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      The RBB Fund Trust

      615 East Michigan Street

      Milwaukee, Wisconsin 53202

      July 24, 2024

      VIA EDGAR TRANSMISSION

      Ellie Quarles

      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. Quarles:

      The purpose of this letter is to respond to the Commission staff’s (the “Staff”) oral comments provided to U.S. Bank Global Fund Services on July 11, 2024 and July 23, 2024 regarding the Trust’s post-effective
        amendment (“PEA”) No. 40 to its registration statement on Form N-1A. PEA No. 40 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 May
        24, 2024. The sole purpose of PEA No. 40 was to register a new series of the Trust, the LRP Dynamic US Core ETF (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.  Furthermore, the Trust notes that
        the Fund’s name is proposed to be redesignated as follows:

                LRP Dynamic US Core ETF

                  à

                Longview Advantage ETF

      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. 40. 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.

      GENERAL

      1. Comment: Please acknowledge that the Trust is responsible for the adequacy and accuracy of the disclosure in the filing.

      Response: The Trust acknowledges that it is responsible for the adequacy and
          accuracy of the disclosure in the filing.

      PROSPECTUS

      Summary Section – Fees and Expenses

      2. Comment: Please provide
          the Staff with the completed Fees and Expenses table and Example.

      Response: The Trust will provide the completed fee table and expense examples as shown below in the Amended Registration Statement.

      Fees and Expenses

      This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage
          commissions that investors may pay on their purchases and sales of Shares.

              Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

              Management Fees

              0.20%

              Distribution (12b-1) Fees

              0.00%

              Other Expenses(1)

              0.09%

              Total Annual Fund Operating Expenses

              0.29%

              Fee Waivers and/or Expense Reimbursements(2)

              -0.05%

              Total Annual Fund Operating Expenses after Fee Waivers and/or Expense Reimbursements(2)

               0.24%

      (1) “Other Expenses” are estimated for the current fiscal year.

      (2)   Hill Investment Group Partners, LLC (the “Adviser”) has contractually agreed (i) to limit the management
          fees charged to the Fund to 0.15% of the Fund’s average daily net assets and (ii) to waive its advisory fee and/or reimburse expenses in order to limit Total Annual Fund Operating Expenses (excluding certain items discussed below) to 0.24% of the
          Fund’s average daily net assets. In determining the Adviser’s obligation to waive advisory fees and/or reimburse expenses, the following expenses are not taken into account and could cause net Total Annual Fund Operating Expenses to exceed 0.24%,
          as applicable: acquired fund fees and expenses, brokerage commissions, extraordinary items, interest or taxes. These contractual limitations are in effect until December 31, 2025, and may not be terminated prior to that date without the approval
          of the Board of Trustees (the “Board”) of The RBB Fund Trust (the “Trust”). If at any time the Fund’s Total Annual Fund Operating Expenses (not including acquired fund fees and expenses, brokerage commissions, extraordinary items, interest or
          taxes) for a year are less than 0.24%, as applicable, the Adviser may recoup any waived or reimbursed amounts from the Fund within three years from the date on which such waiver or reimbursement was made by the Adviser, provided such
          reimbursement does not cause the Fund to exceed (i) expense limitations that were in effect at the time of the waiver or reimbursement or (ii) the current expense limitations.

      Example

      This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and
        then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Fund’s operating expenses remain the same (taking into
          account the contractual expense limitation for the first year). Although your actual costs may be higher or lower, based on these assumptions your costs would be:

              1 Year

              3 Years

              $25

              $88

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      3. Comment: Please confirm
          whether the “Fees and Expenses” table for the Fund should be adjusted to include a line item entry for acquired fund fees and expenses (“AFFE”).

      Response: The Trust supplementally confirms that the Fund does not anticipate the investment strategy will result in reportable AFFE meriting a line item
        in the fee table, and as such no further disclosure is required.

      Summary Section – Principal Investment Strategies

      4. Comment: Since the Fund’s
          name includes the phrase “US” then please add an 80% Policy stating that the Fund will invest at least 80% of its net assets (including borrowings for investment purposes) in investments economically tied to the
            United States. In addition, please describe the specific criteria used by the Fund to determine if an investment is economically tied to the United States.

      Response: The Trust acknowledges the Staff’s comment and, as noted above, will redesignate the name of the Fund as the Longview Advantage ETF. As such,
        no further disclosure is required.

      5. Comment: Please discuss
          the universe of securities that the Fund would consider for its portfolio. Please describe if the Fund will invest solely in equity securities, and if so, the types of equity securities, such as common stock, for its principal investment
          strategy. If the Fund will invest in other types of equity securities for its principal investment strategy then please discuss the related risks.

      Response: The Trust will revise the second paragraph under the “Principal Investment Strategies” section as shown below (added text underlined) in the Amended Registration
        Statement:

      “The Fund invests primarily in equity securities of a diverse group of U.S. companies across market sectors, market capitalizations, and industry groups. Equity
          securities in which the Fund may invest include common stock and derivative instruments that give exposure to equities, such as futures contracts, including futures contracts of U.S. indices. To determine whether a company is a U.S. company, the
          Adviser will consider various factors, including where the company is headquartered, where the company’s principal operations are located, where a majority of the company’s revenues are derived, where the principal trading market is located, the
          country in which the company was legally organized, and whether the company is in the Fund’s benchmark—the Russell 3000® Index.

      The Fund seeks equity securities of U.S. companies that it expects to have higher returns by placing an enhanced emphasis on securities of companies with higher
        profitability-to-value ratios. Conversely, the Fund seeks to underweight or exclude securities it expects to have lower returns, such as securities with lower profitability-to-value ratios.”

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      The Trust further confirms that the corresponding risk factors, including Derivatives Risk, Futures Contracts and Related Risks, and Index Futures Risk, will be added under the Principal Investment
        Risks in the Amended Registration Statement as shown below:

      “Derivatives Risk. Derivatives include instruments and contracts that are based on, and are valued in relation to, one or more underlying securities,
        financial benchmarks or indices, such as futures contracts. The Fund’s holdings of derivative instruments may result in losses exceeding the amounts invested. The use of derivatives is a highly specialized activity that involves investment
        techniques and risks different from those associated with investments in more traditional securities and instruments. The use of derivatives is also subject to operational and legal risks. Operational risks generally refer to risks related to
        potential operational issues, including documentation issues, settlement issues, system failures, inadequate controls, and human error. Legal risks generally refer to risks of loss resulting from insufficient documentation, insufficient capacity or
        authority of counterparty, or legality or enforceability of a contract.

      Futures Contracts and Related Risks. The successful use of futures contracts draws upon the Adviser’s skill and experience with respect to such instruments
        and are subject to special risk considerations. The primary risks associated with the use of futures contracts are:

            •

              futures contracts have a high degree of price variability and are subject to occasional rapid and substantial changes;

            •

              the imperfect correlation between the change in market value of the futures contracts and the market value of the underlying instrument or reference assets with respect to such contracts;

            •

              possible lack of a liquid secondary market for a futures contract and the resulting inability to close a futures contract when desired;

            •

              possible market disruption or other extraordinary events, including but not limited to, governmental intervention;

            •

              potentially unlimited losses caused by unanticipated market movements;

            •

              the Fund’s inability to predict correctly the direction of securities prices, interest rates, currency exchange rates and other economic factors;

            •

              the possibility that the counterparty will default in the performance of its obligations; and

            •

              if the Fund has insufficient cash, it may either have to sell securities from its portfolio to meet daily variation margin requirements with respect to its derivative instruments or close certain positions at a time when it may be
                disadvantageous to do so.

      The use of futures contracts and derivative instruments will have the economic effect of financial leverage. Financial leverage magnifies exposure to the swings in prices of an asset class
        underlying an investment and results in increased volatility, which means the Fund will have the potential for greater losses than if the Fund did not employ leverage in its investment activity. Leveraging tends to magnify, sometimes significantly,
        the effect of any increase or decrease in the Fund’s exposure to an asset class and may cause the value of the Fund’s securities or related derivatives instruments to be volatile. Accordingly, the Fund’s NAV may be volatile because of its
        investment exposure to the Fund. There is no assurance that the Fund’s investment in a derivative instrument with leveraged exposure to certain investments and markets will enable the Fund to achieve its investment objective.

        4

      Index Futures Risk. An index future obligates the Fund to pay or receive an amount of cash equal to a fixed dollar amount specified in the futures contract
        multiplied by the difference between the settlement price of the contract on the contract’s last trading day and the value of the index based on the prices of the securities that comprise the index at the opening of trading in such securities on
        the next business day. No physical delivery of the securities comprising the index is made; generally contracts are closed out prior to the expiration date of the contract.

      The market value of a stock index futures contract is based primarily on the value of the underlying index. Changes in the value of the index will cause roughly corresponding changes in the market
        price of the futures contract. If a stock index is established that is made up of securities whose market characteristics closely parallel the market characteristics of the securities in the Fund’s portfolio, then the market value of a futures
        contract on that index should fluctuate in a way closely resembling the market fluctuation of the portfolio. Thus, for example, if the Fund sells futures contracts, a decline in the market value of the portfolio will be offset by an increase in the
        value of the short futures position to the extent of the hedge (i.e., the size of the futures position). However, if the market value of the portfolio were to increase, the Fund would lose money on the futures contracts. Stock index futures
        contracts are subject to the same risks as other futures contracts.”

      6. Comment: The Staff notes
          that the “Micro-Cap, Small-Cap and Mid-Cap Companies” risk factor states that the Adviser’s selection process does not favor investing in companies with “highly leveraged” capital structures. Accordingly, please
          provide disclosure about how the Fund will consider leverage when investing in a company. Alternatively, delete the corresponding language in the “Micro-Cap, Small-Cap and Mid-Cap Companies” risk factor.

      Response: The Trust will revise the “Micro-Cap, Small-Cap and Mid-Cap
          Companies” risk factor as shown below (deleted text struck through) in the Amended
        Registration Statement:

      “Micro-Cap, Small-Cap and Mid-Cap
          Companies Risk. Securities of companies with micro-, small- and mid-size capitalizations tend to be riskier than securities of companies with large
        capitalizations. This is because micro-, small- and mid-cap companies typically have smaller product lines and less access to liquidity than large cap companies,
        and are therefore more sensitive to economic downturns. In addition, growth prospects of micro-, small- and mid-cap companies tend to be less certain than large
        cap companies, and the dividends paid on micro-, small- and mid-cap stocks are frequently negligible. Moreover, micro-, small- and mid-cap stocks have, on occasion, fluctuated in the opposite direction of large cap stocks or the general stock market. Consequently, securities of micro-, small- and mid-cap companies tend to be more volatile than those of large-cap companies. The market for micro-
        and small-cap securities may be thinly traded and as a result, greater fluctuations in the price of micro- and small-cap securities may occur. In general, the Adviser’s investment philosophy and selection process favor companies that do not have capi