Drinker Biddle & Reath LLP 

One Logan Square 

Suite 2000 

Philadelphia, PA 19103-6996 

(215) 988-2700 (Phone) 

(215) 988-2757 (Facsimile) 

www.drinkerbiddle.com

March 19, 2018

The RBB Fund, Inc. 

615 East Michigan Street 

Milwaukee, WI 53202

Re: Shares Registered by Post-Effective Amendment No. 242 to Registration Statement on Form N-1A (File No. 33-20827)

Ladies and Gentlemen:

We have acted as counsel to The RBB Fund, Inc. (the “Company”) in connection with the preparation and filing with the Securities and Exchange Commission of Post-Effective Amendment No. 242 (the “Amendment”) to the Company’s Registration Statement on Form N-1A under the Securities Act of 1933, as amended. The Board of Directors of the Company has authorized the issuance and sale by the Company of the following classes and numbers of shares of common stock, $0.001 par value per share (collectively, the “Shares”), with respect to the Company’s Summit Global Investments U.S. Low Volatility Equity Fund, Summit Global Investments Small Cap Low Volatility Fund and Summit Global Investments Global Low Volatility Fund:

PORTFOLIO	CLASS	AUTHORIZED SHARES
Summit Global Investments Low Volatility Equity Fund	GGGGG  HHHHH  IIIII	100 million  100 million  100 million
Summit Global Investments Small Cap Low Volatility Fund	AAAAAA  BBBBBB  CCCCCC	100 million  100 million  100 million
Summit Global Investments Global Low Volatility Fund	OOOOO  PPPPP  QQQQQ	100 million  100 million  100 million

March 19, 2018 

Page 2

The Amendment seeks to register an indefinite number of the Shares.

We have reviewed the Company’s Articles of Incorporation, ByLaws, resolutions of its Board of Directors, and such other legal and factual matters as we have deemed appropriate. This opinion is based exclusively on the Maryland General Corporation Law and the federal law of the United States of America.

Based upon and subject to the foregoing, it is our opinion that the Shares, when issued for payment as described in the Company’s Prospectus offering the Shares and in accordance with the Company’s Articles of Incorporation for not less than $0.001 per share, will be legally issued, fully paid and non-assessable by the Company.

We consent to the filing of this opinion as an exhibit to the Amendment to the Company’s Registration Statement.

Very truly yours,

/s/ Drinker Biddle & Reath LLP

Drinker Biddle & Reath LLP