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www.dechert.com

   Alexander Karampatsos

Alexander.Karampatsos@dechert.com

+1 202 261 3402   Direct

November 20,
2024

VIA
EDGAR CORRESPONDENCE

Seamus O’Brien

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549-4644

Re: Hartford Funds Exchange-Traded Trust (the “Registrant”) (SEC File Nos. 333-215165 and 811-23222)

Dear Mr. O’Brien:

We are writing in response
to comments you provided telephonically to Alice A. Pellegrino, Katherine T. Hurley, and me on November 5, 2024 with respect to your
review of the Registrant’s Post-Effective Amendment No. 48, filed on September 20, 2024, relating to Hartford AAA CLO
ETF (“AAA CLO ETF”), Hartford Strategic Income ETF (“Strategic Income ETF”) and Hartford Large Cap Growth ETF
(“Large Cap Growth ETF” and together with the AAA CLO ETF and Strategic Income ETF, the “Funds”), each an existing
series of the Registrant (the “Registration Statement”). On behalf of the Registrant, we have reproduced your comments below
and provided the Funds’ responses immediately thereafter. Capitalized terms have the meanings attributed to such terms in the Post-Effective
Amendment.

1. Comment:
                                Where a comment is made with regard to disclosure in one location, the comment is applicable to all similar disclosure appearing elsewhere
in the Registration Statement.

 Response: The disclosure will be revised accordingly.

2. Comment:
                                Please complete all bracketed and missing information in the Registration Statement.

Response: The disclosure will be revised accordingly.

3. Comment:
                                With respect to the AAA CLO ETF, please provide supplementally a completed Annual Fund Operating Expenses table.

Response: The completed Annual Fund Operating Expenses table for the Fund is attached as Appendix I.

4. Comment:
                                With respect to the AAA CLO ETF, please provide supplementally a completed Expense Example.

Response: The completed Expense Example for the Fund is attached as Appendix I.

5. Comment:
                                With respect to the AAA CLO ETF’s “Principal Investment Strategy” section, please clarify how the Fund determines AAA
rating for purposes of the 80% policy to invest in AAA-rated CLOs and AA rating for the remaining 20%.

Response: The Registrant respectfully acknowledges the Staff’s comment and directs the Staff to the first
sentence of the “Principal Investment Strategy” section, which explains that the ratings for such investments are based on
how they are rated by one or more nationally recognized statistical rating organizations, or if unrated, determined to be of comparable
credit quality by the Fund’s sub-adviser. The Registrant respectfully declines to make any changes in response to this comment.

6. Comment:
                                With respect to the AAA CLO ETF’s “Principal Investment Strategy” section, the Staff notes that “[t]he CLOs in
which the Fund invests may be organized in the US or outside the US.” Please disclose any limits on foreign exposure.

Response: The Registrant notes that certain of the CLOs in which AAA CLO ETF invests are domiciled in the Cayman
Islands. Such CLOs’ underlying exposure is generally to loans issued by U.S. issuers. The Fund has no specific limits on such investments.
For these reasons, the Registrant respectfully declines to incorporate any changes in response to this comment.

7. Comment:
                                With respect to the AAA CLO ETF’s “Principal Investment Strategy” section, please clarify the general geographic
regions in which the Fund invests outside of the US.

Response: Please see our response to Comment 6.

8. Comment:
                                With respect to the AAA CLO ETF’s “Principal Risks” section, please confirm whether the Fund plans to utilize any derivatives,
including credit default swaps, as part of its principal investment strategy.

Response: The Registrant confirms that the utilization of derivatives is not a principal investment strategy of
the AAA CLO ETF.

9. Comment:
                                With respect to the AAA CLO ETF’s “Principal Risks” section, please consider including disclosure in the Fund’s
principal investment strategy if investing in loans and loan participations are principal strategies of the Fund.

Response: The Registrant respectfully notes that the Fund’s principal investment strategy is to invest in
CLOs, which, in turn, have exposure to loans and loan participations. The Registrant does not believe additional disclosure on this point
is necessary.

10. Comment:
                                 With respect to the AAA CLO ETF’s “Principal Risks” section, please disclose under “Liquidity Risk” or
 “Exchange-Traded Funds Risk” that in stressed market conditions, the market for ETF shares may become less liquid in response
to deteriorating liquidity for the ETF’s underlying holdings. Please also note that this adverse effect on liquidity could lead
to wider bid/ask spreads and differences between market price and NAV for ETF shares.

Response: The Registrant acknowledges the Staff’s comment and respectfully notes that the risks discussed
in this comment are addressed in “Market Price Risk.” The Registrant notes that “Market Price Risk” will be updated
to reflect additional disclosure in accordance with this comment.

11. Comment:
                                 With respect to the AAA CLO ETF, please disclose whether all or a portion of the Fund’s underlying securities trade in a market
that is closed while the market in which the Fund’s shares are traded is open. Please disclose that this difference could lead
to differences between the market price and the Fund’s NAV.

Response: The Registrant acknowledges the Staff’s comment and respectfully notes that the risks discussed
in this comment are addressed in “Market Price Risk.” The Registrant notes that “Market Price Risk” will be updated
to reflect additional disclosure in accordance with this comment.

12. Comment:
                                 With respect to the AAA CLO ETF, please provide supplementally a completed performance table.

Response: The completed performance table for the Fund is attached as Appendix I.

13. Comment:
                                 With respect to the Large Cap Growth ETF, please provide supplementally a completed Annual Fund Operating Expenses table.

Response: The completed Annual Fund Operating Expenses table for the Fund is attached as Appendix II.

14. Comment:
                                 With respect to the Large Cap Growth ETF, please provide supplementally a completed Expense Example.

Response: The completed Expense Example for the Fund is attached as Appendix II.

15. Comment:
                                 With respect to the Large Cap Growth ETF, please confirm that no material changes were made to the Fund’s principal investment
strategies or risks.

Response: The Registrant notes that risks related to the Large Cap Growth ETF’s former semi-transparent structure
were removed from the Large Cap Growth ETF’s Principal Risks section. The Registrant notes that the following changes were made
to the Large Cap Growth ETF’s principal investment strategy: (i) removal of the reference to the Fund investing up to 25% of
its net assets in American Depositary Receipts, (ii) removal of the references to active trading and (iii) addition of “communications
services” to the sectors in which the Fund may focus. The Registrant notes that corresponding changes to (i) and (ii) above
were made to the Fund’s “Principal Risks.” The Registrant confirms that no other material changes were made to the Large
Cap Growth ETF’s “Principal Risks” and “Principal Investment Strategy” sections.

16. Comment:
                                 With respect to Large Cap Growth ETF’s “Authorized Participant Concentration Risk”, please confirm the inclusion of
additional risk disclosure as requested in Comments 10 and 11.

Response: Please see our response to Comments 10 and 11.

17. Comment:
                                 With respect to the Large Cap Growth ETF, please provide supplementally a completed performance table.

Response: The completed performance table for the Fund is attached as Appendix II.

18. Comment:
                                 With respect to the Strategic Income ETF, please provide supplementally a completed Annual Fund Operating Expenses table.

Response: The completed Annual Fund Operating Expenses table for the Fund is attached as Appendix III.

19. Comment:
                                 With respect to the Strategic Income ETF, please provide supplementally a completed Expense Example.

Response: The completed Expense Example for the Fund is attached as Appendix III.

20. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, please provide a definition for
 “highly rated securities” and disclose the corresponding credit rating for such securities.

Response: The Registrant will revise the disclosure in response to this comment.

21. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, please disclose the credit rating
for “junk bonds”.

Response: The Registrant respectfully declines to incorporate any changes in response to this comment and notes
that the disclosure discussed in this comment is addressed in the “Investment Grade and Non-Investment Grade Securities” section
of the Registration Statement.

22. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, the Staff notes that the disclosure
states that “[t]he Fund may invest in various types of debt securities.” Please revise the disclosure to state the
types of securities in which the Fund “will” invest and confirm that the types of securities are principal investments.

Response: The Registrant respectfully declines to revise the disclosure in response to this comment as Registrant
believes that the use of “may” is appropriate in the context in which it is used.  Specifically, pursuant to Item 4(a) of
Form N-1A, the discussion of the Fund’s principal investment strategy states that the Fund invests primarily in domestic and
foreign debt securities.  In other words, the Fund invests and will invest primarily in debt securities.  Among those debt securities,
the Fund may invest in corporate bonds; debt securities issued by foreign governments; U.S. government and agency securities; bank
loans or loan participation interests in secured, second lien or unsecured variable, fixed or floating rate loans; and securitized
debt (such as mortgage-related and asset-backed securities, including collateralized loan obligations). The use of the term “may”
is intended to give the Fund flexibility to invest in these specific debt securities to the extent such securities are better opportunities
for the Fund.

23. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, please disclose any limits on foreign
exposure.

Response: The Registrant confirms that there are no stated limits on foreign exposure for the Strategic Income ETF.
Accordingly, the Registrant respectfully declines to make any changes in response to this comment.

24. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, please define “emerging markets.”

Response: The Registrant will add disclosure to the “Additional Information Regarding Investment Strategies
and Risks” section of the prospectus in response to this comment.

25. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, the Staff notes that the disclosure
states that “[t]he Fund may use derivatives including futures contracts, swaps, options and forward foreign currency contracts,
to manage portfolio risk, for efficient replication of securities the Fund could buy or for other investment purposes.” Please
clarify the types of investments in which the Fund “may” invest versus those in which it “will” invest.

Response: The Registrant will revise the disclosure in response to this comment. With respect to the use of “may”
versus “will,” please see our response to Comment 22.

26. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, the Staff notes that the disclosure
states that “[t]he Fund seeks to be diversified across sectors, although the Fund is not required to invest in all sectors at all
times and may invest 100% of its net assets in one sector if conditions warrant.” Please supplementally explain how the Fund does
not violate its fundamental investment restriction to not concentrate its investments in a particular industry.

Response: The Fund seeks to be diversified across sectors, which are broader in scope than industries. No particular
sector necessarily relates to any one industry or group of related industries. For example, corporate bonds, as a sector, combine securities
of issuers from many different industries. Thus, the Fund’s principal investment strategy does not and will not violate its fundamental
investment restriction.

27. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, the Staff notes that the disclosure
states that “[t]he Fund may invest in certain restricted securities, such as securities that are only eligible for resale
pursuant to Rule 144A, and securities of U.S. and non-U.S. issuers that are issued pursuant to Regulation S.” Please revise
the disclosure to clarify that the Fund “will” invest in certain restricted securities.

Response: The Registrant acknowledges the Staff’s comment and notes that the disclosure is accurate as written.
The Registrant respectfully declines to make any changes in response to this comment for the reasons set forth in our response to Comment
22.

28. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Investment Strategy” section, please revise the disclosure to
remove extraneous information regarding derivatives. In general, see letter from Barry Miller, Associate Director, Division of Investment
Management, to Karrie McMillan, General Counsel, Investment Company Institute, July 30, 2010 (http://www.sec.gov/divisions/investment/guidance/ici7010.pdf).

Response: The Registrant is aware of and has reviewed the Barry Miller letter referenced above. The Registrant believes
that the disclosure regarding the use of derivatives describes how such derivatives are expected to be used in connection with the Fund’s
principal investment strategy. The Registrant respectfully declines to make any changes in response to this comment.

29. Comment:
                                 With respect to the Strategic Income ETF’s “Principal Risks” section, please confirm the inclusion of additional risk
disclosure from Comments 10, 11 and 16.

Response: The Registrant notes that “Market Price Risk” will be updated to reflect additional detail
in accordance with Comment 10 and Comment 11.

30. Comment:
                                 With respect to the Statement of Additional Information, please include the Funds’ non-fundamental investment policies under Rule 35d-1
in the section titled “Non-Fundamental Investment Restrictions of the Funds.”

Response: The Registrant acknowledges the Staff’s comment and notes that such policies are included in the
statutory prospectus and do not, therefore, need