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CORRESP
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August 23, 2024

VIA EDGAR

David P. Mathews
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re:          New Age Alpha Funds Trust (the “Trust”)
File Nos. 333-277581; 811-23945

Dear Mr. Mathews,

On June 20, 2024, the Trust filed the above-referenced
registration statement on Form N-1A (the “Registration Statement”) for the NAA Allocation Fund, NAA Large Cap Value Fund,
NAA Large Core Fund, NAA Market Neutral Real Estate Fund, NAA Mid Growth Fund, NAA Opportunity Fund, NAA Risk Managed Real Estate Fund,
NAA SMid Cap Value Fund, and NAA World Equity Income Fund (each a “Fund” and, collectively, the “Funds”). On August
14, 2024, you provided oral comments regarding the Registration Statement. This correspondence filing responds to those comments. For
your convenience and reference, I have summarized the comments in this letter and provided the Trust’s response to each comment
below.

GENERAL COMMENTS

Fees and Expenses

 1. Comment: In correspondence, please describe how other expenses were reasonably estimated for the
Funds, taking into account the expenses for the Predecessor Funds’ (as defined in the prospectus) most recent fiscal year, and describe
what adjustments were made for the Funds’ expenses as compared to expenses of the Predecessor Funds.

Response: Other
expenses for each Fund were reasonably estimated by considering the actual expenses incurred by the respective Predecessor Funds during
their most recent fiscal year. In making these estimations, the expenses of the Predecessor Funds were closely analyzed, with adjustments
made to account for any differences in the operational structure, asset size, and management strategies of the new Funds compared to the
Predecessor Funds. Specifically, adjustments were made to reflect changes in scale, such as economies of scale that could reduce certain
expenses, as well as potential increases in costs due to any enhancements in the Funds’ services or investment strategies. Adjustments
were also made to reflect the changes in fees charged by the service providers to the Funds as compared to the service providers to the
Predecessor Funds. These adjustments ensure that the estimated expenses accurately reflect the anticipated costs for each Fund in its
current form.

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Portfolio Turnover

 2. Comment: Please provide the portfolio turnover rate for each Predecessor Fund’s most recent
fiscal year.

Response: The Trust has provided
the portfolio turnover rate for each Predecessor Fund’s most recent fiscal year.

Principal Investment Strategies

 3. Comment: Please briefly define either in the summary or in the statutory prospectus what convertible
securities are and the various types of convertibles in which the Fund may invest. Also, if the Fund expects to invest in contingent convertible
securities (known as CoCos), consider including a description of their characteristics, conversion features, and risks.

Response: The Trust has added
the following definition of the convertible securities in the summary prospectus for each applicable Fund.

“Convertible securities
are hybrid financial instruments that typically consist of bonds, debentures, or preferred shares that can be converted into a specified
number of common or preferred shares of the issuing company, typically at the option of the security holder.”

The Funds do not expect to invest
in contingent convertible securities.

 4. Comment: For each series pursuing an investment strategy that may include investments in other
mutual funds, exchange-traded funds (“ETFs”), or private funds, please confirm in correspondence that the acquired fund fees
and expenses (“AFFE”) are expected to be less than 0.01% for each such series. Or if not, please include a line item in the
expense table for the AFFE.

In addition, in
the disclosure for each series, clarify whether other mutual funds and ETFs invested in by the Funds will also pursue a strategy similar
to that pursued by the Fund. Include in the description of the adviser’s selection process how such funds and ETFs will be selected.

Response: Each
Fund confirms that it expects AFFE to be less than 0.01% during its first fiscal year.

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The Trust has clarified
in the disclosure that the mutual funds and ETFs selected for each Fund will pursue strategies similar to those of the Fund. The adviser’s
selection process will prioritize liquidity and size, ensuring these investments align with and support the Fund’s overall strategy.

 5. Comment: For any series that invests in fixed-income securities, please clarify in the summary
description of strategies what ratings qualify as investment grade, in addition to the descriptions provided in the Statement of Additional
Information.

Response: For
each Fund that invests in fixed-income securities, the Trust has revised the disclosure to clarify that the Fund will invest in both investment-grade
and high-yield fixed-income securities. Investment-grade securities are defined as those rated BBB- or higher by Standard & Poor’s
Ratings Services, Baa3 or higher by Moody’s Investors Service, Inc., or an equivalent rating by another nationally recognized statistical
rating organization. High-yield securities, often referred to as “below investment grade,” include those rated below BBB-
or Baa3.

 6. Comment: Please qualify the following and any similar statements regarding the results of the Adviser’s
application of its proprietary strategies, “…the Adviser avoids the most likely overvalued securities and invests in the
most likely undervalued securities”, such as adding the adviser “seeks” or “strives” to avoid.

Response:
The Trust has revised the disclosure to clarify that “the Adviser seeks to avoid the most likely overpriced securities
and invest in the most likely underpriced securities…”. (Emphasis added.)

Performance Summary

 7. Comment: Please indicate whether the investment restrictions of a Predecessor Fund were substantially
similar to the Fund’s investment restrictions and also note any differences in investment adviser and portfolio management team
as reasons for why the performance of the Fund may differ from that of the Predecessor Fund before the reorganization.

Response: The Trust
has revised the disclosure to address the comment.

 8. Comment: On the performance bar charts, please specify what class of shares are indicated in the
chart.

Response:
The Trust has revised each Fund’s performance bar chart to include the share class.

FinTech Law

6224 Turpin Hills Drive     |     Cincinnati,
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991-8472

PROSPECTUS

NAA ALLOCATION FUND

Principal Investment Strategies,
page 2

 9. Comment: Please describe generally the market conditions that are anticipated to exist during periods
when the Fund is invested according to each of the three stated exposure allocation positions. Additionally, describe the likelihood of
different allocations during periods not corresponding to the three stated allocations.

Response: The
Fund has revised the disclosure to remove the reference to the three stated exposure allocation positions. As a result, we believe this
comment is no longer applicable.

NAA LARGE CAP VALUE FUND

Fees and Expenses, page 7

 10. Comment: In correspondence, please explain why other expenses were adjusted from amounts with respect
to only one Predecessor Fund when this series is being launched as a result of reorganization of four predecessor funds. Also consider
expanding the disclosure in footnote 1 to acknowledge the existence of all four predecessor funds and explain how fees of the Fund were
estimated considering all four predecessor funds.

Response: As
noted in the correspondence for the related Form N-14 Combined Proxy Statement/Prospectus, the Guggenheim Large Cap Value Fund was determined
to be the accounting and performance survivor under a North American Security Trust1 analysis.
The Fund has updated the footnote to state that the Predecessor Fund was deemed the accounting and performance survivor and note the
other series that were part of the reorganization.

Performance Summary, page 10

 11. Comment: Please clarify in the description right before the heading that the Predecessor Fund was
a series of the Guggenheim Funds Trust whereas the Predecessor Funds 2-4 were a series of the Transparent Value Trust.

Response: The
Fund has clarified the Predecessor Funds’ description to address the comment.

1 1993
SEC No-Act, LEXIS 876 (pub. avail. Aug. 5, 1994).

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NAA LARGE CORE FUND

Principal Investment Strategies,
page 13

 12. Comment: Briefly describe in the summary what is meant by value and growth investing styles, as
these are the two elements of core, which is in the name of the Fund. Describe how they balance with each other.

Response: The
Fund has added the description to address the comment.

Principal Risks, page 14

 13. Comment: Consider adding risk factors specific to growth and value investing styles.

Response: The
Fund has added the risk factors specific to growth and value investing styles.

NAA MARKET NEUTRAL REAL ESTATE FUND

Fees and Expenses, page 18

 14. Comment: As short positions are described as being achieved by either borrowing or through the
use of derivatives, please add a line item in the fee table to reflect borrowing and short selling expenses. Or in correspondence, confirm
that the Fund will primarily use derivatives to establish short positions.

Also add a footnote
to the fee table describing the costs of investing in swaps or other derivatives, which are not included in the fee table and expense
example. Include an estimate of the indirect costs of investing in swaps or other derivatives for the current fiscal year.

Response: The
Fund confirms that it intends to primarily use derivatives to gain short exposure. The Trust has updated the disclosure to include
a footnote to the fee table estimating the costs of investing in swaps or other
derivatives.

Principal
Investment Strategies, page 19

 15. Comment: Given the Fund’s policy to invest 80% of its assets in real estate-related securities,
please quantify in the disclosure the expected percentage of Fund assets that will be invested in other funds that invest in junk bonds,
asset-backed securities, and commercial paper. Clarify what “substantial” might mean.

Response: The
Fund has clarified its disclosure to indicate that it does not expect to invest in underlying funds on a principal basis. Therefore, the
expected percentage of Fund assets invested in other funds that invest in junk bonds, asset-backed securities, and commercial paper is
anticipated to be minimal. The term “substantial” has been clarified in the disclosure to refer to investments that could
significantly impact the Fund’s overall strategy or risk profile, which is not expected to be the case here.

FinTech Law

6224 Turpin Hills Drive     |     Cincinnati,
OH 45244-3557     |     fintechlegal.io     |     (513)
991-8472

NAA MID GROWTH FUND

Principal Investment Strategies,
pages 26-27

 16. Comment: Please clarify the definitions of mid-cap and small-cap to include a specific range in
dollar amounts of capitalization or companies falling into these categories, as defined by the Fund.

Response: The
Fund has updated its definition of mid-capitalization to include specific ranges in dollar amounts of market capitalization, as referenced
by an established market index. Specifically, mid-capitalization is companies with market capitalizations generally within the range of
the S&P MidCap 400® Index. The capitalization range of the S&P MidCap 400® Index is between $1.3 billion and $20.8 billion
as of July 31, 2024. This index provides a clear and widely recognized basis for categorizing companies by market capitalization, ensuring
that the Fund’s definition aligns with established standards.

 17. Comment: Please identify what other assets, other than securities, the adviser intends to invest
in to achieve the Fund’s investment objective. Please describe such assets and associated risk factors.

Response:
The Fund does not anticipate investing in assets other than securities to achieve its investment objective. As a result, the reference
to “other assets” has been removed from the disclosure.

NAA OPPORTUNITY FUND

Fees and Expenses, page 31

 18. Comment: As short positions are described as being achieved by either borrowing or through the
use of derivatives, please add a line item in the fee table to reflect borrowing and short selling expenses. Or in correspondence, confirm
that the Fund will primarily use derivatives to establish short positions.

Also add a footnote
to the fee table describing the costs of investing in swaps or other derivatives, which are not included in the fee table and expense
example. Include an estimate of the indirect costs of investing in swaps or other derivatives for the current fiscal year.

Response: The
Fund confirms that it intends to primarily use derivatives to gain short exposure. The Trust has updated the disclosure to include
a footnote to the fee table estimating the costs of investing in swaps or other
derivatives.

FinTech Law

6224 Turpin Hills Drive     |     Cincinnati,
OH 45244-3557     |     fintechlegal.io     |     (513)
991-8472

Principal Investment Strategies, page 32

 19. Comment: Please consider briefly defining what constitutes a small, mid, and large-cap company,
including dollar amount ranges. Also, clarify whether the Fund may invest in any non-U.S. issuers or whether it will be entirely invested
in domestic issuers since the description of investment strategy suggests investment only in domestic issuers, but the Principal Risks
include foreign securities risk.

Response: The
Fund has clarified its definitions of large-cap, mid-cap, and small-cap companies to include specific ranges in dollar amounts of market
capitalization, as referenced by established market indices. Specifically, large-cap companies are defined as those with market capitalizations
generally falling within the range of the S&P 500® Index. The capitalization range of the S&P 500® Index is between $5.4
billion and $3.4 trillion as of July 31, 2024. Mid-cap companies are defined as those with market capitalizations generally within the
range of the S&P MidCap 400® Index. The capitalization range of the S&P MidCap 400® Index is between $1.3 billion and
$20.8 billion as of July 31, 2024. Small-cap companies are defined as those with market capitalizations generally within the range of
the S&P SmallCap 600® Index. The capitalization range of the S&P SmallCap 600® Index is between $150 million and $8.4
billion as of July 31, 2024. These indices provide a clear and widely recognized basis for categorizing companies by market capitalization,
ensuring that the Fund’s definitions align with established standards.

The Fund will not
invest in foreign securities, and as such, the reference to foreign securities risk has been deleted from the disclosure.

NAA RISK MANAGED REAL ESTATE FUND

Fees and Expenses, page 38

 20. Comment: As short positions are described as being achieved by either borrowing or through the
use of derivatives, please add a line item in the fee table to reflect borrowing and short selling expenses. Or in correspondence, confirm
that the Fund will primarily use derivatives to establish short positions.

Also add a footnote
to the fee table describing the costs of investing in swaps or other derivatives, which are not included in the fee table and expense
example. Include an estimate o