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ALTI Private
Equity Access and Commitments Fund

December 13, 2023

VIA EDGAR AND
OVERNIGHT MAIL

Ryan Sutcliffe,
Esq.

Division of Investment
Management

U.S. Securities
and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: ALTI
                                            Private Equity Access and Commitments Fund (the “Fund”)

Registration Statement
                                            on Form N-2 File Nos. 333-235545, 811-23501

Dear Mr. Sutcliffe:

This
letter is in response to oral comments received from the staff (the “Staff”) of the Securities and Exchange Commission
(the “SEC”) regarding a Registration Statement on Form N-2 (the “Registration Statement”) relating
to the Fund.

The
following sets forth the Staff’s comments and the Fund’s responses thereto.

 1. Please
include a legality opinion for the new Class I shares as an exhibit to the Registration Statement.

The
Fund has updated the Registration Statement as requested to include a legality opinion as an exhibit.

 2. Please
add a parenthetical or sentence explaining what is a continuation vehicle on the cover (third paragraph) of the Registration Statement.

The
Fund has updated the Registration Statement as requested.

 3. Please
discuss supplementally why the Fund may need to retain portions of distributions following liquidations of PE investments in light of
the Fund’s sub-advisory and/or money market allocations.  Are present shareholders aware of this potential retention or is
this filing their first notice?  Please disclose what percentages the Adviser anticipates requesting for retention from the board.

The
Fund may need to retain portions of the distributions for a variety of reasons such as: (a) to cover ongoing liquidirty requirements
to cover expenses, fees and shareholder redemptions, (b) to maintain an appropriate balance of investments to ensure compliance with
the 80% naming rule or (c) to maintain appropriate diversification of investments under the 1940 Act requirements. Since it is difficult
to predict timing of the Private Equity distributions, it may be necessary to retain a portion of those distributions to ensure the portfolio
remains appropriately balanced and able to meet its obligations. The Fund hereby confirms to the Staff that the Fund’s existing
shareholders are aware of this policy and have not objected.

The
Fund has updated the Registration Statement as requested to disclose a percentage.

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 4. Please
include the following retained distribution language at the bottom of page 2 of the Registration Statement:  The
Adviser may need to retain some of the distributions to ensure adequate cash flow for fees, expenses, redemptions or other liabilities
of the Fund. Any retained amount will be subject to approval by the Fund’s Board of Trustees (the “Board”).

The
Fund has updated the Registration Statement as requested.

 5. Please
reconcile the following sentence with the repurchase disclosure included elsewhere in the Registration Statement that does not have such
a requirement: The Fund is only required
to conduct tender offers twice annually; therefore, the Fund may be less likely to conduct tenders during periods of exceptional market
conditions.

The
Fund has updated the Registration Statement as requested.

 6. The
Staff requests removal of footnote 6 to the Fee table.

The
Fund has updated the Registration Statement as requested.

 7. Please
revise to note any applicable early repurchase fee in the following sentence on page 44 of the Registration Statement: The
Fund does not impose any charges in connection with repurchases of Shares.

The
Fund has updated the Registration Statement as requested.

 8. Please
clarify in disclosure that in-kind distributions of securities, if any, would be pro rata or at the investor’s election in the
following sentence on page 45 of the Registration Statement: Although the amounts required to be paid by the Fund for
the tendered Shares will generally be paid in cash, the Fund may under certain limited circumstances pay all or a portion of the amounts
due by an in-kind distribution of securities.  Please also explain in the disclosure what limited circumstances means.

The
Fund has updated the Registration Statement as requested.

 9. On
page 40 of the SAI, please clarify or revise the reference to “Investment Manager.”

The
Fund has updated the Registration Statement as requested.

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Should
you have any questions regarding this letter, please contact me at (212) 506-2176.

Sincerely,

/s/ Brian
D. Hirshberg

Brian
D. Hirshberg, Esq.

Cc: Joseph
Bonvouloir

Anna T.
Pinedo, Mayer Brown LLP

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