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CORRESP
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    1900 K Street, NW

    Washington, DC 20006-1110

    +1 202 261 3300 Main

    +1 202 261 3333 Fax

    www.dechert.com

    ADAM T. TEUFEL

    adam.teufel@dechert.com

    +1 202 261 3464 Direct

    +1 202 261 3333 Fax

June 16, 2023

VIA EDGAR

Filing Desk

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Deborah O’Neal

Re: Schwab Strategic Trust (File Nos. 333-160595
and 811-22311) (the “Registrant”)

Dear Ms. O’Neal:

This letter responds to the comments of the U.S.
Securities and Exchange Commission (“SEC”) staff (“Staff”) on Post-Effective Amendment (“PEA”) No.
154 to the Registrant’s registration statement on Form N-1A (“Registration Statement”) under the Securities Act of 1933,
as amended (“1933 Act”), and Amendment No. 156 under the Investment Company Act of 1940, as amended (the “1940 Act”),
filed pursuant to Rule 485(a)(2) under the 1933 Act on January 17, 2023. PEA No. 154 relates to the registration of shares of Schwab High
Yield Bond ETF (the “Fund”), which is a new series of the Registrant. The SEC staff’s (the “Staff”) comments
were provided by you to Adam T. Teufel of Dechert LLP on March 1, 2023.

Throughout this letter, capitalized terms have
the same meaning as in PEA No. 154, unless otherwise noted. A summary of the Staff’s comments, followed by the responses of the
Registrant, is set forth below:

 1. Comment: In the Fund’s principal investment strategies, please consider clarifying
that the ICE BofA US Cash Pay High Yield Constrained Index (the “Index”) is the index that the Fund seeks to track.

Response: The Registrant
notes that the Fund’s investment objective is “to track as closely as possible, before fees and expenses, the total return
of an index that measures the performance of U.S. dollar denominated below investment grade corporate debt.” The first sentence
of the Fund’s principal investment strategies states, in bold font, that “To pursue its goal, the fund generally invests in
securities that are included in the ICE BofA US Cash Pay High Yield Constrained Index.” The Registrant believes that the disclosure
included in the Fund’s investment objective read in conjunction with the prominent disclosure in the Fund’s principal investment
strategies makes it sufficiently clear to potential investors that

    June 16, 2023

    Page 2

the Fund seeks to track the Index. The
Registrant therefore respectfully declines to revise the disclosure.

 2. Comment: In the Fund’s principal investment strategies, please consider disclosing
the average weighted maturity of the Index as of a certain date.

Response: The Registrant
is not aware of any requirement in Form N-1A that requires a fund to disclose the average weighted maturity of its index as of a certain
date. The Registrant therefore respectfully declines to add the disclosure.

 3. Comment: In the Fund’s principal investment strategies, please consider adding “(junk
bonds)” after “below investment grade bonds.”

Response: The Registrant
has revised the first paragraph in the principal investment strategies as follows:

“To pursue its goal, the fund
generally invests in securities that are included in the ICE BofA US Cash Pay High Yield Constrained Index†. ICE BofA US Cash
Pay High Yield Constrained Index tracks the performance of U.S. dollar denominated below investment grade corporate debt (junk
bonds), currently in a coupon paying period, that is publicly issued in the U.S. domestic market. Qualifying securities must
have a below investment grade rating (based on an average of Moody’s, S&P and Fitch), at least 18 months to final maturity at
the time of issuance, at least one year remaining term to final maturity as of the rebalancing date, a fixed coupon schedule and a minimum
amount outstanding of $250 million.”

 4. Comment: Please provide the Staff a copy of the completed “Fund fees and expenses”
and “Example” tables for the Fund.

Response: The completed
 “Fund fees and expenses” and “Example” tables is attached hereto at Appendix A.

 5. Comment: On page 13 of the Fund’s Statement of Additional Information, please consider
changing the word “may” to “will” so that the disclosure reads as follows: The fund may not “[c]oncentrate
investments in a particular industry or group of industries… except that the fund will concentrate its investments
to approximately the same extent that the index the fund is designed to track concentrates in the securities of a particular industry
or group of industries . . .” Please note that freedom of action to concentrate (or not concentrate), in other than U.S. government
securities, pursuant to management investment discretion,

    June 16, 2023

    Page 3

without shareholder approval, has generally
been considered by the Staff to be prohibited by Sections 8(b)(1) and 13(a)(3) of the 1940 Act.

Response: The Registrant
respectfully notes that, under various circumstances, it may not be possible or practicable to purchase all of the securities included
in the Index (or at the specified weightings) and the Fund may use sampling techniques as a result, as further described in the Fund’s
principal investment strategies. As such, it is possible that the Index concentrates in a specified industry, but the Fund does not when
utilizing a sampling strategy rather than a replication strategy. Accordingly, the Registrant respectfully declines to make the requested
changes.

 6. Comment: On page 29 of the Fund’s Statement of Additional Information, please delete
the following disclosure: “(iv) acceptance of the Deposit Securities would have certain adverse tax consequences to the fund;”
and “(vi) acceptance of the Fund Deposit would otherwise, in the discretion of the Trust or Schwab Asset Management, have an adverse
effect on the Trust or the rights of beneficial owners…” The Staff recognizes that the disclosure in question may be derived
from statements related to prior exemptive relief obtained by ETFs. However, in connection with the recent proposal and adoption of rule
6c-11, the Commission stated its belief that “an ETF generally may suspend the issuance of creation units only for a limited time
and only due to extraordinary circumstances, such as when the markets on which the ETF’s portfolio holdings are traded are closed
for a limited period of time.” See “Exchange-Traded Funds,” Release No. 33-10515, at pp.67-68 (June 28, 2018). In adopting
the rule, the Commission further noted that “[i]f a suspension of creations impairs the arbitrage mechanism, it could lead to significant
deviation between what retail investors pay (or receive) in the secondary market and the ETF’s approximate NAV. Such a result would
run counter to the basis for relief from section 22(d) and rule 22c-1 and therefore would be inconsistent with rule 6c-11.” See
 “Exchange-Traded Funds,” Release No. 33-10695, at p.59 (Sep. 25, 2019). While the Staff recognizes that in certain limited
circumstances, ETFs may have a sound basis for rejecting individual creation orders, the Staff believes that the disclosure in question
is sufficiently broad to run counter to the SEC’s position to the extent the rejection of orders would effectively result in the
suspension of creations.

Response: The Registrant
received a substantially similar comment to its Post-Effective Amendment No. 141 to which the undersigned responded on behalf of the Registrant
by letter dated June 2, 2022. Such prior response noted certain changes that were made to the Registrant’s disclosure in response
to the Staff’s comment, thus no further changes are being made at this time. As noted in the prior response, the
Registrant respectfully submits that the 1940 Act does not obligate the Fund to accept a particular creation order. The SEC

    June 16, 2023

    Page 4

has acknowledged this principle. See,
e.g., Investment Company Swing Pricing, 81 Fed. Reg. 82084, 82128 (Nov. 18, 2016) (“we note that unlike redemptions, funds may
reserve the right to decline purchase requests”); Disclosure Regarding Market Timing and Selective Disclosure of Portfolio Holding,
69 Fed. Reg. 22299, 22302 (Apr. 23, 2004) (stating that “a fund may reserve the right to reject a purchase or exchange request for
any reason, provided that it discloses this policy in its prospectus.”); see also Exchange-Traded Funds, 83 Fed. Reg. 37332,
37349 (July 31, 2018) (“we believe an ETF generally may suspend the issuance of creation units only for a limited time and only
due to extraordinary circumstances . . . .”). The referenced disclosure, combined with other disclosure in the Fund’s registration
statement, alerts prospective investors of the right of the Registrant to reject a particular creation order consistent with this principle;
it is not intended to address a scenario where an ETF suspends all creation orders indefinitely. The Registrant therefore declines to
revise the disclosure.

*          *          *

Should you have any questions or comments, please
contact the undersigned at 202.261.3464.

Sincerely,

/s/ Adam T. Teufel

Adam T. Teufel

    June 16, 2023

    Page 5

Appendix A

Fund Fees and Expenses

​This
table describes the fees and expenses you may pay if you buy, hold and sell shares of the fund. You may pay other fees, such as brokerage
commissions and other fees to financial intermediaries, which are not reflected in the table and Example below.

    Shareholder Fees (fees paid directly from your investment)

    ​

    ​
    ​
    ​
    None
    ​

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

    Management fees​
    ​
    ​
    0.10
    ​

    Other expenses(1)
    ​
    ​
    None​
    ​

    Total annual fund operating expenses
    ​
    ​
    0.10
    ​

​

(1)
“Other expenses” is an estimate based on
the expenses the fund expects to incur for its first full fiscal year.​

​

Example

This example is intended to help you compare the cost of investing in the
fund with the cost of investing in other funds. The example assumes that you invest $10,000 in the fund for the time periods indicated
and then sell all of your shares at the end of those time periods. The example also assumes that your investment has a 5% return each
year and that the fund’s operating expenses remain the same. Your actual costs may be higher or lower.

    ​
    Expenses on a $10,000 Investment
    ​

    ​
    1 Year
    ​
    ​
    3 Years
    ​

    $10

    $32