Faegre Drinker Biddle & Reath LLP

One Logan Square

Suite 2000

Philadelphia, PA 19103-6996

Telephone: (215) 988-2700

July 10, 2023

The RBB Fund, Inc.

615 East Michigan Street

Milwaukee, WI 53202

Re: Shares Registered by Post-Effective Amendment No. 307 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. 307 (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 Oakhurst Fixed Income Fund, Oakhurst Short Duration Bond Fund, Oakhurst Short Duration High Yield Credit Fund, and F/m Investments Large Cap Focused Fund, each a new series of the Company:

PORTFOLIO	CLASS	AUTHORIZED SHARES
Oakhurst Fixed Income Fund	EEEEEEEE FFFFFFFF	100 million 100 million
Oakhurst Short Duration Bond Fund	GGGGGGGG HHHHHHHH	100 million 100 million
Oakhurst Short Duration High Yield Credit Fund	IIIIIIII JJJJJJJJ	100 million 100 million
F/m Investments Large Cap Focused Fund	KKKKKKKK LLLLLLLL	100 million 100 million

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

We have reviewed the Company’s Articles of Incorporation, By-Laws, 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 Prospectuses offering the respective Shares and in accordance with the Company’s Articles of Incorporation, as amended and supplemented, 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/Faegre Drinker Biddle & Reath LLP

Faegre Drinker Biddle & Reath LLP