SecProbe.io

CORRESP
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    Chicago

New York

Washington, DC

London

San Francisco

Los Angeles

Singapore

Dallas

Miami

vedderprice.com

    May
31, 2024
    Deborah Bielicke Eades

Shareholder

+1 312 609 7661

deades@vedderprice.com

    Via
                            Edgar

        U.S.
        Securities and Exchange Commission

        Division of Investment Management

        100 F Street NE

        Washington, DC 20549

        Attn: Ms. Kim McManus

 Re: SP
                                         Funds 2030 Target Date Fund

                                         SP Funds 2040 Target Date Fund

                                         SP Funds 2050 Target Date Fund (each, a “Fund” and collectively, the “Funds”)

                                         Registration Statement on Form N-1A

                                         File Nos. 333-274015 and 811-23893

Dear
Ms. McManus:

On
behalf of the registrant, SP Funds Trust (the “Registrant”), we are providing supplemental exhibits to our original
May 22, 2024 responses to the Staff’s comments regarding the Registrant’s Post-Effective Amendment No. 1 to the registration
statement on Form N-1A (the “Registration Statement”). Each response is applicable to each of the Funds found in the
Registration Statement. In addition, this filing reflects the completion of all missing information in the Registration Statement
and the filing of all remaining exhibits.

 1. Response:
                                         Attached as Exhibit A is the marked summary prospectus section for the SP Funds 2030
                                         Target Date Fund, which reflect changes made to the summary prospectus section for each
                                         Fund. All changes to the risk section were carried through to similar language in item
                                         9 to the statutory prospectus and the SAI. This disclosure reflects changes made by the
                                         Registrant in response to comments 1, 6, 7, 10 through 14, 16 and 17.

 2. Response:
                                         Attached as Exhibit B is the relevant marked portion of item 9 to the statutory prospectus
                                         for the Funds. This reflects changes made by the Registrant in response to comments 4,
                                         5, 9, 15, 18 and 19.

 3. Response:
                                         Attached as Exhibit C is the marked statement of additional information for the SP Funds 2030 Target Date
                                         Fund. This reflects changes made by the Registrant in response to comment 20.

222 North LaSalle Street | Chicago, Illinois
60601 | T +1 312 609 7500 | F +1 312 609 5005

Vedder Price P.C. is affiliated
with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price
Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.

May 31, 2024

Page 2

If
you have any questions regarding these responses, please contact the undersigned at (312) 609-7661.

Very truly yours,

/s/ Deborah Bielicke Eades

Deborah Bielicke Eades

Shareholder

May 31, 2024

Page 3

EXHIBIT
A

SP FUNDS 2030 TARGET DATE
FUNDDATE FUND – FUND SUMMARY

Investment Objective

The SP Funds 2030 Target Date Fund
(the “Fund” or the “2030 Fund”) seeks a high level of total return through its target date. Thereafter,
the Fund primarily seeks high current income and secondarily capital appreciation.

Fees and Expenses of the Fund

This table describes the fees and
expenses that you may pay if you buy, hold, and sell shares of the Fund (the “Shares”). You may pay other fees,
such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and example below.

    Annual Fund Operating Expenses (Expenses That You Pay Each Year as a Percentage of The
    Investor
    Institutional

    Value of Your Investment)
    Shares
    Shares

    Management Fees(1)
    [•] 0.45%
    [•]0.45%

    Other Expenses
    0.00%
    0.00%

    Distribution and/or Service (12b-1) Fees
    .250.25%
    –

    Shareholder Servicing Fee
    0.15%
    –

    Acquired Fund Fees and Expenses(2)
    [•]0.20%
    [•]0.20%

    Total Annual Fund Operating Expenses
    [•]1.05%
    [•]0.65%

 (1) Under the Investment Advisory
                                                                                              Agreement, the AdvisorFund
                                                                                              pays the Adviser an annual unitary management fee. The Adviser is responsible for substantially all expenses of
                                                                                              each fund share class, including the cost of transfer agency, custody, fund administration, compensation paid to the
                                                                                              Independent Board Members, legal, audit and other services, except for the fee payments to the Advisor under the Investment
                                                                                              Advisory Agreement (also known as a “unitary advisory fee”), interest expense,
                                                                                              and excluding interest charges on borrowings, dividends and other expenses on securities sold short, taxes, brokerage
                                                                                              commissions and other expenses incurred in placing orders for the purchase and sale of securities and other investment
                                                                                              instruments, acquired fund fees and expenses, taxes,
                                                                                              brokerage expensesaccrued deferred tax
                                                                                              liability, distribution fees orand expenses
                                                                                              (if any), and litigation expenses and other non-routine
                                                                                              or extraordinary expenses.

 (2) Because the Fund is new, Acquired Fund Fees and Expenses
are based on estimated amounts for the current fiscal year.

Expense Example

This Expense Example is intended to help
you compare the cost of investing in the Fund with the cost of investing in other funds. The Expense Example assumes that you invest
$10,000 in the Fund for the time periods indicated and then redeem all of your Shares at the end of those periods. The Expense
Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same.
The Expense Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although
your actual costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    Investor Shares
    [•] $107
    [•] $334

    Institutional Shares
    [•] $66
    [•] $208

Portfolio Turnover

The Fund pays transaction costs,
such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover
rate may indicate higher transaction costs and may result in higher taxes when Shares are held in a taxable account. These costs,
which are not reflected in total annual fund operating expenses or in the Expense Example above, affect the Fund’s performance.
Because the Fund is newly offered, portfolio turnover information is not available.

Principal Investment Strategies

The Fund employs an asset allocation
strategy designed for investors who are expecting to retire (assuming a shareholder turns 65 in the year indicated in the Fund’s
name) or who otherwise have a long-term savings objective on or around the specific target year (target date), as indicated in
the Fund’s name, and who are likely to stop making new investments at that time. The Fund is a
diversified investment company that operates as a fund-of-funds.

Under normal conditions, the investment
manager allocates the Fund’s assets among its target asset classes by investing primarily in a distinctly-weighted combination
of other funds (underlying funds), based on each underlying fund's predominant asset class and strategy. The Fund will invest its
assets primarily in underlying funds that follow a Shariah-compliant investment strategy. The Fund

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invests primarily in exchange-traded
funds advised or sub-advised by the investment manager. The affiliated funds in which the Fund currently
may invest include SP Funds S&P 500 Sharia Industry Exclusions ETF, SP Funds Dow Jones Global Sukuk ETF, SP Funds S&P Global
REIT Sharia ETF, SP Funds S&P Global Technology ETF and SP Funds S&P World (ex-US) ETF. The Adviser engages a third party
to certify Shariah compliance for affiliated funds. The Fund may allocate its assets among other third-party funds to
seek exposure to asset classes not offered by the investment manager or when the investment manager determines it is prudent to
do so. Such third-party funds may not follow Shariah principles.

The Adviser uses the following glide path – the target
allocation among asset classes — as the Fund approaches its target date:

    Years To Target Date
    STOCKS
    REAL
    SUKUK
    GOLD
    CASH

    ESTATE

    6 Years to Target Date
    40%
    10%
    43.5%
    2.5%
    4.0%

    43 Years to Target Date
    25.0%
    10.0%
    55.0%
    5.0%
    5.0%

    Target Date
    15.0%
    12.5%
    55.0%
    7.5%
    10.0%

The underlying funds and the percentage
allocations in the glide path may be changed from time to time by the Fund’s investment manager without the approval of shareholders,
and, under normal conditions, the percentage allocations may vary up to [•]5%
from the stated allocations. The target date allocation will apply after the target date and during
the withdrawal period. Shariah principles prohibit investment in certain types of businesses and prohibit investment
in conventional bonds, debentures and other interest-bearing obligations of indebtedness. Accordingly, the Funds will seek exposure
to underlying funds that invest in Sukuk in lieu of conventional interest-bearing instruments and the Fund’s allocation to
cash will not bear interest. Sukuk is a Shariah-compliant financial certificate representing an
interest in underlying assets, which has bond-like characteristicsundivided shares
of ownership of a tangible asset as it relates to a specific project or investment activity.

While the Fund is designed for
investors expecting to retire or reach another savings goal and begin withdrawals around the target date, investors should also
consider other factors, such as their risk tolerance, personal circumstances, legal considerations, tax consequences and status,
complete financial situation and needs and individual goals, some or all of which can change frequently. It is possible to lose
money by investing in the Fund, including at and after the target date. The Fund does not guarantee a level of income or principal
at or after the target date.

Principal Investment Risks

The principal risks of investing in the
Fund are summarized below. As with any investment, there is a risk that you could lose all or a portion of your investment in the
Fund. Some or all of these risks may adversely affect the Fund’s net asset value per share (“NAV”), trading price,
yield, total return, and/or ability to meet its investment objective. For more information about the risks of investing in the
Fund, see the section in the Fund’s Prospectus titled “Additional Information About the Fund—Principal Risks
of Investing in the Fund.”

Principal Risks of the Fund’s Investment Strategies

General Market Risk. Securities
markets and individual securities, such as equity securities, may increase or decrease
in value. Security prices may fluctuate widely over short or extended periods in response to market or economic news and conditions,
and securities markets also tend to move in cycles. If there is a general decline in the securities markets, it is possible your
investment may lose value regardless of the individual results of the companies in which the underlying funds invest. The magnitude
of up and down price or market fluctuations over time is sometimes referred to as “volatility,” and it can be significant.
In addition, different asset classes and geographic markets may experience periods of significant correlation with each other.
As a result of this correlation, the securities and markets in which the underlying funds invest may experience volatility due
to market, economic, political or social events and conditions that may not readily appear to directly relate to such securities,
the securities’ issuer or the markets in which they trade.

Retirement Income Risk.
The Fund does not provide a guarantee that sufficient capital appreciation will be achieved to provide adequate income at and through
retirement. The Fund also does not ensure that you will have assets in your account sufficient to cover your retirement expenses;
this will depend on the amount of money you have invested in the Fund, the length of time you have held your investment, the returns
of the markets over time, the amount you spend in retirement, and your other assets and income sources. Such
risk includes the risk of financial loss, including losses near, or after the Fund’s target date.

Asset Allocation Risk. The
Fund’s ability to achieve its investment goal depends upon the investment manager’s skill in determining the Fund’s
broad asset allocation mix and selecting underlying funds. There is the possibility that the investment manager’s

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evaluations and assumptions regarding asset classes
and underlying funds will not successfully achieve the Fund's investment goal in view of actual market trends.

Investing in ETFs Risk.
The Fund’s investments in ETFs may subject the Fund to additional risks than if the Fund would have invested directly in
the ETFs’ underlying securities. These risks include the possibility that an ETF may experience a lack of liquidity that
can result in greater volatility than its underlying securities or an ETF may trade at a premium or discount to its net asset value;
or, if an index ETF, an ETF may not replicate exactly the performance of the benchmark index it seeks to track. Because the Fund
invests in underlying ETFs, and the Fund’s performance is directly related to the performance of the underlying ETFs held
by it, the ability of the Fund to achieve its investment goal is directly related to the ability of the underlying ETFs to meet
their investment goals. In addition, investing in an ETF may also be more costly than if the Fund had owned the underlying securities
directly. The Fund, and indirectly, shareholders of the Fund, bear a proportionate share of the ETF’s expenses, which include
management and advisory fees and other expenses. In addition, the Fund pays brokerage commissions in connection with the purchase
and sale of shares of ETFs. The cost of investing in the Fund will generally be higher than the cost
of investing directly in an underlying ETF due to its fees and expenses.

Affiliated Funds Risk. In managing
the Fund, the investment manager will have authority to select and substitute underlying funds and ETFs. The investment manager
may be subject to potential conflicts of interest in selecting underlying funds and ETFs because the fees paid to the investment
manager by some underlying funds and ETFs are higher than the fees paid by other