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CORRESP
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Exchange Place Advisors Trust

c/o Ultimus Fund Solutions, LLC

225 Pictoria Drive, Suite 450

Cincinnati, Ohio 45246

September 25, 2024

Via EDGAR CORRESPONDENCE

Valerie J. Lithotomos, Esq.

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: Exchange Place Advisors Trust (formerly North Square Investments Trust)

(the “Trust” or the “Registrant”)

	File Nos. 811-23373; 333-226989

Dear Ms. Lithotomos:

This letter responds to comments
of the staff of the U.S. Securities and Exchange Commission (the “Staff”) (the “SEC”) regarding Post-Effective
Amendment No. 37 to the Trust’s Registration Statement on Form N-1A (the “Amendment”). The Amendment was filed on July
26, 2024 pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended (“Securities Act”), to disclose an investment
strategy change being made to the North Square Core Plus Bond Fund (the “Fund”), a series of the Trust. You provided the Staff’s
comments to the Amendment by telephone on September 10, 2024 to 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 (including in the Exhibits hereto) have the meaning given to them in the Amendment.

GENERAL

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 and its management
acknowledges the responsibility described above.

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Comment 2. Please provide all missing
information, and eliminate all blanks and bracketed items.

Response. The Registrant will include
the remaining missing information in a subsequent amendment to the Registrant’s Registration Statement.

Comment 3. Please explain why the Fund
did not need a shareholder meeting in connection with the change in the Fund’s investment sub-advisers.

Response. The Registrant and North Square
Investments, LLC (the “Adviser”) have been granted exemptive relief from the SEC, which permits the Adviser, on behalf of
the Fund and subject to the approval of the Board of Trustees of the Registrant (the “Board”), including a majority of the
independent members of the Board, to hire, and to modify any existing or future sub-advisory agreement with, unaffiliated sub-advisers
and affiliated sub-advisers, including sub-advisers that are wholly-owned subsidiaries (as defined in the Investment Company Act of 1940,
as amended (the “1940 Act)) of the Adviser or its parent company and sub-advisers that are partially-owned by, or otherwise affiliated
with, the Adviser or its parent company.

SUMMARY SECTION – Fees and Expenses of the Fund

Comment 4. Please provide a completed
fees and expenses table and example with the response at least five (5) business days before the Amendment becomes effective.

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

SUMMARY SECTION – Principal Investment Strategies

Comment 5. We note that the Fund has completely changed
its investment strategies. We have the following comments concerning these changes:

1. Please supplementally inform the Staff why
the Board believes these changes are consistent with its fiduciary duties and are in the best interests of its shareholders -- who did
not vote for these changes. In your response:

Explain in detail what information the Board
considered, and how it weighed the information in arriving at its decision.

Explain in detail why the Board concluded that
this approach was better for shareholders than other alternatives, such as liquidating the Fund and starting a new Fund.

Support your explanation of the Board’s
deliberations with data. For example, if cost was a consideration, provide data on the expected cost savings from the proposed changes,
as compared with starting a new Fund.

2. Please also explain why the Adviser believes
these changes are consistent with its fiduciary duty to this Fund.

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3. Has the Fund notified its shareholders of
this planned change? If so, please provide the Staff with a copy of the notice and when and how (e.g., letter, e-mail) it was sent.
If not, when will the Fund distribute such a notice and how?

4. What is the composition of the Fund’s
shareholder base (e.g., affiliated versus unaffiliated, retail versus institutional, domestic versus foreign)? What percentage
of the Fund’s shares are held by retail investors?

5. Please explain in your response why making
these changes in a post-effective amendment to the registration statement of an existing Fund, as opposed to an amendment adding a new
Fund, is consistent with the text and policy of Rule 485(a) under the Securities Act. Explain why you believe this does not provide an
unfair competitive advantage over other registrants, which add new series under Rule 485(a) that go effective within 75 days (as opposed
to 60 days).

6. Please inform the Staff in your response letter
what percentage of the Fund’s current portfolio needs to be re-positioned as a result of these changes.

7. Have any shareholders contacted the Fund or
intermediaries about this planned transaction? If so, describe the nature of such communications including whether anyone has expressed
displeasure or disagreement with the planned transaction or threatened legal action.

Response. The change
to the investment strategy of the Fund reflected the recommendation by the Adviser. The Adviser recommended the change because, despite
the Adviser’s efforts over the last two years to market the Fund, the Adviser does not believe it can materially grow the Fund’s
assets with its current strategy due to, among other factors, changes in the markets, the relative performance of the Fund, alternatives
to the Fund in fixed income markets, and Morningstar Inc.’s category placement. The Adviser noted that, in light of these challenges,
the Adviser considered various alternatives for the Fund and, after careful analysis, believes that the Fund’s shareholders would
benefit from the Fund’s assets being managed in a core-plus bond strategy, utilizing two of the Trust’s current Sub-Advisers,
CSM Advisors, LLC and Red Cedar Investment Management, LLC (the “New Sub-Advisers”), one for each of two Fund sleeves (core
and plus). The Adviser further noted that the Morningstar U.S. Core Plus Bond category is a large mutual fund category and the Adviser
believes such change would place the Fund in a more marketable position going forward, which could benefit shareholders, and also could
allow Fund shareholders to more accurately evaluate the Fund’s relative performance against a meaningful benchmark. In addition,
the Adviser noted that although the investment management strategy would differ from the current one, the core-bond strategy would still
share the same investment goal as the current strategy with respect to seeking lower volatility and risk relative to the U.S. equity markets.

A board of trustees, in its role as a board
and exercising its fiduciary duty, does not dictate to an investment adviser of an investment company how to invest to achieve maximum
return for shareholders, but rather relies on the expertise of the investment adviser to manage the investment

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portfolio.
With respect to the Fund, the Board considered the Adviser’s expertise and gave deference to its insights that the revised investment
strategy and New Sub-Advisers had the potential to attract new investors and assets into the Fund and may in fact benefit the Fund’s
shareholders. The Board believes that its approval of the changes is consistent with its fiduciary duties and that such changes are in
the best interests of shareholders because the changes are designed to address concerns raised by the Adviser regarding the viability
of the Fund by utilizing a revised investment strategy utilizing the New Sub-Advisers that could be more competitive in the current market
and could also potentially address any relative underperformance.

The
prospectus disclosure relating to the Fund makes clear that the Fund’s investment strategy is not a fundamental policy and
may be changed by the Board without shareholder action. The Registrant respectfully submits that a change of this nature is consistent
with actions taken by investment company boards in the ordinary course without shareholder action, and that organization of a new fund
in order to accomplish this change would require undue time and expense and would not be in the best interest of shareholders. The Registrant
also notes that the Fund filed and mailed a supplement pursuant to Rule 497 to give shareholders advance notice of the changes and the
opportunity to sell their shares if they disagreed with the changes.

The Adviser believes that the changes are consistent
with its fiduciary duties to the Fund for the same reasons discussed above with respect to its proposal and the Board’s determination.

The change to the investment strategy of the
Fund is being implemented in connection with a change in sub-adviser to this Fund. As noted above, and as the prospectus of the Fund discloses,
the Fund operates in accordance with a “manager-of-managers” exemptive order issued by the SEC (the “Order”).
Among the advantages of the manager-of-managers structure is the role of the Fund’s Adviser in proposing the retention of a sub-adviser
to the Fund, continuously monitoring and evaluating the sub-adviser’s performance, and, where appropriate, recommending changes
in sub-advisers. In connection with changes in sub-advisers, the description of a fund’s investment strategy is typically revised
to reflect differences between the specific investment approach of a new sub-adviser and that of the legacy sub-adviser.

In connection with the Fund’s proposed
sub-adviser and investment strategy changes, the Board took into account information provided to it at Board meetings held on March 29-30,
2023, June 21-22, 2023, September 12-13, 2023 , December 6-7, 2023 and March 21-22, 2024. The Adviser made a specific recommendation regarding
the expected benefits to the Fund and its shareholders of the change in sub-adviser and to the investment strategy of the Fund. Over the
course of multiple meetings, the Adviser and the New Sub-Advisers, as applicable, provided a substantial amount of information to the
Fund’s Board, including information regarding the investment program and performance of the Fund and the current Sub-Adviser and
the investment program and investment experience of the proposed New Sub-Advisers, and information regarding the New Sub-Advisers’
investment personnel, compliance programs, and operations. The Board also took into account its familiarity with the proposed New Sub-Advisers
through their services as sub-advisers for other funds in the Trust. The Board also noted that one of the New Sub-Advisers was an affiliate
of the Fund’s current Sub-Adviser and of the Adviser. The Board was also provided

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with
information regarding the change in related fees, including information as to the effect of any change on the Adviser’s profitability.
In this regard, the Adviser represented that the management fee of the Fund would be decreased and the Fund’s overall expense cap
would be lowered in connection with the proposed changes and that shareholders would further benefit from such savings.

The Board considered the proposal thoroughly
over multiple meetings and an extended period of time in the exercise of its business judgment, requesting additional information where
appropriate. The bases for the Board’s approval of a sub-advisory agreement with each of the new Sub-Advisers will be disclosed
publicly in the Fund’s next applicable financial statements and in an information statement, in accordance with the Order. The Independent
Trustees were advised in these matters by independent counsel. In its deliberations, the Board considered whether a change in sub-adviser
and in the Fund’ investment strategy was in the best interests of the Fund and its shareholders. The recommendation and approval
process, which included due diligence by the Adviser and the careful review and consideration by the Board of detailed information (both
oral and written), with the assistance of independent counsel, supported the discharge by each of the Adviser and of the Board of their
respective fiduciary duties.

Consistent with the conditions of the Order,
the Registrant will deliver to shareholders a detailed information statement for the Sub-Adviser change within 90 days of the change,
which change is expected to occur on or about September 27, 2024. As noted above, the Registrant confirms that the Fund mailed a supplement
to shareholders dated July 26, 2024 notifying shareholders of the planned changes to the Fund’s name, investment objective, principal
investment strategies, sub-advisers, fees and expenses and share classes. The supplement was filed with the SEC on July 26, 2024 (Accession
No. 0001580642-24-003914), and is included as Exhibit B to this letter. This supplement and notice timeline was intended to coincide with
the Staff’s review of the Fund’s Rule 485(a) filing and specifically stated that the changes would be submitted as part of
a revised registration statement for review by the Staff and would be subject to revisions in response to comments received from the Staff.

As to the use of a filing under Rule 485(a)
under the Securities Act to reflect these changes as opposed to the organization of a new fund and the implementation of these changes
without shareholder approval, the Registrant respectfully submits that this is one of the principal advantages of the manager-of-managers
structure and has been specifically contemplated by the SEC and its Staff in the development and granting of manager-of-managers exemptive
relief. The Registrant also notes that the Fund’s current investment strategy includes investments in fixed income securities. Further,
the Registrant does not believe this approach creates an unfair competitive advantage over other registrants as the proposed changes to
the investment strategy are unique to this Fund and its New Sub-Advisers and are not being made in reaction to new product developments
in the market but as being in the best interests of current shareholders, including as an opportunity for potential growth over the longer
term.

The New Sub-Advisers intend on repositioning
approximately 100% of the Fund’s assets. The repositioning is necessary because the New Sub-Advisers will be investing principally
in debt securities rather than investing across multiple investment strategies and investment techniques

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that
were designed to generate return and manage risk exposure across varying marketing conditions by employing three separate investment
styles.

The
Registrant is not aware of any shareholders contacting the Fund or intermediaries about this planned transaction. Currently almost all
of the Fund’s shareholders are retail shareholders, even if some of their shares are held in title by investment advisers for their
benefit. The Adviser believes that approximately 100% of the Fund’s shareholders are domestic investors and estimates that approximately
70% of the shares are held by clients of advisers affiliated with the Adviser.

Comment 6. In the description of Red Cedar’s Plus
investment strategy, please either define or clarify the term “rising stars.”

Response. The Registrant
has added the following sentence: “Rising stars” are securities which exhibit improvi