SecProbe.io

CORRESP
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Morgan Lewis

Beau Yanoshik

Partner

+1.202.373.6133

beau.yanoshik@morganlewis.com

Via
EDGAR Correspondence

August
2, 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 July 22, 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.

Statement
of Additional Information (“SAI”)

 1. Comment:	Please revise the fund’s fundamental policy regarding industry concentration
below to remove the phrase “under normal circumstances” from the policy. The staff believes this phrase is open to broad interpretation
including circumstances beyond the fund taking a temporary defensive position. Alternatively, include in the industry concentration policy
the circumstances under which the fund would depart from the policy (e.g., to take a temporary defensive position).

The fund may not invest more
than 25% of its assets in the securities of issuers in any single industry, provided that there shall be no limitation on the purchase
of obligations issued or guaranteed by the U.S. Government, its agencies or instrumentalities or shares of other investment companies;
except that under normal circumstances the fund will invest more than 25% of its assets in the banking industry.

Morgan, Lewis & Bockius
llp

1111 Pennsylvania Avenue,
NW

Washington, DC 20004	 +1.202.739.3000

United States
+1.202.739.3001

	                Response:	The
Registrant has replaced the fund’s fundamental policy regarding industry concentration with the following:

The fund may not invest more
than 25% of its assets in the securities of issuers in any single industry, provided that there shall be no limitation on the purchase
of obligations issued or guaranteed by the U.S. Government, its agencies or instrumentalities or shares of other investment companies;
except that the fund will invest more than 25% of its assets in the banking industry (however, during periods when the fund invests for
temporary defensive purposes, the fund’s assets may not be concentrated in the banking industry).

Part
C/Exhibits

 2. Comment:	The fund’s Amended and Restated Declaration of Trust includes (1) limits/requirements
on derivative and direct actions, (2) requires jurisdiction only in the Chosen Courts (as defined in Section 11.4(d)), and (3) includes
a waiver of jury trial provision. Please summarize each of these provisions in the prospectus as requested in the initial comments provided
by the staff with respect to Post-Effective Amendment No. 4. The staff position is that this
disclosure must be included because the Declaration of Trust provisions materially affect the rights of shareholders to bring an action
and the disclosure of these provisions in the prospectus is necessary to provide investors with material information relevant to their
investment decision.

	               Response:	While,
as previously noted, the Registrant is not aware of any Form N-1A requirement to include such disclosure, the Registrant has added disclosure
to the SAI to address this comment.

Prospectus

 3. Comment:	Please explain what “market expectations” means as used in the following
sentence included in the revised Principal Investment Strategy section.

Once the fair market value
of a bond is estimated, the portfolio managers then assess market expectations to determine why the bond is over- or undervalued.

	Response:	The
Registrant has replaced the sentence above with the following:

Once the fair market value
of a bond is estimated, the portfolio managers then assess broad market factors that may impact the market price of a given security (e.g.,
expected future inflation, expected economic growth, path of interest rates) to determine if and why the bond is over- or undervalued.

 4. Comment:	Please explain how the portfolio managers manage the fund’s duration and yield
curve positioning based on market expectations as stated in the following sentence included in the revised Principal Investment Strategy
section.

The portfolio managers manage
the fund’s duration and yield curve positioning based on market expectations.

	                        Response:	The
Registrant has replaced the sentence above with the following:

The portfolio managers manage
the fund’s duration and yield curve positioning based on the portfolio managers’ expectations of future interest rates compared
to current yield curves.

* * * * * * * * * *

We hope the foregoing is responsive to each of the
comments you provided. Please do not hesitate to contact me at (202) 373-6133 if you have any questions concerning the foregoing.

Sincerely,

/s/ Beau Yanoshik

Beau Yanoshik

cc:	W. John McGuire

Jeff Prusnofsky