SecProbe.io

CORRESP
 1
 filename1.htm

 [Chapman
and Cutler LLP Letterhead]

 July 28, 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 the
follow-up comments provided by the staff of the Securities and Exchange Commission (the "Staff" ) on July 16, 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 – Annual Shareholder Report

 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.

 Please supplement your previous
response to address the latter part of the disclosure and ensure appropriate disclosures are included in the Fund's annual shareholder
report to also discuss the extent to which the Fund's distribution policy resulted in distributions of capital.

 Response
to Comment 1

 The Trust confirms that it
will add the requested disclosure in future annual shareholder reports to the extent the Fund's distribution policy resulted in
distributions of capital.

 Comment
2 – 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.
 The Staff further notes that items 8-10 do not appear to be included in the materials posted on the Fund's website.

 Response
to Comment 2

 The Trust confirms that Items
8-10 will be separately included under Financials and Other Information on the Fund's website.

 ********

 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