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CORRESP
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    [Letterhead of Morgan, Lewis
      & Bockius LLP]

      via EDGAR
            Correspondence

        February 20, 2025

    Messrs. Daniele Marchesani, Matt Williams and Mark Cowan

    Division of Investment Management

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

          Re:

            SSGA Active Trust (the “Registrant”); SEC File Nos. 333-173276 and 811-22542; Post-Effective Amendment No. 220 to the Registrant’s Registration Statement on Form N-1A
              (“Amendment No. 220”)

    Dear Messrs. Marchesani, Williams, and Cowan:

    This letter responds to comments you provided in telephonic conversations with me on December 20, 2024 and January 13 and 24, 2025, with respect to
      Amendment No. 220. Amendment No. 220 was filed on September 10, 2024, and included disclosure with respect to the SPDR SSGA Apollo IG Public & Private Credit ETF (the “Fund”), a new series of the Registrant, as set forth in the Fund’s Prospectus
      and Statement of Additional Information filed as part of Amendment No. 220.

    Summaries of the comments with respect to the Fund, and responses thereto on behalf of the Registrant, are provided below. All page references refer to the
      pages in Amendment No. 220.  Capitalized terms not defined herein should be given the meaning provided in Amendment No. 220.

    December 20, 2024 Comments

          1.

            Comment: With respect to the response to comment 22 in the Registrant’s
              letter dated December 18, 2024 (the “Initial Letter”), please clarify whether Apollo or its affiliated persons may create or redeem creation units through an AP with such AP acting on an agency basis for Apollo.

            Response: The Registrant confirms neither Apollo nor its affiliated persons
              will seek to create or redeem creation units through an AP.

          2.

            Comment: With respect to the response to comment 3 in the Initial Letter,
              please provide more details about the Adviser’s revenue sharing agreement that is contemplated with Apollo and the Fund’s sub-license agreement with the Adviser to use Apollo in the Fund’s name.

          a.

            Please generally describe the details of the revenue sharing arrangement and how the revenue sharing will be determined.

            Response: It is currently expected that the Adviser will pay Apollo out of
              its legitimate profits.

          b.

            Will the revenue sharing arrangement create a conflict of interest for SSGA in managing the Fund and allocating Fund assets to AOS Investments?

            Response:  The Adviser does not expect the revenue sharing arrangement to
              create a conflict of interest.

          c.

            Will the Fund reimburse the Adviser for fees the Adviser may pay to Apollo in connection with the Adviser’s license agreement with Apollo?

            Response:  No, the Fund will not reimburse the Adviser for any fees the
              Adviser may pay Apollo in connection with the Adviser’s license agreement with Apollo.

          3.

            Comment: Further to the response to comment 4(a) in the Initial Letter,
              please note the Staff does not believe that the potential for an ETF to include an asset in a redemption basket in-kind would qualify as being able to dispose of that asset for purposes of Rule 22e-4. The Staff also notes the response to
              comment 4(a) says “[t]he Liquidity Agreement and the ability to buy and sell AOS Investments with Apollo is not exclusive. Certain other broker-dealers may make markets and provide quotations for the AOS Investments, and the Adviser could and
              may seek to sell AOS Investments to any interested, willing, and eligible counterparty.” Will the Fund rely on these other potential counterparties on a regular basis for purposes of determining liquidity of AOS Investment under Rule 22e-4?

            Response: The Registrant acknowledges the Staff’s comment with respect to
              inclusion of assets in redemption baskets and Rule 22e-4. To the extent counterparties other than Apollo are interested in selling to or purchasing from the Fund, the Fund may consider such counterparties and information provided by such
              counterparties when determining liquidity of AOS Investments under Rule 22e-4.

          4.

            Comment: The Staff notes the Liquidity Agreement states that “[t]he Fund
              acknowledges that the firm bid levels reflected on the Executable Quotation Sheets are based on Apollo’s commercially reasonable assessment of the value of the AOS Investments immediately preceding the publication of the applicable Executable
              Quotation Sheet, taking into account several factors including, but not limited to, then-current market conditions, interest rates, any then-recent transactions for the same or similar securities, any recent levels communicated to similarly
              situated market participants and other then-current information deemed relevant by Apollo.” For purposes of the illiquid investment classification under Rule 22e-4, how will the Fund determine the market value it will use to assess whether a

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            future sale of an AOS Investment would significantly change the AOS Investment’s market value and how will it make such an assessment given the Fund will not know (i)
              Apollo’s bid on the date of the sale, and (ii) to what extent such bid would reflect such AOS Investment’s market value.

            Response: The Adviser prices private credit securities independently from
              Apollo, including under Rule 22e-4. As noted in the Liquidity Risk Management Framework, the Adviser’s liquidity risk management team will generally consider market impact via the daily price reviews of firm bid quotes on AOS Investments
              relative to the price included in the Fund’s NAV. If the difference exceeds an established threshold, it would be flagged via the Adviser’s monitoring program and may be classified as “illiquid.”

          5.

            Comment: With respect to the response to comment 14 in the Initial Letter
              regarding valuation, the Registrant states that as part of the Adviser’s daily valuation procedures, it will review “. . . a run of all trades that Apollo entered into with other market participants and the execution prices. . . .” Please
              explain how the Adviser will be able to gain access to this data on a daily basis.

            Response: Apollo has contractually agreed to provide the Adviser with daily
              trade runs.

    January 13, 2025 Comments

          6.

            Comment: Please ensure the Fund’s ticker symbol and series and class IDs have been completed on EDGAR prior to effectiveness.

            Response: The Registrant confirms the Fund’s ticker and
              series and class IDs will be updated on EDGAR prior to effectiveness.

          7.

            Comment: Please add a line item for Acquired Fund Fees and Expenses to the “Annual Fund Operating Expenses” table if the Fund will incur acquired fund fees and expenses equal to or greater than one
              basis point.

            Response:  The Registrant confirms that, to the extent
              applicable, it will include a line item for Acquired Fund Fees and Expenses to the “Annual Fund Operating Expenses” table.

          8.

            Comment: Please remember to provide a copy of the Liquidity
              Risk Management Program, which may be provided confidentially under separate cover.

            Response: The Registrant will provide a description of the
              Liquidity Risk Management Framework under separate cover.

          9.

            Comment: The response to comment 1(a) in the Initial Letter
              refers to the publication or posting of quotation (or bid) sheets. Please explain what is meant by published/post. Where will the quotation sheets be published/posted, to who, and will they be publicly available?

            Response: The quotation sheets will generally be published by
              Apollo and posted to the Adviser via pre-agreed to communication tools (which may include Bloomberg chat). The quotations sheets will not be publicly available.

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          10.

            Comment: Please disclose in the registration statement the daily limit described in response to comment 1(b)
                of the Initial Letter.

            Response: The Registrant respectfully declines to disclose in
              the Fund’s registration statement the daily limit described in the previous response to comment 1(b) given the proprietary confidential nature of the contractual arrangement.

            The Adviser believes that the contractual level included in the Liquidity Agreement is designed to cover the estimated seven-day stress redemption rate
              as of the date hereof. Further, the Registrant notes that the contractual level is not a maximum limit on what Apollo is able to or may repurchase on a given day, meaning that Apollo can and may choose to repurchase AOS Investments above the
              25% minimum daily level to which they have contractually agreed.

          11.

            Comment: The Registrant’s response to comment 2 in the Initial Letter implies that AOS Investments will be
                limited to securities such as privately issued asset-backed securities. However, the response to comment 12 in the Initial Letter states that “. . . AOS Investments that are not publicly traded are expected to be loans or other securities
                for which Apollo has the faculties to source or originate and provide bid and ask prices.” Please clarify the response to comment 2 in the context of loans for which Apollo “has the faculties to originate.”

            Response: The Registrant notes that when referring to “loans”
              in the response to comment 12 in the Initial Letter, a more accurate description would be “notes.” As such, the response would be referring to “notes” that Apollo has the faculties to source. The Fund also retains the ability to hold loans,
              although loans may not be a part of the Fund’s portfolio at any given moment. The Registrant will ensure that the appropriate disclosure is revised and/or included to make clear where it is referring to notes versus loans, as applicable.

            With respect to Fund transactions in AOS Investments with Apollo entities, AOS Investments that are securities will be transacted through an Apollo
              entity that is a registered broker-dealer under the Exchange Act, whereas AOS Investments that are loans (i.e., non-securities) would be transacted through an Apollo entity that is not a registered broker-dealer under the Exchange Act.  Such
              Apollo legal entity is expected to be the trading entity through which Apollo trades loans on a secondary basis and, with respect to the Fund and such AOS Investments, may earn loan sales-related commissions and other placement fees.  The
              relevant Apollo legal entity is not a federal-chartered or state-chartered bank.

          12.

            Comment: The Staff notes that the response to comment 5 in the Initial Letter indicates Apollo has a limited
                role with respect to the Fund and its investments, both as non-exclusive broker (sourcing private credit investments) and a non-exclusive liquidity provider. Given this limited role, the Staff continues to question whether it is misleading
                to include a reference to Apollo in the Fund’s name. Please revise the Fund’s name to better reflect Apollo’s limited role in the sourcing of private credit investments for the Fund.

            Response: The Registrant believes the name of the Fund is
              appropriate for the reasons provided in its previous response to comment 5 in the Initial Letter. The Registrant does not believe the inclusion of the word “Apollo” in the name of the Fund is materially deceptive or misleading, or covered by
              Rule 35d-1. In addition, the disclosure included in the Fund’s prospectus clearly articulates Apollo’s role and clearly establishes the nexus between Apollo

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            and the Fund. Further, the Registrant does not believe there is any implied exclusive relationship particularly when the relationship is sufficiently
              described in the disclosure included in the Fund’s prospectus. Given the significant nexus between Apollo and the Fund, the Registrant believes it is appropriate to include the word “Apollo” in the name of the Fund.

          13.

            Comment: The Staff notes the response to comment 6 in the
              Initial Letter and the reference that Apollo will serve as non-exclusive liquidity provider to the Fund. Please clarify in the registration statement that the arrangement with Apollo is not exclusive.

            Response: The Registrant will add clarifying disclosure to
              the registration statement, to the extent necessary, indicating that Apollo will provide, on a non-exclusive basis, liquidity for the AOS Investments only.

          14.

            Comment: The Staff notes the response to comment 6 in the
              Initial Letter indicates that Apollo’s primary role as a broker sourcing potential private credit investments for the Fund is non-exclusive, yet the response to comment 5 in the Initial Letter regarding the Names Rule suggests the
              relationship is exclusive. Please reconcile.

            Response: The exclusive relationship noted in previous
              response 5 is solely with respect to sourcing of AOS Investments and not exclusive to sourcing of private credit investments originated or sourced by third parties other than Apollo.

          15.

            Comment: The response to comment 7 in the Initial Letter
              notes that Apollo may earn a spread on principal transactions it effects with the Fund. Please disclose in the registration statement any direct or indirect compensation to Apollo. See Item 19(d) of Form N-1A.

            Response: The Registrant, as with any broker in the fixed
              income markets, would not have insight into Apollo’s economics on any trades Apollo effects with the Fund. To the extent necessary, the Registrant will ensure that the Fund’s registration statement provides adequate disclosure with respect to
              the relationship with Apollo; however, the Fund’s Liquidity Agreement is not a fee arrangement.  Further, the Registrant does not believe the Liquidity Agreement is a “management-related service contract” for purposes of Item 19(d) of Form
              N-1A.

          16.

            Comment: The Staff notes the Registrant’s response to comment 9 in the Initial Letter, which indicates that the anticipated range of AOS Investments will be between 10-35% of the Fund’s portfolio.
              Please disclose this range in the registration statement.

            Response: The Registrant will add disclosure to the Fund’s
              registration statement indicating that the percentage range of AOS Investments is generally anticipated to be between 10-35%, noting that AOS Investments may comprise less than 10% or more than 35% of the Fund's investment portfolio at any
              given time.  The percentage allocation of Fund investments to AOS Investments will be determined solely in the discretion of the portfolio managers of the Fund and will vary depending on several factors, including, but not limited to, the
              portfolio managers’ viewpoints regarding available AOS Investments, market conditions, credit analysis, and other factors the portfolio manager