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May 31, 2024

EDGAR Operations Branch

Division of Investment Management

Securities and Exchange Commission

Attn: Ms. Karen Rossotto

100 F Street, N.E.

Washington, DC 20549

Capitol Series Trust
(the “Registrant”)

SEC File No. 811-22895

Dear Ms. Rossotto:

Below please find our responses to your comments
with respect to the Registrant’s Post-Effective Amendment 142 (“PEA No. 142”) to its Registration Statement
on Form N-1A (“Registration Statement”), as filed with the U.S. Securities and Exchange Commission (the “SEC”)
on September 26, 2023 (accession number 0001580642-23-005130). The purpose of PEA No. 142 is to add the Nightview Fund (the “Fund”)
as a series of the Registrant.

Before addressing your prior comments, however,
we would like to apprise the staff of the current status of our filing and our requested date of effectiveness. As noted, PEA 142 was
filed on September 26, 2023, with a requested effectiveness date of 75 days from the filing, or December 10, 2023. However, based on the
comments that Registrant received from the staff, including Jeffrey Long of the Division of Investment Management’s Disclosure Review
and Accounting Office, and taking into account the scheduling challenges associated with orchestrating a conversion of the Predecessor
Fund in a time frame, as well as the proximity of the originally proposed effectiveness date for the Fund and the December 31 fiscal year
end of the Predecessor Fund, Registrant made a decision to delay the effectiveness of the Fund until such time as the audited financials
of the Predecessor Fund for the fiscal year ended December 31, 2023 could be included in the filing. To that end, we filed post-effective
amendments pursuant to Rule 485bxt on December 8, 2023, January 10, 2024, February 9, 2024, March 11, 2024, April 10, 2024, and most recently
May 9, 2024 (with a proposed effectiveness date of June 10, 2024.)

Drafts of the audited financial statements
for the Predecessor Fund as of December 31, 2023 became available only recently and were provided to Mr. Long for his review on April
23. Our plan going forward is to file simultaneously with this comment letter response Registrants Post-Effective Amendment No. 158, pursuant
to Rule 485(a), which incorporates our responses to the staff’s comment letter and also provides audited financials of the Predecessor
Fund, with a request that the Fund’s effectiveness be accelerated to June 10, 2024 or as soon as practical thereafter in order to
accommodate a service conversion and asset transfer on or shortly after that date. Registrant also wishes to apprise the staff that at
an in-person meeting of Registrant’s Board on March 12, 2024, the Board and its Independent Trustees, voting separately, approved
a Trading

Subadvisory
Agreement between Nightview Capital, LLC, the Fund’s investment adviser (“Adviser”), and Exchange Traded Concepts,
LLC (“ETC” or “Subadviser”), an Oklahoma limited liability company with its principal place of business at 10900
Hefner Pointe Dr., Suite 400, Oklahoma City, OK 73210. ETC’s role, as set forth in the Subadvisory Agreement, is limited to assisting
the Adviser in the execution of trades for the Fund. Under the terms of the Subadvisory Agreement, the Adviser has retained and has not
delegated to the Subadviser either the authority or the responsibility to determine the types of assets that will be purchased, retained
or sold by the Fund, or the portion or the of the Assets will be invested or held uninvested in cash, or the determination of what cash
investment vehicles the Fund will invest in. Registrant has incorporated disclosure regarding the Subadviser into the prospectus, and
will include a copy of the Subadvisory Agreement as an exhibit in Post-Effective Amendment No. 158.

Staff Comments Related
to the Prospectus

Comment 1: Please include a footnote
to Acquired Fund Fees and Expenses in the Fees and Expenses table that states Acquired Fund Fees and Expenses are estimated for the current
fiscal year.

Response to Comment 1: The Registrant
has incorporated the requested footnote.

Comment 2: Please include 5 Year and
10 Year expense examples because the Fund is showing prior or related performance.

Response to Comment 2: The Registrant
has incorporated the requested 5 Years and 10 Years expense examples.

Comment 3: Please consider whether the
second bullet under the eleventh paragraph in the Fund’s Principal Investment Strategies section related to the Landgrab Mentality
is consistent with the Fund’s investment policy to invest 80% in U.S. issuers. If international securities are a principal investment
of the Fund, please disclose accordingly.

Response
to Comment 3: In response to Comment 3, we have modified the principal investment strategies disclosure of the prospectus by adding
the following language following the first sentence of the first heading under the heading Principal Investment Strategies paragraph to
read as follows:

“The
Fund may invest up to 20% of its net assets in securities and instruments that trade in U.S. dollars on U.S. exchanges but are economically
tied to foreign developed markets, including American Depositary Receipts (ADRs). ADRs are issued by U.S.
banks (depositories) and represent ownership interests in securities of foreign companies that are deposited with those banks. The Fund
may invest in sponsored ADR arrangements wherein the foreign issuer assumes the obligation to pay some or all of the depository’s
transaction fees or unsponsored ADR arrangements wherein the foreign issuer assumes no obligations and the depositary’s transaction
fees are paid directly by the ADR holder."

We have modified the principal
investment risks disclosure of the prospectus to read as follows:

Foreign
Security Risk. Foreign investments, including ADRs, are subject to sovereign risk and may be adversely affected by changes
in currency exchange rates, future political and economic developments, and the possible imposition of exchange controls or other foreign
governmental laws or restrictions There may be less publicly available information about a foreign company than about a U.S. company,
and accounting, auditing and financial reporting standards and requirements may not be comparable. Depending on the specifics of the investment,
the Fund’s foreign investments may also be subject to the following specific risks:

 · ADR Risk. Investments
in ADRs are subject to many of the same risks that are associated with direct investments in securities of foreign issuers (see, “Foreign
Security Risk” above). These risks may adversely affect the value of the Fund’s investments in ADRs. In addition, ADRs may
not track the price of the underlying foreign securities, and their value may change materially at times when the U.S. markets are not
open for trading In a sponsored ADR arrangement, the foreign issuer assumes the obligation to pay some or all of the depository’s
transaction fees Under an unsponsored ADR arrangement, the foreign issuer assumes no obligations and the depositary’s transaction
fees are paid directly by the ADR holders. Because unsponsored ADR arrangements are organized independently and without the cooperation
of the issuer of the underlying securities, available information concerning the foreign issuer may not be as current as for sponsored
ADRs and voting rights with respect to the deposited securities are not passed through.

Comment 4: This comment relates to the
use of the word “concentrated” in the second sentence and “concentration” in the last sentence of the seventeenth
paragraph in the Fund’s Principal Investment Strategies section, which state as follows:

“It is a “best ideas”
portfolio, and typically will be more concentrated than many ETFs or mutual funds.”

“However, the Fund’s performance
will most likely be more volatile than the S&P 500 Total Return Index given its concentration relative to the Index.”.

Please rephrase or delete both terms to eliminate
confusion regarding concentration because the Fund will not be concentrated in a particular industry or group of industries under the
Investment Company Act of 1940.

Response to Comment 4:  The two
sentences have been revised as follows:

 1. “It is a “best ideas” portfolio that is characterized
as non-diversified for purposes of the Investment Company Act of 1940 and typically will be less diversified than many ETFs or mutual
funds.”

 2. However, the Fund’s performance will most likely be more volatile
than the S&P 500 Total Return Index given the level of its diversification relative to the Index.”

Comment 5: It is unclear in the disclosure
what the relationship is between the Fund’s principal investment strategy and its investment objective of outperformance of the
S&P 500 Total Return Index over a rolling five-year period. Clarify in the disclosure how this goal is determined given the Fund's
strategy (i.e., tie the strategy to the objective).

Response to Comment 5:

In response to Comment 5, Registrant has added
the following modified disclosure as a substitute for the first 2 paragraphs in the prospectus under the heading “Principal Investment
Strategies”:

The Fund is actively managed and under normal
circumstances invests at least 80% of its net assets in securities and instruments issued by or economically tied to U.S. issuers.  In
addition, the Fund may invest up to 20% of its net assets in securities and instruments issued by U.S. banks but economically tied to
foreign developed markets, including American Depositary Receipts (“ADRs”). ADRs are issued by U.S. banks (depositories) and
represent ownership interests in securities of foreign companies that are deposited with those banks. The Fund may invest in sponsored
ADR arrangements wherein the foreign issuer assumes the obligation to pay some or all of the depository’s transaction fees or unsponsored
ADR arrangements wherein the foreign issuer assumes no obligations and the depositary’s transaction fees are paid directly by the
ADR holder

In seeking to achieve its investment objective
of long-term capital appreciation, with a goal of outperforming the S&P 500 Total Return Index over a
rolling five-year period, the Adviser adheres to its long-held belief in long-term, fundamental value investing, and seeks to invest
in companies that it believes are trading at a material discount to the Adviser’s estimate of fair value, with clear catalysts for
a narrowing of that discount over the course of several years. The Adviser’s primary focus in attempting to achieve its investment
objective is on identifying innovative, forward-looking businesses that can generate growth for the foreseeable future, continually reinvest
in the business, and focus on providing a superior value proposition to their consumers.

Comment 6: The last paragraph in the Fund’s
Principal Investment Strategies section, as referenced below, relates to defensive strategies. Please consider whether these are Principal
Investment Strategies of the Fund and, if not, please move the disclosure to Item 9 later in the Prospectus.

During periods when the Fund’s assets
(or portion thereof) are not fully invested in accordance with the above, all or a portion of the Fund may be invested in cash instruments,
which for this purpose include U.S. Treasury obligations; cash and cash equivalents including commercial paper, certificates of deposit
and bankers’ acceptances; repurchase agreements; shares of money market mutual funds; and high-quality, short-term debt instruments
including, in addition to U.S. Treasury obligations, other U.S. government securities (collectively, “Cash Instruments”).
Additionally, to respond to certain adverse market, economic, political or other conditions, the Fund may invest 100% of its assets, without
limitation, in cash

instruments.
The Fund may be invested in this manner for extended periods, depending on the Adviser’s assessment of market conditions. During
this time, the Fund may not be able to meet its investment objective. To the extent that the Fund invests in ETFs or money market mutual
funds, the Fund would bear its pro rata portion of each such ETF or money market fund’s advisory fees and operational expenses.

Response to Comment 6: The Registrant
has moved the referenced disclosure to Item 9 later in the Prospectus.

Comment 7: Relating to the Fund’s Past
Performance, please provide the following information supplementally in correspondence:

 a. Describe the background of the Predecessor Fund, including information about when and why the Predecessor
Fund was created.

Response to Comment 7.a. The
Predecessor Fund commenced operations on March 1, 2018. The Predecessor Fund was created in order to realize efficiencies relative to
the Adviser’s prior model of managing numerous separate accounts in the same investment strategy. Shortly before the Predecessor
Fund Commenced operations, the Adviser converted separate accounts into a private fund employing a long/short equity strategy, and the
Adviser quickly recognized the benefits of the private fund structure.

 b. State that the adviser for the Fund was the adviser for the Predecessor Fund for the entire performance
period shown. Also, state whether the adviser managed any other funds that were materially equivalent to the Fund. Were these other funds
converted to registered companies, and if not, why not? Please explain why the Predecessor Fund was chosen to be registered and if any
other materially equivalent fund had lower performance as compared with the Predecessor Fund.

Response to Comment 7.b. The
Adviser represents that it served as the Adviser for the Predecessor Fund for the entire performance period shown, and that it did not
manage any other funds that were materially equivalent to the Fund.

 c. State whether the adviser believes that the Predecessor Fund could have complied with Subchapter M of
the Internal Revenue Code.

Response to Comment 7.c. Because
the Predecessor Fund was not required to comply with subchapter M, and did not monitor compliance with Subchapter M, Registrant’s
response to this question is somewhat speculative. The Predecessor Fund invested solely in publicly traded equity securities traded on
US exchanges, and did not employ leverage, derivatives, short positions, or other instruments. It was characterized as non-diversified,
just as it will be characterized as non-diversified as a registered fund. While there were

times
that the Predecessor Fund had too few securities to mathematically comply with Subchapter M, at other times the fund had the requisite
number of securities to satisfy the subchapter M test. It is clear however, that there is nothing inherent in the strategy that would
preclude it from being managed as a non-diversified portfolio that complies with the requirements of Section 851(b) of the Internal Revenue
Code.

 d. Describe whether the Predecessor Fund made any investment strategy changes within a one-year period prior
to the date the registration statement was filed and whether such changes were made in anticipation of the conversion to a registered
investment company. In addition, please discuss any variation in the level of assets (e.g., via redemptions, transfers of assets to another
person or fund, cash infusions) of the Predecessor Fund within a one-year period prior to the date the registration statement was filed.
If any investors in the Predecessor Fund redeemed out of the Predecessor Fund within a one year of this date, please describe whether
such investors were able to invest in a fund with substantially similar investment strategies to that of the Predecessor Fund.

Response to Comment 7.d.
Adviser represents that there were no changes to the Predecessor Fund’s investment strategy within a one-year period prior to the
date the registration statement was filed. While not changing the investment strategy of the Predecessor Fund at all, the Adviser configured
the P