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CORRESP
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VIA EDGAR TRANSMISSION

Mr. Tony Burack

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”)

Response to Comments Regarding
Financial Statement Review

File Nos. 811-23377; 333-227298

Dear Mr. Burack:

This correspondence responds to the comments the
Trust received from the staff of the Commission (the “Staff”) on February 6, 2024, with respect to recent Form N-CSR and Form
N-CEN filings and registration statements for the series of the Trust and their respective fiscal year ends as set forth in the table
below (each, a “Fund” and collectively, the “Funds”):

    Series ID
    Series Name
    FYE

Reviewed

    S000070461
    SP Funds S&P Global REIT Sharia ETF
    11/30/2022

    S000067283
    SP Funds S&P 500 Sharia Industry Exclusions ETF
    11/30/2022

    S000067282
    SP Funds Dow Jones Global Sukuk ETF
    11/30/2022

    S000070511
    Sound Equity Dividend Income ETF
    11/30/2022

    S000070510
    Sound Enhanced Fixed Income ETF
    11/30/2022

    S000066941
    RPAR Risk Parity ETF
    12/31/2022

    S000074863
    UPAR Ultra Risk Parity ETF
    12/31/2022

    S000065096
    SoFi Be Your Own Boss ETF
    2/28/2023

    S000065095
    SoFi Social 50 ETF
    2/28/2023

    S000069652
    SoFi Weekly Income ETF
    2/28/2023

    S000065094
    SoFi Next 500 ETF
    2/28/2023

    S000072049
    SoFi Smart Energy ETF
    2/28/2023

    S000065093
    SoFi Select 500 ETF
    2/28/2023

    S000076633
    SoFi Web 3 ETF
    2/28/2023

    S000071722
    SoFi Weekly Dividend ETF
    2/28/2023

    S000071415
    Acruence Active Hedge U.S. Equity ETF
    3/31/2023

    S000072647
    SonicShares Global Shipping ETF
    3/31/2023

    S000072366
    ZEGA Buy and Hedge ETF
    4/30/2023

    S000072268
    Robinson Alternative Yield Pre-Merger SPAC ETF
    4/30/2023

    S000073705
    FolioBeyond Alternative Income and Interest Rate Hedge ETF
    7/31/2023

    S000072498
    ATAC Credit Rotation ETF
    8/31/2023

    S000069950
    Adasina Social Justice All Cap Global ETF
    8/31/2023

    S000069694
    Leatherback Long/Short Alternative Yield ETF
    8/31/2023

    S000070010
    ATAC US Rotation ETF
    8/31/2023

    S000076475
    Gotham 1000 Value ETF
    9/30/2023

    S000069980
    Gotham Enhanced 500 ETF
    9/30/2023

    S000071844
    American Customer Satisfaction ETF
    9/30/2023

For your convenience, the comments have been reproduced
with responses following each comment.

 1. It was noted for SP Funds S&P Global REIT Sharia ETF, SP Funds S&P 500 Sharia Industry Exclusions
ETF and SP Funds Dow Jones Global Sukuk ETF the Management Discussion of Fund Performance (“MDFP”) in the November 20, 2022
shareholder reports did not address performance for the most recent fiscal years ending November 30, 2022, but instead only discussed
periods of performance that extended beyond each fiscal year-end.

Response: The Trust acknowledges
and concurs with the Staff’s assessment. The Trust confirms that MDFPs in future shareholder reports will address portfolio performance
for at least the fiscal periods covered by each shareholder report.

 2. The Trust was asked to confirm all average annual total returns in the Adasina Social Justice All Cap
Global ETF’s August 31, 2022 shareholder report’s Performance Summary section. It was also noted the Growth of $10,000 chart
results may not match to the average total returns in the accompanying performance table.

Response: The Trust confirms the
1 year returns and the average annual returns within the performance table are accurate. The Trust acknowledges the Growth of $10,000
chart does have a discrepancy as the Adasina Social Justice All Cap Global ETF – Market graph line was mistakenly used for the Dow
Jones Global Index graph line and vice versa. The Trust confirms enhanced checks are in place to ensure accurate performance graphs are presented.

 3. It was noted that certain Funds’ Schedule of Investments within their respective shareholder
reports disclose securities that were fair valued with unobservable inputs. The Staff requests that securities noted as fair valued with
unobservable inputs have a footnote disclosing such securities as Level 3 valued securities pursuant to Regulation S-X.

Response: The Trust confirms that
in future Schedules of Investments it will note fair valued securities where unobservable inputs were used in valuation as a Level 3 valued
security.

 4. The Staff suggested, although not required pursuant to Regulation S-X, that for future Schedules of
Investments of the SP Funds Dow Jones Global Sukuk ETF or other series within the Trust, that securities with an interest rate ceiling
or floor to disclose such ceiling or floor interest rates, as applicable.

Response: The Trust confirms that
in future Schedules of Investments it will endeavor to disclose ceiling or floor interest rates.

 5. The Staff noted the Leatherback Long/Short Alternative Yield ETF and ATAC US Rotation ETFs shareholder
reports disclosed Tax Expense within each of their Statements of Operations. The Staff requests that appropriate descriptive disclosure
of such Tax Expense be included in the Notes to Financial Statements for future shareholder reports.

Response: The Trust confirms that
in future shareholder report Notes to Financial Statement it will include descriptive disclosure as it applies to tax expenses incurred
and disclosed in the Statement of Operations.

 6. The Staff noted that for the respective annual shareholder reports for the ATAC Credit Rotation ETF,
ATAC US Rotation ETF and SoFi Weekly Dividend ETFs there was return of capital reported within each Fund’s Statement of Changes
in Net Assets, but was not disclosed as such in each Fund’s Form N-CEN responses to Item B.23 as it relates to Rule 19a-1 Notice
dissemination. The Staff requests confirmation that the Trust intended to respond Yes to Item B.23 for each Fund and that Rule 19a-1 Notices
were required and disseminated.

Response: The Trust responds that
Item B.23 on Form N-CEN for each Fund should have been answered as Yes to requiring a Rule 19a-1 Notice. The Trust further confirms that
Rule 19a-1 Notices were not disseminated to shareholders pursuant to Rule 19a-1. The Trust further confirms that enhanced procedures are
in place to ensure that Rule 19a-1 Notices are prepared and disseminated in the future and that Item B.23 will be responded to accordingly
in future Form N-CEN filings.

 7. The Staff noted there were multiple Form N-CSR Section 302 Certification 4.(d) disclosures that referenced
“last fiscal quarter” as opposed to “period covered by this report”. The Staff asks for confirmation there were
no changes to the registrant’s internal control over financial reporting for the period covered by the applicable reports. The Staff
also requests confirmation from the Trust that the updated Form N-CSR Section 302 Certifications will be used in all filings in the future.

Response: The Trust responds that
there were no changes to report for the respective periods ended for all Form N-CSRs filed during the periods under review. The Trust
further confirms the updated Form N-CSR Section 302 Certification will be used in all filings going forward.

 8. The Staff requested that for Gotham 1000 Value ETF, Gotham Enhanced 500 ETF, ATAC Credit Rotation ETF and ATAC US Rotation ETFs
respective Form N-CSRs the Trust confirm if there was disclosure that was applicable for Item 4. (i) and (j) as there were no responses
included in the filings. The Staff also requests confirmation from the Trust that the updated Form N-CSR be used in all filings in the
future.

Response: The Trust acknowledges
and concurs there were no responses for Item 4. (i) and (j) as noted. The Trust confirms the following would have been the appropriate
responses:

(i) The registrant has not been
identified by the U.S. Securities and Exchange Commission as having filed an annual report issued by a registered public accounting firm
branch or office that is located in a foreign jurisdiction where the Public Company Accounting Oversight Board is unable to inspect or
completely investigate because of a position taken by an authority in that jurisdiction.

(j) The registrant is not a foreign
issuer.

The Trust further confirms the updated Form
N-CSR will be used in all filings going forward.

 9. The Staff, referencing amended Form N-CSR filings on December 7, 2023 for Gotham 1000 Value ETF, Gotham
Enhanced 500 ETF and American Customer Satisfaction ETF, noted the Trust did not file updated certifications pursuant to Section 906 of
the Sarbanes-Oxley Act of 2002 for the Trust’s Principal Officers. The Staff requests that filings be updated to reflect certification
dates that align with the date of the amended filings.

Response: The Trust
acknowledges that Principal Officer certifications were not executed with updated dates for the amended filings for the Gotham 1000
Value ETF, Gotham Enhanced 500 ETF and American Customer Satisfaction ETF Form N-CSRs. The Trust confirms that based on the
Staff’s request amended filings have been completed with updated Principal Officer certifications.

 10. The Staff noted the shareholder report for SP Funds Dow Jones Global Sukuk ETF (the “Sukuk ETF”)
disclosed securities incorporated in the Cayman Islands at 52.3% of total investments. The Staff suggests the Trust consider if additional
risk disclosures are applicable considering the Cayman Island exposure in future registration statement updates.

Response: The Trust has considered
whether risk disclosure applicable to investments in the Cayman Islands is appropriate for the Sukuk ETF and respectfully declines to
add additional risk disclosure. Although the Sukuk ETF has invested a significant portion of its assets in sukuk of entities formed or
incorporated in the Cayman Islands, Luxembourg or Jersey, the Trust notes that such sukuk is generally issued by special purpose vehicles
of parent entities or companies organized in different countries, most commonly Saudi Arabia and the United Arab Emirates. The Trust believes
that the principal risk to the Sukuk ETF is most directly related to the parent entities or companies organized in Saudi Arabia and the
United Arab Emirates and, accordingly, has included principal risk disclosure relating to investments tied to such countries in the Sukuk
ETF’s prospectus.

 11. The Staff, in review of shareholder reports, noted that certain Funds within the Trust participate
in Securities Lending and suggest the Trust consider additional registration statement disclosure on potential securities lending exposure
relative to total portfolio assets for each Fund and any additional risk disclosure relating to securities lending.

Response: The Trust notes that none
of the Funds in the Trust pursues securities lending as a principal investment strategy and further notes that, at present, it does not
believe that any Fund’s current exposure to securities lending presents a principal risk to a Fund. The Trust adds that the Statement
of Additional Information for each Fund that engages in securities lending includes disclosure relating to risks a Fund may be exposed
to through securities lending. However, the Trust undertakes to review a Fund’s exposure to securities lending when updating such
Fund’s registration statement to consider whether additional risk disclosure would be appropriate at that time.

If you have any questions or require further information,
please contact Aaron Perkovich at 414-699-9292 or aperkovich@tidalfg.com.

Sincerely,

/s/ Aaron Perkovich

Aaron Perkovich

Treasurer/Principal Financial Officer

Tidal ETF Trust