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    Eversheds Sutherland
    (US) LLP

    700 Sixth Street, NW, Suite
    700

    Washington, DC 20001-3980

    D: +1 202.383.0472

    F: +1 202.637.3593

    cynthiabeyea@

    eversheds-sutherland.com

June 1, 2022

Karen Rossotto, Esq.

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

 Re: USCF ETF Trust

File Nos. 333-196273, 811-22930

Dear Ms. Rossotto:

On February 9, 2022, USCF ETF Trust (the “Trust”)
filed post-effective amendment no. 123 to the above-referenced registration statement on Form N-1A with the Securities and Exchange Commission
(the “SEC”) to register a new series of the Trust, the USCF ESG Dividend Income Fund (now renamed the USCF Dividend Income
Fund) (the “Fund”). On March 29, 2022, May 24, 2022, and May 26, 2022, you provided oral comments to me on behalf of the SEC
staff (the “Staff”) during a telephone call.

Set forth below in italics under the heading
“Initial Comments” is each Staff comment from the March 29, 2022 call, and each comment is immediately followed by the Trust’s
response thereto. Set forth below in italics under the heading “Subsequent Comments” is each Staff comment from the May 24th
and May 26th calls, and each comment is immediately followed by the Trust’s response thereto. The Subsequent Comments
were provided in response to the Trust’s draft response to the Initial Comments. Terms not defined herein have the meanings ascribed
to them in the prospectus. References to prospectus page numbers refer to the prospectus contained in post-effective amendment no. 123
to the Trust’s registration statement on Form N-1A.

INITIAL COMMENTS

Prospectus

Principal Investment Strategies of the Fund

 1. Because the Fund has ESG in its name it is required to adopt an 80% test. Please include such a test.

Response: The Fund respectfully declines to
adopt an 80% policy to invest in ESG-related investments.

Rule 35d-1 under the Investment Company Act of 1940,
as amended (the “1940 Act”) requires a fund to adopt an 80% policy when the fund’s name contains a term that indicates
the fund focuses on a particular type of investment. Rule 35d-1 does not specifically address the term “ESG” and the Fund
is unaware of any relevant rules indicating that Rule 35d-1 applies to the term ESG.

Guidance published by the Staff related to Rule 35d-1
(including the Rule’s adopting release) states that terms such as “fixed income,” “equity,” and “high-yield”
indicate a particular type of investment, and must comply with Rule 35d-1, while terms such as such as “income,” “growth,”
and “value” are not subject to Rule 35d-1 because these terms suggest a particular strategy rather than an investment type.
The Fund believes that ESG does not indicate a particular type of investment, but rather an investment strategy, similar to terms such
as “growth” and “value.” The Fund further notes that the Staff recently requested comments on Rule 35d-1 regarding
whether “ESG” and similar terms should be covered under Rule 35d-1, suggesting that the Staff does not have a definitive policy
regarding the term ESG. The request for comment also acknowledged that many funds currently use the term “ESG” in their names,
and several of those funds treat the term as an investment strategy, and have not instituted an 80% investment policy.

Eversheds Sutherland (US) LLP is part of a global legal practice, operating
through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of
offices, please visit www.eversheds-sutherland.com.

  Karen Rossotto, Esq.

  June 1, 2022

  Page 2

Although the Fund disagrees with the Staff regarding
the applicability of Rule 35d-1 to the term ESG, the Fund does acknowledge the importance of compliance with Section 35(d) of the 1940
Act, i.e., having a fund name that is not materially deceptive or misleading. The Fund believes that its name is not materially deceptive
or misleading, because its registration statement clearly describes a strategy focused on dividend income producing investments that are
issued by companies that exhibit the Fund’s ESG criteria (such criteria is described in the principal investment strategy, as revised
in response to comments below). The Fund will only invest in securities of companies that meet both its financial criteria and ESG criteria
and does not intend to invest in other securities under normal circumstances.

 2. In the investment strategy, please describe the objective criteria the
Fund uses in assessing what issuers it considers to have strong ESG values. Please include references to indexes, third party ratings,
screens and the factors the screens use, as applicable.

Response: The Fund has revised the relevant
disclosure related to the Sub-Adviser’s ESG assessments in its principal investment strategy as follows:

As an integral part of its process
to evaluate potential portfolio companies, the Sub-Adviser conducts an ESG assessment. The Sub-Adviser will first screen out companies
based on certain objective ESG characteristics. Such screening criteria eliminates: (i) companies that extract coal; (ii) companies that
derive greater than 10% of revenue from production of alcohol, tobacco, or firearms; and (iii) companies that provide parts or services
that are tailor-made and necessary for the lethal function of controversial weapons. The Sub-Adviser uses audited reports and other publicly
available information in order to determine whether a company should be screened out of the Fund’s investable universe.

In addition to the companies
eliminated by the screening process, the Sub-Adviser seeks to eliminate, based on its own assessment, companies that have demonstrated
a history of weak governance or repeated failures to prevent or mitigate ESG risks. The Sub-Adviser evaluates a company’s performance
relative to peers on environmental or social indicators. Examples of such ESG key performance indicators include the frequency and scope
of its ESG disclosures, human rights record and policies, and corporate board structure. More specifically, the Sub-Adviser’s ESG
assessments focus on the following criteria:

 · Governance
and Ethics. The Sub-Adviser believes that oversight of management is a board’s responsibility, and further, that oversight of
the board is an investor right and responsibility. As such, the Sub-Adviser considers the structure of a company’s board and whether
it has an independent chair, the extent to which the company is controlled by insiders and family members, and the responsiveness of the
board to investor votes. The Sub-Adviser also considers the strength and vision of a company’s leaders and the company’s strategy
and vision.

 · Environmental
Record. The Sub-Adviser seeks to invest in companies that seek to maintain a clean environmental record and mitigate the negative
impacts of their operations on the environment. In assessing a company, the Sub-Adviser considers how a company manages its use of, and
impact on, natural resources and the planet, and how it mitigates any unintentional or unavoidable environmental harms or depletion caused
by its operations.

  Karen Rossotto, Esq.

  June 1, 2022

  Page 3

 · Human
Rights Record. The Sub-Adviser favors companies that have human rights policies, practices, and due diligence processes that are grounded
in international norms, including the United Nation’s Guiding Principles on Business and Human Rights.

 · Diversity.
The Sub-Adviser reviews each company for certain indicators, including the racial, ethnic, and gender composition of its Board, management,
and workforce, to reveal areas where human capital management is lagging, recruitment is failing to capture the range of expertise and
suitable candidates available, where homogeneity might be creating narrowness of perspectives and/or confirmation bias, and where a company’s
competitive advantage may be at risk.

In completing its ESG assessments,
the Sub-Adviser does not rely on any one source of information, but rather collects information from multiple sources including a company’s
audited reports and other publicly available information (such as sustainability reports and voluntary ESG disclosures); third-party ESG
research and ratings from ESG data providers; non-profit benchmark reports, research, and analysis; media reports; and discussions with
company management.

 3. If the Fund will invest in emerging markets, please disclose that. If
unsponsored ADRs are a principal investment, please disclose that in disclosed risks in the summary.

Response: The Fund may invest in ADRs of companies
that are headquartered in emerging markets countries, and has added disclosure related to emerging markets in the principal risks section.
The Fund will not invest in any unsponsored ADRs.

 4. If the Fund intends to focus on particular sectors, please disclose those sectors in the strategy.

Response: The Fund does not intend
to focus on any particular sector.

 5. In the second paragraph on page two of the prospectus, clarify the Fund’s
definition of ESG and its specific ESG areas of focus. Among each of the factors listed in the paragraph, which factor will the Fund focus
on and, with respect to that factor, what is the Fund specifically looking for?

Response: The Fund has revised the principal
investment strategy to clarify the Fund’s definition of ESG. Please refer to the response to Comment 2.

 6. The second and third paragraphs on page two of the prospectus reference
screens, please clarify what the Fund is screening out in the disclosure. Are these two references to screens the same screen? Please
clarify the investment process in the disclosure.

Response: The Fund has revised the principal
investment strategy to, among other items, clarify its use of screens. Please refer to the response to Comment 2.

 7. In the strategy, please identify any provider of third-party research
that the Fund intends to use or the primary provider if the Fund intends to use multiple third-party providers. Please also briefly summarize
each provider’s criteria and methodologies in the principal strategy. Also consider any related principal risks to the Fund’s
use of third-party data providers since the criteria used by providers can differ significantly.

  Karen Rossotto, Esq.

  June 1, 2022

  Page 4

Response: The Sub-Adviser does not rely on
any one third party research provider and seeks to collect information from a large variety of providers when making ESG assessments.
The research providers used by the Sub-Adviser may change over time, new research providers may become available, and certain research
providers might be more or less useful depending on the type of investment under review. Further, existing research providers may change
their criteria and methodologies to reflect current trends or events. Due to the large amount of research providers used, and the potential
for changes to those providers and their methodologies, the Fund does not believe that naming these providers in the principal strategy
is appropriate or meaningful, as such disclosure may quickly become outdated or inaccurate. The Fund believes that the ESG Investing Risk
included in the prospectus (revised in response to Comment 10), addresses the risks associated with use of third party data providers.

 8. To the extent not addressed in response to Comment 7, please describe
the underlying data the Fund reviews to determine whether it meets its ESG criteria and the sources of the data.

Response: The Fund believes that it has fully
described its use of ESG data in prior responses.

 9. The fourth paragraph on page two of the prospectus discusses taking into
consideration both the financial and the ESG profile of a company. Please clarify the Fund’s investment process to indicate which
of these characteristics the Fund prioritizes.

Response: Any investment made by the Fund’s
portfolio managers must meet both the financial criteria and the ESG criteria for the Fund. The portfolio managers consider financial
criteria and ESG criteria equally when making investment decisions. For example, the Fund will not invest in a company that meets all
of the Fund’s financial criteria, but fails to exhibit the Fund’s desired ESG criteria and vice versa. The referenced disclosure
has been updated to clarify that these criteria are equally considered.

Principal Risks
of Investing in the Fund

 10. Within the ESG Risk Factor, please include disclosure indicating, as
applicable, that (1) because the Fund’s ESG criteria may exclude the securities of certain issuers for non-financial reasons, the
Fund may forego some market opportunities available to funds that do not use ESG criteria; (2) ESG criteria may be linked to long-term
rather than short-term returns; (3) because when analyzing ESG criteria for securities the Sub-Adviser relies on the information and scoring
models published by third-party sources there is a risk that this information may be incorrect or only take into account one of many ESG-related
components of portfolio companies and the scores and ratings across third-party providers may be inconsistent or incomparable.

Response: The Fund has revised “ESG Investing
Risk” in the summary and statutory section of the prospectus to include the requested disclosures.

 11. At an appropriate place in the registration statement, please disclose
that, in stressed market conditions, the market for an ETF’s shares may become less liquid in response to deteriorating liquidity
in the markets for the ETF’s underlying portfolio holdings.  Please also note that this adverse effect on liquidity for the
ETF’s shares in turn could lead to wider bid/ask spreads and differences between the market price of the ETF’s shares and
the underlying value of those shares.

Response: The Fund has revised “Secondary Market Risk”
in the summary and statutory section of the prospectus to incorporate the requested disclosure.

  Karen Rossotto, Esq.

  June 1, 2022

  Page 5

 12. As the Fund invests in foreign securities, please disclose that, where
all or a portion of the ETF’s underlying securities trade in a market that is closed when the market in which the ETF’s shares
are listed and trading in that market is open, there may be changes between the last quote from its closed foreign market and the value
of such security during the ETF’s domestic trading day.  In addition, please note that this in turn could lead to differences
between the market price of the ETF’s shares and the underlying value of those shares.

Response: The Fund has revised “Foreign Securities Risk”
in the summary and statutory section of the prospectus to include the requested disclosures.

Fund Performance

 13. If performance can be found somewhere during the first year, like a website
or a phone number, please disclose that.

Response: The Fund has updated the “Fund
Performance” section of the prospectus to indicate where shareholders can obtain updated performance information.

Prior Performance
of Similar Accounts

 14. We note the Fund’s strategy references ESG in its name while the
Composite’s name suggests that it excluded carbon energy. It is our understanding that ESG is substantially broader in focus than
simply excluding carbon energy. Please tell us in correspondence more about the Composite’s strategy and your basis for believing
the Fund and Composite have substantially similar objectives, policies, and strategies.

Response: The Fund will utilize a strategy
identical to the strategy of the Composite, including utilizing the same ESG screening process. Since its inception as an asset manager
in 1991, the Sub-Adviser has integrated ESG screening and analysis into its investment philosophy, and ESG analysis is integral to the
Sub-Adviser’s identity as an asset manager. The Sub-Adviser does not include “ESG” in the names of the strat