UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES


Investment Company Act file number 811-22298


Starboard Investment Trust
(Exact name of registrant as specified in charter)


116 South Franklin Street, Rocky Mount, North Carolina  27804
(Address of principal executive offices)  (Zip code)


Paracorp Inc.
2140 South Dupont Hwy., Camden, DE  19934
 (Name and address of agent for service)


Registrant's telephone number, including area code: 252-972-9922


Date of fiscal year end:  September 30


Date of reporting period:   March 31, 2021

Item 1. REPORT TO STOCKHOLDERS.





Statements in this Semi-Annual Report that reflect projections or expectations of future financial or economic performance of the QCI Balanced Fund (“Fund”) and of the market in general and statements of the Fund’s plans and objectives for future operations are forward-looking statements. No assurance can be given that actual results or events will not differ materially from those projected, estimated, assumed or anticipated in any such forward-looking statements. Important factors that could result in such differences, in addition to the other factors noted with such forward-looking statements, include, without limitation, general economic conditions such as inflation, recession and interest rates.  Past performance is not a guarantee of future results.


An investor should consider the investment objectives, risks, charges, and expenses of the Fund carefully before investing.  The prospectus contains this and other information about the Fund.  A copy of the prospectus is available at e-qci.com or by calling Shareholder Services at 800-773-3863.  The prospectus should be read carefully before investing.


The QCI Balanced Fund is a series of the Starboard Investment Trust.



For More Information on the QCI Balanced Fund:

See Our Web site at e-qci.com
or
Call Our Shareholder Services Group at 800-773-3863.


QCI Balanced Fund
             
                     
Schedule of Investments
             
(Unaudited)
               
                     
As of March 31, 2021
             
           

Principal
Coupon
Rate

Maturity Date
 

 Value (Note 1)
                     
CORPORATE BONDS - 18.85%
         
                     
 
Communication Services - 1.57%
         
   
Verizon Communications, Inc.
 $ 985,000
4.125%
3/16/2027
 $
       1,112,050
                   
       1,112,050
 
Consumer Discretionary - 1.55%
         
   
Anheuser-Busch Cos., LLC
    505,000
3.650%
2/1/2026
 
         553,240
   
Lowe's Cos., Inc.
   
    500,000
3.375%
9/15/2025
 
         544,125
                   
       1,097,365
 
Consumer Staples - 1.55%
         
   
General Mills, Inc.
   
    975,000
4.200%
4/17/2028
 
       1,099,168
                   
       1,099,168
 
Energy - 0.80%
             
   
Chevron Corp.
   
    535,000
2.895%
3/3/2024
 
         569,884
                   
         569,884
 
Financials - 5.87%
             
   
Bank of America Corp.
 
 1,115,000
1.366%
10/21/2022
 
       1,121,325
   
JP Morgan Chase & Co.
 1,085,000
3.900%
7/15/2025
 
       1,194,366
   
US Bancorp
   
    785,000
3.600%
9/11/2024
 
         854,406
   
Wells Fargo Bank NA
 
 1,000,000
0.845%
9/9/2022
 
       1,002,598
                   
       4,172,695
 
Industrials - 3.18%
             
   
Deere & Co.
   
 1,045,000
2.750%
4/15/2025
 
       1,112,251
   
Norfolk Southern Corp.
 
    245,000
3.250%
12/1/2021
 
         247,919
   
Norfolk Southern Corp.
 
    880,000
3.000%
4/1/2022
 
         897,022
                   
       2,257,192
 
Information Technology - 3.15%
         
   
Apple, Inc.
   
 1,065,000
2.450%
8/4/2026
 
       1,121,119
   
Microsoft Corp.
   
 1,015,000
3.300%
2/6/2027
 
       1,115,878
                   
       2,236,997
 
Utilties - 1.18%
             
   
Duke Energy Corp.
   
    805,000
2.650%
9/1/2026
 
         841,069
                   
         841,069
                     
   
Total Corporate Bonds (Cost $13,457,198)
       
     13,386,420
                     
FEDERAL AGENCY OBLIGATIONS - 12.11%
         
 
Financials - 12.11%
             
   
Federal Home Loan Banks
    760,000
1.125%
7/14/2021
 
         761,984
   
Federal Home Loan Mortgage Corp.
 2,080,000
0.250%
6/26/2023
 
       2,080,582
   
Federal National Mortgage Association
 1,830,000
1.875%
9/24/2026
 
       1,909,111
   
Federal National Mortgage Association
 1,315,000
2.000%
1/5/2022
 
       1,333,673
   
Federal National Mortgage Association
 2,345,000
2.625%
9/6/2024
 
       2,516,302
                     
   
Total Federal Agency Obligations (Cost $8,358,637)
     
       8,601,652
                     
                     
                   
 (Continued)


QCI Balanced Fund
             
                     
Schedule of Investments - Continued
         
(Unaudited)
               
                     
As of March 31, 2021
             
           

Principal
Interest
Rate

Maturity Date
 

 Value (Note 1)
                     
UNITED STATES TREASURY NOTES - 4.95%
         
   
United States Treasury Note
 $1,385,000
2.375%
8/15/2024
 $
       1,473,510
   
United States Treasury Note
   1,705,000
1.625%
11/15/2022
 
       1,745,760
   
United States Treasury Note
      300,000
0.125%
11/30/2022
 
         299,895
                     
   
Total United States Treasury Notes (Cost $3,431,851)
     
       3,519,165
                     
MUNICIPAL BONDS - 1.85%
           
   
New York State Urban Development Corp.
      750,000
3.270%
3/15/2028
 
         816,698
   
New York State Urban Development Corp.
      285,000
3.320%
3/15/2029
 
         308,894
   
University of North Texas System
      190,000
2.898%
4/15/2021
 
         190,153
                     
   
Total Municipal Bonds (Cost $1,230,587)
       
       1,315,745
                     
PREFERRED STOCK - 0.77%
         
 
Utilities - 0.77%
       
Shares
   
   
NextEra Energy, Inc.
       
          10,969
 
         544,062
                     
   
Total Preferred Stock (Cost $544,826)
       
         544,062
                     
COMMON STOCKS - 51.77%
           
                     
 
Communication Services - 4.73%
   
Shares
   
 

Alphabet, Inc. - Class C
   
               500
 
       1,034,315
 

Facebook, Inc.
       
            2,471
 
         727,784
 

The Walt Disney Co.
       
            4,170
 
         769,448
   
Verizon Communications, Inc.
   
          14,225
 
         827,184
                   
       3,358,731
 
Consumer Discretionary - 7.03%
         
 

Amazon.com, Inc.
       
               499
 
       1,543,946
 

Booking Holdings, Inc.
     
               438
 
       1,020,470
   
McDonald's Corp.
       
            3,033
 
         679,817
   
Starbucks Corp.
       
            4,942
 
         540,012
   
The Home Depot, Inc.
     
            2,115
 
         645,604
   
The TJX Cos., Inc.
       
            8,538
 
         564,789
                   
       4,994,638
 
Consumer Staples - 3.23%
         
   
Constellation Brands, Inc.
   
            3,085
 
         703,380
   
PepsiCo, Inc.
       
            5,405
 
         764,537
   
The Procter & Gamble Co.
   
            6,085
 
         824,091
                   
       2,292,008
 
Energy - 3.44%
             
   
Chevron Corp.
       
            8,625
 
         903,814
   
Enbridge, Inc.
       
          18,558
 
         675,511
   
Exxon Mobil Corp.
       
          15,500
 
         865,365
                   
       2,444,690
                     
                     
                     
                   
 (Continued)

QCI Balanced Fund
             
                     
Schedule of Investments - Continued
         
(Unaudited)
               
                     
As of March 31, 2021
             
               

Shares
 

 Value (Note 1)
                     
COMMON STOCKS - Continued
         
                     
 
Financials - 10.24%
             
   
Bank of America Corp.
     
          22,886
 $
         885,459
 

Berkshire Hathaway, Inc. - Class B
   
            5,500
 
       1,405,085
   
Chubb Ltd.
       
            3,575
 
         564,743
   
JPMorgan Chase & Co.
   
            5,046
 
         768,152
 

Manning & Napier, Inc.
     
        175,000
 
       1,132,250
   
Mastercard, Inc.
       
            2,300
 
         818,915
   
Regions Financial Corp.
   
          32,630
 
         674,136
   
The Goldman Sachs Group, Inc.
   
            1,129
 
         369,183
   
The PNC Financial Services Group, Inc.
   
            3,726
 
         653,578
                   
       7,271,501
                     
 
Health Care - 7.99%
             
   
Abbott Laboratories
       
            6,564
 
         786,630
 

Biogen, Inc.
       
            2,385
 
         667,204
 

Exact Sciences Corp.
     
            1,838
 
         242,212
   
Humana, Inc.
       
            1,427
 
         598,270
 

Illumina, Inc.
       
               913
 
         350,647
 

Incyte Corp.
       
            7,000
 
         568,890
   
Johnson & Johnson
       
            6,622
 
       1,088,326
   
Roche Holding AG
       
          19,000
 
         770,640
   
Zoetis, Inc.
       
            3,816
 
         600,944
                   
       5,673,763
 
Industrials - 4.68%
             
   
General Dynamics Corp.
   
            3,500
 
         635,460
 

Southwest Airlines Co.
     
          12,419
 
         758,304
 

The Boeing Co.
       
            5,000
 
       1,273,600
 

The LS Starrett Co.
       
          10,878
 
           70,163
   
United Parcel Service, Inc.
   
            3,442
 
         585,106
                   
       3,322,633
 
Information Technology - 9.39%
         
   
Apple, Inc.
       
          17,000
 
       2,076,550
 

Check Point Software Technologies Ltd.
   
            6,000
 
         671,820
   
Microsoft Corp.
       
            7,000
 
       1,650,390
   
NVIDIA Corp.
       
               928
 
         495,487
   
QUALCOMM, Inc.
       
            2,979
 
         394,986
 

ServiceNow, Inc.
       
            1,200
 
         600,132
   
Taiwan Semiconductor Manufacturing Co. Ltd.
 
            3,469
 
         410,313
   
Universal Display Corp.
     
            1,567
 
         371,018
                   
       6,670,696
 
Utilities - 1.04%
             
   
NextEra Energy, Inc.
       
            9,800
 
         740,978
                   
         740,978
                     
   
Total Common Stocks (Cost $25,621,674)
       
     36,769,638
                   
 (Continued)

QCI Balanced Fund
             
                     
Schedule of Investments - Continued
         
(Unaudited)
               
                     
As of March 31, 2021
             
               

Shares
 

Value (Note 1)
                     
EXCHANGE-TRADED PRODUCTS - 6.69%
         
                     
 
Commodity Fund - 1.43%
         
 

SPDR Gold Shares
       
            6,340
 $
       1,014,146
                   
       1,014,146
 
Materials - 5.26%
             
   
Schwab US TIPS ETF
     
          23,506
 
       1,437,627
   
Vanguard Mortgage-Backed Securities ETF
   
          43,028
 
       2,296,404
                   
       3,734,031
                     
   
Total Exchange-Traded Products (Cost $4,697,989)
     
       4,748,177
                     
REAL ESTATE INVESTMENT TRUST - 0.81%
         
 
Real Estate Investment Trust - 0.81%
         
   
Americold Realty Trust
     
          15,000
 
         577,050
                     
   
Total Real Estate Investment Trust (Cost $499,506)
     
         577,050
                     
CALL OPTIONS PURCHASED - 7.04%
Number of
Exercise
 Expiration
 Notional
   
         
Contracts
Price
 Date
 Value
   
 
(a) 
CBOE Market Volatility
                        450
 $       30.00
7/21/2021
 $      873,000
 $
         126,000
                     
   
Total Call Options Purchased (Premiums Received $248,033)
   
         126,000
                     
SHORT-TERM INVESTMENT - 2.52%
         
   
Fidelity Institutional Money Market Funds -
 
Shares
   
   
  Government Portfolio, 0.01% §
   
      1,791,044
 
       1,791,044
                     
   
Total Short-Term Investment (Cost $1,791,044)
     
       1,791,044
                     
Total Value of Investments (Cost $59,881,345) - 100.50%
   
 $
     71,378,953
                     
Liabilities in Excess of Other Assets  - (0.50)%
       
        (353,503)
                     
 
Net Assets - 100.00%
         
 $
     71,025,450
                     

Non-income producing investment
         
§ 
Represents 7 day effective yield on March 31, 2021.
       
(a)
Counterparty is Interactive Brokers LLC.
         
                     
                     
                     
                     
                     
                     
                     
                     
                     
                   
 (Continued)

QCI Balanced Fund
             
                     
Schedule of Investments - Continued
         
(Unaudited)
               
                     
As of March 31, 2021
             
                     
                     
                     
     
Summary of Investments
         
     
by Sector
   
% of Net
       
     
(Unaudited)
   
Assets
 
Value
   
     
Corporate Bonds:
         
     
  Communication Services
1.57%
 
 $   1,112,050
   
     
  Consumer Discretionary
1.55%
 
      1,097,365
   
     
  Consumer Staples
1.55%
 
      1,099,168
   
     
  Energy
   
0.80%
 
        569,884
   
     
  Financials
   
5.87%
 
      4,172,695
   
     
  Industrials
   
3.18%
 
      2,257,192
   
     
  Information Technology
3.15%
 
      2,236,997
   
     
  Utilities
   
1.18%
 
        841,069
   
     
Federal Agency Obligations:
         
     
  Financials
   
12.11%
 
      8,601,652
   
     
United States Treasury Notes
4.95%
 
      3,519,165
   
     
Municipal Bonds
1.85%
 
      1,315,745
   
     
Preferred Stock:
         
     
  Utilities
   
0.77%
 
        544,062
   
     
Common Stocks:
         
     
  Communication Services
4.73%
 
      3,358,731
   
     
  Consumer Discretionary
7.03%
 
      4,994,638
   
     
  Consumer Staples
3.23%
 
      2,292,008
   
     
  Energy
   
3.44%
 
      2,444,690
   
     
  Financials
   
10.24%
 
      7,271,501
   
     
  Health Care
 
7.99%
 
      5,673,763
   
     
  Industrials
   
4.68%
 
      3,322,633
   
     
  Information Technology
9.39%
 
      6,670,696
   
     
  Utilities
   
1.04%
 
        740,978
   
     
Exchange-Traded Products:
         
     
  Fixed Income
1.43%
 
      1,014,146
   
     
  Materials
   
5.26%
 
      3,734,031
   
     
Real Estate Investment Trust
0.81%
 
        577,050
   
     
Call Option Purchased
0.18%
 
        126,000
   
     
Short-Term Investment
2.52%
 
      1,791,044
   
     
Liabilities in Excess of Other Assets
-0.50%
 
       (353,503)
   
     
Total Net Assets
100.00%
 
 $ 71,025,450
   
                     
                     
                     
                     
                     
                     
                     
                     
                     
                     
See Notes to Financial Statements
         

QCI Balanced Fund
   
       
Statement of Assets and Liabilities
   
(Unaudited)
   
       
As of March 31, 2021
   
       
Assets:
   
Investments, at value (cost $59,881,345)
$
  71,378,953
Receivables:
   

Fund shares sold  
          6,535

Dividends and interest  
      125,331
Prepaid expenses:
   

Registration and filing fees  
        13,709

Fund accounting fees  
          2,330
       
Total assets
 
  71,526,858
       
Liabilities:
   
Due to broker
 
      248,296
Payables:
   

Investments purchased  
      192,714

Fund shares purchased  
            675
Accrued expenses:
   
 
Advisory fees
 
        37,938
 
Professional fees
 
        15,767
 
Shareholder fulfillment fees
 
          1,625
 
Custody fees
 
          1,325
 
Insurance fees
 
            721
 
Security pricing fees
 
            472
 
Trustee fees and meeting expenses
 
            460
 
Miscellaneous expenses
 
            439
 
Interest expense
 
            384
 
Compliance fees
 
            370
 
Administration fees
 
            222
       
Total liabilities
 
      501,408
       
Net Assets
 $
  71,025,450
       
Net Assets Consist of:
   
Paid in Interest
 $
  56,075,199
Distributable Earnings
 
  14,950,251
       
Total Net Assets
 $
  71,025,450
Institutional Class Shares Outstanding, no par value (unlimited authorized shares)
 
   5,352,232
Net Asset Value, Maximum Offering Price and Redemption Price Per Share
 $
          13.27
       
       
       
       
       
       
       
See Notes to Financial Statements
   

QCI Balanced Fund
   
       
Statement of Operations
   
(Unaudited)
   
       
For the fiscal period ended March 31, 2021
   
       
Investment Income:
   
Dividends (net of foreign withholding tax $12,669)
$
      325,973
Interest
 
      198,069
       
 
Total Investment Income
 
      524,042
       
Expenses:
   
Advisory fees (Note 2)
 
      255,075
Administration fees (Note 2)
 
        39,249
Professional fees
 
        19,234
Registration and filing fees
 
        18,648
Fund accounting fees (Note 2)
 
        17,011
Transfer agent fees (Note 2)
 
        10,500
Custody fees (Note 2)
 
         9,423
Shareholder fulfillment expenses
 
         7,660
Compliance service fees (Note 2)
 
         6,370
Trustee fees and meeting expenses (Note 3)
 
         4,550
Security pricing fees
 
         4,324
Miscellaneous expenses (Note 2)
 
         2,184
Insurance fees
 
         2,019
Interest expense
 
            648
       
Total Expenses
 
      396,895
       
Fees waived by the Advisor (Note 2)
 
       (52,616)
       
Net Expenses
 
      344,279
       
Net Investment Income
 
      179,763
       
Realized and Unrealized Gain on Investments
   
       
Net realized gain from:
   
 
Investment transactions and options written
 
   3,739,925
 
Capital gain distributions from underlying funds
 
            417
Total net realized gain
 
   3,740,342
       
Net change in unrealized appreciation on investments
 
   2,550,472
       
Net Realized and Unrealized Gain on Investments
 
   6,290,814
       
Net Increase in Net Assets Resulting from Operations
$
   6,470,577
       
       
       
       
       
See Notes to Financial Statements
   

QCI Balanced Fund
           
                     
Statements of Changes in Net Assets
           
               
March 31,

September 30,
For the fiscal year or period ended
     
2021 (a)
 
2020
                     
Operations:
             
Net investment income
   
 $
       179,763
 $
       600,076
Net realized gain from investment transactions and options written
 
    3,739,925
 
    3,452,419
Capital gain distributions from underlying funds
     
             417
 
               -
Net change in unrealized appreciation on investments
         
   
and options written
     
    2,550,472
 
    1,607,690
                     
Net Increase in Net Assets Resulting from Operations
   
    6,470,577
 
    5,660,185
                     
Distributions to Shareholders
     
   (3,901,408)
 
   (1,138,419)
                     
Decrease in Net Assets Resulting from Distributions
   
   (3,901,408)
 
   (1,138,419)
                     
Beneficial Interest Transactions:
           
Shares sold
       
    6,296,713
 
    8,027,087
Reinvested dividends and distributions
     
    3,890,441
 
    1,133,354
Shares repurchased
     
 (10,408,990)
 
   (8,343,136)
                     
Increase (Decrease) in Net Assets from Beneficial Interest Transactions
 
      (221,836)
 
       817,305
                     
Net Increase in Net Assets
     
    2,347,333
 
    5,339,071
                     
Net Assets:
             
Beginning of period
     
  68,678,117
 
  63,339,046
End of period
     
 $
  71,025,450
 $
  68,678,117
                     
Institutional Share Class Information:
           
Shares sold
       
       483,492
 
       649,493
Reinvested distributions
     
       303,655
 
         93,531
Shares repurchased
     
      (793,796)
 
      (692,890)
                     
Net Increase (Decrease) in Shares of Beneficial Interest
   
         (6,649)
 
         50,134
                     
(a)
Unaudited.
             
                     
                     
                     
                     
                     
                     
                     
                     
                     
                     
                     
                     
                     
                     
See Notes to Financial Statements
           

QCI Balanced Fund
                     
                               
Financial Highlights
                     
         
Institutional Class Shares
For a share outstanding during each
March 31,
 
September 30,
of the fiscal years or period ended
 
2021
(f)
2020
 
2019
 
2018
 
2017
 
                               
Net Asset Value, Beginning of Period
 $
   12.82
  $
   11.93
  $
   12.81
  $
   11.68
  $
  10.95
 
                               
Income from Investment Operations:
                     
Net investment income (b)
 
0.03
 
0.11
 
0.15
 
0.12
 
0.10
 
Net realized and unrealized gain
                     
 
on securities
 
1.16
 
0.99
 
0.27
 
1.13
 
0.73
 
                               
Total from Investment Operations
 
1.19
 
1.10
 
0.42
 
1.25
 
0.83
 
                               
Less Distributions to Shareholders:
                     
Net investment income
 
(0.04)
 
(0.11)
 
(0.24)
 
(0.12)
 
   (0.10)
 
Net realized gains
 
    (0.70)
 
    (0.10)
 
    (1.06)
 
        -
 
       -
 
                               
Total from Distributions to Shareholders
 
(0.74)
 
(0.21)
 
(1.30)
 
(0.12)
 
   (0.10)
 
                               
Net Asset Value, End of Period
 $
   13.27
  $
   12.82
  $
   11.93
  $
   12.81
  $
  11.68
 
                               
Total Return (e)
   
9.47%
(h)
9.38%
 
4.38%
 
10.76%
 
7.59%
 
                               
Net Assets, End of Period (in thousands)
 $
  71,025
  $
  68,678
  $
 63,339
  $
 63,474
  $
 60,315
 
                               
Ratios of:
                         
Gross Expenses to Average Net Assets (a)(d)
1.11%
(g)
1.15%
 
1.17%
 
1.14%
 
1.19%
 
Net Expenses to Average Net Assets (a)
 
0.97%
(g)
0.97%
 
0.97%
 
1.00%
 
1.00%
 
Net Investment Income to Average Net Assets (a)(c)
0.50%
(g)
0.92%
 
1.29%
 
0.99%
 
0.86%
 
                               
Portfolio turnover rate
 
26.14%
(h)
47.81%
 
48.59%
 
43.92%
 
29.19%
 
                               
                               
                               
                               
(a)
Does not include expenses of the investment companies in which the Fund invests.
     
(b)
Calculated using average shares method.
                     
(c)
Recognition of net investment income by the Fund is affected by the timing of the declaration of dividends by the underlying investment companies in which the Fund invests.
(d)
Represents the ratio of expenses to average net assets absent fee waivers and/or expense reimbursements by the Advisor.
(e)

Total returns shown are historical in nature and assume changes in share price, reinvestment of dividends and capital gains distributions, if any, and excludes the effect of applicable sales charges and redemption fees. Had the Advisor not waived a portion of its fees, total returns would have been lower.
(f)
Unaudited.
                       
(g)
Annualized.
                       
(h)
Not annualized.
                     
                               
                               
                               
                               
See Notes to Financial Statements
                     

QCI Balanced Fund

Notes to Financial Statements
(Unaudited)

As of March 31, 2021

1.  Organization and Significant Accounting Policies

The QCI Balanced Fund (the “Fund”) is a series of the Starboard Investment Trust (the “Trust”). The Trust is organized as a Delaware statutory trust and is registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as an open-end management investment company.

The Fund is a separate, diversified series of the Trust and commenced operations on January 30, 2014. The investment objective of the Fund is to balance current income and principal conservation with the opportunity for long-term growth.  The Fund seeks to achieve its investment objective by investing in a diverse portfolio of corporate, agency, and U.S. Government fixed income securities, preferred stock, common stock of primarily large and mid-capitalization issuers, and derivative securities.  Allocation to equity and fixed income securities will range from 25%-75% of assets.
The following is a summary of significant accounting policies consistently followed by the Fund.  The policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”).  The Fund follows the accounting and reporting guidance in the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification 946 “Financial Services – Investment Companies,” and Financial Accounting Standards Update (“ASU”) 2013-08.

Investment Valuation
The Fund’s investments in securities are carried at fair value.  Securities listed on an exchange or quoted on a national market system are valued at the last sales price as of 4:00 p.m. Eastern Time. Securities traded in the NASDAQ over-the-counter market are generally valued at the NASDAQ Official Closing Price. Other securities traded in the over-the-counter market and listed securities for which no sale was reported on that date are valued at the most recent bid price. Securities and assets for which representative market quotations are not readily available (e.g., if the exchange on which the portfolio security is principally traded closes early or if trading of the particular portfolio security is halted during the day and does not resume prior to the Fund’s net asset value calculation) or which cannot be accurately valued using the Fund’s normal pricing procedures are valued at fair value as determined in good faith under policies approved by the Trustees.  A portfolio security’s “fair value” price may differ from the price next available for that portfolio security using the Fund’s normal pricing procedures.  Instruments with maturities of 60 days or less are valued at amortized cost, which approximates market value.

Fair Value Measurement
Various inputs are used in determining the value of the Fund's investments.  These inputs are summarized in the three broad levels listed below:
Level 1: quoted prices in active markets for identical securities
Level 2: other significant observable inputs (including quoted prices for similar securities and identical securities in inactive markets, interest rates, credit risk, etc.)
Level 3: significant unobservable inputs (including the Fund’s own assumptions in determining fair value of investments)

The availability of observable inputs can vary from security to security and is affected by a wide variety of factors, including, for example, the type of security, whether the security is new and not yet established in the marketplace, the liquidity of markets, and other characteristics particular to the security. To the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgment. Accordingly, the degree of judgment exercised in determining fair value is greatest for instruments categorized in Level 3.

The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety, is determined based on the lowest level input that is significant to the fair value measurement in its entirety.



(Continued)

QCI Balanced Fund

Notes to Financial Statements
(Unaudited)

As of March 31, 2021

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. The following table summarizes the inputs as of March 31, 2021 for the Fund’s assets measured at fair value:

QCI Balanced Fund
   
Investments in Securities (a)
 
Total
 
Level 1
 
Level 2
 
Level 3
Assets
               
Corporate Bonds*
$
13,386,420
$
-
$
13,386,420
$
-
Federal Agency Obligations
 
8,601,652
 
-
 
8,601,652
 
-
United States Treasury Notes
 
3,519,165
 
-
 
3,519,165
 
-
Municipal Bonds
 
1,315,745
 
-
 
1,315,745
 
-
Preferred Stock
 
544,062
 
544,062
 
-
 
-
Common Stocks*
 
36,769,638
 
36,769,638
 
-
 
-
Exchange-Traded Products*
 
4,748,177
 
4,748,177
 
-
 
-
Real Estate Investment Trust
 
577,050
 
577,050
 
-
 
-
Call Options Purchased
 
126,000
 
126,000
 
-
 
-
Short-Term Investment
 
1,791,044
 
1,791,044
 
-
 
-
Total Assets
$
71,378,953
$
44,555,971
$
26,822,982
$
-
                 
                 
 *    Refer to the Schedule of Investments for industry classification.
(a)
The Fund held no Level 3 securities during the fiscal period ended March 31, 2021.

Foreign Currency Translation
Portfolio securities and other assets and liabilities denominated in foreign currencies are translated into U.S. dollars based on the exchange rate of such currencies against U.S. dollars on the date of valuation.  Purchases and sales of securities and income items denominated in foreign currencies are translated into U.S. dollars at the exchange rate in effect on the transaction date.

The Fund does not separately report the effect of changes in foreign exchange rates from changes in market prices on securities held.  Such changes are included in net realized and unrealized gain or loss from investments.

Realized foreign exchange gains or losses arise from sales of foreign currencies, currency gains or losses realized between the trade and settlement dates on securities transactions and the difference between the recorded amounts of dividends, interest, and foreign withholding taxes, and the U.S. dollar equivalent of the amounts actually received or paid.  Net unrealized foreign exchange gains and losses arise from changes in foreign exchange rates on foreign denominated assets and liabilities other than investments in securities held at the end of the reporting period.  These amounts can be found on the Statement of Operations.

Investment Transactions and Investment Income
Investment transactions are accounted for as of the date purchased or sold (trade date).  Dividend income is recorded on the ex-dividend date.  Interest income is recorded on the accrual basis and includes accretion/amortization of discounts and premiums using the effective interest method.  Gains and losses are determined on the identified cost basis, which is the same basis used for Federal income tax purposes.

Expenses
The Fund bears expenses incurred specifically on its behalf as well as a portion of Trust level expenses, which are allocated according to methods reviewed annually by the Board of Trustees.


(Continued)

QCI Balanced Fund

Notes to Financial Statements
(Unaudited)

As of March 31, 2021

Distributions
The Fund may declare and distribute dividends from net investment income (if any), quarterly.  Distributions from capital gains (if any) are generally declared and distributed annually. Dividends and distributions to shareholders are recorded on ex-date.

Estimates
The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and the disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of increases and decreases in the net assets from operations during the reporting period.  Actual results could differ from those estimates.

Federal Income Taxes
No provision for income taxes is included in the accompanying financial statements, as the Fund intends to distribute to shareholders all taxable investment income and realized gains and otherwise comply with Subchapter M of the Internal Revenue Code applicable to regulated investment companies.

2.
Transactions with Related Parties and Service Providers

Advisor
The Fund pays a monthly fee to QCI Asset Management, Inc. (the “Advisor”) calculated at the annual rate of 0.72% of the Fund’s average daily net assets.

The Advisor has entered into a contractual agreement (the “Expense Limitation Agreement”) with the Trust, on behalf of the Fund, under which it has agreed to waive or reduce its fees and to assume other expenses of the Fund, if necessary, in amounts that limit the Fund’s total operating expenses (exclusive of (i) any front-end or contingent deferred loads; (ii) brokerage fees and commissions, (iii) acquired fund fees and expenses; (iv) fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including, for example, option and swap fees and expenses); (v) borrowing costs (such as interest and dividend expense on securities sold short); (vi) taxes; and (vii) extraordinary expenses, such as litigation expenses (which may include indemnification of Fund officers and Trustees and contractual indemnification of Fund service providers (other than the Advisor)) to not more than 0.97% of the average daily net assets of the Fund.  The current term of the Expense Limitation Agreement remains in effect until January 31, 2022.  While there can be no assurance that the Expense Limitation Agreement will continue after that date, it is expected to continue from year-to-year thereafter.  The Advisor cannot recoup any amounts previously waived or reimbursed.

For the fiscal period ended March 31, 2021, $255,075 in advisory fees were incurred, and $52,616 of fees were waived by the Advisor.

Administrator
The Fund pays a monthly fee to The Nottingham Company (the “Administrator”) based upon the average daily net assets of the Fund and calculated at the annual rates as shown in the schedule below subject to a minimum of $2,000 per month.  The Administrator also receives a fee to procure and pay the Fund’s custodian, as additional compensation for fund accounting and recordkeeping services, and additional compensation for certain costs involved with the daily valuation of securities and as reimbursement for out-of-pocket expenses. The Administrator also receives a miscellaneous compensation fee for peer group, comparative analysis, and compliance support totaling $350 per month. As of March 31, 2021, the Administrator received $2,184 in miscellaneous reporting expenses.




(Continued)

QCI Balanced Fund

Notes to Financial Statements
(Unaudited)

As of March 31, 2021

A breakdown of the fees is provided in the following table:

Administration Fees*
Custody Fees*
Fund
Accounting
Fees
(minimum
monthly)
 
Fund
Accounting
Fees
(asset-
based fee)
Blue Sky
Administration
Fees (annual)
 
Average Net Assets
Annual
Rate
 
Average Net Assets
Annual
Rate
First $250 million
0.100%
First $200 million
0.020%
 $2,250
 0.01%
 $150 per state
Next $250 million
0.080%
Over $200 million
0.009%
     
Next $250 million
0.060%
         
Next $250 million
0.050%
*Minimum monthly fees of $2,000 and $417 for Administration and Custody, respectively.
Next $1 billion
0.040%
       Over $2 billion
0.030%

The Fund incurred $39,249 in administration fees, $9,423 in custody fees, and $17,011 in fund accounting fees for the fiscal period ended March 31, 2021.

Compliance Services
During the fiscal period ended March 31, 2021, The Nottingham Company, Inc. served as the Trust’s compliance services provider including services as the Trust’s Chief Compliance Officer.  The Nottingham Company, Inc. is entitled to receive customary fees from the Fund for its services pursuant to the Compliance Services Agreement with the Fund.

Transfer Agent
Nottingham Shareholder Services, LLC (“Transfer Agent”) serves as transfer, dividend paying, and shareholder servicing agent for the Fund.  For its services, the Transfer Agent is entitled to receive compensation from the Fund pursuant to the Transfer Agent’s fee arrangements with the Fund.  The Fund incurred $10,500 in transfer agent fees during the fiscal period ended March 31, 2021.

Distributor
Capital Investment Group, Inc. (the “Distributor”) serves as the Fund’s principal underwriter and distributor.

For the period from October 1, 2020 through December 31, 2020, the Distributor received $5,000 per year paid in monthly installments for services provided and expenses assumed.

Effective January 1, 2021, the Distributor receives $6,500 per year paid in monthly installments for services provided and expenses assumed.  Additional expenses may be incurred for processing fees during the year.  This expense is included in the shareholder fulfillment expenses on the Statement of Operations.

3.   Trustees and Officers

The Trust is governed by the Board of Trustees, which is responsible for the management and supervision of the Fund.  The Trustees meet periodically throughout the year to review contractual agreements with companies that furnish services to the Fund; review performance of the Advisor and the Fund; and oversee activities of the Fund.  Officers of the Trust and Trustees who are interested persons of the Trust or the Advisor will receive no salary or fees from the Trust.  Each Trustee who is not an “interested person” of the Trust or the Advisor within the meaning of the Investment Company Act of 1940, as amended (the “Independent Trustee”) receives $2,000 per series per year, $200 per meeting attended, and $500 per series per special meeting related to contract renewal issues.  The Trust reimburses each Trustee and officer of the Trust for his or her travel and other expenses related to attendance of Board meetings.  The Trust reimbursed each Trustee and officer of the Trust for his or her travel and other expenses related to attendance of Board meetings.  Additional fees were incurred during the year as special meetings were necessary in addition to the regularly scheduled meetings of the Board of Trustees.


(Continued)

QCI Balanced Fund

Notes to Financial Statements
(Unaudited)

As of March 31, 2021

Certain officers of the Trust may also be officers of the Administrator.

4.   Purchases and Sales of Investment Securities

For the fiscal period ended March 31, 2021, the aggregate cost of purchases and proceeds from sales of investment securities (excluding short-term securities) were as follows:

Purchases of Securities
 
Proceeds from Sales of Securities
$20,672,901
 
$18,065,314

Purchases of Government
Securities
 
Proceeds from Sales of Government
Securities
 $5,520,384
 
   $3,420,000

5.   Federal Income Tax

Distributions are determined in accordance with Federal income tax regulations, which differ from GAAP, and, therefore, may differ significantly in amount or character from net investment income and realized gains for financial reporting purposes.  Financial reporting records are adjusted for permanent book/tax differences to reflect tax character but are not adjusted for temporary differences.

Management reviewed the Fund’s tax positions taken on federal income tax returns for the open tax years ended from September 30, 2018 through September 30, 2020, and through the period ended March 31, 2021, and determined the Fund does not have a liability for uncertain tax positions.  The Fund recognizes interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statement of Operations.  During the open tax years/period, the Fund did not incur any interest or penalties.

Distributions during the fiscal year/period ended were characterized for tax purposes as follows:

 
Distributions from
For the Fiscal Year
Or Period Ended
 
 
Ordinary Income
Long-Term-
Capital Gains
03/31/2021
 
                 $      3,901,408
$                -
09/30/2020
 
                 $         600,421
$     537,998

 At March 31, 2021, the tax-basis cost of investments and components of distributable earnings were as follows:

Cost of Investments
 
 $   59,881,345
     
Unrealized Appreciation
 
 $   12,160,468
Unrealized Depreciation
 
     (662,860)
Net Unrealized Appreciation
 
$   11,497,608
     

6.  Commitments and Contingencies

Under the Trust’s organizational documents, its officers and Trustees are indemnified against certain liabilities arising out of the performance of their duties to the Fund.  In addition, in the normal course of business, the Trust entered into contracts with its service providers, on behalf of the Fund, and others that provide for general indemnifications.  The Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund.  The Fund expects risk of loss to be remote.


(Continued)

QCI Balanced Fund

Notes to Financial Statements
(Unaudited)

As of March 31, 2021

7.  Beneficial Ownership

The beneficial ownership, either directly or indirectly, of 25% or more of the voting securities of a fund creates a presumption of control of a fund, under Section 2(a)(9) of the Investment Company Act of 1940.  As of March 31, 2021, Charles Schwab held 48.73% of the Fund. The Fund has no knowledge as to whether all or any portion of the shares owned of record by Charles Schwab are also owned beneficially.

8.   Subsequent Events

In accordance with GAAP, management has evaluated the need for disclosures and/or adjustments resulting from subsequent events through the date of issuance of these financial statements.  Management has concluded there are no additional matters, other than those noted above, requiring recognition or disclosure.

QCI Balanced Fund

Additional Information
(Unaudited)

As of March 31, 2021

1.
Proxy Voting Policies and Voting Record

A copy of the Advisor’s Proxy and Corporate Action Voting Policies and Procedures is included as Appendix B to the Fund’s Statement of Additional Information and is available, without charge, upon request, by calling 800-773-3863, and on the website of the Securities and Exchange Commission (“SEC”) at http://www.sec.gov.  Information regarding how the Fund voted proxies relating to portfolio securities during the most recent 12-month period ended June 30 is available (1) without charge, upon request, by calling the Fund at the number above and (2) on the SEC’s website at http://www.sec.gov.

2.
Quarterly Portfolio Holdings

The Fund files its complete schedule of portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-PORT.  The Fund’s Forms N-PORT are available on the SEC’s website at http://www.sec.gov.  You may also obtain copies without charge, upon request, by calling the Fund at 800-773-3863.

3.
Tax Information

We are required to advise you within 60 days of the Fund’s fiscal year-end regarding federal tax status of certain distributions received by shareholders during each fiscal year.  The following information is provided for the Fund’s fiscal period ended March 31, 2021.

During the fiscal period ended March 31, 2021, the Fund paid $3,901,408 in income distributions but no long-term capital gain distributions.

Dividend and distributions received by retirement plans such as IRAs, Keogh-type plans, and 403(b) plans need not be reported as taxable income.  However, many retirement plans may need this information for their annual information meeting.

4.
Schedule of Shareholder Expenses

As a shareholder of the Fund, you incur ongoing costs, including management fees; distribution and/or service (12b-1) fees; and other Fund expenses. This Example is intended to help you understand your ongoing costs (in dollars) of investing in the Fund and to compare these costs with the ongoing costs of investing in other mutual funds.

The Example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period from October 1, 2020 through March 31, 2021.

Actual Expenses – The first line of the table below provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (e.g., an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the first line under the heading entitled “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.

Hypothetical Example for Comparison Purposes – The second line of the table below provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare the ongoing costs of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of the other funds.

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any transactional costs, such as sales charges (loads), redemption fees, or exchange fees. Therefore, the second line of the table is useful in comparing ongoing costs only and will not help you determine the relative total costs of owning different funds. In addition, if these transactional costs were included, your costs would have been higher.


(Continued)

QCI Balanced Fund

Additional Information
(Unaudited)

As of March 31, 2021

Institutional Class Shares
Beginning
Account Value
October 1, 2020
Ending
Account Value
March 31, 2021
Expenses Paid
During Period*
Actual
Hypothetical (5% annual return before expenses)
     
$1,000.00
$1,094.70
$5.07
$1,000.00
$1,020.09
$4.89
*Expenses are equal to the average account value over the period multiplied by the Fund’s annualized expense ratio of 0.97%, multiplied by 182/365 (to reflect the one-half year period).






ITEM 2.
CODE OF ETHICS.
Not applicable.

ITEM 3.
AUDIT COMMITTEE FINANCIAL EXPERT.
Not applicable.

ITEM 4.
PRINCIPAL ACCOUNTANT FEES AND SERVICES.
Not applicable.

ITEM 5.
AUDIT COMMITTEE OF LISTED REGISTRANTS.
Not applicable.

ITEM 6.
SCHEDULE OF INVESTMENTS.
A copy of Schedule I - Investments in securities of unaffiliated issuers as of the close of the reporting period is included as part of the report to shareholders filed under Item 1 of this Form.

ITEM 7.
DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
Not applicable.

ITEM 8.
PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
Not applicable.


ITEM 9.
PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.
Not applicable.

ITEM 10.
SUBMISSION OF MATTERS TO A VOTE OF SECURITYHOLDERS.
None.

Item 11.
CONTROLS AND PROCEDURES.
(a)
The President and Principal Executive Officer and the Treasurer and Principal Financial Officer have concluded that the registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) are effective based on their evaluation of these disclosure controls and procedures required by Rule 30a-3(b) under the Investment Company Act of 1940 and Rules 13a-15(b) or 15d-15(b) under the Exchange Act of 1934, as of a date within 90 days of the filing of this report.
(b)
There were no changes in the registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.

ITEM 12.
DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
Not applicable.

ITEM 13.
EXHIBITS.
(a)(1)
Not applicable.
(a)(2)
Certifications pursuant to Rule 30a-2(a) under the Investment Company Act of 1940 are filed herewith.
(a)(3)
Not applicable.
(a)(4)
Not applicable.
(b)
Certifications pursuant to Rule 30a-2(b) under the Act and Section 906 of the Sarbanes-Oxley Act of 2002 are filed herewith.



SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 
Starboard Investment Trust
     
     
    /s/ Katherine M. Honey
 
By:
 
Katherine M. Honey
President and Principal Executive Officer
     
 
Date:
June 9, 2021
     



Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.


     
    /s/ Katherine M. Honey
 
By:
 
Katherine M. Honey
President and Principal Executive Officer
     
 
Date:
June 9, 2021
     
     
    /s/ Ashley H. Lanham
 
By:
Ashley H. Lanham
Treasurer, Principal Financial Officer, and Principal Accounting Officer
     
 
Date:
June 9, 2021
 











Exhibit 13(a)(2)
CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE 1940 ACT AND
SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002


I, Katherine M. Honey, certify that:

1.
I have reviewed this report on Form N-CSR of the QCI Balanced Fund, a series of the Starboard Investment Trust;

2.
Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash follows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4.
The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal controls over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a.
Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b.
Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c.
Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented int his report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

d.
Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.
The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

a.
All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

b.
Any fraud, whether or not materials, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.


 
By:
/s/ Katherine M. Honey
   
Katherine M. Honey
President and Principal Executive Officer
     
 
Date:
June 9, 2021



Exhibit 13(a)(2)
CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE 1940 ACT AND
SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002


I, Ashley H. Lanham, certify that:

1.
I have reviewed this report on Form N-CSR of the QCI Balanced Fund, a series of the Starboard Investment Trust;

2.
Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash follows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4.
The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal controls over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a.
Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b.
Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c.
Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented int his report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

d.
Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.
The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

a.
All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

b.
Any fraud, whether or not materials, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.


 
By:
/s/ Ashley H. Lanham
   
Ashley H. Lanham
Treasurer, Principal Financial Officer, and Principal Accounting Officer
     
 
Date:
June 9, 2021

Exhibit 13(b)

CERTIFICATION
PURSUANT TO RULE 30A-2(B) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

In connection with the semi-annual report of the QCI Balanced Fund (the “Fund”), a series of the Starboard Investment Trust on Form N-CSR for the period ended March 31, 2021, as filed with the Securities and Exchange Commission (the “Report”), the undersigned, Katherine M. Honey, President and Principal Executive Officer of the Fund, does hereby certify, to her knowledge, that:


(1)
The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and


(2)
The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Fund.


 
By:
/s/ Katherine M. Honey
    Katherine M. Honey
President and Principal Executive Officer
     
 
Date:
June 9, 2021



A signed original of this written statement required by Section 906 has been provided to the Starboard Investment Trust and will be retained by the Starboard Investment Trust and furnished to the Securities and Exchange Commission or its staff upon request.  This certification is being furnished to the Commission pursuant to 18 U.S.C. ss. 1350 and is not being filed as part of the Form N-CSR with the Commission.




Exhibit 13(b)

CERTIFICATION
PURSUANT TO RULE 30A-2(B) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

In connection with the semi-annual report of the QCI Balanced Fund (the “Fund”), a series of the Starboard Investment Trust on Form N-CSR for the period ended March 31, 2021, as filed with the Securities and Exchange Commission (the “Report”), the undersigned, Ashley H. Lanham, Treasurer, Principal Financial Officer, and Principal Accounting Officer of the Fund, does hereby certify, to her knowledge, that:


(1)
The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and


(2)
The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Fund.


 
By:
/s/ Ashley H. Lanham
   
Ashley H. Lanham
Treasurer, Principal Financial Officer, and Principal Accounting Officer
     
 
Date:
June 9, 2021




A signed original of this written statement required by Section 906 has been provided to the Starboard Investment Trust and will be retained by the Starboard Investment Trust and furnished to the Securities and Exchange Commission or its staff upon request.  This certification is being furnished to the Commission pursuant to 18 U.S.C. ss. 1350 and is not being filed as part of the Form N-CSR with the Commission.