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      EDGAR CORRESPONDENCE

      February 22, 2024

      U.S. Securities and Exchange Commission

        Division of Investment Management – Disclosure Review and Accounting Office

      100 F Street NE

        Washington DC 20549

      Attention: Valerie Lithotomos

              Re:

              Davis Fundamental ETF Trust, File Nos.: 811‑23181, 333-213073

      Dear Ms. Lithotomos:

      This letter is in response to comments you provided on February 12, 2024, with respect to the 485(a) filing of Davis Select U.S.
        Equity ETF, Davis Select Financial ETF, Davis Select Worldwide ETF, and Davis Select International ETF, all series of Davis Fundamental ETF Trust, as identified above. SEC comments are in bold. Registrant’s responses immediately follow.

                1.

                We request that you respond to these comments no later than five business days before
                  the filing is scheduled to become effective automatically. If this is not possible, we request that you file an amendment under Rule 485(b) delaying effectiveness as needed until Staff comments result.

      We confirm that we will respond no later than five business days before the filing is scheduled to become effective automatically.

                2.

                Please fill in all blanks, brackets, and otherwise missing information sufficiently
                  in advance of effectiveness for review.

      We confirm that all blanks, brackets, and otherwise missing information will be filled in in advance of effectiveness for review.

                3.

                Please unbold the fee and expense paragraph, the example paragraph, and the portfolio
                  turnover paragraph in Item 3 of Form N-1A. With regards to expenses, please provide fees and expenses and the example sufficiently in advance of effectiveness for review.

      We have made these changes, and will provide the fees and expenses and the example sufficiently in advance of effectiveness for
        review.

                4.

                Please confirm whether the fee waiver is good for one year.

      The Adviser is obligated to continue to expense cap through March 1, 2025.

                5.

                In the Statement of Additional Information, please modify the “Acceptance of Orders
                  of Creation Units” section.

      This section has been modified as follows:

      Acceptance of
          Orders of Creation Units. The Trust reserves the absolute right to reject an order for Creation Units transmitted in respect of a Fund at
        its discretion, including, without limitation, if (1) the order is not in proper form; (2) the Deposit Securities or Deposit Cash, as applicable, delivered by the Participant are not as disseminated through the facilities of the NSCC for that date
        by the Custodian; (3) the investor(s), upon obtaining the shares ordered, would own 80% or more of the currently outstanding shares of a Fund; (4) the acceptance of the Fund Deposit would, in the opinion of counsel, be unlawful; (5) the acceptance
        or receipt of the order for a Creation Unit would, in the opinion of counsel to the Trust, be unlawful; or (6) in the event that circumstances outside the control of the Trust, the Custodian, the Transfer Agent and/or the Adviser make it for all
        practical purposes not feasible to process orders for Creation Units.

                6.

                For each of the funds that principally invest in emerging markets, please provide
                  that fund’s definition of emerging market. For example, it could be a country list or a particular data provider’s list.

      Under the section titled “Principal Risks of Investing in the Funds,” “Emerging Markets Risk (DWLD, DINT, and DFNL only)” has been
        expanded upon with the addition of the following:

      As of December 31, 2023, the countries considered “emerging markets” were: Bahrain, Bangladesh, Benin, Bermuda, Brazil, Burkina
        Faso, Chile, China, Colombia, Croatia, Czech Republic, Egypt, Estonia, Greece, Guinea-Bissau, Hungary, Iceland, India, Indonesia, Ivory Coast, Jordan, Kazakhstan, Kenya, Korea, Kuwait, Latvia, Lithuania, Malaysia, Mali, Mauritius, Mexico, Morocco,
        Niger, Nigeria, Oman, Pakistan, Peru, Philippines, Poland, Qatar, Romania, Saudi Arabia, Senegal, Serbia, Slovenia, South Africa, Sri Lanka, Taiwan, Thailand, Togo, Tunisia, Turkey, United Arab Emirates, and Vietnam. Additionally, certain countries
        that are not on this list may be included at Davis Advisor’s discretion.

                7.

                Please disclose that, where all or a portion of the ETF’s underlying securities trade
                  in a market that is closed when the market in which the ETF’s shares are listed and trading in that market is open, there may be changes between the last quote from its closed foreign market and the value of such security during the ETF’s
                  domestic trading day. In addition, please note that this in turn could lead to differences between the market price of the ETF’s shares and the underlying value of those shares.

      We have added the following language under the section titled “Principal Investment Strategies”:

      Many foreign markets operate at times that do not coincide with the New York Stock Exchange. As a result, the closing prices of
        securities that trade on foreign markets may be as much as 15 hours old by the time a fund calculates its net asset value, and may not reflect the current market values of those securities. In particular, the closing prices of foreign securities
        may not reflect their market values at a fund’s net asset value calculation if a significant event that will affect the value of those securities has occurred since the closing prices were established on the foreign exchange or market, but before
        the fund’s net asset value calculation. This situation could lead to a pricing error and dilution of shareholders’ investment in the fund.

                8.

                Please bold the first paragraph following the financial highlights heading consistent
                  with Item 13 of Form N-1A.

      We have made this change.

      Please call the undersigned at (520) 434-3793 with any comments or questions.

      Respectfully,

      /s/ Lisa Cohen

           Lisa Cohen

           Vice President and Secretary

        Davis Select U.S. Equity ETF (DUSA)

        Davis Select International ETF (DINT)

        Davis Select Worldwide ETF (DWLD)

        Davis Select Financial ETF (DFNL)

        PROSPECTUS

        February 29, 2024

        Portfolios of Davis Fundamental ETF Trust are Actively Managed Exchange-Traded Funds

        Principal U.S. Listing Exchange for each ETF: Cboe Global Markets, Inc.

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

        Contents

                Davis Select U.S. Equity ETF Summary | Ticker: DUSA

                3

                Davis Select International ETF Summary | Ticker: DINT

                7

                Davis Select Worldwide ETF Summary | Ticker: DWLD

                12

                Davis Select Financial ETF Summary | Ticker: DFNL

                17

                Additional Information About Investment Objectives, Principal Strategies and Principal Risks

                22

                Non-Principal Investment Strategies and Related Risks

                27

                Management and Organization

                28

                Shareholder Information

                29

                Buying and Selling Shares

                29

                How Your Shares Are Valued

                30

                Portfolio Holdings

                31

                How the Funds Pay Earnings

                31

                Federal Income Taxes

                32

                Fees Paid to Dealers and Other Financial Intermediaries

                34

                Frequent Purchases and Redemptions of Fund Shares

                34

                Financial Highlights

                37

        This prospectus contains important information. Please read it carefully before investing and keep it for future reference.

        No financial adviser, dealer, salesperson or any other person has been authorized to give any information or to make any representations, other than those
          contained in this prospectus, in connection with the offer contained in this prospectus and, if given or made, such other information or representations must not be relied on as having been authorized by the Funds, the Funds’ investment adviser
          or the Funds’ distributor.

        This prospectus does not constitute an offer by the Funds or by the Funds’ distributor to sell or a solicitation of an offer to buy any of the securities
          offered hereby in any jurisdiction to any person to whom it is unlawful for the Funds to make such an offer.

        Davis Select U.S. Equity ETF Summary | Ticker: DUSA

        Investment Objective

        The Fund seeks long-term capital growth and capital preservation.

        Fees and Expenses of the Fund

        These tables describe the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as
            brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.

                Annual Fund Operating Expenses

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

                Management Fees

                0.55%

                Other Expenses

                0.06%

                Total Annual Operating Expenses

                0.61%

                Less Fee Waiver or Expense Reimbursement*

                0.00%

                Net Expenses

                0.61%

              *

                The Adviser is contractually committed to waive fees and/or reimburse the Fund’s expenses to the extent necessary to cap total annual fund operating expenses at 0.65%. The Adviser is obligated to continue the
                  expense cap through March 1, 2025. The expense cap cannot be modified prior to this date without the consent of the Board of Trustees. After that date, there is no assurance that the Adviser will continue to cap expenses. The Adviser may
                  not recoup any of the operating expenses it has reimbursed to the Fund.

        Example. This Example is intended to help you compare the
          cost of investing in the Fund with the cost of investing in other mutual funds. This Example does not take into account brokerage commissions that you may pay when purchasing or selling shares. The Example assumes that you invest $10,000 in the
          Fund for the time periods indicated and then redeem 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 the same. Although your
          actual costs may be higher or lower, based on these assumptions your costs would be:

                1 Year

                3 Years

                5 Years

                10 Years

                $62

                $195

                $340

                $762

        Portfolio Turnover

        The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher
          transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the example, affect the Fund’s performance.
          During the most recent fiscal year, the Fund’s portfolio turnover rate was 18% of the average value of its portfolio.

        Principal Investment Strategies

        The Fund is an actively managed exchange-traded fund (“ETF”). Davis Selected Advisers, L.P. (“Davis Advisors” or the “Adviser”), the Fund’s investment
          adviser, uses the Davis Investment Discipline to invest the Fund’s portfolio principally in common stocks issued by large companies with market capitalizations of at least $10 billion. Under normal market conditions, the Fund will invest at least
          80% of the Fund’s net assets plus any borrowings for investment purposes in equity securities issued by U.S. companies. The Fund is non-diversified and, therefore, is allowed to focus its investments in fewer companies than a fund that is
          required to diversify its portfolio. The Fund’s portfolio generally contains between 15 and 35 companies, although the precise number of its investments will vary over time. The Fund may invest a portion of its assets in financial services
          companies. The Fund may also invest in mid- and small-capitalization companies, which the Fund considers to be those companies with less than $10 billion in market capitalization. The Fund may invest up to 20% of net assets in non-U.S. companies.
          These non-U.S. company investments may include American Depositary Receipts (“ADRs”) and Global Depositary Receipts (“GDRs” and together “Depositary Receipts”). Depositary Receipts are receipts that represent ownership of shares of a non-U.S.
          issuer held in trust by a bank or similar financial institution.

        Davis Investment Discipline. Davis Advisors manages equity funds using the Davis Investment Discipline. Davis
          Advisors conducts extensive research to try to identify businesses that possess characteristics that Davis Advisors believes foster the creation of long-term value, such as proven management, a durable franchise and business model, and
          sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading at discounts to their intrinsic worth. Davis Advisors emphasizes individual stock selection and believes that the ability to evaluate
          management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into the relative value of different businesses. Such research, however rigorous, involves predictions and forecasts that are
          inherently uncertain. After determining which companies Davis Advisors believes the Fund should own, Davis Advisors then turns its analysis to determining the intrinsic value of those companies’ equity securities. Davis Advisors seeks companies
          whose equity securities can be purchased at a discount from Davis Advisors’ estimate of the company’s intrinsic value based upon fundamental analysis of cash flows, assets and liabilities, and other criteria that Davis Advisors deems to be
          material on a company-by-company basis. Davis Advisors’ goal is to invest in companies for the long term (ideally, five years or longer, although this goal may not be met). Davis Advisors considers selling a company’s equity securities if the
          securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, if the ratio of the risks and rewards of continuing to own the company’s equity securities is no longer attractive, to raise cash to purchase a more attractive
          investment opportunity, to satisfy net redemptions, or for other purposes.

        Principal Risks of Investing in Davis Select U.S. Equity ETF

        You may lose money by investing in Davis Select U.S. Equity ETF and the Fund’s performance could trail that of other investments.
          Investors in the Fund should have a long-term p