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The RBB Fund Trust

615 East Michigan Street

Milwaukee, Wisconsin 53202

August 16, 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:

On July 24, 2024, the Trust responded 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 (the “July Response Letter”). 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 purpose of this letter is to update
the Fund’s responses to Comments No. 2, No. 3 and No. 5 as previously indicated in the July Response Letter. As a point of
information, Hill Investment Group Partners, LLC (the “Adviser”), the investment adviser to the Fund, has determined
to adjust the management fee from 0.20% of the Fund’s average daily net assets to 0.25%, but the limit of the management
fee charged to the Fund will remain as 0.15% of the Fund’s average daily net assets until December 31, 2025, as previously
indicated in the July Response Letter. In addition, the Adviser has determined that the Fund expects to hold shares of exchange-traded
funds (“ETFs”) as part of the Fund’s principal investment strategy during the first year of the Fund’s
operation. Accordingly, the responses to Comments No. 2, No. 3 and No. 5 have been revised as shown below.

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     →      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
    0.25%

    Distribution (12b-1) Fees
    0.00%

    Other Expenses(1)
    0.10%

    Total Annual Fund Operating Expenses
    0.35%

    Fee Waivers and/or Expense Reimbursements(2)
    -0.10%

    Total Annual Fund Operating Expenses after Fee Waivers and/or Expense Reimbursements(2)
     0.25%

 (1) “Other Expenses” are estimated for the current
fiscal year. “Other Expenses” include acquired fund fees and expenses (“AFFE”) of 0.01%, which are indirect
fees and expenses that the Fund incurs from holding the shares of other mutual funds, including money market funds and exchange
traded funds. AFFE is 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 Total Annual Fund Operating Expenses to exceed 0.24%, as applicable: AFFE, 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 AFFE, 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.

    2

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

    $26
    $102

 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 confirms that there will be reportable AFFE of 0.01%, and has adjusted the Fees and Expenses table and Example accordingly
(see the proposed response to Comment No. 2 above).

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 may also hold shares of other registered investment companies, including ETFs, during
the first year of its operations, to the extent permitted by applicable law and subject to certain restrictions.

    3

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.”

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;

    4

 ● 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.

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.

Other Investment Company
Risk. To the extent the Fund invests in other investment companies, including ETFs, its performance will be affected by the
performance of those other investment companies. Investments in other investment companies are subject to the risks of the other
investment companies’ investments, as well as to the other investment companies’ expenses. An ETF may trade in the
secondary market at a price below the value of its underlying portfolio and may not be liquid. An actively managed ETF’s
performance will reflect its adviser’s ability to make investment decisions that are suited to achieving the ETF’s
investment objectives. A passively managed ETF may not replicate the performance of the index it intends to track.”

    5

 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-,