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CORRESP
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      March 15, 2024

      VIA EDGAR

        ==========

        Beckie Marquigny

        Division of Investment Management

        Securities and Exchange Commission

        Filing Desk

        100 F Street, N.E.

        Washington, DC 20549

            RE:

              Spinnaker ETF Series; File Nos. 333-215942 and 811-22398

      Dear Ms. Marquigny,

      On December 29, 2023, Spinnaker ETF Series (the “Trust” or the “Registrant”) filed a registration statement
        under the Securities Act of 1933 on Form N-1A (the “Registration Statement”) with respect to the North Shore Equity Rotation ETF (the “Fund”). On February 14, 2024, you provided oral comments, and we filed correspondence responding to those
        comments on March 8, 2024. On March 13, 2024, you provided additional comments based on our responses. Please find below a summary of those comments and the Registrant's responses, which the Registrant has authorized us to make on behalf of the
        Registrant.

      Prospectus:

      Summary

      Comment 1. The
        Fund’s investment objective states that it seeks to outperform the S&P 500 Index over full market cycles by investing in various sectors of the equity market.
        Please also disclose what constitutes a full market cycle (e.g. do all four stages have to be completed? What if the market doesn’t move linearly such as moving from stage 1 to stage 2 and then back to stage 1 rather than progressing to stage 3?).

      Response. The
        Registrant has removed the reference to full market cycles as the Fund seeks to outperform the S&P 500 on a constant basis at each stage of the market cycle identified in the prospectus, not over a certain time period.

      Comment 2. In the
        introduction to the fee table, please bold the third sentence.

      Response. The
        Registrant has revised the disclosure as requested.

      Comment 3. In the
        first sentence of “Portfolio Turnover”, please change “may” to “will”.

      Response. The
        Registrant has revised the disclosure as requested.

      Comment 4. Please
        add a clear statement to the beginning of the strategy that states the Fund’s investment thesis succinctly.

      Response. The
        Registrant has added the following disclosure:

      The Fund’s Advisor seeks to identify, in its opinion and based on its research, in which
        stage of the business cycle the U.S. economy is currently and in which stage of the business cycle the U.S. economy is going to be in the near future. The Advisor then selects securities for the Fund within the sectors that have historically
        performed well in that stage of the business cycle.

      Comment 5. In
        “Principal Investment Strategies”, it notes in the 80% test that the Fund may invest in equity securities indirectly through ETFs. Please add disclosure clarify how the Fund will count ETFs for purposes of its 80% test.

      Response. The Registrant has added the following disclosure:

      The Fund will look through to an ETF’s underlying holdings to determine the Fund’s
        compliance with its 80% policy.

      Comment 6.  In
        “Principal Investment Strategies”, in the second paragraph, please clarify the difference between “economic indicators” and “leading economic indicators”.

      Response. The
        Registrant has added the following disclosure:

      Current economic indicators indicate what the current state of the economy is, and leading
        economic indicators indicate what the state of the economy is going to be in the near future.

      Comment 7. In
        “Principal Investment Strategies”, it describes how the Adviser selects securities based on which of four stages within the typical business cycle the Adviser believes the economy is in. Please explain what a “typical” market cycle means vs
        atypical given that the Advisor does not follow a different investment protocol for atypical market cycles.

      Response. The
        Registrant has revised the disclosure to remove reference to “typical” as they are all stages of every business cycle. The Registrant has added the following disclosure:

      These stages do not necessarily all occur before returning to a prior stage of the cycle
        (for instance, the market may return to the recessionary stage after the recovery stage rather than moving on to the expansionary stage). The order of the stages can also vary.

      Comment 8. In
        “Principal Investment Strategies”, it notes that the Fund invests in both domestic and foreign equity securities. Given that the Fund’s investment thesis centers on the Adviser’s view of US market cycle stages, please
        explain how the foreign securities in which the Fund invests respond to these US market cycles.

      Response. The
        Registrant has added the following disclosure:

      The Fund’s investments in equity securities include both
        domestic and foreign securities. The Advisor may select both foreign and domestic securities in a given sector that is expected to perform well in a given stage of the business cycle. Foreign markets often exhibit a positive correlation with the
        U.S. market (meaning they often behave similarly). This means that the Advisor would expect a foreign security in a given sector to benefit from a given market cycle stage in a similar manner to how a domestic security in a given sector would be
        expected to benefit. A particular foreign security may, however, present a unique investment opportunity, such as potentially better values in certain sectors. For instance, during a recession, the utilities sector may generally perform well due to
        its essential service nature. In such a scenario, you might find a foreign utility company trading at a more attractive valuation compared to a similar U.S. company. The Advisor will select both domestic and foreign securities for the Fund’s
        portfolio depending on which provides the better investment opportunity at a given point in time.

      Comment 9. Please add disclosure
        regarding the types of commodities in which the Fund may invest through the ETFs and ETNs and add corresponding risk disclosure. Please also revise the disclosure to define what is meant by “commodity themed”. Please also supplementally confirm
        whether the Fund will invest in bitcoin ETFs or other currency related ETFs.

      Response. The Adviser has confirmed to
        the Registrant that the Fund is not expected to invest in bitcoin ETFs. The Adviser has confirmed to the Registrant that investments in commodity ETFs and ETNs will not be a principal strategy of the Fund, so the Registrant has removed the
        references to those securities.

      Comment 10. In “Principal Investment
        Risks – Management Risk,” please directly discuss the role of human error by the portfolio managers such as poor or incorrect decisions in addition to the existing disclosure.

      Response. The Registrant has revised the
        disclosure to reinsert the deleted disclosure.

      * * *

      If you have any questions or comments, please contact the undersigned at 678.553.2432.  Thank you in advance
        for your consideration.

      Sincerely,

      /s/ Tanya L. Boyle

      Tanya L. Boyle

        FUND SUMMARY – NORTH SHORE EQUITY ROTATION ETF INVESTMENT OBJECTIVE

        The North Shore Equity Rotation ETF (the “Fund”) seeks to outperform the S&P 500

        Index over a full market cycles by investing in various sectors of the equity market.

        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”). The fees are expressed as a percentage of the Fund’s average net assets. You may pay other fees, such as brokerage
            commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below. These costs are not included in the expense example below.

                Annual Fund Operating Expenses

                (ongoing expenses that you pay each year as a percentage of the
                  value of your investment)

                Management Fees

                0.75%

                Other Expenses1

                0.72%

                Acquired Fund Fees and
                    Expenses1

                0.04%

                Total Annual Fund Operating Expenses

                1.51%

                Fee Waiver and/or Expense
                    Limitation2

                0.57%

                Total Annual Fund Operating Expenses
                  After Fee Waiver and/or Expense Reimbursement

                0.94%

        1. Estimated for the current fiscal year.

        2. Split Rock Private Trading & Wealth Management, LLC (the “Advisor”) has entered into an expense limitation agreement with the Fund under which it has agreed to waive or reduce its fees

        and to assume other expenses of the Fund, if
          necessary, in an amount that limits the Fund’s annual 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 0.90% of the average daily net assets of

        the Fund through March 31, 2025, and may be
          terminated by the Board of Trustees at any time. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in

        future years (within the three years from the
          date the fees had been waived or reimbursed), if such recoupment can be achieved within the lesser of the foregoing expense limit or those in place at the

        time of recapture.

        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 redeem (or you hold) all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and the Fund’s operating expenses remain the same. The Example includes the Fund’s
          contractual expense limitation through March 31, 2025. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

        2

                1 Year

                3 Years

                $96

                $421

        Portfolio Turnover. The Fund willmay pay
            transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Shares are held in a taxable
            account. These costs, which are not reflected in the Annual Fund Operating Expenses or in the Example, affect the Fund’s performance. Because the Fund has only recently begun operations, no historical portfolio turnover information is
            available. Portfolio turnover information will be provided once available.

        PRINCIPAL INVESTMENT STRATEGIES

        The Fund is an actively managed exchange-traded fund (“ETF”). As an actively managed
          fund, the Fund will not seek to replicate the performance of an index. Under normal market conditions, the Fund will invest at least 80% of its net assets (plus borrowings for investment purposes) in U.S. and foreign equity securities. The Fund
          may make these investments in equity securities directly or indirectly through ETFs. The Fund will look through to an ETF’s underlying holdings to determine the Fund’s compliance
              with its 80% policy. The Fund’s
              Advisor seeks to identify, in its opinion and based on its research, in which stage of the business cycle the U.S. economy is currently and in which stage of the business cycle the U.S. economy is going to be in the near future. The Advisor then selects securities for the Fund within the sectors that have historically performed well in that stage of the business cycle.

        The Fund’s goal is to outperform the S&P 500 Index primarily by overweighting
          and/or underweighting the sectors represented in the S&P 500 Index relative to their weightings in the index based on the Advisor’s research regarding the equity market’s current and pending economic cycles. This research entails a review of
          current economic indicators, such as gross domestic product (“GDP”), employment, consumer spending and inflation to assess the current phase of the business cycle. Additionally, the Advisor reviews leading economic indicators, that tend to
          precede changes in the overall economy, to anticipate potential shifts in the cycle. Current economic indicators indicate what the current state of the economy is, and leading economic indicators
              indicate what the state of the economy is going to be in the near future. The Advisor reviews this data on at least a monthly basis.

        The Advisor believes that there are four distinct stages within the  typical  business cycle:

        recession, recovery, expansion, and slowdown.

              1.

                The Advisor identifies the recession stage to begin after two successive quarters of falling GDP. In this stage, the Fund will typically more heavily invest in
                  equity securities in the consumer staples, utilities, and health care sectors.

              2.

                The Advisor identifies the recovery stage as observing increased business activity and economic growth. Increased business activity and economic growth is defined
                  as GDP growth, rising employment, increasing consumer spending, and

        3

        improving business confidence. In this stage, the Fund may
          strategically invest in sectors that the Adviser believes have historically performed well in both recessions and recoveries (equity securities in the real estate, technology, consumer discretionary, and materials sectors) in an effort to
          anticipate the transition to the next market cycle stage.

              3.

                The Advisor identifies the expansionary stage as observing growth of the economy beyond the recovery and is characterized by increased output, employment, and
                  income. The Advisor believes this stage occurs when the annual GDP growth reaches about 2.5%-3%, where it believes the economy is growing at a rate that is sufficient to create jobs and boost incomes, but it is not growing so fast that it
                  causes inflation to increase quickly. In this stage, the Fund will typically more heavily invest in equity securities in the technology and financials sectors.

              4.

                The Advisor identifies the slowdown stage as observing growth beginning to slow but the economy is not necessarily contracting yet. The Advisor believes this stage
                  occurs when it observes slowing GDP growth, declining employment growth, weakening consumer spending and slowing business investment compared. In this stage, the Fund will typically more heavily invest in equity securities in the consumer
                  staples and health care sector