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Exchange Place Advisors Trust

c/o Ultimus Fund Solutions, LLC

225 Pictoria Drive, Suite 450

Cincinnati, OH 45246

December 30, 2025

VIA EDGAR CORRESPONDENCE

Brian Szilagyi

Staff Accountant

U.S. Securities and Exchange Commission

Division of Investment Management, Disclosure Review
and Accounting Office

100 F Street, N.E.

Washington, D.C. 20549

 Re: Exchange Place Advisors Trust (the “Trust” or the “Registrant”)

File Nos. 333-226989; 811-23373

Dear Mr. Szilagyi:

In a telephone conversation with Stacy H. Louizos.
Esq., Trust Counsel, and Zachary P. Richmond, Treasurer of the Trust, on December 5, 2025, you communicated the U.S. Securities and Exchange
Commission (the “SEC”) staff’s (the “Staff”) comments on the Trust’s Form N-CSR/A filed on August
11, 2025 and the Trust’s Form N-CEN filed on August 14, 2025, each under the Investment Company Act of 1940, as amended (the “1940
Act”), on behalf of its series (each, a “Fund” and together, the “Funds”). A summary of the Staff’s
comments, along with the Registrant’s responses, is set forth below.

Comment 1. The Staff notes that Item
C.7.k of Form N-CEN is checked for the North Square RCIM Tax-Advantaged Preferred and Income Securities ETF (the “Fund”).
Please discuss in correspondence why the Fund is not presenting information on its website in compliance with Rule 6c-11(c)(i)-(vi) under
the 1940 Act.

Response.  The Registrant respectfully
submits and confirms that the information required by each item under Rule 6c-11(c)(i)-(vi) under the 1940 Act is on the Fund’s
website at https://northsquareinvest.com/strategies/tax-adv-preferred-etf/.

Comment 2. In the Financial Highlights
for any Funds that are “funds of funds,” please add a footnote to the net investment income ratios stating that the ratios
do not reflect the proportionate share of income and expenses of the underlying funds in which the Funds invest. See ASC 946-205-50-16.

Response. The Registrant acknowledges
the Staff’s comment and will add a footnote to the net investment income ratios stating that the ratios do not reflect the proportionate
share of income

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and expenses of the underlying funds in which the
Funds that are “funds of funds” invest in future financial statements.

Comment 3. The Staff notes that, in
Note 15 to the Financial Statements (Business Combinations), it is reported that the North Square Small Cap Value Fund (the “New
Fund”) is the accounting survivor of the reorganization of the New Fund with the Foundry Partners Small Cap Value Fund (the “Predecessor
Fund”) (the “Reorganization”), while the Form N-14 filed with the SEC on March 14, 2025 describing such Reorganization
disclosed that the Predecessor Fund is the accounting survivor of the Reorganization. Please explain the apparent discrepancy.

Response. The Registrant confirms that
the Predecessor Fund is the accounting survivor of the Reorganization and that Note 15 to the Financial Statements contains an error.
The Registrant notes that, in Note 1 to the Financial Statements (Organization), it is correctly disclosed that the Predecessor Fund is
the accounting survivor of the Reorganization.

Comment 4. The Staff notes that, in
Note 1 to the Financial Statements (Organization), it is reported that each Fund operates as a single operating segment and that each
Fund’s income, expenses, assets, and performance are regularly monitored and assessed as a whole by North Square Investments, LLC
(the “Adviser”), who is responsible for the oversight functions of each Fund, using the information presented in the financial
statements and financial highlights. Please explain how all personnel at the Adviser are considered a “group” for purposes
of determination of the Chief Operating Decision Maker.

Response. The
disclosure stating each Fund operates as a single operating segment is intended to describe that each Fund’s investment results
are monitored and evaluated on a fund-specific and fund-wide basis and that each Fund does not have separate components or activities
that would be evaluated independently. The disclosure is not intended to suggest that the Adviser operates as a “group” within
the meaning of ASC 280, nor that the Adviser is being identified as a chief operating decision maker for segment-reporting purposes.

The Adviser’s role is
limited to providing investment management services to each Fund, and the Fund’s income, expenses, assets, and performance are reviewed
as a whole using the information presented in such Fund’s financial statements and financial highlights. Because each Fund is a
single reporting entity with at most one operating segment, certain concepts in ASC 280 relating to operating segments, groups, or aggregation
are not applicable.

To avoid any potential misunderstanding,
the Registrant will revise future disclosures to add or clarify language that could be interpreted as referencing ASC 280 concepts, including
the following:

“The Funds have adopted Financial Accounting
Standards Board (“FASB”) Accounting Standards Update 2023-07, Segment Reporting (Topic 280) - Improvements to Reportable Segment
Disclosures. Adoption of the standard impacted financial statement disclosures only and did not affect each Fund’s financial position
or the results of its operations. An operating segment is defined in Topic 280 as a component of a public entity that engages in business
activities

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from which it may recognize revenues and incur
expenses, has operating results that are regularly reviewed by the public entity’s chief operating decision maker (“CODM”)
to make decisions about resources to be allocated to the segment and assess its performance, and has discrete financial information available.
The CODM is the President and Principal Executive Officer of the Trust. Each Fund operates as a single operating segment. Each Fund’s
income, expenses, assets, changes in net assets resulting from operations and performance are regularly monitored and assessed as a whole
by the CODM responsible for oversight functions of each Fund, using the information presented in the financial statements and financial
highlights.”

Comment 5. Please explain, given the
amount of tax claims receivable noted in the Statements of Assets and Liabilities for the North Square Altrinsic International Equity
Fund (the “Fund”), from which countries foreign dividend taxes have been withheld from the Fund and how such reclaims are
monitored and collected.

Response. The countries that were the
sources of the Fund’s tax reclaims as of May 31, 2025 were Belgium, Brazil, Switzerland, Germany, Spain, France, Ireland, Japan
and Sweden. Ultimus Fund Solutions, LLC (“Ultimus”), the administrator and fund accountant for the Fund, has established procedures
related to tax reclaims that are designed to ensure that tax reclaims are properly identified, documented, submitted and monitored. Under
these procedures, the Fund’s investment adviser or the Fund’s custodian/sub custodian are responsible for identifying reclaim
opportunities and providing necessary transaction data. Ultimus is responsible for calculating reclaim amounts, recording receivables,
and maintaining related books and records. The Fund’s custodian or sub-custodian is responsible for submitting tax reclaim documentation
to the applicable taxing authorities or tax agents, unless otherwise delegated. In practical terms, as dividends are accrued, Ultimus’
accounting system also records tax reclaims receivable amounts based on tax rates entered in a tax master table. Periodically, usually
quarterly, Ultimus will request a tax reclaim report from the global custodian or tax reclaim agent and, based on that information, will
reconcile and/or if needed, make adjustments to the books. Any material differences are researched with the custodian and the Fund’s
investment adviser.

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We believe that the foregoing has been responsive
to the Staff’s comments. Please call the undersigned at 513-577-1693 if you wish to discuss this correspondence further.

Sincerely,

/s/ Karen Jacoppo-Wood

Karen Jacoppo-Wood

Secretary

cc: 	     M. Dean, Northern Lights Compliance Services,
LLC

S. Louizos, Esq., Blank Rome LLP

Z. Richmond, Treasurer of the
Trust

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