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      The RBB Fund Trust

      615 East Michigan Street

      Milwaukee, Wisconsin 53202

      November 22, 2022

      VIA EDGAR TRANSMISSION

      Emily Rowland

      Securities and Exchange Commission

      100 F Street, N.E.

      Washington, DC 20549

                Re:

                The RBB Fund Trust (the “Trust”)

                File Nos.: 333-200168 and 811-23011

      Dear Ms. Rowland:

      The purpose of this letter is to respond to oral comments provided to U.S. Bank Global Fund Services regarding the Trust’s Post-Effective Amendment (“PEA”) No. 17 to its
        Registration Statement on Form N-1A. PEA No. 17 was filed with the Securities and Exchange Commission (the “Commission”) pursuant to Rule 485(a)(2) under the Securities Act of 1933, as amended, on Form N-1A on September 15, 2022. The sole purpose
        of PEA No. 17 was to register a new series of the Trust. This letter responds to the Commission staff’s (the “Staff”) comments on the Evermore Global Value Fund (the “Fund”).

      The Trust will file a subsequent PEA under Rule 485(b) (“Amended Registration Statement”) to update any missing information, respond to Staff comments, and file updated
        exhibits.

      For your convenience, each comment made by the Staff has been reproduced in bold typeface immediately followed by the Trust’s response. Capitalized but undefined terms used
        herein have the meanings assigned to them in PEA No. 17. The Trust confirms that the response to Staff comments provided in one section will be similarly updated in other parallel sections, except as noted by the Trust.

      PROSPECTUS

      Cover Page

                1.

                Comment: Please remove the first two paragraphs, as the language is no longer required under Rule 30e-3 under the Investment
                    Company Act of 1940, as amended (the “1940 Act”).

       Response: The Trust will make the requested change in the
          Amended Registration Statement.

                2.

                Comment: In the last paragraph, please spell out the defined term “SEC.”

        Response: The Trust will make the requested change in the Amended Registration Statement.

      Summary Section – Fees and Expenses of the Fund

      3.           Comment: Please bold the second sentence in the paragraph preceding
          the expenses and fees table.

      Response: The Trust will make the requested change in the
          Amended Registration Statement.

      4.           Comment: Please delete the last sentence in the paragraph preceding
          the expenses and fees table as it is duplicative.

      Response: The Trust will make the requested change in the
          Amended Registration Statement.

      5.            Comment: Please supplementally compare
          the management fee and total annual fund operating expenses between the Fund and the Predecessor Fund.

      Response: The Trust supplementally confirms that the
          management fee for the Fund and the Predecessor Fund are identical at 0.99% of the Fund’s and Predecessor Fund’s average daily net assets. Similarly, the Adviser has contractually agreed to limit the amount of each of the Fund’s and the Predecessor Fund’s total annual operating expenses (excluding taxes, interest on
            borrowings, acquired fund fees and expenses, dividends on securities sold short, brokerage commissions, and other expenditures, which are capitalized in accordance with generally accepted accounting principles, and other extraordinary expenses
            not incurred in the ordinary course of business) to 1.60% of each of the Fund’s and Predecessor Fund’s average daily net assets attributable to Investor Shares and to 1.35% of average daily net assets attributable to Institutional Shares
            through December 31, 2023. However, the greater efficiencies and economies of scale, as well as the shared expense structure upon the Fund’s reorganization into The RBB Fund Trust complex are expected to result in reduced “other expenses” as
            compared to the Predecessor Fund.

      6.            Please confirm whether any dividend or
          interest expense associated with short sales should be included in the fee table.

      Response: The Trust supplementally confirms that dividend or interest expenses from short sales at this time are not expected to be material. However, if
        warranted, the Trust will disclose related dividend or interest expenses from short sales as a separate line item in future registration statements.

      Summary Section – Example

      7.            Comment: In the second sentence, please
          add the word “hold” when referring to whether shares are redeemed or held at the end of the periods.

      Response: The Trust will make the requested change in the
          Amended Registration Statement as shown below:

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      “The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then hold or redeem your shares
        at the end of those periods.”

      Summary Section – Principal Investment Strategies

      8.            Comment: In the fourth paragraph, please
          add disclosure discussing how the Fund defines issuers located in foreign countries.

      Response: The Trust will make the requested change in the
          Amended Registration Statement as shown below:

      “The Fund determines where a company is located, and thus, whether a company is considered to be located in a foreign country by considering whether: (i)
        it is organized under the laws of or maintains its principal office in a country located outside the United States; (ii) its securities are principally traded on trading markets in countries located outside the United States; (iii) it derives at
        least 50% of its total revenue or profits from either goods produced or services performed or sales made in countries located outside the United States; or (iv) it has at least 50% of its assets in countries located outside the United States.”

      9.            Comment: In the fourth paragraph, please
          add disclosure that the Fund’s investments in foreign securities are denominated in foreign currencies.

      Response: The Trust will make the requested change in the
          Amended Registration Statement as shown below:

      “The Fund will invest at least 40% of its assets, and may invest up to 100% of its assets, in the securities of
          issuers located in various foreign countries, including both developed and emerging markets, whose securities may be denominated in foreign currencies.”

      10.          Comment: If the Fund will be making
          significant investments in China then please add additional Item 4 and Item 9 disclosure, including a related risk factor.

      Response: The Trust supplementally confirms that the Fund is
          not expected to make significant investments in China.

      11.          Comment: If the Fund will invest in
          derivative instruments as part of its principal investment strategies then please provide further detailed disclosure concerning how the Fund uses derivative instruments to meet its objectives. Alternatively, remove references to derivative
          instruments in the Principal Investment strategies section.

      Response: The Trust will revise the sixth paragraph of the
          section entitled “Fund Summary – Principal Investment Strategies” in the Amended Registration Statement as follows:

        3

      “The Fund may invest a portion of its assets in derivative instruments. These may include forward contracts, options and futures
        contracts. The Fund invests in derivatives primarily to hedge its exposure to changes in the values of foreign currencies, typically through the use of foreign currency derivatives, including forward foreign currency exchange contracts. A
          forward foreign currency exchange contract is an agreement to buy or sell a specific currency at a future date and at a price set at the time of the contract. The Fund also seeks to hedge exposure to
            certain markets and securities.”

      12.          Comment: In the ninth paragraph please
          list the industry or industries that the Fund expects to invest up to 25% of its assets.

      Response: The Trust will make the requested change in the
          Amended Registration Statement as shown below:

      “The Fund currently expects to invest a significant portion of its assets in the communication services, energy,
          financial, industrials, and information technology sectors, which means that the Fund will be more affected by the performance of such sectors than a fund that is not so significantly invested.”

      13.          Comment: In the second sentence of the
          ninth paragraph please delete the phrase “of the market value.”

      Response: The Trust will make the requested change in the
          Amended Registration Statement.

      Summary Section – Principal Investment Risks

      14.          Comment: If the Fund is advised by or
          sold through an insured depository institution, please state that an investment in the Fund is not a deposit of the bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.

      Response: The Trust supplementally confirms that The Fund is
          not advised or sold through an insured depository institution.

      15.          Comment: Please ensure the Principal
          Investment Risks are consistent with the risks listed in the section entitled “Additional Information about Investment Strategies and Risks of Investing in the Fund – Risks of Investing in the Fund.”

      Response: The Trust will make the requested change in the
          Amended Registration Statement.

      16.          Comment: Please rearrange the risk
          factors in order of importance, as it is unlikely that “Large Shareholder Purchase and Redemption Risk” is the most important risk affecting the Fund.

      Response: The Trust is not aware of any statute or rule from
          the Commission that would require the principal risks to be disclosed in any particular order. The Trust has considered the Commission’s written guidance on ordering of risks, and the Trust believes that each risk disclosed in response to Item
          4(b) of Form N-1A is a principal risk of the Fund and that each such risk is relevant for investors, and that displaying the risk factors in alphabetical order facilitates finding particular risks and comparing them with other funds. Accordingly,
          the Trust will re-order the risk factors in alphabetical order.

        4

      17.          Comment: Please provide disclosure of the
          effects of Brexit within the “Foreign Securities” risk factor. Alternatively, please supplementally explain why it is not required.

      Response: The Trust will make the requested change in the
          Amended Registration Statement as shown below:

      “Foreign Securities Risk. Securities

          of companies located outside the U.S. involve additional risks that can increase the potential for losses in the Fund to the extent that it invests in these securities. Investments in foreign securities may be affected by currency controls and
          exchange rates; different accounting, auditing, financial reporting, less publicly available information, and legal standards and practices; expropriation; changes in tax policy; greater market volatility; political, social or economic
          instability; differing securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. Foreign securities in
          which the Fund invests may be traded in markets that close before the time that the Fund calculates its NAV. Furthermore, certain foreign securities in which the Fund invests may be listed on foreign exchanges that trade on weekends or other days
          when the Fund does not calculate its NAV. As a result, the value of the Fund’s holdings may change on days when shareholders are not able to purchase or redeem the Fund’s shares. Certain of these risks also may apply to securities of U.S.
          companies with significant foreign operations. These risks can increase the potential for losses in the Fund and affect its share price. To the extent that the Fund’s assets are significantly invested in a single country or geographic region, the
          Fund will be subject to the risks associated with that particular country or region.

      In addition, on January 31, 2020, the United Kingdom (“UK”) officially withdrew from
            the European Union (“EU”), commonly referred to as “Brexit.” Following a transition period, the UK’s post-Brexit trade agreement with the EU went into effect on January 1, 2021. Until the economic effects of Brexit become clearer, and while a
            period of political, regulatory and commercial uncertainty continues, there remains a risk that Brexit may negatively impact the Fund’s investments and cause it to lose money. Any further withdrawals from the EU could cause additional market
            disruption globally.”

      18.          Comment: Please add a risk factor for
          large-cap equity securities as these are mentioned in the Principal Investment Strategies section.

        Response: The Trust will add the following risk factors in
            the Amended Registration Statement as shown below:

        5

      “Large Companies Risk. The securities of large-capitalization companies may be relatively mature compared to
        smaller companies and therefore subject to slower growth during times of economic expansion. Large-capitalization companies may also be unable to respond quickly to new competitive challenges, such as changes in technology and consumer tastes.”

      19.          Comment: Please add the following
          sentence to the “Industry and Sector” risk factor: “The Fund may focus its investments in the following sectors:”.

      Response: The Trust will make the requested change in the
          Amended Registration Statement.

      20.          Comment: Please move the first sentence
          of the “Currency Exchange Rate” risk factor to the Principal Investment Strategy section.

      Response: The Trust will revise the first and second
          sentences of the “Currency Exchange Rate” risk factor as shown below:

      “Foreign securities may be issued and traded in foreign
            currencies. As a result, Their values of foreign securities issued and traded in foreign currencies may be affected by changes in exchange rates between
          foreign currencies and the U.S. dollar, as well as between currencies of countries other than the U.S.”

      21.          Comment: Please modify the “Debt
          Securities Risk – Interest Rate” risk factor to reflect the current interest rate environment.

      Response: The Trust will make the requested change in the
          Amended Registration Statement as shown below:

      “Interest Rate Risk. Over the past several
          years, the Federal Reserve has maintained the level of interest rates at or near historic lows. However, more recently, interest rates have begun to increase as a result of action that has been taken by the Federal Reserve, which has raised, and
          may continue to raise, interest rates. If interest rates rise, the Fund’s yield may not increase proportionately, and the maturities of fixed income securities that have the ability to be prepaid or called
          by the issuer may be extended. Changing interest rates may have unpredictable effects on the markets and the Fund’s investme