SecProbe.io

CORRESP
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filename1.htm

Tidal
ETF Trust

234
West Florida Street, Suite 203

Milwaukee,
Wisconsin 53204

March
13, 2024

VIA
EDGAR TRANSMISSION

Mr.
David Matthews

Division
of Investment Management, Disclosure Review Office

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Re: Tidal
                                            ETF Trust (the “Trust”)

  Post-Effective Amendment No. 212 to the Trust’s Registration
                                        Statement on Form N-1A (the “Amendment”)

  File Nos. 333-227298, 811-23377

Dear
Mr. Matthews:

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 March 8, 2024, with respect to the Amendment and changes to the investment strategies of the Unlimited
HFND Multi-Strategy Return Tracker ETF (the “Fund”). 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.

 1. With
                                            respect to the Subsidiary, please:

 i. Disclose
                                            that the Fund complies with the provisions of the Investment Company Act governing each of
                                            (i) investment policies (Section 8), (ii) capital structure and leverage (Section
                                            18), and (iii) affiliated transactions and custody (Section 17), on an aggregate basis with
                                            the Subsidiary.

 ii. Confirm
                                            in correspondence with the Staff that the Subsidiary will consolidate its financial statements
                                            with the Fund’s financial statements, and that the fees and expenses of the Subsidiary
                                            will be reflected in the Fund’s fee table.

 iii. Confirm
                                            in correspondence that the Subsidiary will agree to designate an agent for service of process
                                            in the United States.

 iv. Confirm
                                            in correspondence that the Subsidiary and its board of directors will agree to inspection
                                            by the Staff of the Subsidiary’s books and records, which will be maintained in accordance
                                            with Section 31 of the Investment Company Act and the rules thereunder.

Response:

 i. The
                                            Trust confirms that the Prospectus will be revised to reflect the foregoing. In particular,
                                            the Prospectus will be revised to include language substantially as follows:

The
Fund complies with the provisions of the 1940 Act relating to investment policies, capital structure and leverage on an aggregate basis
with the Subsidiary. The Subsidiary also complies with the provisions of Section 17 of the 1940 Act relating to affiliated transactions
and custody.

 ii. The
                                            Trust hereby confirms to the Staff that the Subsidiary will consolidate its financial statements
                                            with the Fund’s financial statements, and that the fees and expenses of the Subsidiary
                                            will be reflected in the Fund’s fee table.

 iii. The
                                            Trust confirms that the Subsidiary will agree to designate an agent for service of process
                                            in the United States.

 iv. The
                                            Trust agrees that the Subsidiary and/or its Board of Directors will agree to inspection by
                                            the Staff of the Subsidiary’s book and records, which will be maintained in accordance
                                            with Section 31 of the 1940 Act and the rules thereunder.

 2. With
                                            respect to the following sentence under the heading “Cayman Subsidiary,” please
                                            remove the reference to shares of the Subsidiary being offered or sold to other investors:
                                            “The Fund is the sole investor in the Subsidiary and does not expect the shares of
                                            the Subsidiary to be offered or sold to other investors.”

Response:
The Trust confirms that the Prospectus has been revised to remove such reference.

 3. With
                                            respect to Subsidiary risk disclosures, please conform statements in the SAI that the Subsidiary
                                            is expected to be used primarily to provide the Fund with exposure to futures contracts to
                                            statements in the prospectus, that the Subsidiary will be used to provide fund exposure to
                                            both futures contracts and swaps.

Response:
The Trust confirms that the SAI Subsidiary Risk disclosure has been bolstered to reflect that the Fund will use the Subsidiary to provide
the Fund with exposure to both futures contracts and swaps.

If
you have any questions or require further information, please contact Michael Pellegrino at (844) 986-7700 #746 or mpellegrino@tidalfg.com.

Sincerely,

/s/
Michael T. Pellegrino

Michael
T. Pellegrino, General Counsel

Tidal
Investments LLC