SecProbe.io

September 19, 2024
 VIA E-MAIL
 Maureen E. Towle Allspring Funds Management, LLC
1415 Vantage Park Drive, 3
rd Floor
Charlotte, NC 28203  Re: Allspring Exchange-Traded Funds Trust   Pre-Effective Amendment No. 1 to Registration Statement on Form N-1A
File Nos. 333-240113; 811-23597
 Dear Ms. Towle:
On August 12, 2024, Allspring Exchange-Traded Funds Trust (the “Trust”) filed a pre-
effective amendment to a registration statement  on Form N-1A under the Securities Act of 1933
(the “Securities Act”) and the Investment Company Act of 1940 (the “1940 Act”) to offer shares
of six ETFs ( the “ Funds ”). We have reviewed the amendment and provide our comments below.
 General  1. We note that substantial portions of the filing are incomplete. We may have additional
comments on such portions when you comple te them in a pre-effective amendment, on
disclosures made in response to this lett er, on information supplied supplementally, or on
exhibits added in any amendments.
2. Please supplementally explain if you have subm itted, or expect to submit, any exemptive
application or no-action request in connect ion with the registration statement.

3. Where a comment is made in one location, it a pplies to all similar disclosure appearing
elsewhere in the registration statement. Plea se confirm in your response letter that, in
response to staff comments, changes have been made to the disclosure for each applicable
ETF.
  Prospectus Summaries  Core Bond ETF
4. Page 2, Fees and Expenses. At least one week before effectiveness, please provide the
staff a completed fee table and expense ex ample. In addition, please confirm any fee
waivers reflected in the fee table will continue  for at least one year from effectiveness.

Maureen E. Towle
September 19, 2024

2
 5. Page 2, Principal Investment Strategy.  The di sclosure describes that the fund will invest
principally in investment grade debt sec urities.  Please confirm supplementally that
investments in lower rated, high yield securities are not part of the principal strategy.
 6. Page 3, Principal Investment Risks, Foreign I nvestment Risk.  For each ETF investing 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 t he underlying value of those shares. Such
disclosure may appear in risks or in disclosure about the ETF trading.

7. Page 4, Principal Investment Risks, Derivati ves Risk.  Disclosure refers to the Fund ’s,
“use of derivatives, such as futures, options and swap agreements ….”  Please clarify
disclosure as to the Fund ’s derivatives strategy and related risks.  For example, futures
are discussed in the principal strategy disclosure, but options and swaps are not.

Core Plus Bond ETF

8. Page 6, Principal Investment Strategy. The princ ipal strategy disclosure states that the
fund may invest in foreign debt, including emerging markets debt .  Please provide a
definition for emerging markets.

9. Page 8, Principal Investment Risks, Futures Cont ract Risk.  Futures risk is listed as a
principal risk but is not mentioned in princ ipal strategy (currency derivatives such as
forwards and currency contracts are mentione d).  Please revise disclosure to match
principal strategy disclosure with principal risk disclosure.
Income Plus ETF

10. Page 11, Principal Investment Strategy. The pri ncipal strategy disclosure states, “The
pursuit of the Fund’s investment objective of total return, a component of which consists
of a high level of current income, however, implies that the Fund will normally seek to
have significant holdings of securities offeri ng higher yields relative to U.S. Treasuries. ”
Please revise the disclosure to remove the term “implies ,” for example, disclosure might
state, “the Fund will normally seek to have significant holdings of securities offering
higher yields relative to U.S. Treasuries. ”

11. Page 11, Principal Investment Risks.  As pa rt of its principal strategy, the fund will
manage currency “as a separate asset class” to seek potential appreciation, including through spot currency transactions.  In light of this principal strategy disclosure, please consider additional principal risk disclosure  as to the risks associated with the fund’s
foreign currency investments.

Maureen E. Towle
September 19, 2024

3
 Large Core ETF

12. Page 16, Principal Investment Risks.  The pri ncipal risk disclosure includes Derivatives
Risk while the Fund ’s principal strategy does not include disclosure as to its use of
derivatives.  Please revise the disclosure  to match principal strategy disclosure with
principal risk disclosure.
13. Page 16, Principal Investment Risks.  The principal risk disclosure includes Focused
Portfolio Risk which indicates the fund will be impacted by volatility in a small number
of issuers.  Please consider additional disclo sure in principal strategies if the fund intends
to hold large, concentrated positions in a small number of issuers.  We note disclosure
stating the fund intends to hold 40 to 60 large cap U.S. companies.
 Large Growth ETF

14. Page 19, Principal Investment Strategy.  Disclosure states, “ The portfolio management
team categorizes its holdings into one of four buckets (core growth, consistent growth, cyclical growth, and emerging growth) which serves to open up the universe of available
investment opportunities and lessen volatility compared to peers. ”  Please clarify if
investments in “emerging growth” companie s are limited to the fund’s 20% bucket as
80% of the fund is invested in large cap U.S. companies.  Furthermore, revise the statement to clarify how the categorization of  holdings will “open up” the investment
opportunities of the fund.  Similarly, please revise the statement to clarify how the
categorization of holdings will “lessen volatility compared to peers.”

15. Page 19, Principal Investment Risks.  The pri ncipal risk disclosure includes the caption
Growth/Value Investing Risk.  Please revise to describe only the risks of Growth Investing as the fund ’s principal strategy is to invest in “high -quality growth companies.”
 Statement of Additional Information  16. Page 50, Illiquid Securities.  This  disclosure, and subsequent disclosure, refers to money
market funds.  As this Statement of Informat ion does not cover any money market funds,
the references to such funds should be deleted.

17. Page 75, Acceptance of Orders of Creation Un its. As discussed below, please delete the
statement that the Fund reserves the “absolute” right to reject or suspend creations .
Please also remove from the disclosure the right to reject or suspend creations if, “(d) the
acceptance of the Deposit Securities would have  certain adverse tax consequences to the
Fund" and “(f) the acceptance of the Fund Deposit would otherwise, in the discretion of
the Trust or Manager, have an adverse eff ect on the Trust or the rights of the beneficial
owners ….”

The staff recognizes that the disclosure in  question may be derived from statements
related to prior exemptive relief obtained by ETFs.  However, in connection with the
recent proposal and adoption of rule 6c- 11, the Commission stated its belief that “an ETF
generally may suspend the issuance of creati on units only for a limited time and only due
to extraordinary circumstances, such as when the markets on which the ETF’s portfolio

Maureen E. Towle
September 19, 2024

4
 holdings are traded are closed  for a limited period of time.”  See “Exchange -Traded
Funds,” Release No. 33 -10515, at pp.67-68 (June 28, 2018).  In adopting the rule, the
Commission further noted that “[i]f a suspension of creations impairs the arbitrage mechanism, it could lead to significant de viation between what retail investors pay (or
receive) in the secondary market and the ETF’s approximate  NAV. Such a result would
run counter to the basis for relief from section 22(d) and rule 22c-1 and therefore would be inconsistent with rule 6c- 11.”  See “Exchange -Traded Funds,” Release No. 33 -10695,
at p.59 (Sep. 25, 2019).  While the staff recognize s that in certain limited circumstances,
ETFs may have a sound basis for rejecting indi vidual creation orders, the staff believes
that the disclosure noted above is sufficiently broad to run counter to the Commission’s
position to the extent the rejection of orders w ould effectively result in the suspension of
creations.

Part C: Other Information

18. Page 4, Exhibits. Please file the finaliz ed exhibits once they are available.

*    *    *
Responses to this letter should be made in a letter to me filed on Edgar and in the form
of a pre-effective amendment filed pursuant to Rule 472 under the Securities Act.  Where no change will be made in the filing in response to  a comment, please indicate this fact in the
letter to us and briefly state the basis for your position.
You should review and comply with all applicable requirements of the federal securities
laws in connection with the preparation and distribution of preliminary prospectuses.
Although we have completed our initial review of the regi stration statement, the filing
will be reviewed further after we receive your response.  Therefore, we reserve the right to comment further on the registration statement an d any amendments.  After we have resolved
all issues, the Fund and its underwriter must reque st acceleration of the effective date of the
registration statement.
In closing, we remind you that the Fund and its management are responsible for the
accuracy and adequacy of their disclosures in the registration statement, notwithstanding
any review, comments, action, or absence of action by the staff.

Should you have any questions regarding this letter , please feel free to contact me at
(202) 551-6760.                 Sincerely,                      /s/ Jeffrey A. Foor
               Jeffrey A. Foor               Senior Counsel

cc: Jennifer McHugh      Senior Special Counsel