SecProbe.io

CORRESP
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November
27, 2024

Ms.
Rebecca Marquigny

Division
of Investment Management, Disclosure Review Office

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. Marquigny:

On
September 30, 2024, 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 The Opal International
Dividend Income 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 videoconferencing to Daniel Moler on November 11, 2024. 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.

 Comment
                            1. We
note the Fund name includes “Opal” for Opal Capital LLC but does not include the name of TrueMark. Please supplementally
confirm that the Fund is not operating under a Manager of Managers Order. Otherwise, insert TrueMark before Opal in the Fund name. If
the Fund is not operating under the Manager of Managers order, confirm that shareholder approval is needed for changing the sub-adviser.

 Response. The
                                            Registrant confirms that the Fund is not operating under a Manager of Managers Order and
                                            would seek shareholder approval to change the sub-adviser.

 Comment
                            2. The
investment objective of the Fund lacks appropriate context. In the principal investment strategy section, briefly tell investors what
this MSCI ACWI Ex-US High Dividend Yield Total Return Index is and describe the volatility and dividend yield that it measures.

 Response. The
                                            Registrant has added the following disclosure in the summary and statutory prospectus:

“The
MSCI ACWI ex USA High Dividend Yield Total Return Index (the “Index”) referenced in the objective of the Fund is designed
to reflect the performance of equities in the MSCI ACWI ex USA (excluding REITs) with higher dividend income and quality characteristics
than average dividend yields that are both sustainable and persistent. The Index also applies quality screens and reviews 12-month past
performance to omit stocks with potentially deteriorating fundamentals that could force them to cut or reduce dividends.”

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

November
27, 2024

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 Comment
                            3. Please
include the final fee table in the response. We may have additional comments.

 Response. The
                                            Registrant has included the final fee table in the revised prospectus.

 Comment
                            4. In
the first footnote to the fee table, there is a list of expenses excluded from the unitary fee. Please confirm excluded expenses will
total less than one basis point or reflect them under “Other Expenses” in the table and recalculate the expense examples
accordingly.

 Response. The
                                            Registrant confirms that excluded expenses will total less than one basis point.

 Comment
                            5. The
principal risk disclosure indicates that the Fund is non-diversified but there is no supporting strategy disclosure. Please disclose
this in the principal strategy sections.

Also,
the risk factors note the Fund will invest in emerging markets, underlying ETFs, and unsponsored ADRs and GDRs. If correct, disclose
each of these in the principal strategy narratives (or remove risk references if it is not a principal risk).

 Response. The
                                            Registrant has added the following disclosure to the principal investment strategy sections:

“The
Fund is classified as a “non-diversified” investment company under the Investment Company Act of 1940, as amended, which
means that the Fund may invest a higher percentage of its assets in a fewer number of issuers than is permissible for a “diversified”
fund.”

The
Registrant has revised the disclosure as follows to clarify that the Fund may invest in emerging markets:

“The
Fund invests at least 40% of its net assets in securities of companies that are economically tied to a country or countries outside the
U.S., including emerging markets, meaning the company…”

The
Registrant confirms that the Fund will not be investing in Underlying ETFs as part of its principal strategy and has removed any disclosure
suggesting as much.

The
Registrant confirms that the Fund may invest in unsponsored and/or sponsored ADRs and GDRs and has revised the disclosure as follows:

“The
Fund typically invests in non-U.S. companies through sponsored and/or unsponsored American Depositary
Receipts (“ADRs”) and Global Depositary Receipts (“GDRs”)…”

November
27, 2024

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 Comment
                            6. Please
enhance the Item 9 Principal Investment Strategies section to address how the sub-adviser determines management team quality and what
constitutes a competitive advantage. Additionally, please revise the disclosure to more fully describe the metrics for measuring sustainable
dividends, competitive advantage, and valuation that offers opportunities to generate above average returns.

 Response. The
                                            Registrant has revised the Item 9 principal investment strategy disclosure as shown below:

The
sub-adviser makes its initial identification of potential portfolio securities based on what it believes are
“high quality companies,” which are generally defined as companies (i) having a sustainable competitive advantage relative
to the broader market of dividend-paying companies, (ii) offering stable and growing free cash flows; and (iii) with quality management
teams that possess the capital discipline to distribute dividends to shareholders. its assessment
of a company’s ability and commitment to sustain and grow its dividends. The sub-adviser seeks to identify such
companies by utilizing a combination of quantitative and qualitative indicators of the company’s financial position, growth opportunities,
historical payouts, and management commentary, as well as the competitive landscape. The quality of a management
team is a subjective determination made by the sub-adviser regarding the likelihood that leadership will manage the company with the
interests of shareholders in mind, which involves analyzing past actions of management and/or management commentary. This process leads
to a list of companies the sub-adviser believes are able and committed to sustaining and growing their dividends.

The
sub-adviser then reviews the current market valuation of these companies that to determine
which ones it believes are under-valued. The sub-adviser first identifies “high quality
companies,” which are generally defined as companies with a sustainable competitive advantage, offering stable and growing free
cash flows, and quality management teams that have the capital discipline to distribute dividends to shareholders. The
sub-adviser then selects companies whose stock is trading at a valuation that it believes offers an opportunity to generate above average
returns over time. When valuing a company, tThe sub-adviser
utilizes a variety of metrics (e.g., including price
compared to earnings ratio, price to tangible book value, price to book value, enterprise value to EBITDA,
market capitalization compared to book value, free cash flow yield, etc.) in the valuation process
and seeks to identify. The Fund invests in the companies
that are attractively priced both in absolute terms and relative to their peers with a preference of companies with higher free cash
flow.

Principal
Risks of Investing in the Fund

 Comment
                            7. In
“Active Management Risk,” please directly discuss the role of human error by individual portfolio managers. Specifically,
that portfolio managers may make poor and incorrect decisions. They may (1) rely on poorly chosen, ineffective, investment techniques
and risk analyses or (2) apply poor judgment to otherwise effective investment techniques and analyses methods. Directly state that investors
can lose money as result.

November
27, 2024

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4

 Response. The
                                            Registrant has revised the Item 4 and Item 9 risk disclosures as follows:

“Active
Management Risk. The adviser’s and sub-adviserportfolio
manager’s judgments about
an investment may prove to be incorrect because the portfolio manager applies poor judgment to otherwise
effective investment techniques or relies on ineffective investment techniques and analyses. or
There is no guarantee that the portfolio manager’s judgment will produce the desired fail
to have the intended results.,
which This could adversely impact the Fund’s performance
and cause investors to lose money as a result.”

“Active
Management Risk. The ability of the Fund to meet its investment objective is directly related to
the sub-adviser’s investment process, and there is no guarantee that the process will achieve the Fund’s objective. The
portfolio manager’s reliance on the Fund’s strategy
or the portfolio manager’s judgement about the attractiveness, value, and potential appreciation
of an investment may prove to be incorrect. The portfolio manager’s assessment of the relative value of securities, their attractiveness
and potential appreciation of particular investments in which the Fund invests may prove to be incorrect or the portfolio manager may
rely on ineffective investment techniques, analyses, and processes when assessing potential investments. is
subject to the risk that its investment management strategy may not product the intended results. There
can be no assurance that the securities selected by the adviser and/or sub-adviser will produce positive returns. As
a result, you could lose money by investing in the Fund.”

 Comment
                            8. The
“Dividend Paying Risk” discusses low priced securities. Please clarify what this means. For example, low priced relative
to what? Also, revise the last sentence of risk to tell investors the harm they may sustain if a company eliminates or reduces its dividend.

 Response. Upon
                                            further review, the Registrant has determined that the sentence about “low priced securities”
                                            is not relevant to the Fund’s strategy and that the last sentence of the risk disclosure
                                            is redundant of what is stated in the first sentence. Accordingly, the Registrant has revised
                                            the disclosure as follows:

“While
the Fund may hold securities of companies that have historically paid a high dividend yield, those companies may reduce or discontinue
their dividends, reducing the yield of the Fund. Low priced securities in the Fund may be more susceptible
to these risks. Past dividend payments are not a guarantee of future dividend payments. Also, the market return of high
dividend yield securities, in certain market conditions, may perform worse than other investment strategies or the overall stock market.
The Fund’s emphasis on dividend-paying companies involves the risk that such companies may fall out of favor with investors and
underperform the market. Also, a company may reduce or eliminate its dividend.”

 Comment
                            9. If
the “Early Close/Trading Halt Risk” is correct, please clarify that this risk is anticipated in relation to investments traded
on foreign or emerging markets. If it is not correct, please revise to explain the origin of the risk.

November
27, 2024

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 Response. The
                                            Registrant respectfully declines to clarify that this risk relates to investments traded
                                            on foreign or emerging markets. The Fund may invest in a foreign company whose securities
                                            trade on a U.S. exchange if, for example, the company derives more than 50% of total revenues
                                            or earnings from goods produced, sales made, or services provided outside of the U.S. Furthermore,
                                            the Fund is only required to invest 40% of its net assets in securities of companies that
                                            are economically tied to a country or countries outside the U.S., meaning the rest of the
                                            Fund’s assets may be investments in companies that are economically tied to the U.S.
                                            Thus, this risk factor applies to U.S. and foreign exchanges and investments.

 Comment
                            10. Please
revise “Foreign Exchange Risk” to explain the practical effect in more concrete common language. If this means price swings
for foreign exchange products may be way larger than for domestically traded holdings, say it so that people understand they can lose
a significant portion or all of their investment as a result.

 Response. The
                                            Registrant has revised the disclosure as follows:

“Foreign
Exchanges Risk. Because some securities held by the Fund may trade on foreign exchanges that may
be closed when the Fund’s primary listing exchange is open, there are likely to be deviations between the current price of a security
and the security’s last quoted price from the closed foreign market. This may result in premiums and discounts that are greater
than those experienced by domestic ETFs. If events materially affecting the value of a security in the Fund’s
portfolio occur after the close of trading on a foreign market, an investor who purchases shares of the Fund on the secondary market
before the Fund prices its shares to reflect the fair value of the security may have purchased such shares at a premium or discount to
NAV (depending on whether the events were positive).”

 Comment
                            11. We
note there is no reference to cybersecurity risk or temporary defensive investments. Please revise to address these omissions.

 Response. The
                                            Registrant has added “Cybersecurity Risk” in the Items 4 and 9 risk disclosures
                                            and added “Temporary Defensive Positions” to the Item 9 strategy disclosure.

 Comment
                            12. Based
on the Fund’s anticipated holdings, please consider whether to update the “Market and Geopolitical Risk” with references
to the Russia-Ukraine war and current Israel/Palestine conflict in the Middle East.

 Response. The
                                            Registrant has revised the Item 9 risk disclosure follows:

Market
and Geopolitical Risk. The increasing interconnectivity between global economies and financial markets increases the likelihood that
events or conditions in one region or financial market may adversely impact issuers in a different country, region or financial market.
Securities in the Fund’s portfolio may underperform due to inflation (or expectations for inflation), interest rates, global demand
for particular products or resources, natural disasters, climate change and climate-related events, pandemics, epidemics, terrorism, international
conflicts, regulatory events and governmental or quasi-governmental