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November 20, 2024

FILED VIA EDGAR

Mr. Aaron Brodsky

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Virtus ETF Trust II (the “Registrant”)

File Nos. 333-206600 and 811-23078

Dear Mr. Brodsky:

This correspondence responds to comments
received by the undersigned from the staff of the U.S. Securities and Exchange Commission (the “Staff”) during a telephone
conversation on October 25, 2024, with respect to Post-Effective Amendment No. 88 and Amendment No. 90 to the Registrant’s Registration
Statement on Form N-1A (the “Registration Statement”).

The Registration Statement was filed
pursuant to Rule 485(a)(2) under the Securities Act of 1933 (the “Securities Act”) on September 13, 2024, to register shares
of the Virtus SEIX AAA Private Credit CLO ETF (the “Fund”). The Registrant will file a Post-Effective Amendment pursuant to
Rule 485(b) under the Securities Act prior to or upon the Fund’s effectiveness to (i) reflect revisions discussed herein in response
to your comments; (ii) make certain non-material changes as appropriate; and (iii) file exhibits to the Registration Statement.

Set forth below are the Staff’s
comments and the Registrant’s responses thereto. Capitalized terms used and not defined herein have the meaning given to them in
the Registration Statement.

Prospectus

Fees and Expenses
of the Fund

Comment 1: Please provide a completed fee table
and, if appropriate, include a line item for acquired fund fees and expenses.

Response: The completed fee table and expense example
were provided supplementally to the Staff via email on November 20, 2024.

The Registrant confirms that it has considered whether an
AFFE line item is required based on the Fund’s estimated acquired fund fees and expenses for the first year of operations and determined
that this line item is not required.

Page 2

Principal Investment
Strategy

Comment 2: Please revise the disclosure so that
the Fund has an 80% policy that incorporates “AAA” ratings and “Private Credit CLO.”

Response: In response to the Staff’s comment,
the Registrant has made the following changes to the first paragraph under the Principal Investment Strategy section as follows:

The Fund invests, under normal circumstances, at least 80% of its
net assets (plus the amount of any borrowings for investment purposes) in private credit collateralized loan obligations (“Private
Credit CLOs”) that, at the time of acquisition, are either rated AAA by at least one nationally
recognized statistical rating organization (“NRSRO”), such as S&P Global Ratings (“S&P”), Fitch Ratings,
Inc. (“Fitch”) or Moody’s Investors Service, Inc. (“Moody’s”), or, if unrated, determined by Seix
Investment Advisors (“Seix”) , a division of Virtus Fixed Income Advisers, LLC, the Fund’s sub-adviser, to be of comparable
quality. in which the majority of each such CLO consists of a pool of loans to private
companies. After purchase, a Private Credit CLO may have its rating reduced below
the minimum rating required by the Fund for purchase. In such cases, the Fund will consider whether to continue to hold the Private
Credit CLO. The Fund may temporarily deviate from the 80% policy while deploying new capital as the result of cash creation
or redemption activity, or during unusual market conditions, or highly unusual markets, such as a downgrade
in the rating of one or more securities.

Comment 3: The disclosure on page 3
indicates that the Fund will be investing more than 80% in Private Credit CLOs. Given the liquidity profile of these investments, supplementally
explain how these investments are appropriate for the open-end structure. The response should include: i) information concerning the relevant
factors referenced in the release adopting 22e-4 of the 1940 Act; ii) market data on the liquidity of Private Credit CLOs and how its
changed over times; iii) an analysis of how the liquidity of Private Credit CLOs compare to other CLOs; iv) supplemental explanation of
how the Fund's intended investments are intended to differ from other ETFs that invest 80% of assets in CLOs; and v) an explanation of
any discussion that the Fund has had with Authorized Participants and Market Makers regarding their ability to arbitrage the Fund’s holdings in a manner
that is expected to keep the Fund's market price in line with its NAV.

Response: The Registrant believes that the Fund’s investment
strategy to invest in AAA rated private credit CLOs and the anticipated liquidity of portfolio investments, during both normal and reasonably
foreseeable stressed conditions, is appropriate for an open-end fund because of the liquid nature of the investments. The Adviser, with
assistance from the Fund’s sub-adviser, has analyzed the liquidity of private credit CLOs as an asset class. This review included
an evaluation of the Fund’s compliance with both Rule 22e-4 and the liquidity risk management program (“Program”). In
reviewing the Fund’s potential investments in AAA rated private credit CLO debt, the Adviser considered a variety of factors in
accordance with its Program, including among other things: the existence of an active market for AAA rated private credit CLO debt, including
the number, diversity, and quality of market participants; the frequency of trades or quotes for AAA rated private credit CLO debt and
average daily trading volume of the asset class; volatility of trading prices for the asset class; anticipated bid-ask spreads for the
asset class; a consideration of the structure of AAA rated private credit CLO debt; the ability to trade the asset class and any potential
restrictions on trading or limitations on transfer of AAA rated private credit CLO debt; the anticipated size of the Fund’s position
in AAA rated private credit CLO debt relative to the asset class’s historic trading volume. Registrant also took into account the
sub-adviser’s past experience in trading the asset class.

Page 3

Registrant notes that the market for  private credit CLOs is continuously growing. As noted in the chart below, annual volumes in 2023, for example, has
exceeded $25 billion, which has demonstrated growth from prior years.

Moreover, year to date in 2024, private credit CLO issuance has reached
$42.9 billion, comprising 19% of new CLO issuance. The sub-adviser believes that this indicates that the investor base for this product
is much higher as a percentage of the overall CLO market. Also, there are active trading desks making markets in private credit CLOs,
resulting in liquidity in this segment of the CLO market. Notwithstanding the growing private credit CLO market, the Registrant believes
that the overlap of the Fund’s investments with other ETFs that invest in traditional CLOs will be low. Authorized Participants
and Market Makers have expressed no concerns with maintaining a market in these securities.

Comment 4: Please disclose the
extent to which the CLOs will consist of private credit loans to public companies.

Response: The Registrant anticipates that the Fund
will not invest in CLOs that consist of private credit loans to public companies.

Comment 5: Please disclose how
the Fund is defining private credit and private credit CLO for purposes of the Fund's name and 80% policy. Please add disclosure clarifying
the source of the loan underlying the private credit CLO.

Page 4

Response: In response to the Staff’s
comment, the Registrant has made the following changes to the second paragraph under the Principal Investment Strategy section
as follows:

A CLO is a type of asset backed security
supported by interest and principal payments generated from a pool of loans, which may include, among others, U.S. and non-U.S. senior
secured loans and subordinated corporate loans and privately placed loans. Private credit is funding that
is lent to private companies through a loan that is not sourced from public markets (such as proceeds raised from the sale of listed
equities and publicly traded bonds), nor sourced from traditional financial institutions (such as banks). A Private Credit CLO is a CLO
backed by underlying loans that are primarily (i.e., at least 80%) private credit. The underlying loan may be of any
size, including loans to middle market companies, which the sub-adviser defines as companies with annual
earnings before interest, taxes, depreciation and amortization, or EBITDA, of $10 million to $1 billion at the time of investment.

Comment 6: The Fund's name includes the term Private
Credit CLO, which denotes a type of investment, however, the Fund's 80% policy is to invest in CLOs "in which the majority of each
such CLO consists of a pool of loans to private companies." Please supplementally explain how this complies with the names rule if
the CLOs only consist of a majority of CLOs to private companies.

Response: The Fund confirms that it will invest at
least 80% of its net assets in private credit CLOs that are rated AAA. For the definition of private credit and private credit CLO, please
see response to Comment 5.

Principal Risks

Comment 7: The Fund may invest
up to 20% of its net assets (plus the amount of any borrowings for investment purposes) in, among other things, CLOs holding broadly syndicated
loans. Please clarify whether broadly syndicated loans are referring to loans issued by banks.

Response: Broadly syndicated loans typically include
loans issued by banks. The Registrant respectfully acknowledges the comment;
however, the Registrant believes no clarifying changes are necessary.

Comment 8: The Fund may invest
up to 20% of its net assets (plus the amount of any borrowings for investment purposes) in, among other things, senior loans and high
yield bonds. Please address any risks in investing in these instruments to the extent that they are not already covered.

Response: In response to the Staff’s comment,
the Registrant added Senior Loan and High Yield Bond risk disclosure to the Principal Risks section as follows:

Senior Loan Risk.
The risks of investing in senior loans are similar to the risks of investing in junk bonds, although the senior loans in which
the Fund invests are typically senior and secured, whereas junk bonds often are subordinated and unsecured. In addition, investments
in senior loans may be subject to restrictions on resale, may be less liquid and may trade infrequently on the secondary market. Senior
loans settle on a delayed basis; thus, sale proceeds may not be available to meet redemptions for a substantial period of time after
the sale of the loan.

Page 5

High Yield Bond
Risk. There is a greater risk of issuer default, less liquidity, and increased price volatility related to high yield securities
(commonly referred to as ‘junk bonds”) than investment grade securities.

Comment 9: Please disclose in Item 4 or 9 disclosure
whether the loans underlying the CLOs are unrated, privately rated or otherwise.

Response: Generally, the underlying loans in private
credit CLOs have ratings from at least one rating agency. In response to the Staff’s comment, the Registrant has revised the Item
4 disclosure as follows:

CLO Risk. The risks of investing in CLOs include
both the economic risks of the underlying loans, which are rated below investment grade (i.e., junk
bonds), combined with the risks associated with the CLO structure governing the priority of payments. The degree of such risk
will generally correspond to the specific tranche in which the Fund is invested. The Fund intends to invest primarily
in the rated debt tranches of CLOs; however, any such ratings do not constitute a guarantee, may be downgraded, and in
stressed market environments it is possible that even senior CLO tranches could experience losses due to actual defaults, increased sensitivity
to defaults due to collateral default and the disappearance of the subordinated/equity tranches, market anticipation of defaults, as
well as negative market sentiment with respect to CLO securities as an asset class. The Sub-Adviser may not be able to accurately predict
how specific CLOs or the portfolio of underlying loans for such CLOs will react to changes or stresses in the market, including changes
in interest rates. Generally, the underlying loans in private credit CLOs have ratings from at least one
rating agency. The most common risks associated with investing in CLOs are liquidity risk, interest rate risk, credit risk,
prepayment risk, and the risk of default of the underlying asset, among others.

Comment 10: Please supplementally explain how the
sub-adviser will determine if a majority of loans in a CLO will be issued to private companies, including how transparent the information
is or difficult to ascertain.

Response: The Registrant confirms that the sub-adviser
will receive reports of the underlying holdings of the CLOs.

Comment 11: Please supplementally explain whether
the sub-adviser will have access to credit ratings of loans to private companies included in the CLO. If not, how accurately can the sub-adviser
determine that 80% of the Fund’s portfolio will be invested in AAA rated securities.

Response: The Registrant notes that the Fund will purchase Private
Credit CLOs that are rated AAA, however the underlying loans will be below investment grade, ranging from BB to CCC rated. The recent
amendments (“Amendments”) to Rule 35d-1 of the 1940 do not require the Fund to look through to the CLOs’ underlying
holdings for purposes of the Fund’s 80% investment policy.

Page 6

Under the Amendments, a fund’s name is misleading if the name
includes, in relevant part, terms suggesting that a fund focuses its investments in issuers who have, particular characteristics or a
particular type of investment or investments unless the fund adopts a policy to invest, under normal circumstances, at least 80% of the
value of its assets in investments in accordance with the investment focus that the fund’s name suggests. The name of the Fund
contains both a particular type of investment (private credit CLO) and particular characteristics (AAA). Accordingly, the Registrant
has drafted the Fund’s 80% policy to state that the Fund will invest 80% of its net assets in Private Credit CLOs that are either
rated AAA by at least one nationally recognized statistical rating organization, such as S&P Global Ratings, Fitch Ratings, Inc.
or Moody’s Investors Service, Inc., or, if unrated, determined by the Fund’s sub-adviser, to be of comparable quality.

Comment 12: The Registrant states that the “Fund
may temporarily deviate from the 80% policy while deploying new capital as the result of cash creation or redemption activity, or during
unusual market conditions, or highly unusual market.” Please define unusual market condition or highly unusual market.

Response: In response to the Staff’s comment,
the Registrant has made the following changes to disclosure:

The Fund may temporarily deviate from the 80% policy while
deploying new capital as the result of cash creation or redemption activity, or during unusual market conditions, or highly unusual markets,
such as a downgrade in the rating of one or more securities.

Comment 13: Please confirm supplementally that any sector
focus is consistent with the Fund's policy to not concentrate.

Response: The Registrant confirms that any sector focus will
be consistent with the Fund’s policy to not concentrate.

Comment 14: Within Principal Risks – CLO Risk,
the Fund discloses that it “intends to invest primarily in the rated debt tranches of CLOs.” The disclosure says primarily,
but it should say 80% in compliance with the names rule.

Response: Please see Registrant’s response to Comment
9; the word primarily has been deleted.

Comment 15: Within Principal Risks
– Debt Securities Risk, the Registrant includes disclosure on the risk of investing in variable- and floating-rate debt obligations.
Please add the investments to the Principal Investment St