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  April
23, 2025

VIA EDGAR AND EMAIL

U.S. Securities & Exchange Commission

Division of Investment Management

Office of Disclosure Review & Accounting

100 F Street, NE

Washington, D. C. 20549

Attention: Ms.
Christina DiAngelo Fettig

 Re: Catholic Responsible Investment Funds (File No. 811-23718)

Ms. Fettig:

This letter responds to the comments from the Securities
& Exchange Commission (the “SEC”) Staff given by you to Andrew Metzger, Director of Fund Administration at SEI Investments
Global Funds Services (“SEI”), the Administrator to Catholic Responsible Investment Funds (File No. 811-23718) (the “Trust”),
(each a “Fund,” and, collectively, the “Funds”), in a telephone conversation on March 25, 2025. SEI provides the
Trust and the Funds with administrative and accounting services, officers, and other personnel, and submits these responses on behalf
of the Trust and the Funds.

The SEC Staff comments provided relate to:

 a. the Trust’s annual report as of October 31, 2024, as filed on Form N-CSR (the “Form N-CSR
Annual Report”);

 b. the Trust’s annual report as of October 31, 2024, as filed on Form N-CEN (the “Form N-CEN
Annual Report”) (said Form N-CSR Annual Report and Form N-CEN Annual Report hereinafter referred to collectively as the “Reports”);

 c. the corresponding Prospectuses of the certain Funds, as included in the Trust’s Registration Statement
on Form N-1A (the “Registration Statement”); and

 d. related filings of the Trust.

The SEC Staff comments provided specifically relate
to the Funds set forth immediately below, but these comments, to the extent applicable, should be applied to all Funds in the other series
trusts administered by SEI going forward. As indicated above, each of the following thirteen Funds is a series of a Trust:

Catholic Responsible
Investments Ultra Short Bond Fund

Catholic Responsible
Investments Short Duration Bond Fund

Catholic Responsible
Investments Bond Fund

Catholic Responsible
Investments Opportunistic Bond Fund

Catholic Responsible
Investments Equity Index Fund

Catholic Responsible
Investments Small-Cap Fund

Catholic Responsible
Investments Multi-Style US Equity Fund

Catholic Responsible
Investments International Equity Fund

Catholic Responsible
Investments International Small-Cap Fund

Catholic Responsible
Investments Magnus 45/55 Fund

Catholic Responsible
Investments Magnus 60/40 Alpha Plus Fund

Catholic Responsible
Investments Magnus 60/40 Beta Plus Fund

Catholic Responsible
Investments Magnus 75/25 Fund

We have reproduced the substance of your comments
below, followed by the Trust’s corresponding responses.

SEC Comment 1:

The Management’s Discussion of Fund Performance
(“MDFP”) in the Tailored Shareholder Reports (“TSRs”) seems very general by disclosing the Funds’ investment
objectives and strategies and doesn’t really focus on the investment techniques and strategies used by the adviser. In future filings,
please enhance the MDFP. Also, as a reminder if derivatives have a material effect on fund performance, then derivative activity should
be discussed in the MDFP. Reference: Form N-1A Item 27A(d)(1).

Trust Response to Comment 1:

In future filings, the MDFP in the TSRs
for each of the Funds will include the key factors that materially affected the Fund’s performance during the reporting period,
including the relevant market conditions and the investment strategies and techniques used by the Fund’s investment adviser(s).

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SEC Comment 2:

The Schedule of Investments for the Fund of Funds
requires the Schedule of Investments to be categorized by type and also by the related industry, country or geographic region of the investment.
The Fund of Funds of this Trust only categorize the Schedule of Investments by type. Reference: Regulation S-X Article 12-12 Footnote
2.

Trust Response to Comment 2:

In future filings, the Registrant will
update the Fund of Funds’ Schedules of Investments to include the related industry, country or geographic region of the investment
consistent with Reg S-X.

*	*	*	*	*

SEC Comment 3:

In future filings, on the Schedule of Investments
for the Fund of Funds, please disclose the specific class of shares held of your investments in your affiliated and any non-affiliated
Fund of Funds (the underlying funds).

Trust Response to Comment 3:

In future filings, the Registrant will
update the Schedule of Investments to include the specific class of shares held in the affiliated and non-affiliated Funds of Funds.

*	*	*	*	*

SEC Comment 4:

In future filings, if the Schedule of Investments
for the International funds categorize their Schedule of Investments by country, and these Funds also have a significant concentration
of credit risk by industry, then any significant concentration of credit risk by industry should also be disclosed. Reference: FASB ASC
825-10-15.

Trust Response to Comment 4:

In future filings, the Funds will categorize
the Schedule of Investments by country and by industry where a significant concentration of credit risk by industry makes such a further
breakdown appropriate.

*	*	*	*	*

SEC Comment 5:

The Notes to Financial Statements state that money
market sweep accounts are classified as cash. On the Statement of Assets and Liabilities is anything in the cash and cash equivalents
line item an investment in a Money Market Fund or Treasury Bills? If so, those should be disclosed in future filings as investments.

Trust Response to Comment 5:

In funds that have sweep accounts, excess
cash is swept into a bank-controlled account each night by the custodian. The Registrant does not believe such accounts meet the definition
of an investment for purposes of classification on the Financial Statements.

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SEC Comment 6:

In future filings, please update the income from
the securities lending line item on the Statement of Operations to disclose that this income is net of any rebates or fees paid to borrowers.
Please also narratively disclose in the Notes to Financial Statements that securities lending income is net of any such fees.

Trust Response to Comment 6:

In future filings, the Registrant will
update the line item for securities lending income to reflect that it is “net” income and add verbiage in the Notes to Financial
Statements discussing that the income is net of any rebates or fees paid to borrowers.

*	*	*	*	*

SEC Comment 7:

We noted a line item on the Statement of Operations
for Waiver of Administration Fees. However, we did not see any disclosure in the Notes to Financial Statements regarding the terms of
the administration fee waiver. Please disclose in future filings.

Trust Response to Comment 7:

In future filings, a description of
all fee waivers will be included in the Notes to Financial Statements.

*	*	*	*	*

SEC Comment 8:

In future filings, please disclose the accounting
policy for capital gains tax on foreign securities in the Notes to Financial Statements.

Trust Response to Comment 8:

In future filings, the Registrant will
add the accounting policy for capital gains tax of foreign securities in the Notes to Financial Statements.

*	*	*	*	*

SEC Comment 9:

Note 5: The Investment Advisory and Sub-Advisory
Agreements section in the Notes to Financial Statements does not contain updated or correct sub-adviser information for certain funds.
There were some changes for the funds around July 2024 that are not being reflected in this note. Please correct in future filings.

Trust Response to Comment 9:

Updated sub-adviser information reflecting
recent changes in certain funds will be reflected in future filings.

*	*	*	*	*

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©2025 SEI

SEC Comment 10:

In Note 5 on page 122 of the Notes to Financial
Statements, there is reference to a Small-Cap Index Fund but the fund name is the Small-Cap Fund in the Sub-Advisory note. Please update
the fund name in future filings.

Trust Response to Comment 10:

In future filings, the Registrant will
update the fund name in Note 5 of the Notes to Financial Statements.

*	*	*	*	*

SEC Comment 11:

Disclosure in Form N-CEN and the Notes to Financial
Statements Sub-Advisory Note looks like Mercer appears to be hired effective May 21, 2024 as a sub-adviser but this is not identified
in Form N-CEN or in the Notes to Financial Statements as a sub-adviser.

Trust Response to Comment 11:

In future filings, Form N-CEN and the
Notes to Financial Statements will identify Mercer as a sub-adviser for each of the Funds.

*	*	*	*	*

SEC Comment 12:

Form N-CEN for Short Duration Bond Fund indicated
in Item C.7 that the Fund is a limited derivatives user. Please verify accuracy. It appears that the notional amount of futures reflected
in the Fund’s financial statements was greater than 10% of net assets at the reporting date.

Trust Response to Comment 12:

Item C.7 of the 10/31/24 Form N-CEN correctly checks
Items C.7.n. and C.7.i., identifying the CRI Short Duration Bond Fund as a limited derivatives user based on the net derivatives usage
of the Fund after offset hedging positions are considered.

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SEC Comment 13:

In Form N-CEN for the Small-Cap Fund should Item
C.3.b. have been checked? Per the prospectus it appears to track an index.

Trust Response to Comment 13:

The Small-Cap Fund does track the performance
of the S&P SmallCap 600 Index. This item will be checked in future filings of the Fund’s Form N-CEN.

*	*	*	*	*

SEC Comment 14:

Please explain if any of the Fund of Funds should
have checked the box on Form N-CEN Item C.7.l.

Trust Response to Comment 14:

For each of the four “Magnus”
Funds, Item C.7.m. should have been checked in the Form N-CEN filing, as each of these funds is a “Fund of Funds” relying
on Section12(d)(1)G of the 1940 Act. This item will be checked in future filings of the Magnus Funds’ Form N-CEN. None of the other
Funds rely on the Fund of Funds rule.

*	*	*	*	*

SEC Comment 15:

On N-CEN Item C.6.g for the funds that participated
in securities lending, why do the amounts in the N-CEN not agree to net income from securities lending on the Statement of Operations.

Trust Response to Comment 15:

Due to the timing of cash flows from
the security lending agent, the Registrant’s Fund Administrator records securities lending income based on cash received in the
prior month. When material, the securities lending income is adjusted to account for differences between the estimated income and actual
income earned for financial statement purposes. During the preparation of the annual report, the adjustment to securities lending income
was deemed to be immaterial. The amounts presented in the Form N-CEN reflect the actual income earned, rather than the estimated income.

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SEC Comment 16:

In future filings for N-CSR Item 11 Approval of
the Investment Advisory Agreement Disclosure, please include more specificity, especially in the investment performance, fees and expenses
section. The overall disclosure seems very general in nature. This doesn’t appear to meet the specificity requirements of the instruction
of N-CSR Item 11.

Trust Response to Comment 16:

The Trust respectfully believes that
its current disclosure complies with the disclosure requirements of Item 11 of Form N-CSR. In relevant part, Item 11 provides that a registrant
should discuss “in reasonable detail the material factors and the conclusions with respect thereto that formed the basis of the
board’s approval” of an investment advisory agreement. The Trust’s disclosure satisfies this standard.

With respect to performance, the Trust
does not believe that Item 11 requires specific factual statements regarding how a fund, its benchmark and peer group each performed and
how those performances compared. The Trust’s disclosure describes (i) the specific information reviewed by the Board with respect
to the Funds’ performance, which includes a comparison of the Funds’ performance compared against that of a benchmark index
and relevant peer group, and (ii) the Board’s conclusions with respect thereto. The Trust respectfully believes this disclosure
satisfies Item 11’s material factors and conclusions requirements.

With respect to fees and expenses, Item
11 further provides that, if a board relied upon comparisons of the amounts to be paid under the advisory agreement, the registrant should
“describe the comparisons and how they assisted the board in concluding that the contract should be approved.” The Trust’s
disclosure describes the comparisons the Funds’ board used to evaluate fees paid under the investment advisory and sub-advisory
agreements, where such comparisons included “reports prepared by the Funds’ administrator comparing the Funds’ net and
gross expense ratios and advisory fees to those paid by peer groups of mutual funds as classified by Lipper” and “the management
fees charged by the Adviser and applicable Sub-Advisers to other clients with comparable mandates.” The disclosure further notes
that these comparisons, among other things, assisted the Board in concluding “that the advisory fees were reasonable in light of
the nature and quality of the services rendered by the Adviser and the Sub-Advisers.” The Trust respectfully believes that this
disclosure satisfies the requirements of Item 11.

Notwithstanding the foregoing, going
forward the Trust will continue to work with fund counsel to evaluate the disclosure of the “Board Considerations in Approving the
Advisory Agreement” and determine whether additional specificity or other disclosure changes should be made.

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©2025 SEI

Please contact Andrew Metzger at either (610) 676-2965
or ametzger@seic.com if you have any questions or comments.

    Very truly yours,

    /s/ Andrew Metzger

    Andrew Metzger

    Principal Financial Officer

Catholic Responsible Investment Funds

 cc: Michael Beattie

Stephen Panner

Alexander Smith

 Matthew Maher

Melissa Hanobeck

John J. O’Brien, Esq., Morgan Lewis & Bockius

David Freese, Esq., Morgan Lewis & Bockius

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©2025 SEI