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Faegre Drinker Biddle & Reath LLP

320 South Canal Street, Suite 3300

Chicago, IL 60606

(312) 569-1000 (Phone)

(312) 569-3000 (Facsimile)

www.faegredrinker.com

December 20, 2024

VIA EDGAR TRANSMISSION

Ms. Valerie Lithotomos

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    The RBB Fund Trust (the “Trust”)

    Registration Statement on Form N-1A

    (File Nos.: 033-200168 and 811-23011)

Dear Ms. Lithotomos:

The purpose of this letter is
to respond to the oral comments you provided regarding the Trust’s post-effective amendment (“PEA”) No. 47 to its registration
statement on Form N-1A. PEA No. 47 was filed with the Securities and Exchange Commission (the “Commission”) pursuant to Rule
485(a)(1) under the Securities Act of 1933, as amended, on Form N-1A on November 1, 2024.

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
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 the Registration Statement. The Trust confirms that, where applicable, the responses to the comments
provided in one section of the Registration Statement will be similarly updated in other parallel sections of the Registration Statement,
except as noted by the Trust. The changes to the disclosures discussed below will be reflected in the next post-effective amendment to
the Registration Statement.

    1.
    Comment: As a global comment for all funds, please complete the Fee and Expense tables and provide them to the Commission at least five (5) business days prior to the effective date.

Response: Please see updated Fee
and Expense tables below.

Penn Capital Short Duration High Income Fund:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial
intermediaries, which are not reflected in the tables and examples below.

    Shareholder Fees (fees paid directly from your investment)
    Institutional Class

    Maximum Sales Charge (Load) Imposed on Purchases
    None

    Maximum Deferred Sales Charge (Load) (as a percentage of the original purchase price)
    None

    Maximum Sales Charge (Load) Imposed on Reinvested Dividends
    None

    Annual Fund Operating
    Expenses

    (expenses that you
    pay each year as a percentage of the value of your investment)

    Management Fees
    0.45%

    Distribution and/or Service (12b-1) Fees
    0.00%

    Other Expenses
    0.84%

    Total Annual Fund Operating Expenses
    1.29%

    Less Fee Waiver and/or Expense Reimbursement(1)
    -0.75%

    Total Annual Fund Operating Expenses (After Fee Waiver/Expense Reimbursement)
    0.54%

(1) The RBB Fund Trust (the “Trust”)
and Penn Capital Management Company, LLC (the “Advisor”), have entered into an expense limitation agreement under which the
Advisor has agreed to waive management fees and/or pay Fund expenses to the extent necessary so that the Fund’s total annual operating
expenses (including any acquired fund fees and expenses incurred by the Fund as a result of its investments in other investment companies
managed by the Advisor, but excluding any acquired fund fees and expenses incurred by the Fund as a result of its investments in unaffiliated
investment companies, taxes, interest, brokerage fees, certain insurance costs, and extraordinary and other non-routine expenses) through
the period ending December 31, 2025 do not exceed 0.54% for Institutional Class shares. Under the agreement, the Advisor is entitled to
be reimbursed by the Fund for any fees it waived and expenses it paid for a period of three years following the month of the fee waiver
or payment, to the extent such reimbursement will not cause the Fund to exceed any applicable expense limit that was in place when the
fees were waived or expenses paid. The expense limitation agreement may be terminated by the Board of Trustees of the Trust (the “Board”
or “Trustees”) at any time and also will terminate automatically upon the expiration or termination of the Fund’s advisory
contract with the Advisor.

Example

This example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other mutual 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 your
investment has a 5% return each year, that the Fund’s operating expenses remain the same, and that the expense limitation applies
only for the first year. Although your actual costs may be higher or lower, based on these assumptions your cost would be:

    1 Year
    3 Years
    5 Years
    10 Years

    Institutional Class
    $55
    $335
    $636
    $1,491

Penn Capital Opportunistic High Income Fund:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial
intermediaries, which are not reflected in the tables and examples below.

    Shareholder Fees (fees paid directly from your investment)
    Institutional

Class

    Maximum Sales Charge (Load) Imposed on Purchases
    None

    Maximum Deferred Sales Charge (Load) (as a percentage of the original purchase price)
    None

    Maximum Sales Charge (Load) Imposed on Reinvested Dividends
    None

    Annual Fund Operating
    Expenses

    (expenses that you pay each year as a percentage
    of the value of your investment)

    Management Fees
    0.69%

    Distribution and/or Service (12b-1) Fees
    0.00%

    Other Expenses
    0.77%

    Total Annual Fund Operating Expenses
    1.46%

    Less Fee Waiver and/or Expense Reimbursement(1)
    -0.74%

    Total Annual Fund Operating Expenses (After Fee Waiver/Expense Reimbursement)
    0.72%

(1) The RBB Fund Trust (the “Trust”) and Penn Capital Management Company, LLC (the “Advisor”),
have entered into an expense limitation agreement under which the Advisor has agreed to waive management fees and/or pay Fund expenses
to the extent necessary so that the Fund’s total annual operating expenses (including any acquired fund fees and expenses incurred
by the Fund as a result of its investments in other investment companies managed by the Advisor, but excluding any acquired fund fees
and expenses incurred by the Fund as a result of its investments in unaffiliated investment companies, taxes, interest, brokerage fees,
certain insurance costs, and extraordinary and other non-routine expenses) through the period ending December 31, 2025, do not exceed
0.72% for Institutional Class shares. Under the agreement, the Advisor is entitled to be reimbursed by the Fund for any fees it waived
and expenses it paid for a period of three years following the month of the fee waiver or payment, to the extent such reimbursement will
not cause the Fund to exceed any applicable expense limit that was in place when the fees were waived or expenses paid. The expense limitation
agreement may be terminated by the Board of Trustees of the Trust (the “Board” or “Trustees”) at any time and
also will terminate automatically upon the expiration or termination of the Fund’s advisory contract with the Advisor.

Example

This example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other mutual 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 your
investment has a 5% return each year, that the Fund’s operating expenses remain the same, and that the expense limitation applies
only for the first year. Although your actual costs may be higher or lower, based on these assumptions your cost would be:

    1 Year
    3 Years
    5 Years
    10 Years

    Institutional Class
    $74
    $389
    $727
    $1,683

Penn Capital Mid Cap Core Fund:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial
intermediaries, which are not reflected in the tables and examples below.

    Shareholder Fees (fees paid directly from your investment)
    Institutional

Class

    Maximum Sales Charge (Load) Imposed on Purchases
    None

    Maximum Deferred Sales Charge (Load) (as a percentage of the original purchase price)
    None

    Maximum Sales Charge (Load) Imposed on Reinvested Dividends
    None

    Annual Fund Operating
    Expenses

    (expenses that you pay each year as a percentage
    of the value of your investment)

    Management Fees
    0.90%

    Distribution and/or Service (12b-1) Fees
    0.00%

    Other Expenses
    1.21%

    Total Annual Fund Operating Expenses
    2.11%

    Less Fee Waiver and/or Expense Reimbursement(1)
    -1.05%

    Total Annual Fund Operating Expenses (After Fee Waiver/Expense Reimbursement)
    1.06%

 (1) The RBB Fund Trust (the “Trust”) and Penn Capital Management Company, LLC (the “Advisor”),
have entered into an expense limitation agreement under which the Advisor has agreed to waive management fees and/or pay Fund expenses
to the extent necessary so that the Fund’s total annual operating expenses (excluding any acquired fund fees and expenses, taxes,
interest, brokerage fees, certain insurance costs, and extraordinary and other non-routine expenses) through the period ending December
31, 2025, do not exceed 1.06% for Institutional Class shares. Under the agreement, the Advisor is entitled to be reimbursed by the Fund
for any fees it waived and expenses it paid for a period of three years following the month of the fee waiver or payment, to the extent
such reimbursement will not cause the Fund to exceed any applicable expense limit that was in place when the fees were waived or expenses
paid. The expense limitation agreement may be terminated by the Board of Trustees of the Trust (the “Board” or “Trustees”)
at any time and also will terminate automatically upon the expiration or termination of the Fund’s advisory contract with the Advisor.

Example

This example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other mutual 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 your
investment has a 5% return each year, that the Fund’s operating expenses remain the same, and that the expense limitation applies
only for the first year. Although your actual costs may be higher or lower, based on these assumptions your cost would be:

    1 Year
    3 Years
    5 Years
    10 Years

    Institutional Class
    $108
    $559
    $1,037
    $2,358

Penn Capital Special Situations Small Cap Equity
Fund:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial
intermediaries, which are not reflected in the tables and examples below.

    Shareholder Fees (fees paid directly from your investment)
    Institutional Class

    Maximum Sales Charge (Load) Imposed on Purchases
    None

    Maximum Deferred Sales Charge (Load) (as a percentage of the original purchase price)
    None

    Maximum Sales Charge (Load) Imposed on Reinvested Dividends
    None

    Annual Fund Operating
    Expenses

    (expenses that you pay each year as a percentage
    of the value of your investment)

    Management Fees
    0.95%

    Distribution and/or Service (12b-1) Fees
    0.00%

    Other Expenses
    0.64%

    Total Annual Fund Operating Expenses
    1.59%

    Less Fee Waiver and/or Expense Reimbursement(1)
    -0.50%

    Total Annual Fund Operating Expenses (After Fee Waiver/Expense Reimbursement)
    1.09%

(1) The RBB Fund Trust (the “Trust”) and Penn Capital Management Company, LLC (the “Advisor”),
have entered into an expense limitation agreement under which the Advisor has agreed to waive management fees and/or pay Fund expenses
to the extent necessary so that the Fund’s total annual operating expenses (excluding any acquired fund fees and expenses, taxes,
interest, brokerage fees, certain insurance costs, and extraordinary and other non-routine expenses) through the period ending December
31, 2025, do not exceed 1.09% for Institutional Class shares. Under the agreement, the Advisor is entitled to be reimbursed by the Fund
for any fees it waived and expenses it paid for a period of three years following the month of the fee waiver or payment, to the extent
such reimbursement will not cause the Fund to exceed any applicable expense limit that was in place when the fees were waived or expenses
paid. The expense limitation agreement may be terminated by the Board of Trustees of the Trust (the “Board” or “Trustees”)
at any time and also will terminate automatically upon the expiration or termination of the Fund’s advisory contract with the Advisor.

Example

This example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other mutual 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 your
investment has a 5% return each year, that the Fund’s operating expenses remain the same, and that the expense limitation applies
only for the first year. Although your actual costs may be higher or lower, based on these assumptions your cost would be:

    1 Year
    3 Years
    5 Years
    10 Years

    Institutional Class
    $111
    $453
    $818
    $1,847

    2.
    Comment: As a global comment for all funds, please complete the outstanding information and update all information that is currently in brackets.

Response: The Trust confirms the remaining information
will be completed in the Amended Registration Statement.

Penn Capital

    3.
    Comment: With respect to the proxy statement regarding the approval of a new investment advisory agreement between the Trust, on behalf of each fund, and Penn Capital Management, LLC (“Penn Capital”), please supplementally inform the Commission of the timeline for approval and what the Trust intends to do if the proxy is not approved.

Response: A special meeting of shareholders (the “Special
Meeting”) of the Penn Capital Short Duration High Income Fund, Penn Capital Opportunistic High Income Fund, and Penn Capital Mid
Cap Core Fund (each a “Fund” and together, the “Funds”) was held on November 7, 2024. At the Special Meeting,
shareholders of each Fund voted to approve the proposed new investment advisory agreement between the Trust, on behalf of each Fund, and
Penn Capital.

At the Special Meeting, an insufficient
number of shareholders of the Penn Capital Special Situations Small Cap Equity Fund (the “Special Situations Fund”) were present,
in person or by proxy. As a result, there was no quorum, and the shareholders of the Special Situations Fund were unable to vote on the
proposed investment advisory agreement (“New Advisory Agreement”) between the Trust, on behalf of the Special Situations Fund
and the Adviser. The Special Meeting was adjourned until November 27, 2024 with respect to the Special Situations Fund. However, there
was still no quorum.

To avoid disruption of the Special Situat