SecProbe.io

CORRESP
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Seward
& Kissel LLP

901 K Street, N.W.

Suite 800

Washington, DC 20001

Telephone: (202) 737-8833

Facsimile: (202) 737-5184

February 26, 2024

VIA EDGAR CORRESPONDENCE

Ms. Kim McManus, Esq., Senior Counsel

Ms. Lauren Hamilton, Staff Accountant

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re:	      North Square Investments Trust (the “Trust”
or the “Registrant”)

File Nos. 333-226989; 811-23373

Dear Mses. McManus and Hamilton:

On November 14, 2023, the Trust, on behalf of its
series, Sphere 500 Climate Fund (the “Fund”), filed Post-Effective Amendment No. 27 to the Trust’s Registration Statement
on Form N-1A (the “Amendment”). The Amendment was filed pursuant to Rule 485(a)(2) under the Securities Act of 1933, as amended
(“Securities Act”), to register shares of the Fund. On December 11, 2023, you provided legal comments to the Amendment, and
on January 4, 2024, Ms. Hamilton provided accounting comments to the Amendment, delivered by telephone to Robert M. Kurucza, Esq. and
Karen Jacoppo-Wood, Esq.

Set forth below are your comments, as we understand
them, followed by responses to those comments, which the Trust has authorized me to make on its behalf. Where applicable, revisions indicated
in response to your comments will be reflected in an amendment to the Registrant’s Registration Statement to be filed subsequently
to or concurrently with this letter. All capitalized terms not defined herein have the meaning given to them in the Amendment.

Legal Comments

GENERAL

Comment 1. We remind you that the Trust
and its management are responsible for the accuracy and adequacy of the disclosure notwithstanding any review, comment, action, or absence
of action by staff (the “Staff”) of the U.S. Securities and Exchange Commission.

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Response. The Registrant acknowledges
the responsibility described above.

PRINCIPAL INVESTMENT STRATEGIES

Comment 2. In the description of the
Index, it states, “As You Sow eliminates companies from the Index based on their risk profile of being exposed to the fossil fuel
industry and other exclusionary screens.” Please expand the reference to “other exclusionary screens” to identify the
types of companies that may be excluded and include any related disclosures required by Item 4 and Item 9 of Form N-1A.

Response. The Registrant has revised
the disclosure as follows:

As You Sow eliminates companies from
the Index based primarily on their risk profile of being exposed to the fossil fuel industry and secondarily, by other exclusionary screens,
including companies engaged in deforestation activities, civilian and military firearms manufacturing and related guns/arms sales, prison
and border security operations, and tobacco and e-cigarette manufacturing. The elimination of these companies from the Index is intended
to foster and support the climate-focused, social investing goals of the Fund.

PRINCIPAL RISKS

Comment 3. Please include a discussion
of concentration risk based on the ability of the Index to concentrate in the securities of a particular industry or group of related
industries.

Response. The Registrant has added
the following disclosure to the Prospectus and SAI:

Industry Concentration Risk. In
following its methodology, the Index from time to time may be concentrated to a significant degree in securities of issuers located in
a single industry or group of industries. To the extent that the Index concentrates in the securities of issuers in a particular industry
or group of industries, the Fund also may concentrate its investments to approximately the same extent. By concentrating its investments
in an industry or group of industries, the Fund may face more risks than if it were diversified broadly over numerous industries or groups
of industries. If the Index is not concentrated in a particular industry or group of industries, the Fund will not concentrate in a particular
industry or group of industries.

PERFORMANCE

Comment 4. Please clarify that the index
returns for the Sphere 500 Fossil Free Index™ and the S&P 500® Index reflect no deductions for fees, expenses or taxes.

Response. The Registrant will make
the requested revisions.

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EXHIBITS

Comment 5. Please include the index
license or index sub-license agreement that governs the Fund’s relationship with the index provider as an exhibit to the Registrant’s
Registration Statement on Form N-1A.

Response. The Registrant will include
the applicable agreement as an exhibit to the Registrant’s Registration Statement on Form N-1A.

Comment 6. Please provide the Staff
with the Fund’s completed fee table and expense example. In addition, please confirm whether the Fund is subject to any fee waivers
and recoupments of fees waived.

Response. The Fund’s completed
fee table and expense example are attached hereto as Exhibit A. The Registrant hereby confirms that there are no fee waivers or recoupments
of fees waived associated with the Fund.

Accounting Comments

Comment 1. The Staff reminds the Registrant
to include the consent of the Fund’s independent registered public accounting firm as an exhibit to the Registrant’s Registration
Statement on Form N-1A pursuant to Rule 485(b) of the Securities Act.

Response. The Registration notes
the Staff’s comment and will include the consent of the Fund’s independent registered public accounting firm as an exhibit
to the Registrant’s Registration Statement on Form N-1A pursuant to Rule 485(b) of the Securities Act.

Comment 2. Please
include a hyperlink for any documents that are incorporated by reference in the Registration Statement as required by the 2015 Fixing
America’s Surface Transportation Act (the “FAST Act”) and related rule and form requirements.

Response. The Registrant has revised
the disclosure accordingly.

Comment 3. Please include the Information
Technology Sector Risk that is disclosed in the Fund’s Prospectus in the Fund’s Statement of Additional Information.

Response. The requested change
has been made.

Comment 4. With respect to the automated
Table of Contents contained in the Statement of Additional Information, please correct the error message noted therein.

Response. The Registrant has
corrected the broken link in the Table of Contents that caused the error message.

Comment 5. The Fund’s expense
structure appears to be arranged in a unitary fee structure, whereby the Adviser is obligated to pay service providers on behalf of the
Fund.  Please

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supplementally describe if the agreements filed with
the SEC contain provisions whereby the Fund is contractually obligated to pay such service providers.

Response. The Fund’s Investment
Advisory Agreement provides that the Adviser will pay all service provider fees. The Registrant confirms that the Adviser is current in
all its payments to the Predecessor Fund’s service providers.

If you have any questions or need
further information, please call me at 202-737-8833.

Sincerely,

/s/ Robert M. Kurucza

Robert M. Kurucza

cc: 	K. Jacoppo-Wood, Esq.

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Exhibit A

Fees and Expenses of the Fund

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 table and Expense Example below.

    Annual Fund Operating Expenses

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

    Management Fee
    0.07%

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

    Other Expenses(1)
    0.00%

    Total Annual Fund Operating Expenses
    0.07%

 (1) Estimated expenses for the current fiscal year

Expense 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 redeem all of your shares at the end of those periods. The Example also assumes that your
investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher
or lower, based on these assumptions, your costs would be:

    One Year
    Three Years
    Five Years
    Ten Years

    $7
    $23
    $40
    $90

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