SecProbe.io

CORRESP
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    Morrison Warren
    Chapman and Cutler LLP

    Partner
    320 South Canal Street, 27th Floor

    Chicago, Illinois  60606

    T 312.845.3484

    warren@chapman.com

July 25, 2024

VIA EDGAR CORRESPONDENCE

Mindy Rotter

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Exchange Listed Funds Trust (the
“Registrant”), on behalf of its series,

Stratified LargeCap Index ETF and Stratified LargeCap Hedged ETF

File No. 333-279083

Dear Ms. Rotter:

This letter responds to your
comments provided telephonically regarding the registration statement filed by the Registrant on Form N-14 (the “Registration
Statement”) on June 7, 2024, on behalf of Stratified LargeCap Index ETF and Stratified LargeCap Hedged ETF, each a series of
the Registrant (each, an “Acquiring Fund” and collectively, the “Acquiring Funds”), and Syntax Stratified
LargeCap ETF, Syntax Stratified MidCap ETF, Syntax Stratified SmallCap ETF, Syntax Stratified U.S. Total Market ETF, Syntax Stratified
U.S. Total Market Hedged ETF and Syntax Stratified Total Market II ETF (each, an “Acquired Fund,” and collectively,
the “Acquired Funds” and together with the Acquiring Funds, the “Funds”). Capitalized terms used
but not defined herein have the meanings ascribed to such terms in the Registration Statement and the prospectus contained therein (the
“Prospectus”). We are submitting via EDGAR this letter on behalf of the Funds, which is intended to respond to your
comments.

Comment
1 – Capitalization Table

The Staff notes a Fund name
is incorrectly listed in the capitalization table. The Syntax Stratified U.S. Total Market ETF is missing “U.S.” Please confirm
in correspondence the Fund name will be corrected in a pre-effective amendment.

Response
to Comment 1

The Registrant has revised
the Registration Statement accordingly.

Comment
2 – Capitalization Table

Please review the outstanding
share calculations disclosed in the capitalization table and determine whether a footnote should be added to the capitalization table
to explain any rounding differences.

Response
to Comment 2

The Registrant has revised
the Registration Statement accordingly and included the requested disclosure.

Comment
3 – Capitalization Table

The Staff notes footnote (6)
of the capitalization table includes disclosure indicating that the Stratified LargeCap Index ETF’s net assets will include “estimated
transaction costs of repositioning of approximately $3,687.” Please explain why, as an Acquiring Fund, Stratified LargeCap Index
ETF will incur repositioning costs prior to the effectuation of the Reorganization.

Response
to Comment 3

As reflected in the section
entitled “Portfolio Repositioning,” because each of the Syntax Stratified MidCap ETF and Syntax Stratified SmallCap will be
taxable transactions and have no portfolio overlap with the Acquiring Fund (Stratified LargeCap Index ETF), each of the Syntax Stratified
MidCap ETF and Syntax Stratified SmallCap ETF will convert its existing holdings to cash in advance of the Reorganization. The Acquiring
Fund will reinvest that cash following the Reorganization in accordance with the Acquiring Fund’s strategy. The brokerage cost to
the Acquiring Fund to reposition that cash into securities comprising the Acquiring Fund’s index is estimated to be approximately
$3,687.

Comment
4 – Portfolio Repositioning

In the section entitled “Portfolio
Repositioning,” there is disclosure indicating that the Syntax Stratified U.S. Total Market ETF, Syntax Stratified Total Market
II ETF, and Syntax Stratified U.S. Total Market Hedged ETF are expected to reposition their portfolios in advance of the Reorganization.
However, the Staff notes that the capitalization table does not disclose any estimated transaction costs in connection with the repositioning
of these Funds’ portfolios. Please explain in correspondence why the repositionings of these portfolios are not expected to incur
transaction costs, or revise the capitalization table in a pre-effective amendment to the Registration Statement to include estimates
of such costs.

Response
to Comment 4

The Registrant has reconfirmed
with the Acquired Fund’s investment adviser its expected approach to repositioning and transaction costs and will revise applicable
disclosures. The Syntax Stratified U.S. Total Market ETF, Syntax Stratified Total Market II ETF, and Syntax Stratified U.S. Total Market
Hedged ETF are expected to convert their current holdings to securities aligned with the Acquiring Fund (Stratified LargeCap Index ETF)
by utilizing cash creation orders and then investing that cash in securities comprising the Acquired Fund’s portfolio in advance
of the Reorganization. A revised capitalization table with corrected and updated information will be included in the next pre-effective
amendment to the Registration Statement and is reflected below for the Staff’s reference:

Capitalization.

The following tables set forth
the capitalization of the Acquired Funds and the Acquiring Funds as of June 26, 2024, and on a pro forma basis after giving effect to
the Reorganization. Pursuant to their investment strategies, certain Acquired Funds, Syntax Stratified U.S. Total Market ETF, Syntax Stratified
Total Market II ETF and Syntax Stratified U.S. Total Market Hedged ETF, hold shares of other Acquired Funds, Syntax Stratified LargeCap
ETF, Syntax Stratified MidCap ETF and Syntax Stratified SmallCap ETF. However, as each of Syntax Stratified U.S. Total Market ETF, Syntax
Stratified Total Market II ETF and Syntax Stratified U.S. Total Market Hedged ETF undergoes the portfolio repositioning described above,
it will redeem all the shares owned of each of Syntax Stratified LargeCap ETF, Syntax Stratified MidCap ETF and Syntax Stratified SmallCap
ETF. Therefore, when giving effect to the Reorganization, the net assets and shares outstanding of Syntax Stratified LargeCap ETF, Syntax
Stratified MidCap ETF and Syntax Stratified SmallCap ETF will be less than they were on June 26, 2024 (and thus as they are presented
in the capitalization tables below) because such shares will have been fully redeemed by Syntax Stratified U.S. Total Market ETF, Syntax
Stratified Total Market II ETF and Syntax Stratified U.S. Total Market Hedged ETF pursuant to each’s portfolio repositioning. The
number of shares of Syntax Stratified LargeCap ETF, Syntax Stratified MidCap ETF and Syntax Stratified SmallCap ETF held by each of Syntax
Stratified U.S. Total Market ETF, Syntax Stratified Total Market II ETF and Syntax U.S. Total Market Hedged ETF as of June 26, 2024 that
will be redeemed are set forth below.

    Redeeming Fund

    Shares to Be
    Shares to Be
    Shares to Be

    Redeemed of
    Redeemed of
    Redeemed of

    Syntax Stratified

LargeCap ETF
    Syntax Stratified

MidCap ETF
    Syntax Stratified

 SmallCap ETF

    SYUS
    240,210
    50,491
    24,743

    SYII
    91,508
    19,235
    9,427

    SHUS
    354,231
    74,452
    36,487

    Total
    685,949
    144,178
    70,657

The rows entitled “Adjustments
to Reflect Anticipated Redemptions” in the capitalization tables below further reflect the decrease in net assets and shares outstanding
for each of Syntax Stratified LargeCap ETF, Syntax Stratified MidCap ETF and Syntax Stratified SmallCap ETF that can be anticipated when
their shares are redeemed by Syntax Total Market ETF, Syntax Total Market II ETF and Syntax U.S. Total Market Hedged ETF. The capitalization
table for the Stratified LargeCap Index ETF Reorganization is presented first, followed by the table for the Stratified LargeCap Hedged
ETF Reorganization.

    Stratified LargeCap Index ETF Reorganization
    Net Assets ($)
    Shares Outstanding
    Net Asset

 Value Per

 Share (1)

    Fund Capitalization as of June 26, 2024

    Syntax Stratified LargeCap ETF
    $94,080,671
    1,250,000
    $75.26

    Adjustments to Reflect Anticipated Redemptions
    $(51,627,634) (2)
    (685,949)

    Syntax Stratified MidCap ETF
    $11,580,105
    275,000
    $42.11

    Adjustments to Reflect Anticipated Redemptions
    $(6,071,260) (3)
    (144,178)

    Syntax Stratified SmallCap ETF
    $17,069,230
    400,000
    $42.67

    Adjustments to Reflect Anticipated Redemptions
    $(3,015,151) (4)
    (70,657)

    Syntax Stratified U.S. Total Market ETF
    $21,273,537
    450,000
    $47.27

    Adjustments
    $(4,760) (5)

    Syntax Stratified Total Market II ETF
    $8,104,298
    175,000
    $46.31

    Adjustments
    $(4,116) (6)

    Stratified LargeCap Index ETF (pro forma)
    $91,385,348(7)
    1,214,189
    $75.26

 (1) Net Asset Value (NAV) Per Share amounts are rounded to two decimals for presentation purposes. Calculation
of Net Asset and Adjustment values use unrounded amounts and may cause the sum of pro forma net assets of the Acquiring Fund not to reconcile
to the two decimal NAV presented.

 (2) Reflects the decrease in net assets that would be experienced had the redemption occurred on June 26,
2024, based upon a full redemption of all the shares held by the Redeeming Fund at the Syntax Stratified LargeCap ETF’s NAV Per
Share on June 26, 2024. The actual decrease in the Fund’s net assets will depend upon the NAV Per Share of the Fund when such redemptions
occur, which could be greater or lesser than $75.26 (rounded).

 (3) Reflects the decrease in net assets that would be experienced had the redemption occurred on June 26,
2024, based upon a full redemption of all the shares held by the Redeeming Fund at the Syntax Stratified MidCap ETF’s NAV Per Share
on June 26, 2024. The actual decrease in the Fund’s net assets will depend upon the NAV Per Share of the Fund when such redemptions
occur, which could be greater or lesser than $42.11(rounded).

 (4) Reflects the decrease in net assets that would be experienced had the redemption occurred on June 26,
2024, based upon a full redemption of all the shares held by the Redeeming Fund at the Syntax Stratified SmallCap ETF’s NAV Per
Share on June 26, 2024. The actual decrease in the Fund’s net assets will depend upon the NAV Per Share of the Fund when such redemptions
occur, which could be greater or lesser than $42.67 (rounded).

 (5) Estimated transaction costs of repositioning.

 (6) Estimated transaction costs of repositioning.

 (7) Includes post-Reorganization estimated transaction costs of repositioning of $3,687.

    Stratified LargeCap Hedged ETF Reorganization

    Fund Capitalization as of June 26, 2024

    Net Assets ($)
    Shares Outstanding
    Net Asset

 Value Per

 Share

    Syntax Stratified U.S. Total Market Hedged ETF
    $32,396,079
    800,000
    $40.50

    Stratified LargeCap Hedged ETF (pro forma)
    $32,396,079
    800,000
    $40.50

* * * * * * * * * * * * * * *
* * * * * *

Please call me at (312) 845-3484
if you have additional comments or wish to discuss any of the foregoing responses. Thank you.

    Very truly yours,

    Chapman and Cutler llp

    By:
    /s/ Morrison C. Warren

    Morrison C. Warren, Esq.

cc: Richard Malinowski, Esq., Vice President and Secretary of Exchange
Listed Funds Trust

  Richard Coyle, Esq., Partner,
Chapman and Cutler LLP