SecProbe.io

CORRESP
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    Chicago

New York

Washington, DC

London

San Francisco

Los Angeles

Singapore

    May 30, 2024
    Dallas

        Miami

        vedderprice.com

    VIA EDGAR
    Deborah Bielicke Eades

        Shareholder

        +1 312 609 7661

        deades@vedderprice.com

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

 Attn: Ms. Eileen Smiley

 Re: Palmer Square Funds Trust/Palmer Square Credit Opportunities ETF

Registration Statement on Form N-1A

File Nos. 333-277718 and 811-23946

Dear Ms. Smiley:

On behalf of the registrant, Palmer Square Funds
Trust (the “Registrant”), we are responding to the staff’s comments dated March 29, 2024, in regard to the Registrant’s
initial registration statement on Form N-1A (the “Registration Statement”). In addition, Registrant has added two new series
in this Pre-Effective Amendment. Each new series is a passively managed ETF which seeks to follow investment results that correspond to
proprietary indices created by the adviser.

For convenience, each comment is restated below,
with the response immediately following. To the extent responses herein reflect revised or additional disclosure, such disclosure is included
in Pre-Effective Amendment No. 1 to the Registration Statement filed concurrently herewith. All capitalized terms not defined herein have
the meaning assigned to them in the Registration Statement; any page references herein refer to the initial Registration Statement.

PROSPECTUS

Cover Page

 1. Comment: Please complete all blank fields.

Response:
Registrant has completed all blank fields.

Fees and Expenses of the Fund (Page 1)

 2. Comment: The fee table is incomplete. When completing, please provide an estimate of organizational
and offering costs, disclose the party responsible for paying these expenses, and, if applicable, confirm that they will be included in
the line item for Other Expenses in the fee table.

Response:
The Registrant has completed the fee table. Organizational and offering expenses are paid by the investment adviser from the unitary fee.

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 30, 2024

Page 2

Example (Page 1)

 3. Comment: On Page 1, the Example contains a sentence stating that the example reflects the
Fund’s fee waiver agreement but only for the contractual term of the fee waiver. The fee table, however, does not contain any line
item showing a fee waiver. If such a fee waiver agreement will be in place for at least one year from the date of effectiveness of the
registration statement, please ensure that the fee table is updated accordingly with the contractual term of the waiver agreement referenced
in footnote disclosure to that line item. If a fee waiver agreement will not be in place, please update the introductory disclosure in
the Example to remove reference to the fee waiver agreement.

Response:
Registrant confirms that there will not be a fee waiver in light of the unitary fee structure.

 4. Comment: Because this is a new fund, please include disclosure that the expenses are based
on estimated amounts for the current fiscal year.

Response:
Because of the unitary fee structure, Registrant does not believe this disclosure is relevant.

Principal Investment Strategies (Pages 1-2)

 5. Comment: The first paragraph on Page 1 of this section details a list of investments that
the Fund may invest in. Please confirm that each listed security type is a principal strategy of the Fund.

Response:
The Registrant confirms that each listed security type is a principal strategy of the Fund.

 6. Comment: The last sentence of the first paragraph on Page 1 of this section states that
the Fund can invest in securities of foreign issuers. Please confirm whether securities underlying the ETF are traded outside of a collateralized
settlement system. If so, please disclose in the principal risk section, along with other required disclosure regarding the risks of the
Fund’s ETF structure that there are a limited number of financial institutions that may act as authorized participants that post
collateral for certain trades on an agency basis (i.e., on behalf of other market participants). Please also disclose that, to
the extent that those authorized participants exit the business or are unable to process creation and/or redemption orders and no other
authorized participant is able to step forward to do so, there may be a significantly diminished trading market for the ETF’s shares.
In addition, please note that this could in turn lead to differences between the market price of the ETF’s shares and the underlying
value of those shares.

Response:
The Fund could hold securities that are traded outside of a collateralized settlement system. Registrant has added the requested risk
disclosure in response.

 7. Comment: With respect to the Fund’s disclosed ability to invest in securities of foreign
issuers on Page 1 of this section, please explain supplementally to the staff whether the Fund can invest in emerging markets securities
and non-US or US-dollar denominated debt from emerging markets, and if so, add disclosure in Item 4 if such investments will be principal
strategies or in Item 9 or the SAI, as appropriate, if such investments will be non-principal strategies.

Response:
The Fund is not precluded from investing in emerging market securities. Registrant confirms such investments are not a principal investment
strategy and has added additional disclosure in the SAI.

May 30, 2024

Page 3

 8. Comment: The second full paragraph on Page 2 of this section, states that the Fund “may
also employ derivatives” for hedging purposes and some investments could count towards satisfaction of the Fund’s 80% policy.
Please confirm supplementally to the staff that the list of derivatives will be used as principal strategies. If not, please move this
disclosure to Item 9 or the SAI as appropriate. For the instruments that will be used as principal strategies, particularly for the instruments
that could be used to satisfy the 80% policy, please identify those instruments, and describe with more specificity how those will be
used in Item 4 and/or Item 9 as appropriate.

Response:
Registrant confirms that the listed derivatives will be used as principal strategies and may be used for both. Registrant believes the
summary section already states the intended uses of derivatives – to achieve the Fund’s objective, hedge risk and enhance
liquidity.

 9. Comment: The third full paragraph of this section on Page 2 states that the Fund seeks to
identify investments “that it believes can provide highly competitive rate yields and total return over the long term with relatively
mitigated credit risk.” Please describe how the Fund interprets the phrase “relatively mitigated credit risk” and what
techniques the Fund will employ to mitigate credit risk.

Response:
Registrant has added disclosure regarding the techniques used to mitigate credit risk.

Principal Investment Risks (Pages 2-5)

 10. Comment: Beginning on Page 2 of the prospectus, the principal risks of the Fund are described.
Once the principal investment strategies are finalized and refined, please ensure that there is summary risk disclosure in Item 4 for
each principal strategy listed with enhanced disclosure in Item 9 or the SAI as appropriate. For example, you list investments in covenant-lite
securities as a principal strategy but there is no principal risk disclosure in Item 4 regarding the risks of these securities.

Response:
The Registrant has reviewed the principal strategies and risks and added appropriate disclosure.

 11. Comment: Page 1 of the prospectus discloses that the Fund may invest in US-dollar and non-US
dollar denominated debt securities and securities of foreign issuers but there is no principal risk disclosure of these investments in
Item 4 or Item 9. Please add summary risk disclosure regarding these principal strategies with more enhanced disclosure in Item 9 or the
SAI as appropriate. Also, if the principal strategies of the Fund will include investments in emerging markets, please add disclosure
of the specific risks of those types of investments.

Response:
The Registrant has made the requested changes. Registrant does not intend to invest in emerging market debt securities as a principal
investment strategy.

May 30, 2024

Page 4

 12. Comment: The Fund is an ETF and there is no principal risk disclosure specific to the Fund’s
structure as an ETF. Please add specific risk disclosure that covers, at a minimum, the following points:

 a) Please disclose the risk that the ETF’s
market price may deviate from the value of the ETF’s underlying portfolio holdings, particularly in times of market stress, with
the result that the investors may pay more or receive less than the underlying value of the ETF shares bought or sold. For clarity, consider
disclosing that this can be reflected as a spread between the bid and ask prices for the ETF quoted during the day or a premium or discount
in the closing price from the ETF’s NAV.

 b) Please disclose the risk that an active trading
market for shares of the ETF may not develop or be maintained. Please also note that in times of market stress, market makers or authorized
participants may step away from their respective roles in making a market in shares of the ETF and in executing purchase or redemption
orders, and that this could in turn lead to wider bid/ask spreads and variances between the market price of the ETF’s shares and
the underlying value of those shares.

 c) Please disclose that, where all or a portion
of the ETF’s underlying securities trade in a market that is closed when the market in which the ETF’s shares are listed and
trading in that market is open, there may be changes between the last quote from its closed foreign market and the value of such security
during the ETF’s domestic trading day. In addition, please note that this, in turn, could lead to differences between the market
price of the ETF’s shares and the underlying value of those shares.

 d) Please disclose that, in stressed market conditions,
the market for an ETF’s shares may become less liquid in response to deteriorating liquidity in the markets for the ETF’s
underlying portfolio holdings. Please also note that this adverse effect on liquidity for the ETF’s shares in turn could lead to
wider bid/ask spreads and differences between the market price of the ETF’s shares and the underlying value of those shares.

Response:
The Registrant has made the requested changes.

 13. Comment: The last bullet point on Page 5 of the prospectus states that the Fund is “non-
diversified.” Please reference the Fund’s status as a non-diversified fund in its principal strategies and add risk disclosure
explaining the risks of a non-diversified Fund.

Response:
The Registrant has made the requested change.

Performance
(Page 5)

 14. Comment: Please supplementally identify for the staff the benchmark indices the fund intends
to use for the performance presentation. We may have additional comments.

Response:
The Registrant intends to use the Bloomberg US Corporate 1-3 Year Index as the benchmark indices for the Fund.

Purchase and
Sale of Fund Shares (Page 5)

 15. Comment: The second sentence of this section on Page 5 states that the Fund generally redeems
and sells shares in Creation Units in exchange for a deposit of securities or cash. Given the Fund’s strategy, please confirm supplementally
to the staff whether the Fund anticipates issuing and redeeming Creation Units primarily in cash. If so, please add risk disclosure that
the purchases and redemptions of Creation Units primarily with cash, rather than through in-kind delivery of portfolio securities, may
cause the ETF to incur certain costs. Please also disclose that these costs could include brokerage costs or taxable gains or losses that
it might not have incurred if it had made redemptions in-kind. In addition, please also disclose that these costs could be imposed on
the ETF, and thus decrease the ETF’s net asset value, to the extent that these costs are not offset by a transaction fee payable
by an authorized participant.

Response:
Registrant confirms that it expects to issue and redeem Creation Units primarily in cash. Registrant has added the requested risk disclosure.

May 30, 2024

Page 5

More About the Fund’s Investment Objectives,
Principal Investment Strategies and Risks (Pages 7-14)

 16. Comment: Please conform changes to Item 4 made in response to comments to the Item 9 disclosure
as appropriate.

Response:
The Registrant has made the requested changes.

Statement
of Additional Information

Management of the Trust Trustees and Officers
(Page B-29 & Signature Page)

 17. Comment: The table on Page B-29 of the SAI page 12 indicates that the Trustees and officers
have not been identified for the Trust and the registration statement has been signed only by the chief executive and financial officers.
Please ensure that once the Board of Trustees has been properly constituted, a pre-effective amendment to the registration statement will
be signed by a majority of Trustees and all Trustees and officers of the Trust are identified. See Section 6(a) of Securities Act.

Response:
The Registrant confirms the Trustees will sign Pre-Effective Amendment No. 1 and all subsequent amendments to the Registration Statement.

Purchase and
Redemption of Shares in Creation Units (Page B-41-B-46)

 18. Comment: The section entitled “Acceptance of Orders of Creation Units” on Page
B-44 discloses certain instances when an order for a Creation Unit might be rejected, including two subparagraphs (d) and (e) when such
an order might be rejected based on opinion of counsel. Please explain supplementally why subparagraphs (d) and (e) are necessary or whether
they can be combined.

Response:
The Registrant finds both subparagraphs necessary as they contemplate different instances where counsel opinion provides grounds to reject
an order for a creation unit. The first subparagraph contemplates a counsel opinion that acceptance of the Fund Deposit itself would be
unlawful. The second subparagraph contemplates a counsel opinion that receipt of the order for a creation unit itself would be unlawful.
The Registrant respectfully declines to make the suggested change to this disclosure.

 19. Comment: In the same section on Page B-44, please delete the following language in the first
sentence: “without limitation”.

Response:
The Registrant has made the requested changes.

May 30, 2024

Page 6

Part
C

Exhibits

 20. Comment: The staff needs to review the Declaration of Trust and Bylaws of the Trust prior
to effectiveness. Please transmit to the staff for review once completed.

Response:
The Declaration of Trust and Bylaws of the Trust will be filed with Pre-Effective Amendment No. 1.

 21. Comment: Please confirm that the legal opinion to be filed as Exhibit (i) will be consistent
with Staff Legal Bulletin No. 19, Legality and Tax Opinions in Registered Offerings (October 14, 2011).

Response:
The Registrant confirms that the legal opinion to be filed as Exhibit (i) will be consistent with Staff Legal Bulletin No. 19, Legality
and Tax Opinions in Registered Offerings (October 14, 2011).

Other Information

 22. Comment: If the Registrant may indemnify a director, officer, or controlling person against
liabilities arising under the Securities Act of 1933 (“Securities Act”), please add a description of the indemnification provisions
including an undertaking to the registration statement that states the indemnification lan