June 1, 2023



Via EDGAR ATTORNEYS AT LAW 777 EAST WISCONSIN AVENUE MILWAUKEE, WISCONSIN  53202-5306 414.271.2400 TEL 414.297.4900  FAX foley.com   WRITER’S DIRECT LINE 414.297.5596 pfetzer@foley.com Email   CLIENT/MATTER NUMBER 082961-0151

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re: Hennessy Funds Trust (the “Trust”)

Ladies and Gentlemen:

On behalf of the Trust and its series, Hennessy Stance ESG ETF (the “Fund”), attached please find a Preliminary Proxy Statement on Schedule 14A to seek shareholder approval of the following proposals: (i) approval of a new investment sub-advisory agreement between Hennessy Advisors, Inc., the Fund’s investment adviser, and Vident Advisory, LLC in connection with a pending change of control, which is discussed in greater detail in the filing and other similar filings (see SEC Accession No. 0000894189-23-003718) (“Proposal 1”); and (ii) approval for the Fund to operate under a “manager of managers” arrangement (“Proposal 2”).

With regard to Proposal 1, we have worked with Ryan Charles at Kelley Hunt & Charles, LLC.  Please contact Ryan Charles at (602) 877-7926 or via email at ryan@khc.law, and Peter Fetzer at (414) 297-5596 or via email at pfetzer@foley.com should you have any questions regarding this filing.

Very truly yours,

/s/ Peter D. Fetzer

Peter D. Fetzer

Attachments

cc:Ryan Charles

AUSTIN BOSTON CHICAGO DALLAS DENVER DETROIT HOUSTON JACKSONVILLE LOS ANGELES MADISON MEXICO CITY MIAMI MILWAUKEE NEW YORK ORLANDO SACRAMENTO SAN DIEGO SAN FRANCISCO SALT LAKE CITY SILICON VALLEY   TALLAHASSEE TAMPA WASHINGTON, D.C. BRUSSELS TOKYO