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The RBB Fund Trust

615 East Michigan Street

Milwaukee, Wisconsin 53202

August 26, 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 11, 2024 and July 23, 2024, the Commission
staff’s (the “Staff”) provided oral comments to U.S. Bank Global Fund Services (“GFS”) 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 responded to the Staff’s comments with correspondence dated July 24, 2024.

The Trust filed revised correspondence dated August
16, 2024, to update the Fund’s responses to Comments No. 2, No. 3 and No. 5, incorporating certain new information regarding the
Fund’s investment management fee and the Fund’s anticipated holdings. On August 22, 2024, the Staff provided oral comments
to GFS on the revised response to Comment No. 5, requesting additional disclosures in the “Other Investment Company Risk.”
The purpose of this letter is to update the Fund’s response to Comment No. 5 accordingly (added disclosures underlined).

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
    0.25%

    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. As a result, shareholders of the Fund will indirectly be
subject to the fees and expenses of the other investment companies in which the Fund invests, and these fees and expenses are in addition
to the fees and expenses that Fund shareholders directly bear in connection with the Fund’s own operations. 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-, small- and mid-cap
companies typically have smaller product lines and