SecProbe.io

CORRESP
 1
 filename1.htm

 December
3, 2025

 Christopher
Bellacicco

 Division
of Investment Management

 U.S.
Securities and Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 RE:
GraniteShares ETF Trust (the "Trust" or the "Registrant") File Nos. 333-214796, 811-23214

 Dear
Mr. Ballacicco

 On
September 17, 2025, GraniteShares ETF Trust (the "Trust" or "Registrant"), on behalf of GraniteShares YieldBOOST
Single Stock Universe ETF and GraniteShares YieldBOOST TopYielders ETF (each a "Fund", and collectively, the "Funds")
filed a Post-Effective Amendment #103 to the Trust's Registration Statement (the "Amendment"). The Amendment was filed
pursuant to Rule 485(a)(2) under the Securities Act of 1933, as amended, to register the Funds.

 On
December, 2025, you provided comments to the Amendment to which we have responded. Below, please find those comments and the Registrant's
responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language to a Fund's
prospectus is in italics and deleted language appears struck through.

 COVER
PAGE

 Comment
1 : Please add the cover page disclosures that are included in the other YieldBOOST fund filings, tailored as appropriate.

 Response :
The disclosures have been added.

 SUMMARY
PROSPECTUS

 GraniteShares
YieldBOOST Single Stock Universe ETF

 Comment
2 : Please consider revisions to the Fund's name to clarify that the single stock universe is limited only to GraniteShares
funds.

 Response :
The Registrant appreciates the comment but respectfully declines to implement it. The Registrant allocated significant resource in establishing
the brand "GraniteShares Yieldboost" and has been communicated with the market participants on that basis since the launch
of the offering in December 2024. For that reason, the Registrant wishes to keep the naming convention consistent across its offering.

 Principal
Investment Strategies

 Comment
3 : Please confirm the following part of the second sentence of the second paragraph: "…the income generated from selling
options on an "Underlying Stock" by selling options on leveraged exchange-traded funds designed to deliver 2 times (200%)
the daily performance of the Underlying Stock (the "Underlying ETF")."

 Response :
the statement is confirmed. Options are sold on leveraged ETFs that aim to replicate 2x the daily performances of an underlying stock

 Comment
4 : At the end of the seventh paragraph, the final clause states " which may not be offset by income received by the Fund. "
Please revise "income" to "distributions."

 Response :
The revision has been made.

 Principal
Risks of Investing in the Fund

 Comment
5 : Please add a risk disclosure discussing flex options.

 Response :
the disclosure has been added.

 Comment
6 : Please include extended risk disclosures of the Price Participation Risk and Put Writing Strategy Risk in the Statutory Prospectus.

 Response :
the disclosures have been extended.

 SUMMARY
PROSPECTUS

 GraniteShares
YieldBOOST TopYielders ETF

 Comment
7 : Please carryover any applicable comments from GraniteShares YieldBOOST Single Stock Universe ETF.

 Response :
The comments have been carried over

 Principal
Investment Strategies

 Comment
8 : In the first sentence of the first paragraph under the sub-heading " Portfolio Construction ", please define
the term "Underlying Security".

 Response :
the reference to "Underlying Security" has been changed to "Underlying Stock" with is defined in eth second paragraph
under the section "Principal Investment Strategies".

 Comment
9 : In the fourth paragraph under the sub-heading " Portfolio Construction ", please supplementally explain how the
Fund will comply with its concentration policy if it invests in only three to ten Underlying YieldBOOST ETFs.

 Response :
The disclosure related to the portfolio construction has been revised and now envisages that the fund will invest between 5 to 10 Underlying
YieldBOOST ETF. The following disclosure has been added: " As part of its risk management process, to seek to lower risk and
enhance returns, where possible, the Fund will invest in Underlying YieldBOOST ETFs that provide exposure across various sectors and
industries, reducing the impact of sector specific events. While the Fund intends to have exposure to multiple sectors, it may invest
in Underlying YieldBOOST ETF that provide exposure to a particular sector in amounts greater than 25% of the Fund's total assets
when the Adviser's selection process indicates that such sector exposure would be appropriate for the Fund. The Fund will not invest
more than 25% of its net assets in any particular "industry" as defined under the Standard Industrial Classification code. "

 If
you have any questions, please call the undersigned at (216) 566-5706.

 Very
 truly yours,

 /s/
 Andrew Davall a

 Andrew
 Davalla

 GRANITESHARES
FUNDS

 Prospectus

 December
[ ], 2025

 GRANITESHARES FUNDS

 TICKER SYMBOL

 GraniteShares YieldBOOST Single Stock Universe ETF

 YBST

 GraniteShares YieldBOOST TopYielders ETF

 YBTY

 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.

 GraniteShares Funds are advised by GraniteShares
Advisors LLC.

 An investment in a Fund is not an investment
in the corresponding Underlying ETF. However, each Fund's performance may be significantly dependent on the return of its corresponding
Underlying ETF, especially in periods of market volatility.

 Investors who do not understand the Funds,
or do not intend to monitor their investments, should not buy the Funds.

 There is no assurance that any Fund will achieve
its investment objective and an investment in a Fund could lose money. No single Fund is a complete investment program.

 TABLE OF CONTENTS

 Page

 GraniteShares YieldBOOST Single Stock Universe ETF
 1

 GraniteShares YieldBOOST TopYileders ETF
 13

 Additional Information about the Funds' Investment Objectives, Strategies and Risks
 25

 Fund Website and Disclosure of Portfolio Holdings
 33

 Fund Management
 33

 Buying and Selling Shares
 34

 Dividends, Distributions, and Taxes
 35

 Distribution of Fund Shares
 38

 Premium/Discount Information
 38

 Fund Service Providers
 38

 Financial Highlights
 38

 GraniteShares ETF Trust
 38

 i

 GraniteShares
YIELDBOOST SINGLE STOCK UNIVERSE – Summary

 Investment Objective

 The Fund's primary investment objective
is to seek current income.

 Fund Fees and Expenses

 This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund ("Shares"). The fees are expressed as a percentage of the Fund's
average daily net assets. Investors may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which
are not reflected in the table and example below.

 Management
 Fee

 -
 %

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

 Management
 Fee

 0.29
 %

 Distribution
 and/or Service (12b-1) Fees

 0.00
 %

 Other
 Expenses (1)

 0.10
 %

 Acquired
 Fund Fees and Expenses (2)

 0.99
 %

 Total
 Annual Fund Operating Expenses

 1.38
 %

 Fee
 Waiver/Reimbursements (3)

 -
 %

 Net
 Annual Fund Operating Expenses After Fee Waiver/Reimbursements (1), (2), (3) (1)(2)(3)

 1.38
 %

 (1)
 Other Expenses are estimated for the Fund's initial fiscal year.

 (2)
 Acquired Fund Fees and Expenses are the indirect costs of investing in other investment companies, namely the Underlying YieldBOOST ETFs (as defined below). Total Annual Fund Operating Expenses reflect Fund expenses paid indirectly and do not correlate to the expense ratios in the Fund's Financial Highlights because the Financial Highlights include only the direct operating expenses incurred by the Fund and exclude Acquired Fund Fees and Expenses. The amounts are estimated for the Fund's initial fiscal year.

 (3)
 GraniteShares Advisors LLC has contractually agreed to waive its fees
 and/or pay for operating expenses of the Fund to ensure that total annual fund operating expenses (exclusive of any (i) interest,
 (ii) brokerage fees and commission, (iii) acquired fund fees and expenses, (iv) fees and expenses associated with instruments in
 other collective investment vehicles or derivative instruments (including for example options and swap fees and expenses), (v) interest
 and dividend expense on short sales, (vi) taxes, (vii) other fees related to underlying investments (such as option fees and expenses
 or swap fees and expenses), (viii) expenses incurred in connection with any merger or reorganization or (ix) extraordinary expenses
 such as litigation) will not exceed 0.50%. This agreement is effective until December 31, 2026, and it may be terminated
 before that date only by the Trust's Board of Trustees. GraniteShares Advisors LLC may request recoupment of previously waived
 fees and paid expenses from the Fund for three years from the date such fees and expenses were waived or paid, if such reimbursement
 will not cause the Fund's total expense ratio to exceed the expense limitation in place at the time of the waiver and/or expense
 payment and the expense limitation in place at the time of the recoupment.

 Example

 This Example is intended to help you compare the
cost of investing in the Fund with the cost of investing in mutual funds and other exchange-traded 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 the same. The figures shown would be the same
whether or not you sold your Shares at the end of each period.

 1

 Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

 1 Year
 3 Years

 $ 144.08
 $ 471.18

 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 Shares are held in a taxable account. These costs, which are not reflected in the total annual
fund operating expenses or in the expense example above, affect the Fund's performance. Because the Fund is newly organized, portfolio
turnover information is not yet available.

 Principal Investment Strategies

 The Fund is an actively managed exchange-traded
fund ("ETF") that seeks current income and pay weekly distributions. The Fund is a "fund of funds," meaning that
it primarily invests its assets in the shares of other ETFs, rather than in securities of individual companies. In addition, from time
to time, the Fund may invest directly in the securities and financial instruments in which one or more Underlying YieldBOOST ETFs (defined
below) invests.

 The Fund's portfolio will be primarily composed
of "YieldBOOST ETFs," which are all affiliated ETFs advised by GraniteShares Advisors LLC (the "Adviser") (each,
an "Underlying YieldBOOST ETF"). Each of the Underlying YieldBOOST ETFs in which the Fund may invest has for objective to
achieve 2 times (200%) the income generated from selling options on an "Underlying Stock" by selling options on leveraged
exchange-traded funds designed to deliver 2 times (200%) the daily performance of the Underlying Stock (the "Underlying ETF").
The Underlying YieldBoost ETF's secondary investment objective is to gain exposure to the performance of the Underlying ETF, subject
to a cap on potential investment gains. Each Underlying YieldBoost ETF may implement a downside protection which could affect the net
income level.

 Additional information regarding the Underlying
YieldBOOST ETF is set forth below.

 The Fund will be subject to regulatory constraints
relating to the level of value at risk that the Fund may incur through its derivatives portfolio. To the extent the Fund exceeds these
regulatory thresholds over an extended period, the Fund may determine that it is necessary to make adjustments to the Fund's investment
strategy and the Fund may not achieve its investment objective.

 An investment objective is fundamental if it cannot
be changed without the consent of the holders of a majority of the outstanding Shares. No Fund's investment objective has been adopted
as a fundamental investment policy and therefore each Fund's investment objective may be changed without the consent of that Fund's
shareholders upon approval by the Board of Trustees (the "Board") of GraniteShares ETF Trust (the "Trust") and
60 days' written notice to shareholders.

 There is no guarantee that the Fund's
investment strategy will be properly implemented, and an investor may lose some or all of its investment.

 Due to the investment strategies of the Underlying
YieldBOOST ETFs, the Fund's indirect exposure to gains, if any, of the share price returns of the Underlying Stocks is generally
limited. However, the Fund is subject to all potential losses if the shares of the Underlying Stocks decrease in value, which may not
be offset by distributions received by the Fund.

 Portfolio Construction

 The Fund's portfolio will generally be equally
weighted in each of the available Underlying YieldBOOST ETFs. The Adviser will reallocate the Fund's portfolio on a monthly basis
so that each Underlying YieldBOOST ETF (including any eligible new Underlying YieldBOOST ETF(s)) is equally weighted in the Fund's
portfolio, excluding any Underlying YieldBOOST ETF for which the tax loss harvesting strategy is currently being used. For a new Underlying
YieldBOOST ETF to be eligible for inclusion in the Fund's portfolio, it must have commenced operations and have made an initial
distribution.

 2

 The Fund is classified as "non-diversified"
under the 1940 Act.

 The Adviser will endeavor to optimize tax losses
by implementing the synthetic call strategy as described below. This approach will lead to deviations from an equal allocation for the
specific Underlying YieldBOOST ETFs subject to tax harvesting.

 Tax Loss Harvesting Strategy

 If a specific Underlying YieldBOOST ETF has recently
incurred substantial losses, the Fund may choose to redeem (or otherwise exit) its investment in that particular ETF to seek to capitalize
on tax loss harvesting (a strategy that seeks to minimize the Fund's capital gains). In that case, the Adviser will use the proceeds
from such redemption and directly invest them in the same derivative instruments on the same Underlying ETF(s) as that of the redeemed
Underlying YieldBOOST ETF (as described in the section below "Underlying YieldBOOST ETF's use of the Underlying ETF Derivatives
Contracts"). This approach aims to achieve returns akin to those of the redeemed Underlying YieldBOOST ETF in which the Fund was
invested. The strategy will be employed for a minimum of 31 days to adhere to applicable tax rules.

 Underlying YieldBOOTS ETFs

 Each Underlying YieldBOOST ETF is an actively
managed exchange-traded fund ("ETF") that seeks to pay weekly distributions by selling put options on the Underlying ETF,
which provides exposure to 2 times the daily performance of the Underlying Stock. It is expected that the implied volatility on the Underlying
ETF to be twice the level of the Underlying Stock's implied volatility and selling options on the Underlying ETF to generate, over
the same time horizon and for the same strike levels, twice the premium generated by selling options on the Underlying Stock. The premium
received by the Underlying YieldBOOST ETF from selling options will be distributed at least partially before the maturity of the options.
This allows the Underlying YieldBOOST ETF to make distributions on a weekly basis even if the