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31 West 52nd Street, 17th Floor,
New York, NY 10019 | 800.248.7971 | Virtus.com

September 26, 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 September 4, 2024, with respect to Post-Effective Amendment No. 87 and Amendment No. 89 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 July 23, 2024, to register shares of the Virtus
KAR Mid-Cap 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.

Response: The fee table has been revised consistent with
this comment, as set forth below.

31 West 52nd Street, 17th Floor, New York, NY 10019 | 800.248.7971 | Virtus.com

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

Comment 2: In the first sentence of the first paragraph,
please define what is meant by "less risk."

Response: The disclosure has been revised consistent
with this comment.

Comment 3: In the second sentence of the first paragraph,
please define what is meant by “select group.”

Response: The Registrant has removed the reference to
a “select group.”

Comment 4: In the third sentence of
the first paragraph, please define what is meant by "low financial risk."

31 West 52nd Street, 17th Floor, New York, NY 10019 | 800.248.7971 | Virtus.com

Response: The disclosure has been revised consistent
with this comment.

Comment 5: In the second sentence of
the second paragraph, please provide an upper limit for the Fund's definition of medium market capitalization companies that does not
rely on a rolling multi-year basis. The name's rule is at time of investment, so the use of a rolling measurement is not consistent with
that rule.

Response: The Registrant respectfully
declines to make the requested change. The Registrant believes that the Fund complies with the requirements of Rule 35d-1 given its policy
to invest at least 80% of the value of its net assets (plus any borrowings for investment purposes) in securities of medium market capitalization
companies. Although the upper band of the Registrant’s definition of medium market capitalization companies includes the concept
of a “rolling” calculation, such calculation will likely only result in changes as the index on which such calculation is
based changes, which would typically correspond with rebalances and reconstitutions of that index and/or market price fluctuations of
its component securities. Accordingly, notwithstanding the upper band of the Fund’s capitalization range changing from time to
time as a result of changes to the referenced index or its component securities, the Registrant will satisfy its 80% test at the time
of investment.

Comment 6: In the last sentence of the fourth paragraph,
please confirm that any such sector focus will be 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.

Principal Risks

Comment 7: With respect to ETF Risks,
to the extent applicable, disclose any risks associated with the underlying securities trading in a market that is closed in which the
market in which the ETF trades is open, including the possibility of differences between the market price of the ETF shares and the underlying
value of the shares.

Response: The disclosure has been revised consistent
with this comment.

Statement of Additional
Information

Indicative Intra-day Value

Comment 8: With respect to the third
paragraph, consider noting the disclosure in the first sentence as a principal risk that should appear in the prospectus.

Response: The disclosure in the Principal Risks section
of the prospectus has been revised consistent with this comment. Please see Registrant’s response to Comment 7.

* * * * *

If you have any further comments or questions
regarding this filing, please contact me at 860-503-1285 or by email at daphne.chisolm@virtus.com. Thank you for your attention to these
matters.

  Sincerely,

  /s/ Daphne Chisolm

  Daphne Chisolm

31 West 52nd Street, 17th Floor, New York, NY 10019 | 800.248.7971 | Virtus.com