DRINKER BIDDLE & REATH LLP
One Logan Square
Suite 2000
Philadelphia, PA 19103-6996
215-988-2700
Fax: 215-988-2757
www.drinkerbiddle.com
October 24, 2019
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | The RBB Fund, Inc. (the “Company”) |
(1933 Act Registration No. 33-20827)
(1940 Act Registration No. 811-5518)
Ladies and Gentlemen:
On behalf of the Company, transmitted for filing under the Securities Act of 1933, as amended (the “1933 Act”), is a copy of the Company’s Registration Statement on Form N-14, including exhibits (the “Registration Statement”).
This filing relates to with the proposed acquisition of all of the assets and liabilities of the Equinox Campbell Fund (the “Acquired Fund”), a series of Equinox Funds Trust (the “Trust”), by the Campbell Systematic Macro Fund (the “Acquiring Fund”), a series of the Company.
The combined Proxy Statement/Prospectus contained in this filing will be used in the solicitation of proxies of the shareholders of the Acquired Fund to approve an Agreement and Plan of Reorganization by and among the Trust, the Company and Campbell & Company Investment Adviser LLC, the investment adviser to the Acquiring Fund, which provides for and contemplates: (1) the transfer of all of the assets and liabilities of the Acquired Fund to the Acquiring Fund in exchange for shares of the designated classes of the Acquiring Fund; (2) the distribution of the shares of designated classes of the Acquiring Fund to the shareholders of the Acquired Fund; and (3) the subsequent liquidation and termination of the Acquired Fund.
This filing is being made pursuant to Rule 488 under the 1933 Act, and it is intended that the Registration Statement will become effective automatically on November 25, 2019. Therefore, we would appreciate receiving any comments you may have as soon as possible so that we may be in a position to mail the Proxy Statement/Prospectus contained in the Registration Statement on or about November 26, 2019.
The Company has previously registered an indefinite number of its shares under the 1933 Act pursuant to an election under Rule 24f-2 under the Investment Company Act of 1940, as amended.
Questions and comments concerning the enclosed materials may be directed to me at (215) 988-3307.
| | Very truly yours, | |
| | | |
| | /s/ Jillian L. Bosmann | |
| | Jillian L. Bosmann | |
