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FEDERATED HERMES ADVISER SERIES

4000 Ericsson Drive

Warrendale, Pennsylvania 15086-7561

June 21, 2021

Mark Cowan

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-4720

    RE:

    FEDERATED HERMES ADVISER SERIES (the “Registrant”)

    Federated Hermes MDT Market Neutral Fund (the “Fund”)

    Class A Shares

    Institutional Shares

    1933 Act File No. 333-218374

    1940 Act File No. 811-23259

Dear Mr. Cowan:

The Registrant is filing this correspondence
to respond to comments of the Staff of the Securities and Exchange Commission (“Staff”), provided on May 21, 2021, regarding
its Post-Effective Amendment No. 41 under the Securities Act of 1933 and Amendment No. 42 under the Investment Company Act of 1940 to
the Registration Statement of the above-referenced Registrant and Fund filed on April 8, 2021.

The Registrant notes that the Fund is proposed
to be the acquiring fund in a proposed reorganization (the “Reorganization”) with Hancock Horizon Quantitative Long/Short
Fund (the “Predecessor Fund”)

COMMENT 1. General Comments

 a. Please file BXTs until the closing of the Reorganization (to avoid two funds
with same performance and financials).

 b. If you plan to incorporate by reference this Registration Statement into
the N-14, we would not object to incorporating this Registration Statement into the N-14 and delivering a prospectus only to Target Fund
shareholders, but we would not suggest it. However, if that is the plan, you will need to represent that the Fund will not sell off this
Registration Statement and will sticker the Fund explaining that the Fund will not be operational until the closing of the Reorganization.

 c. Please make sure the Fund’s responses to Staff comments include the
marked disclosure changes that the Registrant intends to make by either including specific pages of the Registration Statement with the
Correspondence or by clearly indicating the revised disclosure in the Correspondence.

 d. Please note that where a comment is made in one section such comment should
be addressed in all other sections where it applies in the Registration Statement.

 e. The Registrant is responsible for the accuracy and adequacy of its disclosure
notwithstanding review by the Staff.

 f. Please remember to update the series/class identifiers on EDGAR to reflect
the ticker symbols once they are available. See Rule 313 of Regulation S-T.

RESPONSE:

 a. It is the Registrant’s understanding that the Fund must become effective
before the effective date of the Form N-14 to which the Fund’s reorganization with the Predecessor Fund relates. This has been a
past requirement of the Staff with which the Registrant has complied. Therefore, the Registrant believes that the Fund must become effective
automatically on June 24, 2021 and respectfully declines to file 485BXTs until the closing of the Reorganization.

 b. The Registrant represents on behalf of the Fund that the Fund will not offer
Fund shares to the public unless and until the Fund’s Reorganization with the Predecessor Fund has closed. A supplement will be
prepared and filed for the Fund explaining that the Fund will not be operational until the closing of the Reorganization.

 c. The Registrant will comply as requested.

 d. The Registrant will comply as requested.

 e. The Registrant understands its responsibility.

 f. The Registrant will comply as requested.

COMMENT 2. Prospectus – Risk/Return
Summary: Investment Objective

The following disclosure is not permitted or
required in the summary. Please move it to the statutory section of the Prospectus in response to Item 9(a).:

“The objective may be changed
by the Fund’s Board of Trustees (the “Trustees”) without shareholder approval.”

RESPONSE:

The Registrant will restate the Fund’s
investment objective in, and move the noted sentence above, to the Fund’s Item 9(a) disclosure to be the first and second sentence
of the first paragraph as follows (addition is bold and underlined):

“The Fund’s investment
objective is to seek to provide long-term capital appreciation while limiting exposure to general stock market risk. The objective may
be changed by the Fund’s Board of Trustees (the “Trustees”) without shareholder approval. The Fund seeks to
achieve its objective by investing …”

COMMENT 3. Prospectus - Risk/Return Summary:
Fees and Expenses

Please delete Footnote 1 since the Rule 12b-1
expenses disclosed are not currently charged by the Fund. This footnote is not permitted by Item 3 of Form N-1A. Dormant fees should be
addressed in Item 12 disclosure.

RESPONSE:

The Registrant confirms that the Distribution
Rule 12b-1 Fee (“12b-1 Fee”) for the Fund’s Class A Shares is “dormant.” While a 5 basis point 12b-1 Fee
for the Class A Shares has been approved by the Fund’s Board of Trustees (the “Board”), 5 basis points of the 12b-1
Fee will not be incurred or charged (“Dormant Fee”) unless and until it is approved to be activated by the Board, including
a majority of the Independent Trustees, and followed by appropriate notification to shareholders, including (as necessary) a supplement
to the prospectus fee table.

Respectfully, the Registrant believes that the
presentation of the Dormant Fee in the Fund’s respective footnote is consistent with Instruction 3(d)(i) to Item 3 of Form N-1A
and is material information for Fund investors. The Fund does not, and cannot, include the dormant portion of the 12b-1 Fee in the fee
table itself.

However, in fairness to investors, the Registrant
believes that it is important to identify in a footnote that: (1) the 12b-1 Fee has been approved by the Board; (2) provide the maximum
allowable fee amount, as applicable; and (3) disclose that a portion of the 12b-1 Fee is not currently being charged and will not be incurred
or charged until approved to be activated by the Board. Therefore, the Registrant respectfully declines to make any changes in response
to this comment.

COMMENT 4. Prospectus - Risk/Return Summary:
Fees and Expenses

The Staff notes that Footnote 2 discloses that Other Expenses, including
Dividends and Other Expenses related to Short Sales and Acquired Fund Fees and Expenses, are estimated.

Since the Fund is not a new fund as defined by Form N-1A Item 3 Instruction
6, Other Expenses should not be estimated, unless you expect that there will be changes in these expenses that are materially different
from the prior fiscal year because of the Reorganization. In that case:

(A) Restate the expense information using the current fees as if they
had been in effect during the previous fiscal year; and

(B) In a footnote to the table, disclose that the expense information
in the table has been restated to reflect current fees. See Form N-1A Item 3, Instruction 3(d).

RESPONSE:

The Registrant confirms that Fund expenses have
been restated to reflect expenses that will be in place following the acquisition of the Predecessor Fund. Current fees are those that
are reflected in the Predecessor Fund’s current prospectus and will be in place until the merger with the Fund.

Accordingly, the Registrant will make the following
revision to footnote 2 to the table (deletions stricken, additions bold and underlined):

“Dividends and Other Expenses
Related to Short Sales, Other Operating Expenses and Acquired Fund Fees and Expenses are based on estimated amounts for the current
fiscal year have been restated to reflect the anticipated fees and expenses of the Fund subsequent to the anticipated reorganization.”

COMMENT 5. Prospectus - Risk/Return Summary:
Fees and Expenses

In Footnote 3, please remove the references to
“on their own initiative” and “voluntary” in the context of waivers and/or reimbursements in order to avoid shareholder
confusion. These references are not permitted or required by Form N-1A Item 3.

RESPONSE:

With respect to the comment to remove the word
“voluntary,” the Fund’s investment adviser (“Adviser”) and certain of their affiliates have, voluntarily
on their own initiative, committed to waive certain amounts of their respective fees and/or reimburse expenses and enter into these agreements
with the Fund’s Board unless or until the Fund’s Board approves terminating or increasing the waivers, thus creating an agreed
rate that must be maintained for a year unless a change is approved by the Board. The Fund’s Fee Limit, as defined in Footnote 3,
is the threshold for total fund operating expenses under the Fund’s fee waiver and/or expense reimbursement arrangements. Please
note that, from time to time, there may be additional voluntary waivers, over and above the one-year committed waiver, but those are not
permitted to be reflected in the fee table per Form N-1A. Therefore, the Registrant respectfully declines to make changes to the disclosure
regarding voluntary waivers and reimbursements.

COMMENT 6. Prospectus - Risk/Return Summary:
Fees and Expenses

We note the disclosure in Footnote 3. A contractual
expense limitation shown in the fee table must be in effect for at least one year from the effective date of the Reorganization. April
1, 2022 is not a full year. See Instruction 3(e) to Item 3 of Form N-1A.

RESPONSE:

The Registrant will revise the Fund’s Footnote
3 to reflect a date that is at least one year from the effective date of the Reorganization as follows (deletion stricken and addition
bold and underlined):

“The Adviser and certain of
its affiliates on their own initiative have agreed to waive certain amounts of their respective fees and/or reimburse expenses. Total
annual fund operating expenses (excluding Acquired Fund Fees and Expenses, Dividends and Other Expenses Related to Short Sales, interest
expense, extraordinary expenses and proxy-related expenses paid by the Fund, if any) paid by the Fund’s A and IS classes (after
the voluntary waivers and/or reimbursements) will not exceed 1.33% and 1.08% (the “Fee Limit”), respectively, up to but not
including the later of (the “Termination Date”): (a) April 1, October 1, 2022; or (b) the date
of the Fund’s next effective Prospectus. While the Adviser and its affiliates currently do not anticipate terminating or increasing
these arrangements prior to the Termination Date, these arrangements may only be terminated or the Fee Limit increased prior to the Termination
Date with the agreement of the Fund’s Board of Trustees.”

COMMENT 7. Prospectus - Risk/Return Summary:
Fees and Expenses Example

Please explain the basis for using two example
scenarios – expenses assuming redemption and expenses assuming no redemption – since the classes do not charge a contingent
deferred sales charge or a redemption fee, per the Fee Table. Alternatively, please revise the Example table.

RESPONSE:

The Registrant will change the Example presentations
to reflect only one set of Example numbers and will make the following revisions to introductory disclosure (deletions are stricken and
addition is bold and underlined):

“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 for the time periods indicated and then redeem or hold all of your Shares at the end of those periods. Expenses
assuming no redemption are also shown. The Example also assumes that your investment has a 5% return each year and that the operating
expenses (excluding any sales loads on reinvested dividends, fee waivers and/or expense reimbursements) are as shown in the table above
and remain the same. The expenses used to calculate the Fund’s examples do not include fee waivers or expense reimbursements. Although
your actual costs and returns may be higher or lower, based on these assumptions your costs would be:”

COMMENT 8. Prospectus - Risk/Return Summary:
Portfolio Turnover

The Staff notes the following disclosure:

“Because the Fund has not yet
commenced operations as of the date of this prospectus, portfolio turnover information is not yet available for the Fund. The investment
objective and strategies of the Fund are substantially identical to the investment objective and strategies of the Predecessor Fund.”

Please delete these two sentences.

RESPONSE:

The Registrant respectfully believes that the
disclosure is accurate. Instruction 5 of Form N-1A Item 3 provides that a Fund must disclose the portfolio turnover rate provided in response
to Item 13(a) for the most recent fiscal year (or for such shorter period as the Fund has been in operation).”

The Registrant notes that the Fund does not have
an operating history and will not have an operating history unless and until the Reorganization is completed. In recognition of this,
the Fund discloses the Predecessor Fund’s portfolio turnover rate for its most recently completed fiscal year. Therefore, the Registrant
believes that this, in combination with the statement that the Fund has no operating history, is accurate, consistent with Form N-1A and
fully informative to shareholders.

COMMENT 9. Prospectus - Risk/Return Summary:
What are the Fund’s Main Investment Strategies?

The Staff notes the following disclosure in the
first paragraph:

“The Fund seeks to achieve its
objective by investing in long positions in publicly traded common stocks which the Fund’s quantitative model predicts will achieve
above-market returns, and short positions in publicly traded common stocks which the Fund’s quantitative model predicts will achieve
below-market returns.”

When will the adviser sell? This section seems
to address purchase but not sale.

RESPONSE:

The Registrant has reviewed the disclosure and
respectfully believes that the current disclosure does address that the Fund would both enter into and exit positions based on the predictions
of its quantitative model. However, in light of the Staff’s comment, the Registrant proposes the following revisions (deletions
stricken, additions bold and underlined):

“The Fund seeks to achieve its
objective by investing in selecting long positions in publicly traded common stocks which the Fund’s
quantitative model predicts will achieve above-market returns, and short positions in publicly traded common stocks which the Fund’s
quantitative model predicts will achieve below-market returns.”

COMMENT 10. Prospectus - Risk/Return Summary:
What are the Fund’s Main Investment Strategies?

 a. Please disclose the strategy that results in “Exchange-Traded Fund
Risk” as a principal risk or delete the risk disclosure.

 b. Please disclose the strategy that gives rise to “REIT Risk.”

 c. We note the “Sector Risk” disclosure. If the Fund invests significantly
in any sector(s), please disclose in the strategy.

 d. We note the “Portfolio Turnover Risk.” Frequent trading strategy
disclosure should be added.

RESPONSE:

a.       Exchange-Traded
Fund Risk. The Registrant has reviewed the disclosure and determined that exchange-traded fund investments are not a principal investment
strategy and thus not a principal risk factor for the Fund. Accordingly, the Registrant will move the exchange-traded fund securities
disclosure and related risk descriptions to the SAI.

b.       REIT
Risk. This risk is related to the Fund’s securities description regarding its investments in real estate investment trusts which
are a type of equity security in which the Fund may principally invest. The Fund’s strategy states that its investments will primarily
include, but are not limited to, equity securities of issuers listed in the Russell 3000 Index. Accordingly, the Registrant respectfully
believes the current strategy, securities and risk disclosures to be accurate and declines to make any revisions.

c.       Sector
Risk. Please see the Registrant’s response to Comment 11( g.) below.

d.       Portfolio
Turnover Risk. The Registrant respectfully believes that the current summary and statutory risk factors and statutory invest