SecProbe.io

CORRESP
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Blank Rome LLP

1271 Avenue of the Americas

New York, NY 10020

(212) 885-5000 (Phone)

(212) 885-5001 (Facsimile)

www.blankrome.com

April 10, 2025

VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Eileen Smiley

Re:       Exchange Place Advisors Trust (Registration No. 333-285408)

    Response to Examiner Comments on Pre-Effective

    Amendment No. 1

Dear Ms. Smiley:

On March 14, 2025, Exchange Place Advisors Trust (the
“Registrant”) filed Pre-Effective Amendment No. 1 (“PEA No. 1”) to its Registration Statement on Form N-14
(the “Proxy Statement/Prospectus”) relating to the reorganization of the Foundry Partners Small Cap Value Fund, a series
of Valued Advisers Trust, with and into the North Square Small Cap Value Fund (the “Fund”), a series of the Registrant.
On March 28, 2025, the staff (the "Staff") of the Securities and Exchange Commission (the "SEC") telephonically
provided the comments below to PEA No. 1 to Andrew P. Cross of Blank Rome LLP. Please see the Registrant’s responses to such
comments below, which the Registrant has authorized Blank Rome LLP to make on its behalf.

Pursuant to Rule 488 under the Securities Act of 1933, as amended (the
“1933 Act”) PEA No. 1 is scheduled to become automatically effective on April 13, 2025.

Where applicable, revisions indicated in response to the Staff’s
comments, along with conforming and/or non-material revisions, will be reflected in a subsequent Rule 497 filing.

Capitalized terms used in this response letter, but not defined herein,
shall have the same meaning as in PEA No. 1. The section and page references that we refer to in the Registrant’s responses are
references to the filed version of PEA No. 1.

General Comments

 1. Comment: 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.

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Response: The Registrant and its management acknowledge
the responsibility described above.

 2. Comment: Provide all missing information and eliminate all blanks and bracketed items.

Response: The Registrant will provide the missing information
and eliminate all blanks and bracketed items.

 3. Comment: Please apply the comments below throughout PEA No. 1 on a consistent basis.

Response: The Registrant will apply the comments below
throughout PEA No. 1 on a consistent basis.

Comment to the Shareholder Letter

 4. Comment: On page 2 of the Shareholder Letter, please revise the third sentence of the first paragraph
to state that the VAT Board unanimously recommends that shareholders vote for the Reorganization proposal.

Response: The requested change will be made.

Comments to the Introduction of the
Proxy Statement/Prospectus

 5. Comment: Please confirm that: (i) the Acquiring Fund Prospectus and SAI (referenced on page iii
of Proxy Statement/Prospectus) will be effective prior to completing and mailing the Proxy Statement/Prospectus; and (ii) all material
comments given by the Staff on the Acquiring Fund Prospectus and SAI have been resolved and are reflected in the Proxy Statement/Prospectus.

Response: The Registrant confirms that: (i) the Acquiring
Fund Prospectus and SAI will be effective prior to completing and mailing the Proxy Statement/Prospectus; and (ii) all material comments
given by the Staff with respect to the Acquiring Fund Prospectus and SAI have been resolved and will be reflected in the Proxy Statement/Prospectus.

Summary Section – Principal
Investment Strategies

 6. Comment: On page 1 of the Proxy Statement/Prospectus, in the Summary of Key Information under
“WHO IS ELIGIBLE TO VOTE ON THE PROPOSAL?,” please add a brief description about how to revoke a proxy or
add a cross-reference to the subsequent discussion of this topic in the Proxy Statement/Prospectus.

Response: The Registrant has added
the following sentence to the Summary of Key Information in response to the question “WHO IS ELIGIBLE TO VOTE ON THE PROPOSAL?:

For additional information about voting on the Reorganization (including
how to revoke your proxy), please see (i) “How Do I Vote on the Reorganization?” in this Summary of Key Information and (ii)
the section entitled VOTING INFORMATION in this Proxy Statement/Prospectus.

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 7. Comment: On page 1 of the Proxy Statement/Prospectus, in the Summary of Key Information under “WHAT ARE THE REASONS FOR
THE PROPOSED REORGANIZATION?,” please add a statement to the first paragraph of the answer to the effect that the Acquiring Fund
will be managed by NSI and CSM as the Adviser and the Sub-Adviser, respectively.

Response: The Registrant has added the following sentence
to the end of the first paragraph of this answer:

The Acquiring Fund will be managed by NSI and CSM as the Adviser
and the Sub-Adviser, respectively.

8.        Comment:
Please disclose in an appropriate place in the Proxy Statement/Prospectus that the Acquiring Fund will comply with the conditions of Section
15(f) under the Investment Company Act of 1940, as amended, and more specifically: (i) for a period of at least three years after the
Reorganization, at least 75% of the board of directors of the Acquiring Fund will be independent of Foundry Partners, the Adviser and
the Sub-Adviser; and (ii) for a period of at least two years after the Reorganization, there will not be an “unfair burden”
imposed on the Acquiring Fund as a result of the Reorganization or any express or implied terms, conditions or understandings applicable
to the Reorganization.

Response: The Registrant has added the following paragraph
under the GENERAL sub-heading to the discussion under the heading THE PROPOSED REORGANIZATION:

As a general matter, the Reorganization complies with the
conditions of Section 15(f) of the 1940 Act since: (i) for a period of at least three years after the Reorganization, at least 75%
of the board of trustees of the Acquiring Fund will be independent of Foundry Partners, the Adviser and the Sub-Adviser; and (ii)
for a period of at least two years after the Reorganization, there will not be an “unfair burden” imposed on the
Acquiring Fund as a result of the Reorganization or any express or implied terms, conditions or understandings applicable to the
Reorganization. In regard to the absence of the imposition of an unfair burden, it is specifically noted that: (1) the expense cap
in place for the Acquiring Fund will be the same as that currently in place for the Acquired Fund, but will be extended for at least
two years from the date of the closing of the Reorganization and through at least September 30, 2027; and (2) the costs of the
Reorganization, including the costs of soliciting proxies, will be borne by Foundry Partners and the Adviser and not the Acquired
Fund or the Acquiring Fund or their respective shareholders.

 9. Comment: Delete the words “or lower than” from the next-to-last sentence of the first paragraph on page 2 of the
Proxy Statement/Prospectus. Consider deleting the parenthetical “(after giving effect to the contractual expense caps)” from
this sentence, since these are not triggered at this time, and adding a new sentence explaining that the expense cap is not currently
being triggered, but will remain in place for at least two years after the Reorganization, and cross-referencing the relevant disclosure
in the Proxy Statement/Prospectus.

Response: The Registrant has revised the next-to-last
sentence of the first paragraph on page 2 of the Proxy Statement/Prospectus as follows:

Finally, following the Reorganization, the annual advisory fees
(after giving effect to the contractual expense caps), and the
expense limitations capping Fund expenses with

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respect to the Acquiring Fund will be the same as or
lower than those of the Target Fund. In addition, immediately following the Reorganization,
the total annual fund operating expenses of the Acquiring Fund are anticipated to be no greater than those of the Acquired Fund. Although
the expense limitations are not presently triggered based on the current level of operating expenses, the Acquiring Fund’s contractual
expense caps, which are the same as those of the Acquired Fund, will remain in place for at least two years from the date of the closing
of the Reorganization and through at least September 30, 2027. Please see (i) “What effect will the Reorganization have on me as
a Shareholder?” in this Summary of Key Information and (ii) COMPARISON OF INVESTMENT ADVISERS AND PORTFOLIO MANAGERS under the sub-heading,
“Investment Adviser to Acquired Fund; Investment Adviser and Sub-Adviser to Acquiring Fund” in the Proxy Statement/Prospectus.

 10. Comment: Consider deleting the parenthetical “(after giving effect to the contractual expense caps)” from third
sentence of the last paragraph on page 2 of the Proxy Statement/Prospectus, since these caps are not triggered at this time.

Response: The Registrant will revise the third sentence
of the last paragraph on page 2 of the Proxy Statement/Prospectus as follows:

The total annual fund operating expenses of Acquiring Fund (after
giving effect to the contractual expense caps) are anticipated to be no greater than those of the Acquired Fund immediately
following the Reorganization.

 11. Comment: In the answer to the first question on page 3 (“HOW DO THE FUNDS’ INVESTMENT OBJECTIVES, PRINCIPAL INVESTMENT
STRATEGIES, PRINCIPAL INVESTMENT RISKS, FISCAL YEAR END, AND INVESTMENT LIMITATIONS AND POLICIES COMPARE?”), describe any material
differences for purposes of the comparison or include a cross-reference to where the differences are described in the Proxy Statement/Prospectus.

Response: The Registrant notes that, while the fiscal year
ends for the Acquiring Fund and Acquired Fund differ, there are no material differences between the Acquiring Fund and the Acquired Fund
with respect to the other items covered by this question. The investment objective, principal investment strategies, and principal investment
risks of the Acquiring Fund are the same or substantially the same as those of the Acquired Fund. The fundamental investment limitations
of the Acquiring Fund are the same or substantially the same as those of the Acquired Fund. The Acquired Fund has certain non-fundamental
investment policies that the Acquiring Fund does not have. There are no changes anticipated to be made to the Acquired Fund’s portfolio
as a result of being reorganized into the Acquiring Fund. The Registrant confirms it will revise the first sentence of this response to
remove the reference to the fiscal year ends of the Acquired and Acquiring Funds and to add the following to the end of this response:

The Acquired Fund has an October 31st
fiscal year end, as compared to a fiscal year end of May 31st for the Acquiring Fund. For more information about any differences
with respect to the investment objectives, principal investment strategies, principal investment risks and investment limitations and
policies of the Acquiring and Acquired Funds, please see ADDITIONAL INFORMATION ABOUT THE FUNDS later in this Proxy Statement / Prospectus.

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 12. Comment: Please confirm that the pro forma table on page 3 of the Proxy Statement/Prospectus is based on the most current fees
and expenses available (as per Item 3 of Form N-14).

Response: The Registrant confirms that the pro forma
table on page 3 of the Proxy Statement/Prospectus is based on the most current fees and expenses available.

 13. Comment: Please confirm that the right to recoupment of previously waived fees and paid expenses by Foundry Partners in respect
of the Acquired Fund will not be carried over to the Adviser or Sub-Adviser in respect of the Acquiring Fund.

Response: The Registrant confirms that the right to recoupment
of previously waived fees and paid expenses by Foundry Partners in respect of the Acquired Fund will not be carried over to the Adviser
or Sub-Adviser in respect of the Acquiring Fund.

 14. Comment: Please use “bold text” for the next-to-last sentence of the paragraph immediately prior to the pro forma
table on page 3 of the Proxy Statement/Prospectus.

Response: The requested change will be made.

 15. Comment: Consider adding a sentence to footnote 2 of the pro forma fee table on page 3 to the effect that the Acquiring Fund
has adopted an expense cap agreement that is not currently being implicated, and including a cross-reference to the discussion of the
expense caps in the Proxy Statement/Prospectus.

Response: The Registrant will add the following to footnote
2 of the pro forma fee table on page 3 of the Proxy Statement/Prospectus:

The Acquiring Fund is subject to contractual expense caps at the
same levels as the current contractual expense caps with respect to the Acquired Fund for at least two years from the date of the closing
of the Reorganization and through at least September 30, 2027, but that will not be implicated immediately following the Reorganization
based on the anticipated level of the Acquiring Fund’s operating expenses. Please see COMPARISON OF INVESTMENT ADVISERS AND PORTFOLIO
MANAGERS under the sub-heading, “Investment Adviser to Acquired Fund; Investment Adviser and Sub-Adviser to Acquiring Fund”.

 16. Comment: Because the Acquiring Fund will have an Adviser and a Sub-Adviser, please disclose briefly in an appropriate place
in the Proxy Statement/Prospectus what the Adviser will do and will pay the Sub-Adviser for day-to-day management of the Fund.

Response: The Registrant will add the following disclosure
before the sentence that is immediately prior to the “Portfolio Managers” sub-heading on p. 18 of the Proxy Statement/Prospectus:

Under the investment advisory agreement in respect of the Acquiring
Fund, the Adviser is responsible for providing or overseeing the provision of all investment management services to the Acquiring Fund,
including furnishing a continuous investment program for the Acquiring Fund and determining what securities and other investments the
Acquiring Fund should buy and sell. The Adviser, together with the administrator to the Acquiring

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Fund, is also responsible for assisting in the supervision and
coordination of all aspects of the Acquiring Fund’s operations, including the coordination of the Acquiring Fund’s other services
providers and the provision of related administrative and other services. The Adviser is authorized to delegate certain of its duties
with respect to the Acquiring Fund to one or more sub-advisers. The Adviser has engaged CSM as the Sub-Adviser pursuant to this authority
and is responsible for overseeing CSM and recommending its hiring, termination, and replacement for approval by the EPAT Board. As the
Sub-Adviser, CSM makes investment decisions for the assets it has been allocated to manage, subject to the overall supervision of the
Adviser.

 17. Comment: In the answer to the last question on page 6 of the Proxy Statement/Prospectus (HOW DO THE BOARDS AND THE FUND’S
SERVICE PROVIDERS, OTHER THAN THE INVESTMENT ADVISER AND DISTRUBTOR, COMPARE?”), please confirm if there are any material differences
in the rights of shareholders or provide a cross-reference to the subsequent disclosure of those rights in the Proxy
Statement/Prospectus.

Response: The Registrant will add the following sentence
to the end of the first paragraph of the answer to this question:

There are some material differences with respect to the rights
of shareholders to the Acquired Fund and the Acquiring Fund relating to shareholder derivative actions, exclusive jurisdiction of courts
in Delaware, the waiver of a jury trial, and the rights of certain shareholders to inspect the shareholder list in limited circumstances.
Please see the disclosure in this Proxy Statement/Prospectus at ADDITIONAL INFORMATION ABOUT THE FUNDS under the sub-heading, “Comparison
of Shareholder Rig