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CORRESP
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  Stradley
Ronon Stevens & Young, LLP

Suite 2600

2005 Market Street

Philadelphia, PA 19103-7018

Telephone 215.564.8000

Fax 215.564.8120

www.stradley.com

Joel
D. Corriero

JCorriero@stradley.com

215.564.8528

January
29, 2024

Via
EDGAR Transmission

Ms.
Anu Dubey

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 “Trust”)

    File
Nos. 333-206600 and 811-23078

Dear
Ms. Dubey:

I
am writing in response to comments you provided to me during a telephone conversation on December 18, 2023, to Post-Effective Amendment
No. 84, Amendment No. 86, to the Trust’s Registration Statement (the “Amendment”), which was filed pursuant to Rule
485(a)(2) under the Securities Act of 1933 (the “Securities Act”) on November 22, 2023, to register shares of the Virtus
AlphaSimplex Managed Futures ETF series of the Trust (the “Fund”). I have reproduced your comments below, followed by our
responses.

General
Comments

 1. Please
                                            acknowledge that the Trust’s responses to the staff’s comments will be filed
                                            on EDGAR at least five business days in advance of the Amendment’s effective date.

RESPONSE:
The Trust acknowledges that the responses to the staff’s comments will be filed in accordance with such request.

Prospectus
Comments

RISK/RETURN
SUMMARY INFORMATION

Fees
and Expenses of the Fund

 2. Please
                                            provide a completed fee table and expense example in your response letter that the staff
                                            can review prior to the Amendment becoming effective.

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RESPONSE:
The completed fee table and expense example for the Fund are included below:

FEES
AND EXPENSES OF THE FUND

This
table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Shares”). You
may incur customary brokerage commissions, and may pay other fees to financial intermediaries, when buying or selling Shares of the Fund,
which are not reflected in the table or example set forth below.

    Shareholder
    Fees (fees paid directly from your investment):
    ​
    None
    ​

    Annual
    Fund Operating Expenses
    ​
    ​
    ​

    (expenses
    that you pay each year as a percentage of the value of your investment):
    ​
    ​
    ​

    Management
    Fee1
    ​
    0.80
    %

    Other
    Expenses2
    ​
    0.00
    %

    Total
    Annual Fund Operating Expenses
    ​
    0.80
    %

 (1) The
                                            management fee is structured as a “unified fee,” out of which the Fund’s
                                            investment adviser, Virtus ETF Advisers LLC (the “Adviser”) pays all of the ordinary
                                            operating expenses of the Fund, except for the following expenses, each of which is paid
                                            by the Fund: the Fund’s management fee; payments under any 12b-1 plan; taxes and other
                                            governmental fees; brokerage fees, commissions and other transaction expenses; interest and
                                            other costs of borrowing; litigation or arbitration expenses; acquired fund fees and expenses;
                                            and extraordinary or other non-routine expenses of the Fund.

 (2) “Other
                                            Expenses” are based on estimated amounts 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. The 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. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1
    Year
    ​
    3
    Years

    $84
    ​
    $263

Principal
Investment Strategy

 3. The
                                            first paragraph of the “Principal Investment Strategy” section states, “The
                                            Fund seeks to provide capital appreciation consistent with the risk/return characteristics
                                            of the managed futures industry.” The Fund’s stated investment objective is “to
                                            generate positive absolute returns over time”; please reconcile the above stated sentence
                                            in the Fund’s “Principal Investment Strategy” section to align with the
                                            Fund’s stated investment objective. If the Fund’s investment objective is positive
                                            absolute returns, please disclose what absolute returns are.

RESPONSE:
The Fund will revise the first sentence of the “Principal Investment Strategy” section as noted below.

    2

“The
Fund seeks to provide capital appreciation generate positive absolute returns (i.e., total returns that
are earned from an investment over time) consistent with the risk/return characteristics of the managed futures industry.”

 4. Please
                                            disclose an 80% policy to invest in the assets suggested by the Fund’s name or, in
                                            the alternative, please revise the Fund’s name (e.g., consider adding the word
                                            “Strategy” to the Fund’s name).

RESPONSE:
The Fund will adopt a policy to invest at least 80% of the value of its net assets (plus any borrowings for investment purposes) in futures
contracts. In accordance with the position of the Securities and Exchange Commission (the “Commission”) as reflected in the
adopting release to recent amendments to Rule 35d-1 under the Investment Company Act of 1940 (“1940 Act”),1 the
Fund will determine the value of its assets for purposes of determining compliance with Rule 35d-1 by valuing each derivatives instrument
using the instrument’s notional amount. As stated by the Commission in such adopting release, the Commission “believe[s]
the use of notional values better reflects the investment exposure of derivatives investments than market values for purposes of assessing
names rule compliance in most cases,” resulting in the Commission “requiring, rather than permitting, the use of notional
values.”2

 5. The
                                            second sentence of the second paragraph of the “Principal Investment Strategy”
                                            section states, “AlphaSimplex believes that managers within the managed futures industry
                                            are able to benefit from persistent price trends that are the result of various behavioral
                                            biases among market participants.” Please revise to clarify what AlphaSimplex’s
                                            belief is.

RESPONSE:
The Fund will replace the referenced sentence with the following:

“AlphaSimplex
believes that investor behavior can lead to trends (or momentum) in market prices and that managers within the managed futures industry
are able to benefit from such persistent price trends by actively trading in futures markets.”

 6. The
                                            third sentence of the second paragraph of the “Principal Investment Strategy”
                                            section states, “The Fund’s principal investment strategy combines advanced replication
                                            techniques with insights from trend models and risk management approaches in an effort to
                                            capture time-varying trend opportunities, across a range of different asset classes, held
                                            both long and short.” Please revise the stated sentence to be in plain English.

RESPONSE:
The Fund will replace the referenced sentence with the following:

“The
Fund’s principal investment strategy combines (i) replication techniques (i.e., mathematical techniques for identifying which trends
appear to be attracting the most attention among managed futures managers) with (ii) quantitative trend models and risk management approaches
(i.e., techniques generally similar to those that managed futures managers use to identify trends to invest in), in an effort to generate
returns that are broadly representative of the managed futures industry. As with the portfolios of many managed futures managers, the
resulting strategy seeks to capture time-varying opportunities, across a range of different asset classes, held both long and short.”

 1 See
                                            Investment Company Names, Release No. IC-35000 (Sept. 20, 2023), available at https://www.sec.gov/files/rules/final/2023/33-11238.pdf.

 2 Id.
                                            at page 212.

    3

 7. The
                                            last sentence of the second paragraph of the “Principal Investment Strategy”
                                            section states, “AlphaSimplex believes that following a wide variety of trends based
                                            on an aggregated view of the managed futures industry as a whole, combined with active risk
                                            management, may allow the Fund to earn a positive expected return over time that is also
                                            representative of the overall industry.” Please identify which industry the stated
                                            sentence is referring to.

RESPONSE:
The Fund will replace the referenced sentence with the following:

“AlphaSimplex
believes that this combination of techniques, together with active risk management, may allow the Fund to earn a positive expected return
over time that is also representative of the overall managed futures industry.”

Please
also note that the “managed futures industry” is not representative of an economic sector or sub-sector, but rather an investment
class in which firms utilize a variety of information and active management techniques to extract returns from the market primarily through
futures contracts and other derivatives. To avoid any confusion, the Fund will add this disclosure to the Prospectus.

 8. The
                                            first sentence of the third paragraph of the “Principal Investment Strategy”
                                            section states, “Under normal market conditions, AlphaSimplex typically will make extensive
                                            use of a variety of derivative instruments, including futures and forward contracts, to capture
                                            the exposures suggested by its strategy while also seeking to add value through volatility
                                            management.” Please describe how the Fund will add value through volatility management.

RESPONSE:
The Fund will replace the referenced sentence with the following:

“Under
normal market conditions, AlphaSimplex typically will make extensive use of a variety of derivative instruments, including futures and
forward contracts, to capture the exposures suggested by its strategy.”

 9. The
                                            second sentence of the third paragraph of the “Principal Investment Strategy”
                                            section states, “These market exposures, which are expected to change over time, primarily
                                            include exposures to the returns of U.S. and non-U.S. equity and fixed-income securities
                                            and securities indices (including both broad- and narrow-based securities indices), currencies,
                                            and commodities.” Please identify the types of fixed income securities exposure that
                                            are part of the Fund’s principal investment strategies.

RESPONSE:
The Fund will replace the referenced sentence with the following:

“These
market exposures, which are expected to change over time, primarily include exposures to the returns of U.S. and non-U.S. equity and
fixed-income securities and securities indices, currencies, and commodities. More specifically, such equity exposures represent equity
indices from various countries or groups of countries (including emerging market countries), fixed-income exposures represent benchmark
government securities in various developed markets, currency exposures represent the values of various foreign currencies relative to
the U.S. dollar, and commodity exposures represent benchmarks within the agriculture, livestock, base metals, precious metals, and energy
commodity sectors.”

    4

 10. That
                                            same sentence referenced in Comment 9 refers to “exposures to the returns of …
                                            non-U.S.” securities and other assets. If such non-U.S. exposure includes emerging
                                            markets as a principal investment strategy, please state so and disclose corresponding risks
                                            in the “Principal Risks” section.

RESPONSE:
The Fund will add an emerging markets risk to the “Principal Risks” section.

 11. Please
                                            disclose any credit quality and maturity policies of the fixed income securities to which
                                            the Fund seeks exposure as part of its principal investment strategies.

RESPONSE:
As noted in the revised description in our response to Comment 9, such fixed-income exposures represent exposures to benchmark government
securities in various developed markets. No additional credit quality or maturity policies apply to those underlying fixed-income securities.

 12. Please
                                            identify the types of commodities to which the Fund seeks exposure as part of its principal
                                            investment strategies and disclose corresponding risks in the “Principal Risks”
                                            section.

RESPONSE:
As noted in the revised description in our response to Comment 9, such commodity exposures represent benchmark commodities within the
agriculture, livestock, base metals, precious metals, and energy commodity sectors. The Fund will also review its commodity-related risk
to determine whether any revisions are appropriate.

 13. The
                                            second sentence to the third paragraph of the “Principal Investment Strategy”
                                            section includes a parenthetical that states, “including both broad- and narrow-based
                                            securities indices.” Please include a description of what narrow-based securities indices
                                            are.

RESPONSE:
As noted in the revised description in our response to Comment 9, the Fund will delete the referenced parenthetical.

 14. The
                                            third sentence to the third paragraph of the “Principal Investment Strategy”
                                            section states, “AlphaSimplex will have great flexibility to allocate the Fund’s