SecProbe.io

CORRESP
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[Chapman
and Cutler LLP Letterhead]

October 3, 2024

VIA EDGAR CORRESPONDENCE

Chris Bellacicco

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Amplify ETF Trust

  File Nos. 333-207937; 811-23108

Dear Mr. Bellacicco:

This letter responds to your
comments, provided by telephone regarding the registration statement filed on Form N-1A for Amplify ETF Trust (the “Trust”)
with the Securities and Exchange Commission (the “Commission”) on August 6, 2024 (the “Registration Statement”).
The Registration Statement relates to the Amplify Bloomberg U.S. Treasury Target 12 Option Income ETF (formerly Amplify Bloomberg
U.S. Treasury 12% Premium Covered Call ETF) (the “Fund”), a series of the Trust. Capitalized terms used herein, but
not otherwise defined, have the meanings ascribed to them in the Registration Statement.

Comment 1 – General

The staff of the Commission
(the “Staff”) reminds the Fund and its management that they are responsible for the accuracy and adequacy of the disclosures,
notwithstanding any review, comments, action or absence of action by the Staff.

Response to Comment 1

The Fund acknowledges the
Staff’s comment.

Comment 2 – General

Please provide responses sufficiently
in advance of effectiveness to provide the Staff with adequate time to review.

Response to Comment 2

The Fund confirms it will
endeavor to provide the Staff with responses sufficiently in advance of effectiveness for its review.

Comment 3 – fee table

Please provide a completed
fee table and example sufficiently in advance of effectiveness for the Staff’s review.

Response to Comment 3

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 4 – Principal Investment Strategies

The Staff requests the to
Fund provide, in plain English, a summary of the Fund’s investment strategy at the beginning of the principal investment strategies
section.

Response to Comment 4

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 5 – Principal Investment Strategies

Please explain what discretion,
if any, that the index provider may exercise in administering the Bloomberg U.S. Treasury 20+ Year 12% Premium Covered Call 2.0 Index
(the “Index”).

Response to Comment 5

The index provider does not
have any discretion in administering the Index. The Index seeks a sought-after annual premium from selling call options, and the index
provider changes the level of call options written consistent with that directive.

Comment 6 – Fund’s Name

Please explain supplementally
to the Staff why “12%” and “Covered” in the Fund’s name is not materially defective or misleading pursuant
to Section 35(d) of the 1940 Act.

Response to Comment 6

The Fund has changed its name
in connection with the Staff’s comment.

Comment 7 – Principal Investment Strategies

The Staff asks that the Fund
please add disclosure briefly describing the Underlying ETF to the second paragraph of the principal investment strategies section.

Response to Comment 7

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

    - 2 -

Comment 8 – Principal Investment Strategies

The Staff asks that the Fund
clarify and explain further the following disclosure: “The Index seeks to receive a targeted annualized premium of 12% through its
selling of call option contracts.”

Response to Comment 8

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 9 – Principal Investment Strategies

The Staff asks the Fund add
disclosure clarifying what determines the size of the sold call options to the following disclosure: “In seeking to receive the
annualized 12% premium, the Index will vary the size of its sold call option contracts on the Underlying ETF.”

Response to Comment 9

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 10 – Principal Investment Strategies

With respect to the sold call
options, the Staff asks that the Fund: (i) please disclose what happens if the calls are exercised; and (ii) please add disclosure clarifying
whether the Fund will hold any investments in the Underlying ETF beyond those serving for cover for calls written.

Response to Comment 10

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

    - 3 -

Comment 11 – Principal Investment Strategies

The Staff notes the following
disclosure:

“However, in circumstances where the Fund
holds U.S. Treasuries directly in lieu of the Underlying ETF, the notional exposure of the sold call option contracts could exceed that
of the Fund’s position in the Underlying ETF, and therefore a portion of such sold call options will be “uncovered”
(meaning the Fund will not directly own sufficient securities underlying the option contracts).”

Please add disclosure explaining
in greater detail why the Fund would hold U.S. Treasuries directly in lieu of the Underlying ETF, when it will do so, and how much of
the holdings will be uncovered. Please note the Staff may have further comments.

Response to Comment 11

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 12 – Principal Investment Strategies

Please disclose the number
of index components. The Staff notes that a range would be acceptable.

Response to Comment 12

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 13 – Principal Investment Strategies

Please briefly explain in
the principal investment strategies when and why the Index would rebalance.

Response to Comment 13

The prospectus has been revised
in accordance with the Staff’s comment, as reflected in Exhibit A.

Comment 14 – Exhibits

The Staff requests the Fund
include any Index License Agreement to which the Fund is a party as an exhibit. The Staff notes that it views this as material contract
under Item 28(h) under Form N-1A.

Response to Comment 14

The Fund notes that it is
not a party to the Index License Agreement. Rather, the Adviser enters into the licensing agreement and the Fund is not a party to that
agreement. The Trust, on behalf of the Fund, then enters into a sub-license agreement. Accordingly, the Fund respectfully declines to
file the Index License Agreement as it is not a party to such agreement, and therefore believes its inclusion is not required under Item
28(h) of Form N-1A.

********

    - 4 -

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

    - 5 -

Exhibit A

The
information in this Prospectus is not complete and may be changed. We may not sell these securities until the registration statement
filed with the Securities and Exchange Commission is effective. This Prospectus is not an offer to sell these securities and it is not
soliciting an offer to buy these securities in any state where the offer of sale is not permitted.

Subject
to Completion

October 3, 2024

Amplify ETF Trust

Amplify Bloomberg U.S. Treasury Target 12 Option
Income ETF

(Cboe BZX – TLTP)

PROSPECTUS

[_], 2024

Amplify Bloomberg U.S. Treasury Target 12 Option
Income ETF (the “Fund”) is a series of Amplify ETF Trust (the “Trust”) and is a passively-managed exchange-traded
fund (an “ETF”) organized as a separate series of a registered investment company. The Fund intends to list and principally
trade its shares on the Cboe BZX Exchange, Inc. (the “Exchange”).
Market prices of shares of the Fund may differ to some degree from their net asset value. The Fund issues and redeems shares at net asset
value only in large blocks of shares called “Creation Units.” Except when aggregated in Creation Units, shares of the Fund
are not redeemable securities of the Fund.

The SEC has not approved
or disapproved these securities or passed upon the accuracy or adequacy of this prospectus. Any representation to the contrary is a criminal
offense.

Contents

    Summary Information
    3

    Additional Information About the Fund’s Strategies and Risks
    14

    Fund Investments
    15

    Additional Information Regarding Fund Risks
    16

    Portfolio Holdings
    24

    Management of the Fund
    24

    How to Buy and Sell Shares
    26

    Dividends, Distributions and Taxes
    28

    Distribution Plan
    32

    Net Asset Value
    32

    Disclaimers
    34

    Fund Service Providers
    34

    Premium/Discount Information
    34

    Other Information
    35

    Financial Highlights
    35

    2

AMPLIFY
BLOOMBERG U.S. TREASURY TARGET 12 OPTION INCOME ETF

Summary Information

INVESTMENT OBJECTIVE

The Amplify Bloomberg U.S.
Treasury Target 12 Option Income ETF seeks investment results that generally correspond to the performance (before fees and expenses)
of the Bloomberg U.S. Treasury 20+ Year 12% Premium Covered Call 2.0 Index (the “Index”).

FUND FEES AND EXPENSES

This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund (“Shares”). 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 Fees
      0.30 %

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

    Acquired Fund Fees and Expenses
      0.08 %

    Other Expenses(1)
      0.00 %

    Total Annual Fund Operating Expenses
      0.38 %

 (1) Estimate based on the expenses
the Fund expects to incur 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. This 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 at current levels. This example does
not include the brokerage commissions that investors may pay to buy and sell Shares. Although your actual costs may be higher or lower,
your costs, based on these assumptions, would be:

    1 YEAR

    3 YEARS

    $31

    $97

PORTFOLIO TURNOVER

The Fund pays transaction
costs, such as commissions, when it purchases and sells securities (or “turns over” its portfolio). A higher portfolio turnover
will cause the Fund to incur additional transaction costs and may result in higher taxes when Shares are held in a taxable account. These
costs, which are not reflected in Total Annual Fund Operating Expenses or in the example, may affect the Fund’s performance. Because
the Fund has not yet commenced investment operations, no portfolio turnover information is available at this time.

    3

PRINCIPAL INVESTMENT STRATEGIES

The
Fund invests at least 80% of its net assets (plus borrowings for investment purposes) in securities that are representative of the Index.
As further described below, the Fund seeks to provide a high level of income through the implementation of the Index investments in the
iShares 20+ Year Treasury Bond ETF (the “Underlying ETF”) and
selling one-week expiration, at-the-money call option contracts that references the Underlying ETF. The Fund expects to make distributions
on a regular basis. Amplify Investments LLC is the investment adviser to the Fund (“Amplify” or the “Adviser”)
and Samsung Asset Management (New York), Inc., serves as the investment sub-adviser to the Fund (“Samsung” or the “Sub-Adviser”).
Bloomberg Index Services Limited developed and maintains the Index (the “Index Provider”). The Index Provider is not affiliated
with the Fund, the Adviser, or the Sub-Adviser.

The Index measures the performance
of holding the Underlying ETF and a written (sold) one-week expiration, at-the-money call option contract that references the Underlying
ETF and generates a targeted annualized option premium income of 12% (the “Target Option Premium”). The Index is comprised
of two components: (i) the Underlying ETF and (ii) a sold call option contract referencing the Underlying ETF that provides the Target
Option Premium. The Underlying ETF seeks to track the investment results of the ICE® U.S. Treasury 20+ Year Bond Index,
which measures the performance of public obligations of the U.S. Treasury that have a remaining maturity greater than or equal to twenty
years. See “Additional Information About the Fund’s Strategies and Risks – Underlying ETF”.

Target Option Premium.
The Index is designed to provide the Target Option Premium through the implementation of written (sold) call option contracts on the Underlying
ETF with weekly expirations. An option contract gives the purchaser of the option, in exchange for the premium paid, the right to purchase
(for a call option) the underlying asset at a specified price (the “strike price”) on a specified date (the “expiration
date”). A call option contract gives the seller of the call option contract (i.e., the “writer”) the obligation
to sell, in exchange for a premium received, a specified amount of an underlying security at a pre-determined price if the holder of the
option contract exercises the option. The Index sells call option contracts with an expiration date of one-week that have strike prices
at the then-current value of the Underlying ETF, also known as “at-the-money.” In seeking to the Target Option Premium, the
Index varies the size of the written call option contract that is attributable to the Underlying ETF in order to generate this sought-after
Target Option Premium income. Upon the expiration of the sold option contract each week, the Index sells a new option contract that seeks
the Target Option Premium. The Fund intends to sell call FLexible EXchange® Options (“FLEX Options”) that reference
the Underlying ETF. The Fund will match the strike price (at-the-money), expiration dates (one-week), and notional exposure to the Underlying
ETF in its sold call option contracts to generate the same premiums as the options sold by the Index. As further described below, by selling
at-the-money call options, the Index will forfeit any of the upside market appreciation (if any) experienced by the Underlying ETF for
which the options are written in exchange for premium received. Option contracts can either be “American” style or “European”
style. The Index and the Fund utilize European style option contracts, which may only be exercised by the holder of the option contract
on the expiration date of such option contract and settled in cash. Therefore, if the price of the Underlying ETF exceeds the strike price,
and the option contract is exercised, the Fund will be obligated to deliver the cash value of the difference between the then current
price of the Underlying ETF and the strike price for the number of shares contemplated by the option contract.

    4

Underling ETF Investment
Exposure. The Fund seeks to provide exposure to the market performance and investment income provided by an investment in the Underlying
ETF. The Fund expects to implement its investment in the Underlying ETF by holding a “representative sampling” of securities
that comprise the Index. A representative sampling strategy seeks to replicate the returns of the Index, meaning it may invest in a sample
of the securities in the Index whose risk, return, and other characteristics closely resemble the risk, return, and other characteristics
of the Index as a whole. In seeking to replicate the returns holding the Underlying ETF, in addition to the holding the Underlying ETF,
the Fund may also invest directly in U.