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EXCHANGE TRADED CONCEPTS

10900 Hefner Pointe Drive, Suite 401

Oklahoma City, Oklahoma 73120

VIA EDGAR

March 19, 2020

John Grzeskiewicz, Esq.

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Exchange Traded Concepts Trust

File Nos. 333-156529; 811-22263

Dear Mr. Grzeskiewicz:

This letter responds to comments relating
to Post-Effective Amendment No. 272 (“PEA No. 272”) to the registration statement on Form N-1A of Exchange Traded Concepts
Trust (the “Registrant”). PEA No. 272 was filed with the Securities and Exchange Commission (“SEC”) on
January 3, 2020 for the purpose of changing the name of the Trust’s FLAG-Forensic Accounting Long-Short ETF (“FLAG”)
to North Shore Dual Share Class ETF (the “ETF” or “DUAL”), as well as changing its investment objective,
investment policies and principal investment strategies. For ease of reference, set forth below are your comments followed by the
Registrant’s responses. Unless otherwise noted, capitalized terms have the same meaning as those contained in PEA No. 272.

As requested, we have delayed the effectiveness
of this registration statement to allow the SEC Staff time to review our responses, in writing, to your comments. While we appreciate
that the SEC Staff will need time to review the responses, we have been informed that FLAG’s current index provider, Vident
Financial, LLC (“Vident”), will cease calculation of the index prior to its rebalance date on March 31. Exchange Traded
Concepts LLC (“ETC”), FLAG’s investment adviser, had initially agreed with Vident that it would be able to stop
calculating the index earlier this month, upon the effectiveness of the ETF, even though Vident had planned to cease calculating
it even earlier than that. However, due to the comments the Staff has raised, Vident continues to calculate FLAG’s index
as a courtesy but, as it would be costly and time consuming , it has determined not to calculate the index for FLAG’s rebalance
or thereafter. Therefore, we are hopeful that we can resolve all of the comments from the Staff in advance of the rebalance date
because, if not, we will be forced to liquidate FLAG which, as discussed further below, was heavily discouraged by the SEC Staff
the last time it conducted an examination of ETC. We note that we are providing our responses five business days before the filing
is to go effective which, as the Staff noted in “ADI 2019-07 – Review of Certain Filings Under Automatic Effectiveness
Rules” allows both the Staff to completely consider the issues raised and assure a review of amendments in a manner that
assists a registrant in meeting its timing expectation.

We also note that, as requested by the
Staff, materials were previously provided to, and/or reviewed by, the Staff in connection with the Trust’s most recent SEC
examination as well as Board materials relating to the consideration of the changes to FLAG contemplated in PEA No. 272. Certain
of these materials are summarized below in response to the Staff’s comments.

Prospectus

General Comments: We note that the
ETF has completely changed its investment strategies. These wholesale changes are accompanied by other significant changes, including
a dropping of a subadvisor resulting in new portfolio managers and a transition from an affiliated index to an unaffiliated index.
We have the following comments concerning these changes:

 1. Comment. Please supplementally inform the staff why the Board of Trustees believes these changes are consistent
with its fiduciary duties and are in the best interests of its shareholders -- who did not vote for these changes. In your response:

 a. Explain in detail what information the Board considered, and how it weighed the information in arriving at its decision.

Response. Generally,
under federal and state law, a Board of Trustees owes fiduciary duties to shareholders by (i) acting in the best interests of funds
they oversee and avoiding self-dealing or conflicts of interest and (ii) acting in good faith with the diligence, care and skill
that an ordinary prudent person in a like position would exercise under similar circumstances and after hearing all relevant facts.

In approving the change from FLAG
to DUAL, the Board considered that, due to Vident’s determination to cease calculating the FLAG’s index, FLAG would
not be able to achieve its investment objective of tracking its index after a certain date. As a general matter, index providers
are permitted to cease calculating an index when they wish, and are under no obligation to continue calculating an index. Consequently,
the Board was made aware that, after a certain date, FLAG shareholders would be holding shares of a fund unable to achieve its
investment objective unless the Board took action.

Secondly, the Board considered
that FLAG had assets under management of approximately $7,775,641 at the time of the Board’s meeting that were not attributable
to seed capital or proprietary investments, the Board and ETC were aware that there were shareholders in FLAG who would be affected
by the future outcome of FLAG.

Third, the Board considered FLAG’s
liquidation in accordance with the liquidation policies and procedures that ETC had adopted in light of the results of the most
recent SEC examination of the Registrant and ETC, which concluded in March 2019. During its examination, the SEC Staff identified
as a deficiency that the Trust had no policies and procedures in place with respect to the Board’s review, approval and oversight
of a fund’s liquidation. The Staff observed from its examination that ETC may make a recommendation for a fund to liquidate
for economic reasons, based on whether it is no longer sustainable for ETC’s clients (generally, a fund sponsor or an index
provider) to continue to subsidize a fund. However, the Staff observed that, without policies and procedures for liquidation in
place, it was not clear with respect to the funds that liquidated that the Board considered whether the funds’ liquidation
would be in the best interests of the fund and its shareholders or that the Board had received the necessary documentation to make
such determination. In particular, the SEC Staff queried whether economic reasons were the only relevant factors in the Board’s
consideration of whether to liquidate a fund and strongly encouraged ETC to not only put policies and procedures in place for the
liquidation process, but also to consider and document what alternatives, if any, there were to liquidating a fund, such as providing
fund shareholders with another investment option or locating another sponsor to support the fund or index provider for the fund.

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Based on the foregoing, the Board
considered whether there were alternatives to liquidation of FLAG that would be in the best interest of FLAG and its shareholders.
The Board noted, despite ETC’s efforts as discussed with the Board, ETC could not locate an index provider that was willing
to provide an index or investment strategy for FLAG that was substantially similar to its current index. However, the Board was
informed that an index provider with whom ETC had an existing relationship was interested in changing FLAG’s index to the
dual share class index (the “DUAL Index”). At a special meeting, the Board was provided with materials about the DUAL
Index, including a white paper evaluating the potential benefits to shareholders of holding shares in dual-class companies. At
the meeting, the Board discussed with the DUAL Index provider these potential benefits, including a discussion regarding empirical
evidence that dual-class companies can provide value to shareholders, citing a 16% rise in dual-share class initial public offerings
from 2010-2018. The Board further considered that many dual-share class companies were not held in indexes that most ETFs track
and consequently ETF shareholders were not receiving the benefits of holding such companies. The Board considered that there was
certain criticism of dual-class companies because shareholders, like the ETF, would have limited voting power; however, they discussed
with the DUAL Index provider how the structure of dual-share class companies were potentially beneficial to all shareholders because
of the retention of company founders and contributors to company growth within the dual share class structure.

Additionally, the Board compared
FLAG’s index to the proposed DUAL Index and considered how a switch in investment objectives to track a different index would
impact FLAG shareholders. The Board noted that, like FLAG, DUAL would be a diversified fund. The Board further noted that the DUAL
Index held over 185 issuers as of June 2019, including many securities of established, large cap companies, such as Facebook, Visa,
Google parent Alphabet, and Domino’s.

 b. Explain in detail why the Board concluded that this approach was better for shareholders than other alternatives, such as liquidating
the ETF and starting a new ETF.

Response. The Board
concluded that a change in the FLAG’s underlying index was in the best interests of shareholders rather than liquidating
the ETF and starting a new Fund because, if FLAG liquidated, current shareholders would experience an unplanned taxable event that
would force them to recognize a gain or loss (which the ETF would not know with respect to any individual shareholder). Further,
the Board considered the comments from the SEC Staff during its examination of ETC, specifically, that the Board should consider
whether there are alternatives to liquidating a fund that would be in the best interest of shareholders. Given the information
received and the discussion with the DUAL Index provider, the Board concluded that it was in the best interests of shareholders
to keep FLAG open with a different investment objective rather than liquidate it. In light of the foregoing, the Board concluded
that, on balance, shareholders would be better served by being presented with an opportunity to continue their investment in the
ETF, albeit employing a new strategy, and allowing individual shareholders to make their own investment decision whether to remain
a shareholder rather than forcing a liquidation on ALL shareholders.

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 c. Support your explanation of the Board’s deliberations with data. For example, if cost was a consideration, provide data
on the expected cost savings from the proposed changes, as compared with starting a new ETF.

Response. The cost
to the Registrant was not a factor the Board considered because the ETF’s unitary management fee would remain the same and,
therefore, there is no additional expense to the ETF. The cost to shareholders of FLAG, however, was considered. As mentioned above,
the Board noted that if FLAG was liquidated, shareholders may face associated tax consequences, and realize gains or losses they
do not wish to realize. The Board evaluated the length of time FLAG had been operational as well as its performance record, concluding
that it was in the best interests of shareholders not to liquidate the Fund. In contrast, the transition to the DUAL Index can
be done through the use of custom baskets, which would not create a taxable event for shareholders. This allows shareholders to
look at the new index and decide if they want to continue to own shares in the new strategy or if they want to sell their shares
and realize the gain or loss they might have. It does not force them into anything, they have the option and can choose what is
in their best interest.

 2. Comment. Please also explain why the Adviser believes these changes are consistent with its fiduciary
duty to this ETF.

Response. As a
fiduciary to its clients, ETC must avoid conflicts of interest with clients that might cause it to purposefully or inadvertently
render less than disinterested advice to advisory clients. ETC as a fiduciary must at all times serve the best interests of its
clients and not subordinate clients’ interest to its own. Consequently, ETC believes that, by not forcing a taxable event
onto FLAG shareholders and providing FLAG shareholders with an opportunity to stay invested in a diversified fund with equity securities,
it is acting consistent with its fiduciary duty. Additionally, in light of the SEC Staff’s comments during its examination
of ETC that it explore other options besides liquidation, ETC believes that taking the opportunity to continue the ETF with a different
index provider is consistent with its fiduciary duty.

 3. Comment. Has the Trust and ETF notified its shareholders of this planned change? If so, please provide the staff
with a copy of the notice and when and how (e.g., letter, e-mail) it was sent. If not, when will the Trust and ETF distribute such
a notice and how?

Response. Other
than the filing of the revised registration statement, which is publicly available, neither the Trust nor the ETF has notified
shareholders of the planned change. The ETF intends to resolve the comments the Staff has on the registration statement and make
the necessary revisions in response to such comments, before notifying shareholders. After the prospectus has been finalized, prior
to its effectiveness, shareholders will be given advance notice via prospectus supplement in order to give them the option of selling
their ETF shares or remaining in the ETF.

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 4. Comment. What is the composition of the ETF’s shareholder base (e.g., affiliated v. unaffiliated, retail
v. institutional, domestic v. foreign)? What percentage of the ETF’s shares are held by retail investors?

Response. Due to
the nature of trading of ETFs, we do not and will not know the percentage of an ETF’s shares held by retail investors. ETFs
trade on the primary market with Authorized Participants, retail investors do not generally trade on the primary market with Authorized
Participants; rather they purchase shares on the secondary market.1
The ETF is also not privy to what an Authorized Participant does with the creation units it purchases from the Fund, which places
an additional degree of separation between the ETF and retail investors, if any. As noted above in response, ETC knows there currently
are no “market maker” seed capital or proprietary investments in the ETF.

 5. Comment. Please explain in your response why making these changes in a post-effective
amendment to the registration statement of an existing ETF, as opposed to an amendment adding a new ETF, is consistent with the
text and policy of Rule 485(a) under the Securities Act. Explain why you believe this does not provide an unfair competitive advantage
over other registrants, which add new series under Rule 485(a) that go effective within 75 days (as opposed to 60 days).

Response. The changes
were made in a post-effective amendment to the registration statement of an existing ETF because the post-effective amendment was
filed for the purpose of making material changes to an existing series, rather than adding a new series, in accordance
with Rule 485(a) under the Securities Act. Rule 485(a)(1) provides for automatic effectiveness of a post-effective amendment containing
material changes to the registration statement of an existing fund on the sixtieth day after filing.2
Because the ETF is an existing series of a fund, it would not be consistent with Rule 485(a) to file under Rule 485(a)(2), which
specifically provides for the automatic effectiveness of a post-effective amendment adding a new series; however, it is entirely
appropriate and consistent with the text and policy of Rule 485(a)(1) to file changes to an existing series, which are subject
to the review of the SEC Staff.3 We do not believe
that filing under Rule 485(a)(2) provides an unfair competitive advantage over other registrants because (i) we are adhering to
the rules promulgated under the Securities Act and the Staff’s pronouncements thereon; (ii) the changes t