Rossotto

U.S. Securities and Exchange Commission

Division of Investment Management

August 24, 2023

Page 3

 5. Staff Comment: In the section Principal Investment Strategies,
                                            please disclose whether the fund will invest in leveraged ETFs.

□ Registrant’s Response:
Registrant responds by directing the staff’s attention to the language on page 3 of the Prospectus, in the last sentence
under subparagraph (2) under the heading “Overview of Portfolio Thermostat Strategy”: “ETFs or mutual funds that use
various derivatives, sometimes referred to as leverage, may be included in the universe of potential Fund holdings as long as the ETF
or mutual fund does not exceed a 1x1 relationship to the underlying index or asset class. Any ETF or mutual fund that uses “leverage”
to create more volatility (such as a 2x1 or 3x1) for the purpose of creating a “multiplier effect” has been determined to
be inappropriate for meeting the Fund’s objectives and will not be included in the universe of potential holdings.”

 6. Staff Comment: In the section Principal Investment Strategies, please consider whether the
designation of the fund as a “fund of funds” is appropriate.

□ Registrant’s Response:
 In response to the staff’s comment, given that the fund is expected to hold from 50% to 100%
of its assets in ETFs, Registrant believes it is both appropriate and necessary to describe the fund of funds strategy as it relates to
that portion of the Fund’s investments and the attendant risks. However, in response to this comment, Registrant has modified the
referenced sentence in the Principal Investment Strategies section of the prospectus to read as follows:

“Under
normal circumstances, the Fund invests more than 50% of its assets, and may invest up to 100% of its assets, in ETFs, and that portion
of the Fund’s investments that are structured as a fund of funds and are subject to the attendant risks of a fund of funds structure”.

 7. Staff Comment: In the section Principal Investment Strategies, paragraph one, please clarify
what “actively managed” means with in relation to “rules-based methodology”. That is, what part of the investment
strategy is actively managed and what part is rules-based, and what data is used to evaluate both quantitative and qualitative factors
in making investment selections.

□ Registrant’s Response:
“Active management” is making subjective or objective decisions of what to buy and sell
within the portfolio, as opposed to “passive” or index investing. “Rules-based methodologies” are not inconsistent
with active management in our process. The combination of securities that can be chosen are based on a set of defined rules. The actual
combination of securities that are implemented into the portfolio are also based on rules but do have a degree of manager discretion.

 8. Staff Comment:  In the section Principal Investment Strategies,
please explain how the principal investment strategies are used to obtain long-term, risk adjusted growth.

Ms. Karen L. Rossotto

U.S. Securities and Exchange Commission

Division of Investment Management

August 24, 2023

Page 4

□ Registrant’s
Response: The Fund aims to limit risk, as defined by “volatility” and “drawdown”
(or declines). The fund is an adaptive strategy, meaning that it adjusts its holdings and allocations to move in concert with ever-changing
market environments. As markets fluctuate, risks within the markets change, whether going from a low volatility environment to a high
volatility environment or vice versa. The fund seeks long-term, risk adjusted growth by attempting to limit portfolio declines during
highly volatile bear markets. By limiting declines, the portfolio has a larger “base” to compound. As an example, a -10% decline
only requires an 11% return to breakeven, but a -50% decline requires going up 100% to breakeven. The Fund aims to limit declines and
provide stable growth to achieve long-term, risk-adjusted growth, meaning growth adjusted for the volatility seen in the portfolio.

 9. Staff Comment: In the Overview of the Portfolio Thermostat Strategy, page, 3, paragraph
marked (1), last sentence, please explain how the “overall market trend” determines portfolio allocation.

Registrant’s
Response:  The “overall market trend” is previously defined within that same paragraph
as being “bullish,” “transitional,” or “bearish.” The overall market trend determines portfolio allocation
in the sense that as a go-anywhere strategy, the Fund’s allocation may differ in each of those 3 market environments. As an example,
in a Bullish market environment, the Fund may have minimal exposure to non-equity ETFs or securities. On the contrary, in a Bearish market
environment, the Fund may have larger exposure to inverse securities and other alternative ETFs to limit the portfolio’s volatility
in an environment where most equity securities are exhibiting high volatility and high risk.

 10. Staff Comment: In the Overview of the Portfolio Thermostat Strategy, page, 3, paragraph
marked (2), please describe what “alternatives” means in connection with the investment strategy. That is, describe what kind
of securities are considered “alternatives”. Also, please describe the credit quality of the fixed income securities the fund
will invest in, whether the fund invests in high yield fixed income securities, and if yes, please disclose that high yield fixed income
securities are also known as “junk bonds”.

□ Registrant’s
Response: Alternative securities are any ETFs in our universe that are not traditional stocks or
bonds. In this case, we are referring specifically to ETFs whose underlying holdings are commodities (such as gold, copper, silver), currencies
(such as USD, Euro, Yen, etc.), and 1x inverse securities (such as inverse S&P 500 or Inverse Emerging Markets). As it relates specifically
to fixed income, the Fund gets exposure to fixed income through the use of ETFs.

Ms. Karen L. Rossotto

U.S. Securities and Exchange Commission

Division of Investment Management

August 24, 2023

Page 5

 11. Staff Comment: In the Overview of the Portfolio Thermostat Strategy, in paragraph marked
(2) please clarify the disclosure in the sentence “The Fund’s universe of investments is created to be as representative as
possible of major style indices, geographic regions, individual countries, market sectors, and industries within market sectors”.
Please describe in more detail what specific securities and ETFs the Fund is investing in and what data is used to evaluate the portfolio’s
construction. Also, in the last sentence on page 3 where the number of individual securities is mentioned (12-14), please explain how
this relates to or correlates with the Fund’s high portfolio turnover ratio.

□ Registrant’s Response:
With respect to the specific clauses of the referenced disclosure and staff comment italicized below, Registrant responds as follows:

“The Fund’s universe of
investments is created to be as representative as possible of major style indices, geographic regions, individual countries, market sectors,
and industries within market sectors”.

The Fund’s universe of potential
holdings is constructed of ETFs and individual listed securities. To give examples, as it relates to equity securities, stocks chosen
for the Fund are typically domestic or an ADR listed on major US exchanges. The ETFs that are used are broad ranging and representative
of many asset classes. To name a few examples, as it relates to ETFs:

 · Major Style Indexes: large cap/mid cap/small cap growth & value index ETF

 · Geographic regions: MSCI EAFE, Europe, Emerging Markets, Asia Pacific, Latin America

 · Individual Countries: Mexico, Japan, Brazil, South Korea, Vietnam, China, India, Switzerland, Italy

 · Market Sectors: S&P 500 11 Sectors (info tech, communications, financials, real estate, industrials,
consumer discretionary, consumer staples, utilities, basic materials, health care, and energy)

 · Industries within market sectors: Biotech, homebuilders, retailers, food and beverage, semiconductors,
insurance, banks

Ms. Karen L. Rossotto

U.S. Securities and Exchange Commission

Division of Investment Management

August 24, 2023

Page 6

What data is used to evaluate the
portfolio’s construction.

The above examples are ETFs. For gaining
exposure to these different styles, regions, etc., there may be a few options varying across ETF providers. The Fund typically uses ETFs
from larger, well-known providers such as State Street or iShares, and occasionally First Trust. When choosing between similar ETFs, the
Fund considers a variety of factors such as internal fund fees, size of the ETF, and volume. These individual ETFs are all rated and ranked
based on a combination of technical indicators for potential holding purposes. The Fund also aims to avoid duplication of securities within
the portfolio.

Also, in the last sentence on page
3 where the number of individual securities is mentioned (12-14), please explain how this relates to or correlates with the Fund’s
high portfolio turnover ratio.

On average, the fund will typically hold
between 12-14 holdings, although it could be as few as 9 or as many as 15. Those holdings will be a combination of ETFs and individual
listed stock securities. The Fund’s individual ETF holdings will range in size from about 5-9% on average and represent up 100%
of the Fund’s holdings. The Fund’s exposure to individual listed stock securities may be up to 50% of the Fund’s holdings.
There would be no effort made to differentiate between the total number of positions split between stocks and ETFs.

The fund has high turnover, given that
each position is roughly between 5-9% of the total portfolio. The turnover of ETFs and individual stock securities would in theory be
about the same, given that security selection decisions for both stocks and ETFs are based on the same indicators. Depending on the type
of market environment, the Fund may be more active in trading. With each position bought and sold, that is 5-9% of the portfolio being
sold, and replaced with another 5-9% position. This can result in high turnover, regardless of the market environment. Typically, in a
more stable market environment, turnover may be lower due to holdings exhibiting “bullish” characteristics for longer periods
of time, but the Fund still would be turning over 5-9% with each transaction.

 12. Staff Comment: At page 4, in the section Overview of the Portfolio Thermostat Strategy,
please explain the concept of “optimal volatility”, how that is measured and how optimal volatility is obtained. With respect
to the sentence “The primary purpose of listed security holdings of individual issuers is to raise the portfolio’s volatility
to an optimum range…”, please explain how in the disclosure how individual securities are used to manage volatility.

Ms. Karen L. Rossotto

U.S. Securities and Exchange Commission

Division of Investment