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Seward & Kissel LLP

901 K Street, NW

Suite 800

Washington, DC 20001

Telephone: (202) 737-8833

Facsimile: (202) 737-5184

www.sewkis.com

June 3, 2024

Via EDGAR CORRESPONDENCE

Mr. Christopher R. Bellacicco, Esq.

Attorney-Adviser

Division of Investment Management, Disclosure Review Office

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

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

    File No. 333-226989

Dear Mr. Bellacicco:

This letter responds to comments
of the staff of the U.S. Securities and Exchange Commission (the “Staff”) regarding Post-Effective Amendment No. 34 to the
Trust’s Registration Statement on Form N-1A (the “Amendment”). The Amendment was filed on March 25, 2024 pursuant to
Rule 485(a)(2) under the Securities Act of 1933, as amended, to register shares of the North Square Kennedy MicroCap Fund (the “Fund”),
a series of the Trust. You provided the Staff’s comments to the Amendment by telephone on May 9, 2024 to Robert M. Kurucza, Esq.,
Karen Jacoppo-Wood, Esq. and Gary Grasso, Esq.

The Staff’s comments and
our responses thereto on behalf of the Registrant and the Fund are set forth below. Where applicable, revisions indicated in response
to your comments will be reflected in an amendment to the Registrant’s Registration Statement to be filed concurrently with or subsequently
to this letter. All capitalized terms not defined herein have the meaning given to them in the Amendment.

Comment 1. We remind you that the Registrant
and its management are responsible for the accuracy and adequacy of the disclosure notwithstanding any review, comment, action, or absence
of action by the Staff.

Response. The Registrant acknowledges
the responsibility described above.

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SUMMARY SECTION – Fees and Expenses of the Fund

Comment 2. Please provide a completed
fees and expenses table and example with the response.

Response. The Registrant has attached
a copy of the Fund’s completed fees and expenses table and expense example as Exhibit A to this letter.

Comment 3. Please supplementally indicate
whether the Fund anticipates frequent investments of $500,000 or more in Class A Shares.

Response. The Registrant confirms that
the Fund does not anticipate frequent investments of $500,000 or more in Class A Shares.

Comment 4. Please confirm that the fee
waiver will be in effect for at least one year from the date of effectiveness.

Response. The Registrant confirms that
the fee waiver will be in effect for at least one year from the date of effectiveness.

Comment 5. If Acquired Fund Fees and
Expenses (“AFFE”) of the Fund’s investments in investment companies and exchange-traded funds is expected to exceed
0.01% of the Fund’s average net assets, then please include AFFE as a separate line item in the fee table. See Instruction 3, Subsection
F of Item 3 of Form N-1A for guidance.

Response. The Registrant confirms that
AFFE for the Fund are not expected to exceed 0.01% of the Fund’s average net assets and, accordingly, that is why there is no caption
provided for AFFE in the Fund’s fee table.

SUMMARY SECTION – Principal Investment Strategies

Comment 6. Please disclose how the Fund defines Emerging
Markets.

Response. In response to the
Staff’s comment, the Registrant has revised the following sentence in the first paragraph of the Fund’s principal investment
strategies section (emphasis added):

While the Fund invests primarily in equity
securities of U.S. issuers, it may invest in securities of foreign issuers, including those in emerging market countries or developing
countries as defined by the World Bank, International Finance Corporation or the Morgan Stanley Capital International (MSCI) emerging
market indices or other comparable indices.

Comment 7. Please remove the phrase
(emphasis added), “In keeping with the Fund’s investment objective, investments in such foreign issuers is not expected
to exceed 20% of the Fund’s net

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assets,” or clarify how limiting investments
in foreign issuers to 20% of the Fund’s net assets is “in keeping with the Fund’s investment objective.”

Response. The Registrant has
revised the disclosure as follows:

Investments in such foreign issuers are not
expected to exceed 20% of the Fund’s net assets.

Comment 8. Please clarify to which index
the following disclosure is referring: “(v) the issuer’s market capitalization consistently exceeds the capitalization range
of the Index.”

Response. The Index referred to is the
Russell Microcap® Index, and the Registrant has revised the disclosure accordingly.

SUMMARY SECTION – Principal Risks of Investing

Comment 9. If the Fund intends to focus
investments in a particular sector, please disclose this and any related risks.

Response. The Registrant notes
that, while the Fund may, from time to time, invest a significant amount of its total assets in different sectors of the economy, it does
not have any predetermined plan to concentrate its investments in a particular sector.

Comment 10. Please supplementally explain
the types of investments that the Fund anticipates will pose liquidity issues.

Response. The Registrant notes
that securities of companies with smaller market capitalizations, investments in foreign markets, including emerging market countries,
Rule 144A securities, certain sectors of fixed income securities that have decreased liquidity, derivatives or securities with substantial
market and/or credit risk may pose liquidity issues.

Comment 11. Please delete the duplicative
Portfolio Turnover Risk and Preferred Stock Risk disclosures.

Response. The requested change
has been made.

MORE ABOUT THE FUND’S INVESTMENT OBJECTIVE,
PRINCIPAL INVESTMENT STRATEGY AND RISKS

Comment 12. The Item 9 strategy disclosure
appears to repeat the Item 4 strategy disclosure. Please note that the disclosure in response to Item 9 of Form N-1A should provide a
more detailed discussion regarding the strategy and related risks of the Fund. Please review and revise this disclosure accordingly. See
Investment Management Guidance Update 2014–08 for guidance on the disclosure to be provided in response to Item 9.

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Response. The Registrant has
carefully reviewed and believes that the current Item 4 disclosure is sufficiently clear and concise to inform shareholders of the Fund’s
principal investment strategies and principal risks in summary fashion, while the Fund’s current Item 9 disclosure provides appropriate
additional detail relating to the Fund’s principal risks and therefore, the Registrant has respectfully determined to retain the
disclosure as is. The Registrant believes that this approach provides effective “layered” disclosure for investors consistent
with the objectives of Form N-1A.

Comment 13. Please consider disclosing
additional risks of micro-cap companies and trading therein including, but not limited to: (i) little or no recent financial information
or disclosures, (ii) halted or restricted trading, and (iii) that such companies may be more susceptible to manipulation.

Response. The Registrant has
revised the Micro-Cap and Small-Cap-Sized Company Risk disclosure to add the following sentence at the end of the Risk:

Further, micro- and small-capitalization companies
may be exposed to additional risks including, but not limited to, having little or no recent financial information or disclosures available
as many micro-capitalization companies do not file financial reports with the SEC, the potential for halted or restricted trading in their
shares, and being more susceptible to manipulation due to their low trading volume and lack of analyst coverage.

Comment 14. The Staff notes that the
Item 4 risk disclosure does not include an IPO Risk, and there is nothing in the strategy disclosure to suggest that the Fund will invest
in IPOs as part of its Principal Investment Strategies. Please revise the disclosure as appropriate.

Response. The Registrant has
revised the disclosure to add the following sentence to the end of the Principal Investment Strategies section: “The Fund also may
invest in initial public offerings (“IPOs”) of equity securities.” The Registrant has also added IPO Risk to the Item
4 risk disclosure.

Comment 15. (a) Please add disclosure
clarifying what “North Square-Related Funds” means, as the term is in capitals and (b) please discuss supplementally how the
Fund plans to satisfy restrictions regarding affiliated transactions under the 1940 Act.

Response. (a) The Registrant
has revised the disclosure to define “North Square-Related Funds” as “other funds advised or sub-advised by North Square
Investments, LLC (the “Adviser”) or its affiliates.” (b) Generally, under Sections 12(d)(1)(F) and 12(d)(1)(G) of the
1940 Act and SEC rules adopted pursuant to the 1940 Act, the Fund may acquire the securities of affiliated and unaffiliated investment
companies subject to certain guidelines and restrictions. In addition, the Fund expects to rely on Rule 12d1-4 under the 1940 Act to the
extent that the Adviser or Sub-Adviser deem such reliance necessary or appropriate.

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Comment 16. Please clarify to which
“debt obligations” the Liquidity Risk is referring in the sentence, “Certain debt obligations may be difficult or impossible
to sell at the time and price that the Sub-Adviser would like to sell,” as the principal investment strategy does not appear to
discuss investing in debt obligations.

Response. The Liquidity Risk disclosure has been revised
as follows in response to the Staff’s comment:

The Fund may not be able to sell some or all
of the investments that it holds due to a lack of demand in the marketplace or other factors such as market turmoil, or if the Fund is
forced to sell an illiquid investment to meet redemption requests or other cash needs it may only be able to sell those investments at
a loss. Illiquid investments may also be difficult to value.

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

Sincerely,

/s/ Robert M. Kurucza

Robert M. Kurucza

Enclosure

cc:	G. Grasso, Esq.

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 tables and examples below. You may qualify for sales charge discounts if you and your
family invest, or agree to invest in the future, at least $50,000 in Class A shares of the Fund. More information about these and other
discounts is available from your financial intermediary and in the section titled “Class A Shares” and in “APPENDIX
A – Waivers and Discounts Available from Certain Intermediaries” of the Prospectus.

    Class A Shares

    Class I Shares

    Shareholder Fees

(fees paid directly from your investment)

    Maximum sales charge (load) imposed on purchases

(as a percentage of offering price)

    5.75%

    None

    Maximum deferred sales charge (load)

(as a percentage of the lesser of the value redeemed or the amount invested)

    None¹

    None

    Redemption fee (as a percentage of amount redeemed)

    None

    None

    Annual Fund Operating Expenses

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

    Management fees

    1.20%

    1.20%

    Distribution and service (Rule 12b-1) fees

    0.25%

    None

    Other expenses

    0.48%

    0.48%

    Shareholder servicing fee
    0.15%

    0.15%

    All other expenses2
    0.33%

    0.33%

    Total annual fund operating expenses

    1.93%

    1.68%

    Fees waived and/or expenses reimbursed

    (0.21)%

    (0.21)%

    Total annual fund operating expenses

after waiving fees and/or reimbursing expenses3

    1.72%

    1.47%

 1. No sales charge applies on investments
of $500,000 or more, but a contingent deferred sales charge (“CDSC”) of 1% will be imposed on certain redemptions of such
shares within 12 months of the date of purchase.

 2. “All Other Expenses” are
estimated for the current fiscal year.

 3. North Square Investments, LLC (“North
Square” or the “Adviser”), the Fund’s investment adviser, has contractually agreed to waive its fees and/or pay
for or reimburse operating expenses of the Fund to ensure that total annual fund operating expenses (excluding any taxes, leverage interest,
brokerage commissions, dividend and interest expenses on short sales, any acquired fund fees and expenses, expenses incurred in connection
with any merger or reorganization, and extraordinary expenses such as litigation expenses) do not exceed 1.72% and 1.47% of the average
daily net assets of the Fund’s Class A and Class I shares, respectively. This agreement is in effect until September 30, 2025, and
it may be terminated before that date only by the Board of Trustees. North Square is permitted to seek reimbursement from the Fund, subject
to certain limitations, of fees waived, payments made or expenses reimbursed to the Fund for a period ending 36 months after the date
of the waiver, payment or reimbursement. This reimbursement may be requested from the Fund if the reimbursement will not cause the Fund’s
annual expense ratio to exceed the lesser of (a) the expense limitation amount in effect at the time such fees were waived, payments made
or expenses reimbursed, or (b) the expense limitation amount in effect at the time of the reimbursement.

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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 (taking into account the contractual fee waiver
until September 30, 2025). Although your actual costs may be higher or lower, based on these assumptions your costs would be:

    One Year
    Three Years

    Class A shares
    $740
    $1,127

    Class I shares
    $150
    $509

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