SecProbe.io

CORRESP
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51
Madison Avenue

New
York, New York 10010

April
3, 2025

Eileen
Smiley

U.S.
Securities and Exchange Commission

Division
of Investment Management

100
F Street, N.E.

Washington,
D.C. 20549

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

Dear
Ms. Smiley,

This
letter responds to the comments you provided telephonically on January 22, 2025, regarding the Registrant’s filing on December
13, 2024, of Post-Effective Amendment No. 126 to its registration statement on Form N-1A under the Securities Act of 1933 (the “1933
Act”) and Amendment No. 132 to its registration statement on Form N-1A under the Investment Company Act of 1940 (the “1940
Act”) (the “Registration Statement”). The Registration Statement relates to the NYLI MacKay Muni Short Duration
ETF, a new series of the Registrant (the “Fund”). Unless otherwise defined, capitalized terms used herein shall have
the meanings ascribed to them in the Registration Statement.

Prospectus

Comment
1: Please complete all fields in the Registration Statement and provide a copy of the Fund’s completed Fees and Expenses of the
Fund disclosures to the staff in advance of the Fund’s final filing.

Response:
The Registrant confirms it will add any information omitted in the Registration Statement. A copy of the Fund’s Fees and Expenses
of the Fund disclosures are attached in Appendix 1.

Comment
2: Comments on disclosure in one location apply to similar disclosures throughout the Registration Statement.

Response:
The Registrant confirms it will incorporate changes to the disclosure where applicable.

    1

Comment
3: As required by Form N-1A, please bold the second sentence in the Fund’s Fees and Expenses of the Fund disclosure.

Response:
The Registrant has made the requested change.

Comment
4: Please supplementary confirm that the expense waiver agreement disclosed in the footnote to the Fund’s Annual Fund Operating
Expenses table will be in place for at least a year.

Response:
The Registrant confirms that the expense waiver agreement disclosed in the footnote to the Fund’s Annual Fund Operating Expenses
table will be in place for at least a year.

Comment
5: The Fund’s Principal Investment Strategies disclosure states that the Subadvisor’s “investment process begins with
an assessment of macro factors that may impact the Municipal Bond market, including tax rates, U.S. Treasury rates, and global
economic data, as well as other regulatory, tax, governmental, and technical factors that may impact the Municipal Bond market.”
(emphasis added) Please confirm that all material factors are listed and if so, consider removing “including” from the sentence.

Response:
Consistent with the requirements of Form N-1A, the Fund’s Principal Investment Strategies disclosure describes how the Fund intends
to achieve its investment objective and the Fund’s principal investment strategies. In addition to the principal strategies listed
in the disclosure, the Subadvisor may also take into account other factors and information, and, therefore, the Registrant has kept the
word “including” in the sentence. The Registrant has added additional disclosure about certain factors the Fund’s Subadvisor
considers as part of its investment process, which is described below in response to Comment 6.

Comment
6: The Fund’s Principal Investment Strategies disclosure states that the investment process includes an assessment of “technical
factors that may impact the Municipal Bond market.” Please add disclosure about these technical factors.

Response:
The Registrant has revised the disclosure to clarify that the Subadvisor’s assessment of technical factors that may impact the
Municipal Bond market includes an analysis of “the supply and demand of municipal instruments, and factors that may impact the
future supply and demand of municipal bonds.”

    2

Comment
7: The Fund’s Principal Investment Strategies disclosure states that the investment process “includes a risk analysis that
gives consideration to a variety of security-specific risks, including but not limited to, environmental, social and governance (“ESG”)
risks that may have a material impact on the performance of a security.” Please add disclosure about the specific ESG risks that
the Fund may consider.

Response:
The Registrant has revised the disclosure to add disclosure about the ESG risks the Fund may consider as follows:

The
Subadvisor’s investment process also includes a risk analysis that gives consideration to a variety of security-specific risks
with respect to municipal bonds, including environmental, social and governance (“ESG”) risks. “ESG risks” are
defined as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material
negative impact on the value of the investment. Certain ESG factors may be more relevant for certain sectors or issuers than others.
Factors considered by the Subadvisor may include an issuer’s exposure to or management of climate risk, energy resources, community
and/or employee relations, demographic shifts, cybersecurity, regulation and financial management of policies and procedures. In addition
to proprietary research, the Subadvisor may use screening tools such as those provided by third-party providers and, to the extent available,
third-party data to identify ESG risk factors that may not have been captured through its own research. The Subadvisor’s consideration
of ESG risk is weighed against other criteria and no sectors, industries or individual issuers are explicitly excluded from the Fund.

Comment
8: In the Principal Risks section, please revise the Fund’s Focused Investment Risk disclosure to reflect the types of securities
in which the Fund may invest.

Response:
The Registrant has revised the Fund’s Focused Investment Risk to reflect the types of securities in which the Fund may invest as
follows:

Focused
Investment Risk

To
the extent that the Fund invests a large percentage of its assets in the securities of issuers within the same or group of states, territories,
commonwealths and possessions of the United States or sectors, an adverse economic, market, political or regulatory development may affect
the value of the Fund’s investments more than if the Fund were more broadly diversified. Securities of issuers within the same
or group of states, territories, commonwealths and possessions of the United States or sectors, may go through cycles of outperformance
and underperformance in comparison to each other and to the general financial markets.

Comment
9: In the Principal Risks section, please revise the Fund’s High Yield Securities Risk disclosure to align with the terminology
used for the description of high yield securities in the Principal Investment Strategies section.

Response:
The Registrant has revised the disclosure to align the terminology used for the description of high yield securities in the Fund’s
High Yield Securities Risk disclosure and the Principal Investment Strategies section.

    3

Comment
10: In the Principal Risks section, the Fund’s disclosure about Interest Rate Risk states that the “Fund may be subject to
a greater risk of rising interest rates during periods of low interest rates.” Please explain why the Fund is subject to a greater
risk of rising interest rates during periods of low interest rates.

Response:
The Registrant has deleted the sentence.

Comment
11: Please explain supplementally why Market Disruption Risk and Recent Market Events is not a principal risk of the Fund.

Response:
The Fund discloses Market Risk as a principal risk of the Fund. In addition to the Fund’s Market Risk disclosure, although not
a principal risk of the Fund, the Fund may be exposed to the impact of certain market disruptions and events. As a result, the Registrant
has included disclosures about such risks in the Fund’s Market Disruption Risk and Recent Market Events disclosure in response
to Item 9 of Form N-1A.

Comment
12: In the Prior Performance of Similar Accounts section, if there are different fees charged to different accounts included in the Composite,
please confirm the Composite performance is calculated net of the highest applicable fee for any account.

Response:
The Performance Net of Fees included in the Composite is net of the current total annual fund net operating
expense ratio of 0.40% applicable to Class I shares of the registered investment company that is included in the Composite. That expense
ratio is higher than the investment advisory fee charged to each of the other accounts included in the Composite by the Subadvisor. The
investment advisory fee charged to each of the other accounts included in the Composite by the Subadvisor, however, does not include
certain service fees, such as custody, administrative and accounting fees, for which clients contract separately and are unknown to the
Subadvisor. Therefore, actual total fees and expenses incurred by investors in the other accounts in the Composite may vary.

Comment
13: In the Prior Performance of Similar Accounts section, please confirm that Performance Net of Fees disclosed in the table reflects
the deduction of all fees and expenses paid by each included account in compliance with the Global Investment Performance Standards (“GIPS®”).

Response:
The Registrant confirms that the Subadvisor has calculated the Composite in accordance with applicable GIPS® requirements.
The Performance Net of Fees information reflects the deduction of fees and expenses as discussed in Comment 12 above.

Comment
14: Please complete all fields in the Prior Performance of Similar Accounts section and provide a copy of the section to the staff in
advance of the Fund’s final filing.

Response:
A copy of the completed Prior Performance of Similar Accounts section is attached in Appendix 2.

    4

Comment
15: Please add disclosure that, for purposes of the Fund’s fundamental policy on concentration, the Fund will consider the investments
held by any underlying fund towards the Fund’s policy on concentrating in any industry or group of industries.

Response:
The Registrant notes, as a preliminary matter, that neither the U.S. Securities and Exchange Commission (the “Commission”)
nor its staff (“Staff”) has issued public guidance or taken a public position as to how, and under what circumstances,
an acquiring fund should look through to an acquired fund’s investments for purposes of the acquiring fund’s concentration
policy. The Registrant notes further that, when the Commission does permit or require a fund to look through to investments underlying
an investment for compliance purposes, it has done so clearly through adopted rules subject to notice and public comment.1

With
regard to a fund adopting a concentration policy, the Staff has stated that Section 8(b)(1) “permits a fund to implement a concentration
policy that allows for some degree of discretion…”2 In fashioning a concentration policy for the Fund, the Registrant
considered that: i) portfolio holdings for an unaffiliated acquired mutual fund are generally not available to the Fund except monthly
with a sixty-day lag; ii) intra-month portfolio holdings of an affiliated acquired mutual fund, to the extent the Fund could obtain them,
may be deemed material non-public information, on which the Fund should not be able to trade; iii) while portfolio holdings for an acquired
exchange-traded fund are publicly available on a daily basis, such disclosure is not organized by industry classification; and iv) portfolio
holdings for any private fund are not available to the Fund. For the Fund to base its concentration policy on a look through to an acquired
fund’s portfolio holdings would therefore be impractical, overly burdensome, impossible or lead to broad inconsistencies in the
way that similar investments would be treated by the Fund.

Rather,
the Registrant believes that the most effective way to monitor the Fund’s concentration with respect to investments in acquired
funds is to rely on the acquired fund’s stated concentration policy. Accordingly, the Fund has adopted a fundamental policy on
concentration, whereby if the Fund invests in an acquired fund that has a policy to concentrate in an industry or group of industries,
the Fund will treat that entire investment as being within that industry or group of industries. The Registrant believes that this treatment
is conservative and meets the requirements of the 1940 Act. To the extent that the Registrant can enhance the clarity of the disclosure
of this policy and its implementation, it will consider any appropriate changes at the next annual update of the Registrant’s registration
statement.

1
See, e.g., Rule 2a-7(d)(3)(ii)(A) under the 1940 Act (permitting the acquisition of a repurchase agreement to be deemed
to be an acquisition of the underlying securities to meet the rule’s issuer diversification calculations); and Rule 5b-3 under
the 1940 Act (permitting the acquisition of repurchase agreement or refunded securities to be treated as an acquisition of underlying
securities for purposes of Section 5 and 12(d)(3) of the 1940 Act).

2
The First Australia Fund, Inc., No-Action Letter (pub. avail. July 29, 1999).

    5

Comment
16: With respect to the Fund’s fundamental policy on concentration, if the Fund invests in private activity securities, please
confirm the Fund will look through a private activity security to the underlying asset or activity to determine the applicable industry
of the security.

Response:
The Registrant confirms the Fund will look through a private activity security to the underlying asset or activity when determining the
applicable industry of the security.

* * * * * * * *

If
you have any questions or comments in connection with the foregoing, please contact Matthew Curtin at (212) 576.7634 or mcurtin@nylinvestments.com;
Richard Coyle of Chapman and Cutler LLP at (312) 845-3724 or rcoyle@chapman.com; or Barry Pershkow of Chapman and Cutler LLP at (202)
478-6492 or pershkow@chapman.com.

    Sincerely,

    /s/
    Matthew V. Curtin

    Matthew
    V. Curtin

    Secretary

 cc: Barry
Pershkow, Esq., Chapman and Cutler LLP

Richard
Coyle, Esq., Chapman and Cutler LLP

    6

Appendix
1

				Fees and Expenses of the Fund

				This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Shares”). Investors may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and example set forth below.

								Shareholder Fees (fees paid directly from your investment):

								None

								Annual Fund Operating Expenses (expenses that you pay each year as
a percentage of the value of your investment):

								​

								​

								​

								Management Fee

								​

								0.25

								%

								Distribution and/or Service (12b-1) Fees

								​

								0.00

								%

								Other Expenses(a)

								​

								0.19

								%

								Total Annual Fund Operating Expenses

								​

								0.44

								%

								Expense Waiver/Reimbursement(b)

								​

								0.19

								%

								Total Annual Fund Operating Expenses After Expense Waiver/Reimbursement

								​

								0.25

								%

				(a)The Fund has not yet commenced operations and Other Expenses are based on estimated amounts for the current fiscal year.

				(b)New York Life Investment Management LLC (“New York Life Investments” or “Advisor”) has contractually agreed to waive or reduce its management fee and/or reimburse expenses of the Fund in an amount that limits “Total Annual Fund Operating Expenses” (exclusive of interest, taxes, brokerage commissions, dividend payments on short sales, acquired fund fees and expenses, other expend