COVER 27 filename27.htm



SEWARD & KISSEL LLP
901 K Street, NW
Suite 800
Washington, DC  20001
Telephone: (202) 737-8833
Facsimile: (202) 737-5184


March 5, 2021

VIA EDGAR

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re:
North Square Investments Trust (the “Registrant”)
 
Pre-Effective Amendment No. 2 to Registration Statement on Form N-14
 
SEC File No. 333-252522


To the Commission:

On behalf of the Registrant, pursuant to the Securities Act of 1933, as amended, electronically transmitted herewith is Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-14 (the “Amendment”) relating to the issuance of shares of beneficial interest in connection with the reorganizations of Stadion Tactical Defensive Fund, Stadion Tactical Growth Fund and Stadion Trilogy Alternative Return Fund, each a series of Stadion Investment Trust, into North Square Tactical Defensive Fund, North Square Tactical Growth Fund and North Square Trilogy Alternative Return Fund, respectively, each a series of the Registrant (the “Reorganizations”).

The Amendment incorporates revisions to the Registrant’s Registration Statement on Form N-14 filed on January 28, 2021 relating to the issuance of common shares in connection with the Reorganizations, in response to comments provided telephonically by the staff of the Securities and Exchange Commission on February 24, 2021 and February 25, 2021 (as addressed in separate correspondence dated March 5, 2021).

Please contact Robert M. Kurucza at (202) 661-7195 or the undersigned at (202) 661-7196 with any comments or questions.

Sincerely,

/s/ Lancelot A. King
 Lancelot A. King
Attachment
cc:  Robert M. Kurucza