SecProbe.io

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Faegre Drinker Biddle
& Reath LLP

320 South Canal Street

Suite 3300

Chicago, IL 60606

www.faegredrinker.com

September 26, 2024

VIA EDGAR TRANSMISSION

Mr. Matthew Williams

Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: The RBB Fund Trust (File Nos.: 333-200168 and 811-23011)

                                                                                (the “Registrant” or the “Trust”)

Dear Mr. Williams:

The following responds
to oral comments provided by the staff of the Securities and Exchange Commission (“Staff”) via telephone on September 20,
2024, regarding the Trust’s Preliminary Proxy Statement filing on Schedule 14A filed on September 10, 2024, filed on behalf of
the Trust and its series, the Penn Capital Short Duration High Income Fund, the Penn Capital Opportunistic High Income Fund, the Penn
Capital Special Situations Small Cap Equity Fund, and the Penn Capital Mid Cap Core Fund.

For your convenience,
each comment made by the Staff has been reproduced in bold typeface immediately followed by the Registrant’s response. Capitalized
but undefined terms used herein have the meanings assigned to them in the Preliminary Proxy Statement. The Registrant confirms that the
response to Staff comments provided in one section of the Preliminary Proxy Statement will be similarly updated in other parallel sections
of the Preliminary Proxy Statement, except as noted by the Registrant.

 1. Comment:
                                            For future reference, all copies of preliminary proxy statements and forms of proxy should
                                            be clearly marked “Preliminary Copies.” (See. Rule 14a-6(e)(1) of Regulation
                                            14A).

Response:
The Registrant so acknowledges.

 2. Comment:
                                            On page 5, please confirm what the word “ultimately” relates to in the answer
                                            “No. These costs ultimately will be borne by the Adviser.”

September 25, 2024

Page 2

Response:
The Registrant confirms that the Adviser will bear the costs of the proxy solicitation and related legal costs in the ordinary course
of business.

 3. Comment:
                                            Please add legend regarding internet availability of proxy materials. (See. Rule 14a-16
                                            of Regulation 14A).

Response:
The Registrant has revised the disclosure as requested.

 5. Comment:
                                            In the discussion under the heading “Board Considerations and Approval” please
                                            disclose any considerations adverse to the proposals. (See. Item 22(c)(11) of Schedule
                                            14A).

Response:
The Registrant has added the following disclosure under “Board Considerations and Approval – Nature, Extent, and
Quality of Services”:

“Because
the services that Penn Capital would provide under the New Advisory Agreement are the same services that Penn Capital provided under
the Original Agreement, the Board determined that there would not be any detrimental effects on the management or operations of each
Fund.”

"The Trustees noted while Seaport has experience in the investment advisory sector through its subsidiary Seaport Global Asset Management
LLC, an investment advisor registered with the SEC, Seaport did not have prior experience advising funds registered under the 1940 Act.
However, the Funds' investment advisory and certain other personnel continued to provide services to the Funds following the Acquisition."

 6. Comment:
                                            On page 12, if applicable, please provide disclosure responsive to Item 22(c)(6) of Schedule
                                            14A in the Proxy Statement.

Response:
The Registrant supplementary confirms that no disclosure is required.

 7. Comment:
                                            On page 17, please state the name, address and principal occupation of the principal executive
                                            officer and each director or general partner of the investment adviser, to the extent not
                                            already disclosed.

Response:
The Registrant has made the requested revisions, as applicable.

 8. Comment:
                                            As a general comment, please provide the information required by Item 22(a)(3)(v) of Schedule
                                            14A.

Response:
The Registrant supplementary confirms that no disclosure is required.

 9. Comment:
                                            On page 21, the second and third sentences under the heading “Quorum” state “For
                                            purposes of determining the presence of a quorum, abstentions and broker non-votes (that
                                            is, proxies from brokers or nominees indicating that such persons have not received instructions
                                            from the beneficial owners or other persons entitled to vote shares on a particular matter
                                            with respect to which the brokers or nominees do not have discretionary power) will be treated
                                            as votes present at the Special Meeting, but abstentions and broker non-votes will not be
                                            treated as votes cast at such meeting. Abstentions and broker non-votes, therefore (i) will
                                            be included for purposes of determining whether a quorum is present; and (ii) will have no
                                            effect on proposals that require a plurality for approval, or on proposals requiring an affirmative
                                            vote of a majority of votes cast for approval.” The proposals herein are considered
                                            non-routine for NYSE Rule 452.11(20). Therefore, please revise disclosure here to state that
                                            broker non-votes will not be counted as present for quorum purposes or as votes cast at the
                                            meeting or otherwise explain how the present disclosure complies with NYSE Rule 452.10.

September 25, 2024

Page 3

Response:
The Registrant has made the requested revisions.

* * * * *

We trust that the foregoing
is responsive to your comments. Questions and further comments concerning this filing may be directed to the undersigned at (312)569-1181.

  Sincerely,

  /s/ Robert D. Bullington

  Robert D. Bullington