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CORRESP
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Tidal
ETF Trust

234
West Florida Street, Suite 203

Milwaukee,
Wisconsin 53204

January
23, 2025

VIA
EDGAR TRANSMISSION

David
Mathews

U.S.
Securities and Exchange Commission

Division
of Investment Management

100
F Street NE

Washington,
DC 20549

Re: Tidal
                                            ETF Trust (the “Trust”)

  Post-Effective Amendment No. 232 to the Trust’s Registration
                                        Statement on Form N-1A (the “Amendment”)
File Nos. 811-23377; 333-227298

Dear
Mr. Mathews:

This
correspondence responds to comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff”
or the “Commission”) on December 5, 2024, with respect to the Registrant’s proposed material changes to the principal
investment strategies of the Unlimited HFEQ Equity Long/Short Return Tracker ETF, Unlimited HFGM Global Macro Return Tracker ETF, Unlimited
HFEV Event Driven Return Tracker ETF, Unlimited HFFI Fixed Income Return Tracker ETF, Unlimited HFEM Emerging Markets Return Tracker
ETF, Unlimited HFMF Managed Futures Return Tracker ETF and Unlimited Ultra HFND Multi-Strategy Return Tracker ETF (each a “Fund”
and collectively the “Funds”). For your convenience, the comments have been reproduced with responses following each comment.
Capitalized terms not otherwise defined have the same meaning as in the Amendment.

The
Trust previously filed a comment response letter on December 13, 2024 (the “Prior Letter”) in response to comments given
by the Staff. The Prior Letter included completed Fees and Expenses tables and Expense Examples for each Fund. However, the Fees and
Expenses tables have been recalculated to reflect, among other things, more refined Fund holding information. To that end, Fees and Expenses
tables and Expense Examples for each Fund are provided on Appendix A to this letter.

Further,
the Trust notes that the Fees and Expenses table for Unlimited HFMF Managed Futures Return Tracker ETF reflects an AFFE of 0.0%. The
Fund’s sub-adviser has confirmed that the Fund’s strategy will primarily use futures contracts. The Fund’s principal
investment strategy has been adjusted accordingly, and a marked copy of the prospectus reflecting such changes has been emailed to the
Staff separately.

If
you have any questions or require further information, please contact Michael Pellegrino at (262) 318-8442 or mpellegrino@tidalfg.com.

Sincerely,

Michael
Pellegrino

Michael
T. Pellegrino

General
Counsel

Tidal
Investments LLC

Appendix
A

UNLIMITED
HFEQ EQUITY LONG/SHORT ETF - FUND SUMMARY

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
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    0.95%

    Distribution and/or Service (12b-1) Fees
    0.00%

    Other Expenses(2)
     0.00%

    Acquired Fund Fees and Expenses(2)(3)
     0.05%

    Total Annual Fund Operating Expenses
    1.00%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (“Tidal” or the “Adviser”), a Tidal Financial Group company, will
    pay, or require a sub-adviser to pay, all expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case
    may be) excluding interest charges on any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions
    and other expenses incurred in placing orders for the purchase and sale of securities and other investment instruments, acquired
    fund fees and expenses, accrued deferred tax liability, distribution fees and expenses paid by the Fund under any distribution plan
    adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), and litigation
    expenses, and other non-routine or extraordinary expenses.

    (2)
    Based on estimated amounts
    for the current fiscal year.

    (3)
    Acquired Fund Fees and
    Expenses are the indirect costs of investing in other investment companies.

Expense
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 hold or 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.
The Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    $102
    $318

UNLIMITED
HFGM GLOBAL MACRO ETF - FUND SUMMARY

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
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
       0.95%

    Distribution and/or Service (12b-1) Fees
       0.00%

    Other Expenses(2)
       0.00%

    Acquired Fund Fees and Expenses(2)(3)
       0.05%

    Total Annual Fund Operating Expenses
       1.00%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (“Tidal” or the “Adviser”), a Tidal Financial Group company, will
    pay, or require a sub-adviser to pay, all expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case
    may be) excluding interest charges on any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions
    and other expenses incurred in placing orders for the purchase and sale of securities and other investment instruments, acquired
    fund fees and expenses, accrued deferred tax liability, distribution fees and expenses paid by the Fund under any distribution plan
    adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), and litigation
    expenses, and other non-routine or extraordinary expenses.

    (2)
    Based on estimated amounts
    for the current fiscal year.

    (3)
    Acquired Fund Fees and
    Expenses are the indirect costs of investing in other investment companies.

Expense
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 hold or 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.
The Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    $102
    $318

UNLIMITED
HFEV EVENT DRIVEN ETF - FUND SUMMARY

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
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
      0.95%

    Distribution and/or Service (12b-1) Fees
      0.00%

    Other Expenses(2)
       0.00%

    Acquired Fund Fees and Expenses(2)(3)
       0.11%

    Total Annual Fund Operating Expenses
         1.06%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (“Tidal” or the “Adviser”), a Tidal Financial Group company, will
    pay, or require a sub-adviser to pay, all expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case
    may be) excluding interest charges on any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions
    and other expenses incurred in placing orders for the purchase and sale of securities and other investment instruments, acquired
    fund fees and expenses, accrued deferred tax liability, distribution fees and expenses paid by the Fund under any distribution plan
    adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), and litigation
    expenses, and other non-routine or extraordinary expenses.

    (2)
    Based on estimated amounts
    for the current fiscal year.

    (3)
    Acquired Fund Fees and
    Expenses are the indirect costs of investing in other investment companies.

Expense
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 hold or 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.
The Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    $108
    $337

UNLIMITED
HFFI FIXED INCOME ETF - FUND SUMMARY

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
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
       0.95%

    Distribution and/or Service (12b-1) Fees
       0.00%

    Other Expenses(2)
       0.00%

    Acquired Fund Fees and Expenses(2)(3)
       0.24%

    Total Annual Fund Operating Expenses
       1.19%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (“Tidal” or the “Adviser”), a Tidal Financial Group company, will
    pay, or require a sub-adviser to pay, all expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case
    may be) excluding interest charges on any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions
    and other expenses incurred in placing orders for the purchase and sale of securities and other investment instruments, acquired
    fund fees and expenses, accrued deferred tax liability, distribution fees and expenses paid by the Fund under any distribution plan
    adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), and litigation
    expenses, and other non-routine or extraordinary expenses.

    (2)
    Based on estimated amounts
    for the current fiscal year.

    (3)
    Acquired Fund Fees and
    Expenses are the indirect costs of investing in other investment companies.

Expense
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 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. The
Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    $121
    $378

UNLIMITED
HFEM EMERGING MARKETS ETF - FUND SUMMARY

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
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
      0.95%

    Distribution and/or Service (12b-1) Fees
      0.00%

    Other Expenses(2)
      0.00%

    Acquired Fund Fees and Expenses(2)(3)
       0.04%

    Total Annual Fund Operating Expenses
       0.99%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (“Tidal” or the “Adviser”), a Tidal Financial Group company, will
    pay, or require a sub-adviser to pay, all expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case
    may be) excluding interest charges on any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions
    and other expenses incurred in placing orders for the purchase and sale of securities and other investment instruments, acquired
    fund fees and expenses, accrued deferred tax liability, distribution fees and expenses paid by the Fund under any distribution plan
    adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), and litigation
    expenses, and other non-routine or extraordinary expenses.

    (2)
    Based on estimated amounts
    for the current fiscal year.

    (3)
    Acquired Fund Fees and
    Expenses are the indirect costs of investing in other investment companies.

Expense
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 hold or 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.
The Example does not take into account brokerage commissions that you may pay on your purchases and sales of Shares. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years

    $101
    $315

UNLIMITED
HFMF MANAGED FUTURES ETF – FUND SUMMARY

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
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example
below.

    Annual
Fund Operating Expenses(1) (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
      0.95%

    Distribution and/or Service (12b-1) Fees
      0.00%

    Other Expenses(2)
      0.00%

    Acquired Fund Fees and Expenses(2)(3)

    0.00%

    Total Annual Fund Operating Expenses
      0.95%

    (1)
    The Fund’s
    investment adviser, Tidal Investments LLC (“Tidal” or the “Adviser”), a Tidal Financial Group company, will
    pay, or require a sub-adviser to pay, all expenses incurred by the Fund (except for advisory fees and sub-advisory fees, as the case
    may be) excluding interest charges on any borrowings, dividends and other expenses on securities sold short, taxes, brokerage commissions
    and other expenses incurred in placing orders