Montgomery, McCracken, Walker & Rhoads, llp
attorneys at law

Don E. Felice	123 South Broad Street	Direct Dial
Admitted in Pennsylvania, New Jersey	Avenue of the Arts	(215) 772-7385
	Philadelphia, PA 19109-1029
	215-772-1500	dfelice@mmwr.com
	Fax 215-772-7620

May 13, 2011

Ms. Mary Cole
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

     Re: The Hirtle Callaghan Trust (“Registrant”)
File Nos.: 33-87762 and 811-08918
Preliminary Proxy Statement         

Dear Ms. Cole:

This correspondence is being provided to you in response to your comments (“Staff Comments”) communicated during our telephone conversation of May 12, 2011, with respect to Registrant’s Preliminary Proxy Statement filed on May 5, 2011.

For your convenience, we have summarized our understanding of the Staff Comments in bold typeface and set forth our response in the following italicized text.

1.	You requested that the language describing how persons named as proxies will vote on proposed adjournments be modified.
	Response: The disclosure has been revised as requested.
2.	You requested that the language explaining the pro forma fee tables be clarified.
	Response: The disclosure has been revised as requested.

If you have any questions regarding the enclosed, please do not hesitate to contact the undersigned at (215) 772-7385.

Very truly yours,

/s/ Don E. Felice

Don E. Felice

cc: Robert Zion
Colette Bull
Audrey C. Talley
Kristin Schantz

¨ Philadelphia, PA ¨ Cherry Hill, NJ ¨ Wilmington, DE ¨ Berwyn, PA ¨ West Chester, PA ¨

A LIMITED LIABILITY PARTNERSHIP FORMED IN PENNSYLVANIA
LOUIS A. PETRONI — NEW JERSEY RESPONSIBLE PARTNER