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February 28, 2020

Filed via EDGAR

Ms. Alison White

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Subject:            Franklin Templeton ETF Trust (the “Trust”)

            (File Nos.  333-208873; 811-23124)

Dear Ms. White:

On behalf of the Trust, submitted herewith via the EDGAR system are the responses to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) that you provided via telephone to J. Stephen Feinour, Jr. with regard to Post-Effective Amendment Nos. 53/57 to the Trust’s Registration Statement on Form N-1A (the “Amendment”), which was filed with the Commission on December 16, 2019 under the Securities Act of 1933 (the “1933 Act”) and the Investment Company Act of 1940, as amended (the “1940 Act”).  The Amendment was filed to register a new series of the Trust to be designated as the Franklin Liberty Ultra Short Bond ETF (the “Fund”).  The Staff’s comments are summarized below, followed by the Fund’s responses thereto.  Terms not defined herein have the meaning set forth for that term in the Amendment.

1.        Comment:  Please provide the completed fee table and expense example for the Fund in your response letter.

          Response:  The completed fee table and expense example for the Fund is attached hereto as Exhibit A.

2.       Comment:  With respect to the fee table, please supplementally confirm that the term of the fee waiver and expense limitation agreement for the Fund will not be less than one year from the effective date of the Fund’s prospectus.

           Response:  The Trust so confirms.

3.       Comment:  Confirm whether the investment manager can recoup fees previously waived or expenses paid under the fee waiver and expense limitation agreement for the Fund and, if so, disclose the terms of such recoupment in the fee waiver footnote.

           Response:  The investment manager is not entitled to recoup fees waived or expenses paid under the Fund’s fee waiver and expense limitation arrangements.  Therefore, no additional disclosure has been added.

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4.       Comment:
In the narrative lead-in to the expense example, please state that the example
reflects the effect of the fee waiver and expense limitation agreement (if
true) for the one year period only.

           Response:
The requested disclosure has been added.

5.      Comment:
In the Fund’s principal strategy disclosure, please disclose the targeted
average weighted maturity and explain what that means.

           Response:
The Fund does not maintain a targeted average weighted maturity and,
accordingly, no disclosure has been added in response to this comment. The
Trust respectfully notes that the investment manager focuses primarily on
duration, rather than maturity, in constructing the Fund’s portfolio. As
disclosed in the prospectus, the Fund targets an estimated average portfolio
duration of one year or less. The Trust believes that the description of the
Fund’s expected duration is appropriate for an “ultra short” fund and
consistent with industry practice.

6.       Comment:
We note that the Fund’s principal investment strategy disclosure references
duration. Please include an example of how duration works (e.g., if a bond has
a duration of 3 years, a 1% rise in rates would be expected to result in a 3%
decline in the bond’s price).

          Response:
The requested disclosure has been added.

7.       Comment:
Please include a prominent statement that the Fund is not a money market fund
and does not seek to maintain a stable net asset value (“NAV”) of $1.00 per
share.

          Response:
The requested disclosure has been added.

8.       Comment:
Please add principal risk disclosure specific to investing in collateralized
loan obligations (“CLOs”), or expand the collateralized debt obligation (“CDO”)
risk disclosure to specifically discuss risks associated with investments in
CLOs.

           Response:
 The Trust respectfully declines to add the requested disclosure, as the Fund’s
prospectus disclosure specifies that CDOs include CLOs. The Trust believes that
the principal risks of investments in CLOs are adequately addressed by the
Fund’s CDO risk disclosure included in the prospectus.

9.       Comment:
Please disclose in the prospectus how the Fund defines emerging markets.

           Response:
The Trust respectfully declines to add the requested disclosure to the
prospectus, and is not aware of any requirement to include such definition, in
light of the Fund’s principal investment strategies.

10.      Comment:
Please advise how the Fund will value derivatives for purposes of determining
compliance with the Fund’s 80% investment policy. Please note, we may have
further comments in light of your response.

           Response:
The Fund intends to take into account exposures created by derivative
instruments for purposes of the Fund’s 80% policy in a manner consistent with
Rule 35d-1 under the 1940 Act. By way of example, if a derivative creates an
exposure equivalent to a cash investment in the underlying instrument equal to
the derivative’s notional amount, the Fund believes it is appropriate to use
that amount for purposes of the 80% test. On the other hand, if a derivative
creates an investment exposure to an instrument in an amount equal to the mark-to-market
value of the derivative, the Fund would typically expect
to use that value for purposes of the 80% test. The Trust respectfully submits
that such treatment is consistent with the SEC’s statement that “[i]n
appropriate circumstances” an investment company could “include a synthetic
instrument in the 80% basket if it has economic characteristics similar to the
securities included in that basket.” See Investment Company Names, Investment
Company Act Release No. 24828, at n. 13 (Jan. 17, 2001).

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11.      Comment:
The prospectus describes circumstances under which the Fund’s creation and
redemption transactions are conducted in cash rather than in-kind. Please
supplementally confirm that the Fund’s cash transactions are consistent with
the Trust’s exemptive relief with respect to the operation of the Fund.

           Response:
The Trust so confirms.

12.      Comment:
Please consider whether the discussion of the discontinuation of LIBOR should be
included in the Fund summary.

           Response:
The Trust has reviewed the fund summary risk disclosure in light of this
comment and has determined that the discussion regarding the discontinuation of
LIBOR is appropriately included in the expanded risk descriptions pursuant to
Item 9 based on the Fund’s anticipated investments.

13.      Comment:
We note that the “Unrated Debt Securities” and “Debt Securities Ratings” risk
disclosure is included in the Item 9 section only. If these risks are principal
risks, please consider adding corresponding disclosure to the fund summary
risks. Otherwise, it is unclear why this disclosure is included only in the
Item 9 risks.

            Response:
The Trust respectfully declines to revise the summary risk disclosure, as the Trust
believes that the discussion of debt securities ratings and unrated securities risks
expands upon the Fund’s credit risk disclosure in the fund summary.

14.        Comment:
With respect to the description of portfolio manager compensation in the SAI,
please disclose the name of the benchmark used to measure a portfolio manager’s
investment performance for these purposes. See Item 20(b) of
Form N-1A.

            Response:
The Trust respectfully declines to revise the disclosure in response to this
comment. With respect to the investment performance related component of
portfolio manager compensation, the disclosure states in relevant part:  “[p]rimary consideration is
given to the historic investment performance over the 1, 3 and 5 preceding
years of all accounts managed by the portfolio manager. The pre-tax
performance of each fund managed is measured relative to a relevant peer group
and/or applicable benchmark as appropriate” (emphasis added).  The Trust believes such disclosure satisfies the
requirements of Item 20(b), including the requirement to “identify any
benchmark used to measure performance and state the length of the period over
which performance is measured.”  The Trust also notes that the disclosure is
standard across funds in the Franklin Templeton fund complex.

15.        Comment:
With respect to the Fund’s Rule 12b-1 distribution plan, please state whether
the plan is a reimbursement type plan or a compensation type plan.

            Response:
The disclosure has been revised as requested.

16.      Comment:
Please file executed versions of the Fund’s investment management agreement,
investment sub-advisory agreement and fee waiver and expense limitation
agreement as exhibits to the Registration Statement in lieu of forms of such
agreements.  Please also file the legal opinion as an exhibit.

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           Response:
The Trust confirms that executed versions of the Fund’s investment management
agreement and legal opinion will be filed as exhibits. However, the fee waiver
and expense limitation arrangements with respect to the Fund are not currently contained
in a written agreement and, therefore, will not be filed as an exhibit to the Registration
Statement. As noted in the footnote to the Annual Fund Operating Expenses
table, these arrangements may not be changed or terminated during the time
periods set forth in the footnote. The disclosure contained in that footnote
has been reviewed and commented on by the Staff previously and the disclosure
had been revised accordingly in response to prior Staff comments. In addition,
the Fund will not utilize a sub-adviser and accordingly, no sub-advisory
agreement will be filed as an exhibit to the Registration Statement.

Please do not hesitate to contact J. Stephen Feinour, Jr. at (215)
564-8521 if you have any questions or wish to discuss any of the responses
presented above.

Very truly yours,

/s/ Navid Tofigh

Navid Tofigh

Vice President and Secretary

Franklin Templeton ETF
Trust

cc: Julie Patel

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Exhibit A

Franklin Liberty
Ultra Short Bond ETF

Fees and Expenses of
the Fund

The following table
describes the fees and expenses that you will incur if you own shares of the
Fund. You may also incur usual and customary brokerage commissions when buying
or selling shares of the Fund, which are not reflected in the Example that
follows.

Annual Fund Operating
Expenses

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

  Management fees

  0.61%

  Distribution
  and service (12b-1) fees

  None

  Other
  expenses1

  0.14%

  Total
  annual Fund operating expenses

  0.75%

  Fee
  waiver and/or expense reimbursement2

  (0.60)%

  Total
  annual Fund operating expenses after fee waiver and/or expense reimbursement2

  0.15%

1. Other expenses
are based on estimated amounts for the current fiscal year.

2. The investment
manager has contractually agreed to waive or assume certain expenses so that
total annual Fund operating expenses (including acquired fund fees and
expenses, but excluding certain non-routine expenses) for the Fund do not
exceed 0.15% until July 31, 2021. Contractual fee waiver and/or expense
reimbursement agreements may not be changed or terminated during the time
period set forth above.

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 the period. The Example also assumes
that your investment has a 5% return each year and that the Fund's operating
expenses remain the same. The Example reflects adjustments made to the Fund’s
operating expenses due to the fee waivers and/or expense reimbursements by
management for the 1 Year numbers only. Although your actual costs may be higher
or lower, based on these assumptions your costs would be:

  1 Year

  3 Years

  $15

  $178

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