SecProbe.io

July 23, 2025

VIA E-MAIL

Bibb L. Strench, Esq.
Thompson Hine LLP 1919 M Street, N.W., Suite 700 Washington, D.C. 20036
Re: FIS Trust  File Nos. 333-288251 and 811-24099
Dear Mr. Strench:
On June 23, FIS Trust (the “Trust”) filed a registration statemen t on Form N-1A under
the Securities Act of 1933 (the “Securities Act”) and the Inves tment Company Act of 1940 (the
“1940 Act”) to offer shares of FIS Bright Po rtfolios Focused Equity ETF and FIS Christian
Stock Fund (each a “Fund” and together, the “Funds”). We have reviewed the registration
statement and provide our comments below. Where a comment is made in one location, it applies
to all similar disclosure appearing elsewhere in the registration statement. All capitalized terms not defined herein have the meaning given to them  in the Registration Statement, and references
to Items are to Form N-1A.  Comments are applic able to both Funds unless otherwise stated.
General 1. We note that portions of the regist ration statement are incomplete ( e.g., portfolio
turnover, performance, name of the sub-a dviser for the FIS Christian Stock Fund, names
of the Trustees). Please ensure that all information is completed and that the auditor’s consent and references to the auditor are provided in an amendment. We may have
additional comments on such portions when you complete them in a pre-effective
amendment, on disclosures made in respons e to this letter, on information supplied
supplementally, or on exhibits added in any amendment.
2. Please supplementally explain if you have sub mitted, or expect to submit, any exemptive
application (including, as referenced in the registration statement, a potential application
for an exemptive order that permits the Adviser, with the Board’s approval, to enter into sub-advisory agreements with one or more  sub-advisers without  obtaining shareholder
approval), or no-action request  in connection with the registration statement.
3. Please confirm whether the Funds will file a registration statement on Form N-14 related
to the planned reorganization, pursuant to whic h each Fund will acquire  all of the assets
and liabilities of its Predece ssor Fund.  Please confirm supplementally that the
registration statement will not be sold on until after the reorganization is consummated.

Bibb L. Strench, Esq.
July 23, 2025 Page 2 of 10  Summary Prospectus
Fund Fees and Expenses
4. Please delete the discussion in footnote 1 of th e Predecessor Fund’s financial highlights.
See General Instruction C.3(b).
Example
5. Please add “hold or” before “redeem” in th e first sentence of the second paragraph.  See
Item 3.
6. Please add the headings “year” and “expenses” to the expense table for the FIS Bright
Portfolios Focused Equity ETF.  See Item 3.
Principal Investment Strategies
7. For the Christian Stock Fund, please clarify in the disclosure how the Fund utilizes the
Benchmark in constructing the portfolio, as per the following sentence: “The portfolio is
constructed with considerations relative to  the sector and regional weights of the
Benchmark to ensure broa d diversification.”
8. For the Christian Stock Fund, pl ease provide more clarity in  the disclosure about the
Christian values filter referenced in the F und's 80% policy.  For example, please describe
the criteria the Adviser uses in its fundament al due diligence process, and the third party
tools that it uses as part of this filter.  We note, for example, that the Focused Equity Fund, uses the Bright Score methodology.  Please also clarify in the disclosure that the
Christian values overlay described in the fo urth paragraph from the bottom, is the same
as the Christian values filter referenced in the Fund's 80% policy.
Principal Risks
9. We note that both Funds disclose an active and frequent trading strategy, but only the
Christian Stock Fund discloses portfolio turnover as a principal risk.  Please add such
principal risk disclosure to the FIS Bright Portfolios Focused Equity ETF.
10. Please remove the Short Position Risk disclosu re as the Funds do not disclose a principal
strategy involving the use of short sales. A lternatively, please add short selling to the
principal investment strategies section of each prospectus.
11. For the FIS Bright Portfolios Focused Equity ETF, please consider grouping the ETF
risks as sub-bullets under the principal risk heading of ETF Risk, as in FIS Christian
Stock Fund.  Please also ensure that the prin cipal ETF risks for the FIS Bright Portfolios
Focused Equity ETF include the following, in addition to the ETF risks already included:
x That the Fund’s market price may deviat e from the value of the Fund’s underlying
portfolio holdings, particularly in times of market stress, with the result that investors may pay more or receive less than the unde rlying value of the Fund shares bought or
sold. For clarity, consider disclosing that this  can be reflected as a spread between the
bid and ask prices for the Fund quoted during the day or a premium or discount in the
closing price from the Fund’s NAV.

Bibb L. Strench, Esq.
July 23, 2025 Page 3 of 10
x 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 Fund and in executing purchase or redempti on orders, and that this could in turn
lead to wider bid/ask spreads and variance s between the market price of the Fund’s
shares and the underlying value of those shares.
x That, in stressed market conditions, the mark et 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/as k spreads and differences between the market
price of the ETF’s shares and the underlying value of those shares.
x Please disclose that purchases and redempti ons of creation units primarily with cash,
rather than through in-kind delivery of por tfolio securities, may cause the Fund to
incur certain costs. Please also disclose that these costs could include brokerage costs or taxable gains or losses th at it might not have incurred if it had made redemption in-
kind. In addition, please disclose that thes e costs could be imposed on the Fund, and
thus decrease the Fund’s net a sset value, to the extent that  the costs are not offset by a
transaction fee payable by an authorized participant.
12. For the Christian Stock Fund, please disclose that where all or a portion of the Fund’s
underlying securities trade in a market that is closed when the market in which the Fund’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 Fund’s
domestic trading day. In addition, please note that  this in turn could lead to differences
between the market price of the Fund’s shares  and the underlying value of those shares.
Management
13. With regard to the FIS Bright Portfolios Focused Equity ETF, please clarify the
commencement date of the Predecessor Fund. With regard to the FIS Christian Stock
Fund, please state the length of service of each portfolio manager ( i.e., provide the
inception date of the Predecessor Fund). See Item 5(b).
Statutory prospectus Other Risks
14. For the Christian Stock Fund, pl ease delete “Authorized Par ticipant Concentration Risk”
to the extent it is duplicative of the Fund’s  principal “Authorized Participant Risk.”
15. We note that “Cybersecurity and Disaster Recovery” is a principal risk for the FIS Bright
Portfolios Focused Equity ETF, but an “Other  Risk” for the Christian Stock Fund.  Please
make conforming changes or explain supplementally why the Funds are different.
Fund Management
16. The staff notes that the Funds will operate under a unitary fee structure. Please confirm in
correspondence whether the Adviser is curren t on all payments to service providers.
Please supplementally explain if  agreements with service providers stipulate payment
from the Funds.

Bibb L. Strench, Esq.
July 23, 2025 Page 4 of 10  Financial Highlights
17. Please include the financial high lights of the Predecessor Funds.  See Item 13.
More Information About the Fund
18. For the Christian Stock Fund, we  note the statement that “the Fund has the ability to raise
up to 50% in cash if the market outlook warrants .”  Please conform this disclosure to the
Fund’s disclosure in response to Item 4 that  describes with more specificity when the
Sub-Adviser can raise up to 50% in cash or cash equivalents.
Statement of Additional Information Cover Page
19. For the FIS Bright Portfolios Focused Equity ETF, please correct the errant reference to
Christian Stock Fund’s prospectus and ot her documents.  Similarly, under “Interested
Trustees,” please correct the references to the “Fund and” FIS Bright Portfolios Focused
Equity ETF in the “**” footnote to the table.
Investment Restric tions and Policies
20. Please disclose as a fundamental policy each Fu nd’s diversified status, and disclose that
the Fund’s diversified status may not be cha nged without the approval of the holders of a
majority of the Fund’s outstanding voting se curities as defined under the 1940 Act.
Management and Othe r Service Providers
21. Given that FIS Bright Portfolios Focused E quity ETF’s Predecessor Fund’s registration
statement became effective in 2024, please delete references to time periods before the
Predecessor Fund’s inception, such as adviso ry fees paid by the Predecessor Fund for
2022 and 2023.
Taxes
22. The second paragraph under “Taxation of the Fund” for the Christian Stock Fund
references the Fund’s “replication or… sa mpling strategy.”  Please delete these
references, given that the Fund is not an i ndex fund, or supplementally explain how they
are applicable.
23. We note that the last sentence of “Investments in Securities of Uncertain Tax Character”
for the Christian Stock Fund is different from  the FIS Bright Portfolios Focused Equity
ETF disclosure ( i.e., the bold disclosure is only included in the latter: “To the extent the
tax treatment of such securities or the income from such securities differs from the tax treatment expected by the Fund, it could af fect the timing or character of income
recognized by the fund, requiring the fund to purchase or sell securities, or otherwise change its portfoli o, in order to comply with the tax rules applicable to
regulated investment companies under the Code ”). Please supplementally explain the
difference or align the disclosures.
Financial Statements
24. As required by the FAST Act Moderniza tion and Simplificati on of Regulation S-
K (Release No. 33-10618 (March 20, 2019)), plea se include hyperlinks  to the financial

Bibb L. Strench, Esq.
July 23, 2025 Page 5 of 10
statements and any other information incor porated by reference into the registration
statement as required by Rule 411 under the Securities Act and Rule 0-4 under the 1940
Act.
Part C: Other Information Item 28: Exhibits
25. Please file finalized exhibits once they are available, and add auditor consents for the
financial statements of the Predecessor Funds.

*    *    *
Responses to this letter should be made in a letter to me f iled on Edgar and in the form
of a pre-effective amendment filed pursuant to  Rule 472 under the Securities Act.  Where no
change will be made in the fili ng in response to a comment, please indicate this fact in the
letter to us and briefly stat e the basis for your position.
You should review and comply with all applicable requireme nts of the federal securities
laws in connection with the preparation and distribution of preliminary prospectuses.
Although we have completed our initial review of the regist ration statement, the filing
will be reviewed further after we receive your re sponse.  Therefore, we reserve the right to
comment further on the registrati on statement and any amendments .  After we have resolved
all issues, the Funds and their underwriter must re quest acceleration of the effective date of the
registration statement.
In closing, we remind you that the Funds a nd their management are responsible for
the accuracy and adequacy of their disclosures in the registration statement, notwithstanding any review, comments, action, or absence of action by the staff.
 Should you have any questions regarding this letter, please feel fr ee to contact me at
(202) 551-8645.
        S i n c e r e l y ,            /s/ Emily Rowland
        Emily Rowland
        Senior Counsel  cc: Andrea Ottomanelli Magove rn, Assistant Director
Elizabeth Bentzinger, Se nior Special Counsel
Melissa McDonough, Accoun ting Branch Chief
Lauren Hamilton, Accounting Reviewer