SecProbe.io

CORRESP
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filename1.htm

Morgan
Lewis

Beau Yanoshik

Partner

+1.202.373.6133

beau.yanoshik@morganlewis.com

Via
EDGAR Correspondence

July
21, 2021

Yoon
Choo, Esq.

U.S.
Securities and Exchange Commission

Division
of Investment Management

100
F Street NE

Washington,
DC 20549

Re:
	BNY Mellon ETF Trust (the “Registrant”)

File
Nos. 333-234030 and 811-23477

Dear
Ms. Choo:

This
letter responds to comments you provided on June 14, 2021, with respect to Post-Effective Amendment No. 4 to the Registrant’s
Registration Statement on Form N-1A. Post-Effective Amendment No. 4 was filed on May 3, 2021, and included disclosure with respect
to the BNY Mellon Ultra Short Income ETF, a separate series of the Registrant. Summaries of the comments and responses thereto
on behalf of the Registrant are provided below.

General
Comment

 1. Comment:	Please supplementally confirm the effective date of the filing.

	Response:	Post-Effective
Amendment No. 4 was filed pursuant to paragraph (a)(2) of Rule 485 under the Securities Act of 1933, with an effective date 75
days after filing. The Registrant subsequently made a 485BXT filing on July 16, 2021 designating a new effective date of August
2, 2021.

 2. Comment:	Prior to effectiveness, please provide the final fee tables and examples, including
disclosure regarding any applicable expense limitations and/or fee waivers. Please also supplementally explain why the footnote
to the fee table has been left blank if the fund will be added to the current advisory agreement.

Morgan, Lewis & Bockius
llp

1111 Pennsylvania Avenue,
NW

Washington, DC 20004               	 +1.202.739.3000

United States
+1.202.739.3001

	Response:	The
completed fee tables and examples have been provided under separate cover. At the time of filing Post-Effective Amendment No. 4,
the exceptions to the fund’s unitary fee had not been finalized and, therefore, the footnote was left blank. The Registrant
notes the footnote has been completed in the fee table provided in response to this comment.

Prospectus

Fund Summary

 3. Comment:	Please supplementally disclose the limits on duration during the market conditions
referred to in the sentence below, included in the Principal Investment Strategy section. If greater than two years, please
supplementally explain why it is appropriate for an ultra short fund to have a duration in excess of two years.

The fund typically seeks
to maintain an effective duration of one year or less, although, under certain market conditions, such as in periods of significant
volatility in interest rates and spreads, the fund’s duration may be longer than one year.

	Response:	The
Registrant confirms that the effective duration of the fund will not exceed two years.

 4. Comment:	Please supplementally provide the name of the fund’s sub-adviser.

	Response:	Dreyfus
Cash Investment Strategies, a division of Mellon Investments Corporation, which is registered with the SEC as an investment adviser,
will serve as the fund’s sub-adviser upon launch.

 5. Comment:	In the Principal Investment Strategy section, please provide plain English
descriptions/explanations of the italicized portions of the following sentences:

 a. Consider account statistical metrics to ensure appropriate portfolio liquidity.

 b. Use a bottom-up optimization approach for yield and risk-adjusted returns by relying on
proprietary research and trading resources at the macro, sector and issuer levels.

 c. Once the level of fair value is estimated, the portfolio managers then perform cyclical research,
which is based on classical fundamental macroeconomics, to assess why a bond is over- or undervalued.

 d. Finally, the last step of the portfolio managers’ macroeconomic assessment is to understand
market expectations, which is used as a behavioral or contrarian indicator.

 e. Active duration and yield curve positioning are not central to the portfolio managers’
investment philosophy.

Response:	The
Registrant has revised the Principal Investment Strategy section to address the comment. The Registrant has provided a comparison
document under separate cover reflecting revisions made to the prospectus included in Post-Effective
Amendment No. 4, including these revisions to the Principal Investment Strategy section.

 6. Comment: 	Please explain how “trading resources” contribute to the bottom-up
optimization approach, as described in the following sentence included in the Principal Investment Strategy section:

Use a bottom-up optimization
approach for yield and risk-adjusted returns by relying on proprietary research and trading resources at the macro, sector
and issuer levels.

Response:	The Registrant
has removed the reference to trading resources in the Principal Investment Strategy section.

 7. Comment:	Please explain how individual security valuation is part of the sub-adviser’s
broad top-down macroeconomic analysis, as described in the following sentence included in the Principal Investment Strategy
section:

Valuation: The portfolio
managers use a number of valuation indicators and quantitative models to help establish fair value for a bond.

Response:	The
Registrant has revised the disclosure to clarify that the establishment of a fair market values for individual bonds is part of
the sub-adviser’s bottom-up approach.

 8. Comment:	Please explain what is meant by “fair value” in the following sentence
included in the Principal Investment Strategy section and its context with respect to the fund’s principal investment
strategies:

Valuation: The portfolio
managers use a number of valuation indicators and quantitative models to help establish fair value for a bond.

Response:	The Registrant
has replaced the term “fair value” with “fair market value.” As part of the investment process, the portfolio
managers establish a fair market value for a bond, then compare that value to the bond’s price in the market to determine
if the bond is over- or undervalued.

 9. Comment: 	In the discussion of “Interest rate risk” in the Principal Risks
section, please disclose that interest rates are currently at historical lows and the potential effects on the fund and the fund’s
investments.

Response: 	The
discussion of “Interest rate risk” has been revised as follows. The Registrant notes the sentence prior to and following
the added sentence discuss the potential effects of low interest rates on the fund and the fund’s investments.

Interest rate risk.
Prices of bonds and other fixed rate fixed-income securities tend to move inversely with changes in interest rates. Typically,
a rise in rates will adversely affect fixed-income securities and, accordingly, will cause the value of the fund’s

investments in these securities
to decline. Recently, interest rates in the U.S. and certain foreign markets have been low relative to historic levels. During
periods of very low interest rates, which occur from time to time due to market forces or actions of governments and/or their central
banks, including the Board of Governors of the Federal Reserve System in the U.S., the fund may be subject to a greater risk of
principal decline from rising interest rates. When interest rates fall, the fund’s investments in new securities may be at
lower yields and may reduce the fund’s income. The magnitude of these fluctuations in the market price of fixed-income securities
is generally greater for securities with longer effective maturities and durations because such instruments do not mature, reset
interest rates or become callable for longer periods of time.

 10. Comment: 	With respect to the discussion of “Foreign government obligations, debt
obligations of supranational entities and sovereign debt obligations risk” in the Principal Risks section, please
supplementally explain why the last two sentences of the discussion (pasted below) are appropriate when the fund’s investments
at the time of purchase have minimum rating requirements that are investment grade.

Some sovereign obligors
have been among the world’s largest debtors to commercial banks, other governments, international financial organizations
and other financial institutions. These obligors, in the past, have experienced substantial difficulties in servicing their external
debt obligations, which led to defaults on certain obligations and the restructuring of certain indebtedness.

Response:	The
Registrant has removed the above disclosure from the Principal Risks section.

 11. Comment:	With respect to the discussion of “Cash transaction risk” in the
Principal Risks section, please also address the risks of creation transactions in cash or supplementally explain why such
disclosure is not applicable.

Response:	The
Registrant believes the current discussion, which discusses potential tax consequences resulting from cash redemptions, is appropriate.
The Registrant notes that cash creations are not expected to result in similar tax consequences as may result from cash redemptions.
The Registrant further notes that, although cash creations and redemptions may result in greater transaction costs for the fund
than in-kind creations and redemptions, the fund charges authorized participants a transaction fee on both creation and redemption
transactions that is designed to offset these costs.

 12. Comment:	Please consider moving the disclosure included in the discussion of “Non-money
market fund risk” in the Principal Risks section to the Principal Investment Strategy section.

Response:	The Registrant
has added the following to the Principal Investment Strategy section:

The fund is not a money
market fund and does not seek to maintain a stable net asset value of $1.00 per share.

 13. Comment: 	Please supplementally identify for the Staff the broad-based securities index
that the fund intends to use.

Response:	The
fund currently intends to use the BofA Merrill Lynch 3-Month U.S. Treasury Bill Index as its broad-based securities index.

 14. Comment:	In the Payments to Broker-Dealers and Other Financial Intermediaries
section, please revise the sentence as follows to track Item 8 of Form N-1A.

If you purchase fund shares
through a broker-dealer or other financial intermediary (such as a bank), the Adviser or its affiliates may pay the financial intermediary
for certain activities related to the fund, including educational training programs, conferences, the development of technology
platforms and reporting systems, or other services related to the sale or promotion of the fund. These payments may create
a conflict of interest by influencing the broker-dealer or other intermediary and your salesperson to recommend the fund over another
investment. Ask your salesperson or visit your financial intermediary’s website for more information.

Response:	The
Registrant has not made the requested change. The Registrant does not believe the disclosure in this section necessarily needs
to track Item 8 of Form N-1A. In particular, the Registrant notes that Item 8 of Form N-1A states “a Fund may modify the
statement [required by Item 8] if the modified statement contains comparable information.” The Registrant believes the current
disclosure is consistent with Item 8 and that the examples the Staff requested be deleted are helpful as they provide examples
of the “certain activities related to the fund” for which the Adviser may pay financial intermediaries.

Fund Details

 15. Comment:	The Staff notes in the Fund Details section that Brady bonds are listed
in the principal strategies discussion but a discussion of “Brady bonds risk” is included as a non-principal risk of
the fund. Please reconcile this discrepancy.

Response:	The
Registrant has removed the reference to Brady bonds in the Fund Details section as well as the Investment Risks section.

 16. Comment:	Please include an explanation/definition of “maturity” to contrast
the explanation/definition of “duration” currently included in the Fund Details section.

Response:	The
disclosure has been revised as follows:

The fund typically
seeks to maintain an effective duration of one year or less, although, under certain market conditions, such as in periods of significant
volatility in interest rates and spreads, the fund’s duration may be longer than one year. The fund does not have any
restrictions on its average effective portfolio maturity or on the maturity or effective duration of the individual fixed-income
securities the fund may purchase. Duration is an indication of an investment’s “interest rate risk,”
or how sensitive a bond or the fund’s portfolio may be to changes in interest rates. Generally,

the longer a bond’s
duration, the more likely it is to react to interest rate fluctuations and the greater its long-term risk/return potential. The
change in the value of a fixed-income security or portfolio can be approximated by multiplying its duration by a change in interest
rates. For example, the market price of a fixed-income security with a duration of three years would be expected to decline 3%
if interest rates rose 1%. Conversely, the market price of the same security would be expected to increase 3% if interest rates
fell 1%. The maturity of a security measures the time until final payment is due. In
calculating effective duration, the The fund may treat a security that can be repurchased by its issuer
on an earlier date (known as a “call date”) as maturing on the call date rather than on its stated maturity date. The
fund does not have any restrictions on its average effective portfolio maturity or on the maturity or effective duration of the
individual fixed-income securities the fund may purchase.

 17. Comment:	Please provide a plain English description/explanation of the italicized portion
of the following sentence:

When the portfolio managers
think about the term structure of interest rates, they generally consider: 1) inflation expectations, 2) growth expectations, 3)
central bank policy expectations and 4) other technical or flow-driven factors.

Response:	The
disclosure has been revised as follows:

When the portfolio
managers think about the term structure of interest rates, they generally consider: 1) inflation expectations, 2) growth expectations,
3) central bank policy expectations and 4) other technical or flow-driven factors such as supply/demand.

 18. Comment:	With respect to the discussion of “Floating and variable rate securities
risk,” please confirm if LIBOR risk is a principal risk of the fund and, if so, please include in the corresponding risk
in the summary as well. In addition, please update the LIBOR related disclosure to note that the decision to extend certain LIBOR
values is final.

Response:	The
Registrant confirms LIBOR risk is not considered a principal risk of the fund. The Registrant has revised the second and third
sentences of the LIBOR related disclosure as follows:

On July 27, 2017,
the United Kingdom’s Financial Conduct Authority, which regulates LIBOR, announced that after 2021, it will cease its
active encouragement of banks to provide quotations needed to sustain the LIBOR rate. it intends to phase out LIBOR
by the end of 2021. On March 5, 2021, November 30, 2020, the administrator of LIBOR announced
a delay in its intention to begin consultation on delaying the phase out of the majority of the
U.S. dollar LIBOR publications until June 30, 2023, with the remainder of LIBOR publications to still end at the end of 2021.

 19. Comment:	The Staff notes that the fund’s principal investment strategies state
that the fund will normally invest in U.S. dollar denominated debt securities. With respect to the

discussion of “Foreign
investment risk” in the Fund Details section, please remove the reference to currency fluctuations or revise the strategies
accordingly.

Response:	The
Registrant has not made the requested change. A foreign issuer may be subject to the risks of currency fluctuations regardless
of whether its securities are U.S. dollar denominated or foreign curre