SecProbe.io

CORRESP
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October 24, 2023

Alison
T. White

Senior
Counsel

Division
of Investment Management

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Elevation
Series Trust; File Nos. 333-265972, 811-23812

Dear
Ms. White:

On
February 16, 2023, Elevation Series Trust (the “Trust” or “Registrant”) filed an amendment to its Registration
Statement under Form N-1A pursuant to the Securities Act of 1933 and the Investment Company Act of 1940 on behalf of SRH REIT Covered
Call ETF (the “Fund”).

The
Trust has revised the disclosures in the Fund’s prospectus, statement of additional information, and Part C in response to comments
given by you via telephone to Daniel Moler on March 27, 2023. Those comments are summarized below, with corresponding responses following
each comment, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Capitalized terms used but not otherwise defined
herein have the meanings ascribed to them in the document to which the applicable comment relates.

General

Comment
1. Please advise supplementally what or who “SRH” is and why it is included in the Fund’s name.

Response.
The Fund is part of the SRH Fund Family, which also includes SRH Total Return Fund, Inc. and the SRH U.S. Quality ETF. Each SRH Fund
is advised by Paralel Advisors LLC and sub-advised or tracks an index provided by Rocky Mountain Advisers, LLC (“RMA”). The
“SRH” in the Fund’s name is intended to honor the founder and former portfolio manager of RMA.

Principal
Investment Strategies of the Fund

Comment
2. Please clarify what is meant by “organic net operating income growth” and “purported investment strategy.”

Response.
As shown in the response to Comment 4, “organic net operating income growth” is defined as the net operating income
growth attributable to the REIT’s existing businesses, excluding any income derived as a result of corporate activities, such as
mergers and asset acquisitions.

Comment
3. “In building the portfolio of approximately 20 to 30 REITs, RMA emphasizes REIT subsectors it believes will outperform the
broad REIT market in the U.S. during the next several years.”

JoAnn.Strasser@ThompsonHine.com
Fax: 614.469.3361 Phone: 614.469.3265

October
24, 2023

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 a. Please
                                            provide examples of REIT subsectors and disclose any specific REIT subsectors you intend
                                            to focus in. Additionally, consider the need for tailored risk disclosure (for example, if
                                            the Fund is investing in office REITs, work from home could be a risk).

 b. Please
                                            explain how RMA forms its views on subsectors that may outperform the broad REIT market.

Response.

 a. As
                                            shown in the response to Comment 4, examples of REIT subsectors include residential, self-storage,
                                            infrastructure, and office. The Fund does not intend to focus in any specific REIT subsectors.

 b. As
                                            shown in the response to Comment 4, RMA forms its views on REIT subsectors in the context
                                            of prevailing macroeconomic and industry trends.

Comment
4. Please clarify in plain English what is meant by “…REITs will be called away…”

Response.
The disclosure has been revised as follows:

REIT
Portfolio

Rocky
Mountain Advisers, LLC (“RMA”), a sub-adviser to the Fund, will select approximately 20-30 REITs
selected for inclusion in the Fund’s portfolio are
chosen based on several quantitative and qualitative factors identified
by Rocky Mountain Advisers, LLC (“RMA”), a sub-adviser to the Fund, to isolate candidates with
likely to provide long-term capital appreciation and consistent
increases in annual distributions growth.
These factors include the REIT’s organic net operating income growth,
management’s incentives and experience, the purported investment strategy, (defined
as the net operating income growth attributable to the REIT’s existing businesses, excluding any income derived as a result of
corporate activities, such as mergers and asset acquisitions), the estimated fair value of its underlying real estate properties,
the quality of it’s the underlying real estate
properties, and the estimated fair value of the underlying real estate properties RMA’s
assessment of the REIT’s managerial team’s investment strategy (i.e. management’s stated strategy in regards to the
management and operation of the REIT’s portfolio), experience, and alignment of incentives with that strategy. In addition
building the portfolio of approximately 20-30 REITs, RMA emphasizes
considers the REIT’s subsectors
it believes will outperform the broad REIT market focus (such as residential, self-storage,
infrastructure, office, etc.) in the context of prevailing macroeconomic and industry trends when
selecting REITs for the Fund’s portfolio U.S. during the next several years. These subsectors
are intentionally overweight relative to the Fund’s benchmark.

REITs
may be sold when RMA observes a major significant
negative change in one of the selection factors such as a change in management or management strategy, the organic growth slows, or the
valuation of the underlying assets declines. At times REITs will be called away because of Additionally,
in connection with the option strategy discussed described
below, a REIT may be sold if a call option written by the Fund on that specific REIT is
exercised.

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24, 2023

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Option
Strategy

Comment
5. In the first sentence, define “REIT Portfolio” or use a lowercase “p” in portfolio.

Response.
The Registrant has made the requested revisions as shown in response to Comment 6.

Comment
6. In the first sentence of the subsection “Call Options,” replace the word “investor” with the word “Fund.”

Response.
The Registrant has made the following revisions:

Option
Strategy

The
Fund also employs an option strategy by writing U.S. exchange-traded covered call options on select securities in the REIT Portfolio
portfolio with the goal of generating additional income and selective repurchase
of such options. A call option written (sold) by the Fund gives the holder (buyer) the right to buy a certain security at a predetermined
strike price from the Fund. The strategy generates income for the Fund from the price (premium) paid by the buyer for the option contract.
The intention of the Fund is to reduce risk and enhance total return by tactically selling call options on some or all of the securities
in the REIT portfolio. The call options may not correspond to approximately 100% of the value of the securities held by the Fund, therefore
representing a partially covered strategy. The Fund is not obligated to write call options on every REIT in the portfolio and at times,
it may have very few call option positions. RMA determines to sell a covered call on a particular security based on a variety of criteria,
including, but not limited to, the premiums available, liquidity of the option contract or underlying REIT, the prospective capital appreciation
of the security, and the market environment. The call options written (sold) may either be traditional exchange-listed options or FLexible
EXchange (“FLEX”) options. The implications of the written (sold) FLEX call options are describe in more detail here:

Call
Options – When the Fund an investor sells
a call option, the Fund investor receives a premium
in exchange for an obligation to sell shares of a reference asset at a strike price on the expiration date if the buyer of the call option
exercises it. If the reference asset closes above the strike price as of the expiration date and the buyer exercises the call option,
the investor Fund will have to pay the difference
between the value of the reference asset and the strike price. If the reference asset closes below the strike price as of the expiration
date, the call option may end up worthless and the investor Fund
retains the premium.

FLEX
Options – FLEX options are options guaranteed by the Options Clearing Corporation (OCC), that allow investors to customize key
contract terms, including expiration date, exercise style, and exercise price, and expanded position limits. Because FLEX options may
not trade regularly, a model-based valuation for the FLEX options that references the quoted prices for listed options may be used to
value the FLEX options.

Principal
Risks of Investing in the Fund

Comment
7. With respect to “Real Estate Investment Risk,” please be more specific about the real estate investment risks here.
For example, what trends or conditions might cause a decline a real estate values or a REITs’ cash flows? How sensitive are REITs
to interest changes and why? For example, are REITs leveraged such that an increase in interest rates would cause a decline in their
distribution, etc.? What current economic or demographic trends are likely to impact the types of REITs you will focus on? Please revise
as appropriate.

October
24, 2023

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Response.
The Registrant has revised the disclosure as follows:

Real
Estate Investment Risk. The Fund concentrates its investments in real estate companies and companies
related to the real estate industry such as REITs. As such, the Fund is subject to
risks associated with the direct ownership of real estate securities and an investment in the Fund will be closely linked to the performance
of the real estate markets. These risks include, among others: declines in the value of real estate; risks related to general and local
economic conditions; possible lack of availability of mortgage funds or other limits to accessing the credit or capital markets; defaults
by borrowers or tenants, particularly during an economic downturn; and changes in interest rates. Real estate
is highly sensitive to general and local economic conditions and developments and is characterized by intense competition and periodic
overbuilding. Many real estate companies, including REITs, utilize leverage (and some may be highly leveraged), which increases investment
risk and the risk normally associated with debt financing, and could potentially magnify the Fund’s losses.

Concentration
Risk. Real estate companies may own a limited number of properties and concentrate their investments in a particular geographic region
or property type.

Equity
REITs Risk. Certain REITs may make direct investments in real estate, often referred to as “Equity REITs.” Equity REITs
invest primarily in real properties and earn rental income from leasing those properties, and may realize gains or losses from the sale
of properties. Equity REITs will be affected by conditions in the real estate rental market and by changes in the value of the properties
they own. A decline in rental income may occur because of extended vacancies, limitations on rents, the failure to collect rents, increased
competition from other properties or poor management. Equity REITs also can be affected by rising interest rates, discussed below.

Interest
Rate Risk. Rising interest rates could result in higher costs of capital for real estate companies, which could negatively affect
a real estate company’s ability to meet its payment obligations. Declining interest rates could result in increased prepayment
on loans and require redeployment of capital in less desirable investments by such real estate company. Rising interest rates may cause
investors to demand a high annual yield from future distributions that, in turn, could decrease the market prices for such REITs. Because
many real estate projects are dependent upon receiving financing, this could cause the value of the REITs in which the Fund invests to
decline.

Leverage
Risk. Real estate companies may use leverage (and some may be highly leveraged), which increases investment risk and the risks normally
associated with debt financing, and could adversely affect a company’s operations and market value in periods of rising interest
rates. Financial covenants related to a real estate company’s leveraging may affect the ability of it to operate effectively.

Liquidity
Risk. Investing in real estate companies may involve risks similar to those associated with investing in small-capitalization companies.
There may be less trading in real estate company shares, which means that buy and sell transactions in those shares could have a magnified
impact on share price, resulting in additional and significant volatility. In addition, real estate is relatively illiquid and, therefore,
a real estate company may have a limited ability to vary or liquidate its investments in properties in response to changes in economic
or other conditions.

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Operational
Risk. Real estate companies are dependent upon management skills and may have limited financial resources. Real estate companies
are generally not diversified and may be subject to heavy cash flow dependency, default by borrowers and self-liquidation. A real estate
company may also have joint ventures in certain of its properties and, consequently, its ability to control decisions relating to such
properties may be limited.

Property
Risk. Real estate companies may be subject to risks relating to functional obsolescence or reduced desirability of properties; extended
vacancies due to economic conditions and tenant bankruptcies; catastrophic events such as earthquakes, hurricanes, tornadoes and terrorist
acts; and casualty or condemnation losses. Real estate income and values also may be greatly affected by demographic trends, such as
population shifts, changing tastes and values, or increasing vacancies or declining rents resulting from legal, cultural, technological,
global or local economic developments.

Regulatory
Risk. Real estate income and values may be adversely affected by applicable domestic laws (including tax laws). Government actions,
such as tax increases, zoning law changes or environmental regulations also may have a major impact on real estate.

Repayment
Risk. The prices of real estate company securities may drop because of the failure of borrowers to repay their loans, poor management,
or the inability to obtain financing either on favorable terms or at all. If the properties do not generate sufficient income to meet
operating expenses, including, where applicable, debt service, ground lease payments, tenant improvements, third-party leasing commissions
and other capital expenditures, the income and ability of the real estate companies to make payments of interest and principal on their
loans will be adversely affected.

U.S.
Tax Risk. Certain U.S. real estate companies, such as REITs, are subject to special U.S. federal tax requirements. A REIT that fails
to comply with such tax requirements may be subject to U.S. federal income taxation, which may affect the value of the REIT and the characterization
of the REIT's distributions. The U.S. federal tax requirement that a REIT distributes substantially all of its net income to its shareholders
may result in the REIT having insufficient capital for future expenditures.

Additional
Information About the Fund’s Principal Risks

Comment
8. In the second paragraph of “Equity Market Risk,” please update the disclosure about interest rates. If interest rates
or other market or economic conditions are likely to present unique risks to the types of REITs you will invest in, revise to provide
tailored disclosure addressing such risk.

Response.
The Registrant has added “Interest Rate Risk” as a sub-bullet of “Real Estate Investment Risk” (as shown
in the response to Comment 7) and amended “Equity Market Risk” as follows:

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Equity
Market Risk. Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in val