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CORRESP
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    Morrison
                                         Warren

    Partner

    Chapman
                                         and Cutler LLP

    320
    South Canal Street, 27th Floor

    Chicago,
    Illinois 60606

    T
    312.845.3484

    warren@chapman.com

August
13, 2024

VIA EDGAR CORRESPONDENCE

Soo Im-Tang

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,

                                            Long Pond Real Estate Select ETF

                                            File No. 333-180871

Dear
Ms. Im-Tang:

This
letter responds to your comments provided telephonically regarding the registration statement filed by the Registrant on Form N-1A (the
“Registration Statement”) with the staff of the Securities and Exchange Commission (the “Staff”)
on May 13, 2024, on behalf of Long Pond Real Estate Select ETF (the “Fund”), a series of the Registrant. 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 Fund, which is intended to respond
to your comments.

Comment
1 – Cover Page

Please
update the cover page of the Prospectus to include the Fund’s ticker symbol, the date of the effectiveness of the Registration
Statement and the primary listing exchange of the Fund’s shares.

Response
to Comment 1

The
Registration Statement has been revised accordingly.

Comment
2 – Fee Table

Please
include a completed fee table and expense example. Please file this at least five business days prior to the effectiveness of the Registration
Statement.

Response
to Comment 2

Pursuant
to the Staff’s comment, a completed fee table and expense example has been set forth on Exhibit A hereto.

Comment
3 – Fee Table

The
Staff notes that the Fund’s strategy disclosure reflects potential investments in other investment companies. Please confirm that
the Fund’s anticipated acquired fund fees and expenses will not exceed 1 basis point for the Fund’s first year, or reflect
such expenses as a separate line item in the fee table.

Response
to Comment 3

Pursuant
to the Staff’s comment, the Registrant confirms that the Fund’s estimated acquired fund fees and expenses will not exceed
one basis point.

Comment
4 – Principal Investment Strategies

In
the section entitled “Principal Investment Strategies,” the Staff notes references to both “sectors” and “industries.”
Please revise to include disclosure clarifying the difference between sectors and industries.

Response
to Comment 4

The
Registrant has included disclosure explaining that for the purpose of classifying companies, sectors are a broader category than industries
and industries comprise sectors.

Comment
5 – Principal Investment Strategies

If
the Fund intends to invest principally in Real Estate Select Companies with a specific geographic focus, please disclose that focus in
the section entitled “Principal Investment Strategies” and include corresponding risk disclosure.

Response
to Comment 5

The
Registrant confirms that the Fund’s principal strategies do not intend to focus on any particular geographic area.

Comment
6 – Principal Investment Strategies

The
Staff notes the following disclosure set forth in the section entitled “Principal Investment Strategies”:

The
Fund may invest in REITs of any type or sub-type.

Please
revise to include disclosure that clarifies what is meant by any “type or sub-type.”

Response
to Comment 6

The
Registrant will include disclosure that clarifies that REITs are classified across several differing component industries depending on
property type, that are further classified into one or more sub-industries per industry.

Comment
7 – Principal Investment Strategies

The
Staff notes the following disclosure set forth in the section entitled “Principal Investment Strategies”:

The
Sub-Adviser identifies companies that meet the criteria for the Fund by assessing the relative attractiveness of each sub-industry,
business model and company in the investable universe. (emphasis added)

Please
revise to include disclosure that clarifies what is meant by “sub-industry.” Please consider providing examples as appropriate.

Response
to Comment 7

The
Registrant confirms that it will clarify the use of the term and include a reference example as follows:

The
Sub-Adviser identifies companies that meet the criteria for the Fund by assessing the relative attractiveness of each industry and sub-industry,
if applicable (for example, the Specialized REIT industry is comprised of REITs of distinct property types classified into sub-industries,
such as Self-Storage REITs, Telecom Tower REITs, Timber REITs and Data Center REITs), business model and company in the investable universe.

Comment
8 – Additional Principal Investment Strategies Information

The
Staff notes the following disclosure set forth in the section entitled “Principal Investment Strategies”:

The
Fund will concentrate its investments (i.e., invest 25% or more of the value of its total assets) in the groups of industries
comprising the real estate and consumer discretionary sectors, collectively.

Please
consider revising to clarify whether the Fund’s concentration policy means that it will invest at least 25% of its assets in the
real estate and consumer discretionary sectors collectively, or whether it will invest at least 25% of its assets in each individual
sector.

Response
to Comment 8

The
Registrant confirms that this policy means that it will invest at least 25% of its assets in the real estate and consumer discretionary
sectors collectively and will reword the sentence to clarify.

Comment
9 – Principal Investment Strategies

The
Staff notes that the Fund will concentrate in the groups of industries comprising the real estate and consumer discretionary sectors.
If this is the intended concentration policy, please ensure these two sectors are included within the definition of “Real Estate
Select Companies” in the Fund’s 80% investment policy.

Response
to Comment 9

The
Registrant confirms that the articulated 80% investment policy includes companies comprising the real estate sector and consumer discretionary
sector. Nonetheless, the Registrant declines to make the inclusion of companies comprising the consumer discretionary more explicit in
the 80% policy because it believes the inclusion of such disclosure would only to serve to confuse investors and because the classification
of certain securities as comprising the consumer discretionary is tangential to the operation of the Fund’s principal investment
strategy.

The
investment focus of the Fund is to invest at least 80% of its net assets in securities defined as “Real Estate Select Companies”.
For the purposes of classifying companies as “Real Estate Select Companies”, the Registrant specifically includes those that
will meet the Staff’s 50% revenue test, as well as those companies that provide goods and services to real estate industry participants,
which are most commonly classified in the consumer discretionary sector, and which have an economic nexus to companies in the real estate
sector, but are unlikely to meet the 50% revenue test. It is estimated that the Fund may allocate to such companies in amounts that exceed
20%, which during periods of such allocation would cause the Fund to fail to meet the requirements of an 80% investment policy that included
only companies in the Real Estate sector and did not include within the 80% investment policy such real-estate related securities that
may exist in other sectors. Therefore, the Registrant believes that the 80% investment policy accurately describes the types of holdings
the Fund is expected to invest in, that the concentration policy accurate describes what types of securities the Fund may hold more than
25% of its assets in.

Comment
10 – Principal Risks - Exchange Traded Funds Risk

Please
confirm whether the securities in which the Fund intends to invest are traded outside of a collateralized settlement system. If so, please
disclose that there are a limited number of financial institutions that may act as authorized participants that post collateral for certain
trades on an agency basis (i.e. on behalf of other market participants). Please also disclose that to the extent that those authorized
participants exit the business or are unable to process creation and/or redemption orders and no other authorized participant is able
to step forward to do so, there may be a significantly diminished trading market for the Fund’s shares. In addition, please note
that this could in turn lead to differences between the market price of the Fund’s shares and the net asset value of those shares.

Response
to Comment 10

The
Registrant confirms it is not currently intended for the Fund to invest in securities traded outside a collateralized settlement system.

Comment
11 – Statement of Additional Information – Investment Restrictions

Regarding
the Fund’s concentration policy, please provide adjacent narrative disclosure indicating the Fund will, for the purposes of determining
whether the Fund’s portfolio is concentrated in a particular industry, consider the concentration of its underlying investment
companies when determining the Fund’s compliance with its concentration policy.

Response
to Comment 11

The
Registrant respectfully declines to make the requested change because it is not aware of any requirement to "look through"
its investments in an investment company to the underlying holdings of the investment company in order to determine compliance with its
policy on concentration.

Comment
12 – Statement of Additional Information - Investment Restrictions

In
Item 4 of the Prospectus, the Fund includes disclosure indicating that it is classified as “non-diversified” under the 1940
Act. However, investment policy #6 in the section entitled “Investment Restrictions” in the Fund’s Statement of Additional
Information indicates that the Fund is “diversified.” Please reconcile.

Response
to Comment 12

The
Statement of Additional Information has been revised accordingly.

Comment
13 – Item 32(c) – Powers of Attorney

The
Staff notes that the powers of attorney incorporated by reference are dated as of October 24, 2023. Please file as exhibits to the Registration
Statement powers of attorney dated within six months of the filing of the amendment to the Registration Statement.

Response
to Comment 13

The
Registrant confirms it will file updated powers of attorney with its next post-effective amendment to the Registration Statement.

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

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

Exhibit
A

Fees and Expenses

This
table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such
as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example below.

    Annual
                                            Fund Operating Expenses

    (expenses
    that you pay each year as a percentage of the value of your investment)

    Management
    Fee
    1.10%

    Distribution
    and Service (12b-1) Fees
    0.00%

    Other
    Expenses1
    0.00%

    Acquired
    Fund Fees and Expenses1
    0.00%

    Total
    Annual Fund Operating Expenses
    1.10%

1
Based on estimated amounts for the current fiscal year.

Example

This
Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then sell all of your shares at the end of those periods. The
Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although
your actual costs may be higher or lower, based on these assumptions your cost would be:

    1
    Year
    3
    Years

    $112
    $350