SecProbe.io

CORRESP
 1
 filename1.htm

 [Chapman
and Cutler LLP Letterhead]

 July 8, 2025

 VIA EDGAR CORRESPONDENCE

 Christina DiAngelo Fettig
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 Re: SOX Review of Exchange Listed Funds Trust

 (File No. 811-22700)

 Dear Ms. DiAngelo Fettig:

 This letter responds to comments
provided by the staff of the Securities and Exchange Commission (the "Staff" ) on May 27, 2025 via telephone, pursuant
to Section 408 of the Sarbanes-Oxley Act of 2002, regarding Saba Closed-End Funds ETF (the "Fund" ), a series of Exchange
Listed Funds Trust (the "Trust" ). Capitalized terms used herein, but not otherwise defined, have the meanings ascribed
to them in the Fund's Annual Report for the fiscal year ended November 30, 2024 (the "Annual Report" ) as filed
on Form N-CSR and Form N-CSR/A with the Staff on February 4, 2025 and April 1, 2025.

 Comment
1 – General

 The Staff notes the Fund filed
a 497 on January 17, 2024. The 497 described changes to the Fund's principal investment strategies. Please explain whether the changes
described in the 497 should be considered material fund changes and thereby require updated disclosure in the Annual Shareholder Report.

 Response
to Comment 1

 The Trust does not believe
the changes described in the January 17, 2024 supplement were of a type that would be considered material fund changes. The changes were
to the last paragraph of the principal investment strategies and were made to clarify and offer a better description of the Fund's
use of short positions as a hedge, expand the types of investments it may short to mitigate risks, and the types of risks the Fund may
seek to mitigate. The Trust has also not identified any disclosure in the Annual Shareholder Report that may require an update in connection
with the Prospectus disclosure change.

 Comment
2 – Form N-CSR/A

 The Staff notes the Fund filed
a Form N-CSR/A on April 1, 2025. In this Form N-CSR/A, the iXBRL tag for the IBOXX Liquid High Yield Index is listed as the broad-based
index while the iXBRL tag for the S&P 500 Index is listed as the additional index. In future filings, please ensure both the broad-based
index and the additional index have the appropriate tags.

 Response
to Comment 2

 The Trust confirms that the
broad-based index and the additional index will be tagged appropriately in future filings.

 Comment
3 – Form N-CSR

 The Form N-CSR states the
Fund "seeks to provide capital appreciation" while the Fund's prospectus states the Fund "seeks to provide capital
appreciation and dividend income." Please ensure these disclosures are aligned in future filings.

 Response
to Comment 3

 The Trust confirms that disclosures
will be aligned in future filings.

 Comment
4 – Form N-CSR

 Item 27A(d)(3) of Form N-1A
states:

 If the Fund has a policy
or practice of maintaining a specified level of distributions to shareholders, disclose if the Fund was unable to meet the specified level
of distributions during the reporting period. Also discuss the extent to which the Fund's distribution policy resulted in distributions
of capital.

 The Staff notes the Fund's
prospectus contains a "Fund Distributions Risk" that states the Fund "seeks to make cash distributions once per month
throughout a calendar year." Per Item 27A(d)(3), please ensure appropriate disclosures are included in the Annual Shareholder Report.

 Response
to Comment 4

 The Trust confirms that it
will add the requested disclosure in future filings to the extent the Fund is unable to meet the specified level of distributions during
the reporting period.

 Comment
5 – Form N-CSR

 The Staff notes the Fund is
required to post Items 7-11 of Form N-CSR to the Fund's website. See 17 CFR §270.30 e -1.
 Please explain how the Trust has complied with this requirement.

 Response
to Comment 5

 The Trust notes the Fund has
posted the Annual Shareholder Report and Annual Financials and Other Information (which include Items 7-11 of Form N-CSR) on the Fund's
website. Therefore, the Trust is in compliance with 17 CFR §270.30 e -1 .

 Comment
6 – Financial Statements

 The Staff notes the Fund invests
in closed-end funds. Some of these underlying funds have multi-class relief. If appropriate, in future filings, please disclose the class
of shares held in each underlying closed-end fund.

 Response
to Comment 6

 The Trust confirms that it
will add the requested disclosure in future filings.

 Comment
7 – Notes to Financial Statements

 In Note 3(b), please disclose
the Adviser pays the Sub-Adviser in future filings.

 Response
to Comment 7

 The Trust confirms that it
will add the requested disclosure in future filings.

 Comment
8 – Notes to Financial Statements

 In Note 2(b), please disclose
the valuation policy for investment in closed-end funds in future filings. Please ensure that each disclosure is tailored to exchange
traded funds and non-exchange traded funds.

 Response
to Comment 8

 The Trust appreciates the
Staff's comment but believes the valuation disclosure adequately describes the policy for the types of securities the Fund intends to
invest in. The Trust confirms that the Fund does not intend to invest in non-exchange traded closed-end funds, which is indirectly referenced
in the Fund's principal investment strategies as part of the Fund's definition of "Underlying Fund", which in
relevant part provides that an Underlying Fund has "… a fixed number of shares trade on a secondary market, such as a securities
exchange."

 The Fund's disclosure
under Note 2(b) identifies closed-end funds within those investments generally categorized as Level 1 that will utilize a market price.
If, for any reason, the Fund were to hold shares of a closed-end fund that either ceased trading or was unlisted, the Trust believes that
disclosure of that security within the Fund's fair valuation framework under Rule 2a-5, and associated disclosures of such an investment
as other than a Level 1 security, would be customary.

 Comment
9 – Form N-CEN

 The Staff notes Items C.8(a)
and C.8(b) were checked "no" on the Fund's Form N-CEN. The Staff additionally notes that the Fund voluntarily waived
advisory fees of an underlying affiliate fund. Please supplementally confirm whether the boxes should have been checked "yes."

 Response
to Comment 9

 The Trust confirms that Items
C.8(a) and C.8(b) should have been checked "yes" due to the voluntary fee waiver.

 Comment
10 – Form N-CEN

 Please supplementally explain
why the total amount for each dealer in Form N-CEN C.17(a)(vii) exceeds the total amount disclosed in Item C.17(b).

 Response
to Comment 10

 The Trust confirms that it
converted the Fund from one fund administration firm to another during the annual reporting period ended November 30, 2024, which are
generally responsible for the data and preparation of Form N-CEN. The total amount disclosed in Item C.17(b) was inaccurate due to the
exclusion of certain brokers from the pre-conversion period in the calculation. The total amount disclosed for each dealer in Form N-CEN
C.17(a)(vii) was correctly reflected on the Form N-CEN.

 ********

 Please call me at (312) 845-3484
if you have any questions or issues you would like to discuss regarding these matters.

 Sincerely yours,

 Chapman and Cutler llp

 By:
 /s/ Morrison C. Warren

 Morrison C. Warren