PermRock Royalty Trust
Simmons Bank, Trustee
P.O. Box 470727
Fort Worth, Texas 76147
May 5, 2022
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Liz Packebusch, Staff Attorney
Re: PermRock Royalty Trust
Registration Statement on Form S-3
Filed on April 28, 2022
File No. 333-264551 (the “Registration Statement”)
Ladies and Gentlemen:
Pursuant to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, PermRock Royalty Trust hereby respectfully requests acceleration of the effective date of the Registration Statement so that it may become effective at 5:00 p.m., Eastern Time, on May 9, 2022, or as soon thereafter as practicable.
Should any member of the staff of the Commission have any questions or comments with respect to this request, please contact Stephen W. Grant, Jr. of Haynes and Boone, LLP at (713) 547-2505.
| Very truly yours, |
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| PERMROCK ROYALTY TRUST |
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| By: | Simmons Bank, as Trustee |
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| By: | /s/ Ron E. Hooper |
| Name: | Ron E. Hooper |
| Title: | Senior Vice President |
cc: Stephen W. Grant, Jr., Haynes and Boone, LLP
Michael A. Freeman, Haynes and Boone, LLP