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CORRESP
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51 Madison Avenue

New
York, New York 10010

April
5, 2024

VIA
EDGAR

Anu
Dubey

U.S.
Securities and Exchange Commission

Division
of Investment Management

100
F Street, N.E.

Washington,
D.C. 20549

 Re: IndexIQ
                                            Active ETF Trust (File No. 333-183489 and File No. 811-22739) (the “Registrant”)

Dear
Ms. Dubey:

This
letter responds to your comments made telephonically on January 23, 2024, regarding the Registrant’s filing on December 18, 2023,
of Post-Effective Amendment No. 113 to its Registration Statement under the Securities Act of 1933 (the “1933 Act”)
and Amendment No. 119 to its Registration Statement under the Investment Company Act of 1940 (the “1940 Act”) (the
“Registration Statement”). The Registration Statement relates to the IQ MacKay Securitized Income ETF (the “Fund”),
a series of the Registrant. Unless otherwise defined, capitalized terms used herein shall have the meanings ascribed to them in the Registration
Statement.

Comment
1: Please supplementally confirm to the Staff that there is no ability of the Advisor to recoup waived expenses.

Response:
The Registrant confirms that the Expense Waiver/Reimbursement Agreement does not provide for the Advisor to recoup fees waived or reimbursed.

Comment
2: It appears that the Fund can invest significantly in non-agency collateralized mortgage obligations (“CMOs”) and
collateralized loan obligations (“CLOs”). Given the liquidity profile of these investments, explain how the Fund determined
that its principal investment strategy is appropriate for an open-end fund. Responses should include information concerning relevant
factors referenced in Rule 22e-4 relief (see Adopting Release, Investment Company Liquidity Risk Management Programs, Release
No. IC-32315 (2016) at pp. 154-155). The Registrant can also include general market data on these types of investments. Please also include
credit quality information about the non-agency CMOs and CLOs the Fund will invest in.

Response:
Consistent with the requirements of Rule 22e-4 under the 1940 Act and the Registrant’s liquidity risk management program, the Advisor,
together with the Subadvisor, has reviewed and assessed the Fund’s potential liquidity risk and determined that the strategy is
appropriate for an open-end fund. The factors the Advisor and Subadvisor considered as part of this review include, but are not limited
to: (i) the attributes of the investments expected to be held by the Fund, including the market size, trading volume, and liquidity of
such investments; (ii) the Fund’s expected position sizes in individual issuers; (iii) any use of borrowing for investment purposes;
and (iv) the expected composition of creation and redemption baskets.

    1

Comment
3: Consider whether the section entitled “Principal Risks” should include a separate risk factor for CLOs.

Response:
The Registrant notes that CLOs are a type of asset-backed security and the Fund’s “Asset-Backed Securities Risk” disclosure
discusses CLOs and the risks attributable to CLOs, as well as other asset-backed securities. As a result, the Registrant believes including
a separate risk factor for CLOs is not necessary and would be duplicative of existing disclosure.

Comment
4: If the Fund invests in junior and/or equity tranches of CLOs and CMOs as a principal investment strategy, please disclose that in
the section entitled “Principal Investment Strategies” and disclose corresponding principal risks.

Response:
The Registrant notes that the Fund does not anticipate investing in equity tranches of CLOs or CMOs. The Fund may invest in junior tranches
of CLOs and CMOs consistent with its disclosed investment policies and strategies.

Comment
5: The Staff notes the disclosure states, “The Fund may also invest in other fixed-income instruments, which include bonds, debt
instruments and other similar instruments…” Please identify any “other similar instruments” that are part of
the Fund’s principal investment strategies and disclose any corresponding principal risks of those investments.

Response:
The Registrant has revised the above-referenced disclosure as follows:

The
Fund may also invest in other fixed-income instruments, which include bonds, debt instruments, and money market and short-term securities
issued by various U.S. and non-U.S. public or private sector entities.

Comment
6: Please briefly disclose what “inverse floating rate debt securities” are.

Response:
The Registrant notes that the following disclosure has been added in the section entitled “Investment Strategies and Risks—Floating
and Variable Rate Securities” in the Statement of Additional Information:

The
Fund may invest in leveraged inverse floating rate debt instruments ("inverse floaters"). The interest rate on an inverse floater
resets in the opposite direction from the market rate of interest to which the inverse floater is indexed. An inverse floater may be
considered to be leveraged to the extent that its interest rate varies by a magnitude that exceeds the magnitude of the change in the
index rate of interest. The higher degree of leverage inherent in inverse floaters is associated with greater volatility in their market
values. Accordingly, the duration of an inverse floater may exceed its stated final maturity. Certain inverse floaters may be classified
as illiquid investments.

    2

Comment
7: Please briefly disclose what “mortgage dollar rolls” and “TBA securities transactions” are and disclose any
corresponding risks of mortgage dollar rolls and TBA securities transactions in the section entitled “Principal Risks.”

Response:
The Registrant notes that the following disclosures have been added in the section entitled “Summary Information—Principal
Risks” of the Prospectus:

Mortgage
Dollar Roll Transaction Risk

A
mortgage dollar roll is a transaction in which the Fund sells mortgage-related securities from its portfolio to a counterparty from whom
it simultaneously agrees to buy a similar security on a delayed delivery basis. Mortgage dollar roll transactions are subject to certain
risks, including the risk that securities returned to the Fund at the end of the roll, while substantially similar, may be inferior to
what was initially sold to the counterparty.

TBA
Securities Risk

In
a TBA securities transaction, the Fund commits to purchase certain securities for a fixed price at a future date. The principal risks
of a TBA securities transaction are that the counterparty may not deliver the security as promised and/or that the value of the TBA security
may decline prior to when the Fund receives the security.

Comment
8: Please confirm that the estimate of interest and dividend expense to be incurred on the Fund’s short positions is reflected
in the Fee Table.

Response:
The Registrant confirms that any estimated interest and dividend expense expected to be incurred on the Fund’s short positions
is reflected in the Fee Table.

Comment
9: Please add quotation marks around “duration to worst” to clarify that it is a term of art. Please also disclose the duration
that the Fund seeks to maintain.

Response:
As noted below in response to Comment 11, the Registrant has removed the reference to “duration to worst.”

Comment
10: Please disclose the Bloomberg U.S. Securitized Index (the “Index”) duration as of a recent date.

Response:
The Registrant respectfully declines to add the requested disclosure. The Registrant does not believe that including the duration of
the Index as of a specific date in the Prospectus would be useful for investors given the availability of recent information about the
duration of the Index or Fund through other sources.

Comment
11: The Staff notes the disclosure states, “Duration to worst is the duration of a bond computed using the bond’s nearest
call date or maturity, whichever comes first. This measure ignores future cash flow fluctuations due to embedded optionality.”
Please revise these sentences in plain English including what “embedded optionality” means. Consider adding a comparison
of what duration to worst measures versus what duration measures.

Response:
The Registrant has revised the disclosure about the Fund’s duration as follows:

The
Fund will generally seek to maintain a weighted average duration within 1.5 years (plus or minus) of the duration of the Bloomberg U.S.
Securitized Index. Duration is a measure used to determine the sensitivity of a security’s price to changes in interest rates.
The longer a security’s duration, the more sensitive it will be to changes in interest rates.

    3

Comment
12: The Staff notes the disclosure states, “The Fund may invest up to 20% of its total assets in securities rated below investment
grade…” Please disclose any credit quality policy with respect to the 80% bucket of the Fund’s principal investments.

Response:
The Fund has not adopted additional policies with respect to its investments within the investment grade category.

Comment
13: Please revise to clarify what “shape of the Treasury yield curve” means.

Response:
The Registrant has revised the above-referenced disclosure as follows:

Investment
selection is based on a rigorous analysis in order to gauge the security’s potential for total return, as well as its sensitivities
to changes in interest rates, volatility, the shape of the Treasury yield curve (i.e., differences in yield between securities
of different maturities), and prepayment variations.

Comment
14: Please consider reordering the risks comprising the section entitled “Principal Risks” in order of importance rather
than alphabetically.

Response:
The Registrant respectfully declines to reorder its principal risk disclosures as requested. Despite the Commission’s numerous
recent amendments to Form N-1A, Item 9(c) of Form N-1A continues to simply require that a registrant “[d]isclose the principal
risks of investing in the Fund.” Item 4(b)(1)(i) of Form N-1A requires a registrant to summarize, but not order in any particular
way, those principal risks.

Thus,
all risks disclosed pursuant to those items are “principal” risks. The Form does not require that a registrant set forth
those risks in order of materiality, or any other order. Moreover, the level of materiality of each risk factor could change as often
as on an intraday basis, i.e., what is the most material risk at one moment may not be the most material risk at the next. Accordingly,
the Registrant believes that emphasizing one risk over another may be potentially misleading to investors. In addition, that practice,
if engaged throughout a fund complex, would require an adviser to monitor the level of principal risk materiality associated with all
of the funds in the complex on a nearly constant basis. In turn, this could require frequent registration statement amendments that would
burden the funds with additional costs and, again, potentially confuse investors who might receive or otherwise view any number of supplements
that re-order risks.

Comment
15: Consider creating a separate risk factor for mortgage-related securities, rather than including in the “Asset-Backed Securities
Risk.”

Response:
The Registrant believes that mortgage-related securities have a number of risks and attributes in common with other types of asset-backed
securities and the Registrant’s existing disclosure includes clear and detailed disclosures about the risks of mortgage-related
securities. As a result, the Registrant respectfully declines to make this change.

    4

Comment
16: The Staff notes the “Money Market/Short-Term Securities Risk.” Please add money market/short-term securities to the section
entitled “Principal Investment Strategies” if these are a principal investment of the Fund.

Response:
The Registrant has revised the disclosure in the section entitled “Principal Investment Strategies” to include the following
disclosure:

The
Fund may also invest in other fixed-income instruments, which include bonds, debt instruments, and money market and short-term securities
issued by various U.S. and non-U.S. public or private sector entities.

Comment
17: Please briefly describe what option contracts are in the “Option Contracts Risk.”

Response:
The Registrant believes the current Option Contracts Risk disclosure contains the information needed by an investor to understand the
risks associated with options contracts. However, the Registrant has added the following disclosure in the section entitled “Investment
Strategies and Risks—Futures Contracts and Options on Futures Contracts” in the Statement of Additional Information:

Options.
An option is a contract in which the "holder" (the buyer) pays a certain amount (the "premium") to the "writer"
(the seller) to obtain the right, but not the obligation, to buy from the writer (in a "call") or sell to the writer (in a
"put") a specific asset at an agreed upon price (the "strike price" or "exercise price") at or before a
certain time (the "expiration date"). The holder pays the premium at inception and has no further financial obligation. The
holder of an option will benefit from favorable movements in the price of the underlying asset but is not exposed to corresponding losses
due to adverse movements in the value of the underlying asset. The writer of an option will receive fees or premiums but is exposed to
losses due to changes in the value of the underlying asset. A Fund may purchase (buy) or write (sell) put and call options on assets,
such as securities, currencies and indices of debt and equity securities and enter into closing transactions with respect to such options
to terminate an existing position.

Comment
18: The Staff notes the disclosure of “Portfolio Turnover Risk.” Please disclose frequent trading in the section entitled
“Principal Investment Strategies” given that this is a principal risk.

Response:
The Registrant notes that frequent trading and portfolio turnover is not a strategy of the Fund. Instead, portfolio turnover occurs as
a result of the implementation of the Fund’s strategies. Accordingly, the Registrant respectfully declines to add disclosure about
frequent trading to the Fund’s Principal Investment Strategies.

Comment
19: Please briefly describe what swap agreements are in the “Swap Agreements Risk.”

Response:
The Registrant notes that the following disclosure has bee added to Swap Agreements Risk:

Swap
agreements are two-party contracts entered into for a set period of time in which the parties agree to exchange payments based on some
underlying reference or asset (such as interest rates).

    5

Comment
20: The Staff notes the “Variable and Floating Rate Instruments Risk” is duplicated disclosure from the “Valuation
Risk” above. Please revise.

Response:
The Registrant has revised “Variable and Floating Rate Instruments Risk” to include the correct disclosure.

Comment
21: Please explain to the Staff whether the Predecessor Account meets the definition of a “fund” as defined in Rule 6-11(a)(2)
of Regulation S-X. If the Predecessor Account meets the definition of a “fund,” please explain how the Rule 6-11 of Regulation
S-X requirements will be met, including the supplemental financial information requirements. In your response, indicate the fiscal year
end of the Predecessor Account and what fiscal year ends and interim periods will be included. If the Predecessor Account does not meet
the definition of a “fund,” please discuss with the Staff what Predecessor Account financial information will be provided,
which may include an audited schedule of investments that complies with Article 12 of Regulation S-X and present the fair value of investments
according to FASB ASC 820.

Response:
The Predecessor Account is an account of New York Life Insurance and Annuity Corporation (NYLIAC) that is managed by the Subadvisor.
PricewaterhouseCoopers LLP (“PwC”) will audit the financial statement of the Predecessor Account, which comprises the