SecProbe.io

CORRESP
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JOHN H. LIVELY, Managing Partner

john.lively@practus.com

11300 Tomahawk Creek Pkwy., Suite 310

Leawood, KS 66211

(913) 660-0778

January 10, 2025

Mr. David Mathews

 Attorney-Adviser

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: ETF Opportunities Trust (File Nos. 333-234544 and 811-23439)

  Brookmont Catastrophic Bond ETF

Dear Mr. Mathews:

This letter provides the responses
of ETF Opportunities Trust (the “Trust” or the “Registrant”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) that you provided to Practus, LLP. The comments related
to Post-Effective Amendment (“PEA”) No. 149 to the registration statement of the Trust, which was filed on July 12, 2024,
pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the “1933 Act”). The PEA was filed to register shares
of a new series of the Trust, the Brookmont Catastrophic Bond ETF (the “Fund”). For your convenience, I have summarized the
comments in this letter and provided the Trust’s response below each comment. Capitalized terms not defined in this letter shall
have the same meaning ascribed to such term in the PEA. It is intended that any revisions to the disclosures contained in the Fund’s
prospectus and statement of additional information that are made in response to the comments contained herein will be reflected in another
post-effective amendment filing to the Trust’s registration statement this filed pursuant to Rule 485(b) under the 1933 Act (the
“485(b) filing”).

Preliminary or
General Comments

 · Please
file this comment response letter on EDGAR at least five days prior to making the 485(b) filing and also send via email to Mr. Mathews
marked pages of the revised disclosure.

 · Please
also apply any new or revised disclosure in one section to similar disclosure in other sections throughout the registration statement.

Response:	As requested, the
Trust will file this comment response letter on EDGAR and send via email to Mr. Mathews marked pages of the revised disclosure as early
as possible prior to the current effective date. The Registrant acknowledges the Staff’s comment and will endeavor to work with
the Staff to resolve all comments before going effective on the registration statement. The Trust intends that new or revised disclosure
that is similar to disclosure in other sections will be applied consistently throughout the registration statement.

JOHN H. LIVELY ● MANAGING
PARTNER

11300 Tomahawk Creek Pkwy
● Ste. 310 ● Leawood, KS 66211 ●
p: 913.660.0778 ● c: 913.523.6112

Practus, LLP ●
John.Lively@Practus.com ● Practus.com

 1. Comment:	Please provide the completed fee table
and example numbers pre-effectively with the Trust’s response. In the response letter, please describe how any estimates were determined
and why the Trust believes that those estimates are reasonable. Also, in correspondence, confirm that the Fund does not intend to engage
in borrowing or short sales in its initial fiscal year, or, if it does, revise the fee table to include expenses associated with those
practices.

Response: 	The completed fee table
and example numbers are provided with this response. The estimates were determined based on projected asset levels, expected expenses,
and industry standards for similar funds. The Trust believes that these estimates are reasonable as they reflect anticipated costs associated
with operating the Fund during its initial fiscal year. The Trust confirms that the Fund does not intend to engage in borrowing or short
sales in its initial fiscal year. Therefore, the fee table does not include expenses associated with those practices.

 2. Comment:	Please confirm, in correspondence, that the fee
waiver/expense reimbursement will be in effective for at least one year from the effective date of the registration statement. Consider
including a description of the Adviser’s ability to recoup the amounts waived or expenses reimbursed or cross reference to that
discussion in Item 10 of the prospectus.

Response: 	The Registrant confirms
that the fee waiver/expense reimbursement agreement will be in effect for at least one year from the effective date of the registration
statement. A description of the Adviser’s ability to recoup waived fees and reimbursed expenses within three years, subject to the
Fund's expense cap, has been added in a footnote to the fee table.

 3. Comment:	The following disclosure is included in the Principal Investment Strategies section
of the prospectus: “These investments also may cover risks such as mortality, longevity and
operational risks.”  In correspondence, please provide more detail regarding the ability to invest in mortality, or operational
risk-related securities, including a description of the types of investments and the extent of the Fund’s allocations.

Response:	 The Fund may invest
in insurance-linked securities that cover mortality and longevity risks, such as mortality bonds or longevity bonds. These instruments
allow the Fund to gain exposure to the risk of significant deviations in actuarial estimates of mortality rates, such as those caused
by pandemics. Operational risk-related securities may include instruments that provide coverage against operational failures associated
with terrorism or other unanticipated events impairing business activity. The Fund anticipates that allocations to these types of securities
will constitute up to 10% of its net assets, depending on market opportunities and conditions.

 4. Comment:	As the Fund’s description of its
                                                                                                       Principal Investment Strategies indicates significant investment in catastrophe bonds in broad categories of related
                                                                                                       insurance-linked securities (“ILS”), and given
the varying liquidity profiles of such investments, please address, in correspondence, how the Fund determined this strategy is appropriate
for an open-end exchange traded fund structure. In your response, please address and include information regarding the following:

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 A. Describe how the Fund and its advisers in executing
the strategy will address each of the relevant liquidity risk management factors set forth in the Commission’s Rule 22e-4 Adopting
Release (on pages 154 and 155 of the release).

Response:	The
Fund has implemented a comprehensive Liquidity Risk Management Program in accordance with Rule 22e-4. The Adviser and Sub-Adviser will
regularly assess the liquidity of portfolio investments, considering factors such as trading volume, settlement periods, volatility of
trading prices for the asset, bid-ask spreads, maturity/term, restrictions on the trading of the assets and the nature of the market for
each security. Stress testing and scenario analysis will be conducted to evaluate unique liquidity considerations associated with weather
events in addition to general adverse market conditions for risk assets. The portfolio is expected to be diversified sufficiently across
specific issues, peril types and regions to allow for bond impairment events without causing the Fund’s illiquid assets to approach
the 15% limitation.

 B. Include market data with respect to historical
and current liquidity for each category of investments the Fund will primarily invest in, and address how liquidity determination categories
will account for and be impacted by, seasonal climate events, specific perils or triggering events, and the aftermath of catastrophic
events, including recent examples.

Response:	The
Adviser has advised the Fund of the following in response to this comment:

Catastrophe
bonds can be purchased directly from the initial purchaser in the primary market or bought or sold in the secondary market. The growing
participation of reinsurers, insurers and new sponsors in the catastrophe bond market has helped maintain high liquidity in the secondary
market, even after major events. For example, during the onset of the COVID-19 pandemic in March 2020 and following Hurricane Ian in
2022—the largest catastrophe bond market loss to date—the secondary market remained active, allowing investors who needed
to liquidate their positions to find buyers. Figure 1 shows monthly volume (USD) from catastrophe bonds sold in the secondary market
from January 2015 to September 2023, as reported to the US Financial Industry Regulatory Authority’s (FINRA) Trade Reporting and
Compliance Engine (TRACE). TRACE tracks catastrophe bond trades executed by U.S. broker-dealers regulated by FINRA and the SEC, capturing
only a portion of the secondary catastrophe bond market activity. Between 2015 and 2023, Figure 1 highlights a record volume of secondary
market trades in March 2020, as investors were able to liquidate catastrophe bond positions due to COVID-related distress in their other
investments.

Figure 1: TRACE monthly sell volume (USD) from January 2015 to September 2023.

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More
recently Florida experienced a rare two Hurricane event hitting generally in the same geographic area in consecutive weeks in Helene and
Milton. During this period the net asset values of the five 40 Act registered funds employing a similar strategy as the Fund had a five-day
maximum draw down of anywhere from 1.06% to 6.9%. As of October 23, 2024 the funds fully recovered returning anywhere between .47% to
1.9% above the pre-Helene/Milton period.

Figure 2a presents a histogram of
the TRACE bid-ask spreads for the 300+ trades recorded during that period, showing minimal absolute variation in the bid-ask spread. Figure
5 also reflects secondary market activity in October and November 2022, following Hurricane Ian’s landfall in Florida on 28 September
2022. Figure 2b displays the histogram of TRACE bid-ask spreads for trades during that time, again indicating little absolute variation.

Figure 2a: Bid-ask spreads of all TRACE trades in March 2020 during market downturn related to COVID.

Figure 2b: Bid-ask spreads of all TRACE trades in October-November 2022 after 2022 Hurricane Ian.

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Since 2015 marks the first full year
of TRACE data, Figure 3 shows the market-weighted average bids and asks from Swiss Re Capital Markets' indicative pricing sheets for the
catastrophe bond market going back to 2000. The chart indicates minimal volatility in bids, asks, and bid-ask spreads under normal conditions,
with only modest widening of spreads during periods of stress (Q4 2008, March 2020, and Q4 2022). This supports the idea that investors
can trade catastrophe bond positions without triggering significant price movements across various market environments. In terms of liquidity,
catastrophe bonds naturally benefit from being part of this broader investor and reinsurance and insurance universe.

Figure 3: Swiss Re cat bond market weighted bids-asks

Over the past two decades,
catastrophe bonds have delivered strong and consistent performance, even during financial crises and major natural disasters, as well
as significant losses in the global reinsurance and insurance industry (e.g., Hurricane Katrina in 2005, the Global Financial Crisis
of 2008, the Eurozone Debt Crisis of 2010-2012, COVID-19, and Hurricane Ian in 2022). As illustrated in Figure 4, catastrophe bonds have
shown significantly lower volatility compared to other asset classes, providing steady long-term returns even in times of heightened
market stress. Since its inception in 2002, the Swiss Re Global Cat Bond Total Return Index, a monthly market index created by Swiss
Re and available on Bloomberg, has experienced over 4x less volatility than equities (MSCI World Index), 2.8x less than high-yield bonds
(Barclays Macro Global High Yield Bond Index), and nearly 2x less than the global aggregate bond index (Bloomberg Global Aggregate Bond
Index). The chart and indices highlight how cyclical assets like equities, corporate bonds, and real estate tend to correlate during
economic downturns. Catastrophe bonds have been valued by the investors for offering uncorrelated source of returns, providing genuine
diversification when other cyclical markets are correlated and declining.

Figure 4: Comparison of Swiss Re Global Cat Bond Index Total Return against Other Market Benchmarks from 2002 to early 2024 (Source – Swiss Re Capital Markets).

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 C. Explain how each type of catastrophe bond or related
ILS will be classified under the Fund’s Rule 22e-4 liquidity risk management program and specify whether liquidity classifications
will be made on an asset class basis or on an instrument by instrument basis, and if classified on an asset class basis, explain how this
is appropriate given unique characteristics of each instrument as to peril, geography, and trigger events.

Response:	Liquidity
classifications will be made on an instrument-by-instrument basis due to the unique characteristics of each security. Factors such as
peril type, geographic exposure, trigger mechanisms, and market demand will be considered to determine the liquidity category of each
investment. The Adviser believes that the portfolio will range anywhere from highly liquid to less liquid with a rare occasion of illiquid
holdings. At any given time the Adviser believes that the portfolio will be roughly 25-50% in either highly liquid or moderately liquid
assets (cumulatively 50% to 100% in highly or moderately liquid being able to convert into cash within 7 days). In market environments
where risk assets are selling off the Adviser believes the portfolio could be up anywhere between 5%-20% in less liquid securities, but
believes these events are temporary in nature and are reflective of a broader market selloff impacting many risk assets. Additionally,
the Adviser believes that on a rare occasion the Fund may hold a de minimis amount of illiquid holdings. These would be driven by an impending
impairment of a bond where the bonds do not trade resulting in the Adviser using a model-based valuation. The Adviser expects that these
instances will be rare given that the annual impairment loss rate of the asset class is between 2-3% and upon impairment the Adviser anticipates
a significant write-down of the impaired asset. The Adviser expects to have below 5% in illiquid positions in the Fund at any given time,
likely closer to 0%.

 D. Discuss the Adviser’s and Sub-Adviser’s
experience investing in catastrophe bonds and related ILS and how that experience will inform their liquidity assessments for each category
of investment and consider adding additional details in this regard to the disclosure in Item 10 of the prospectus.

Response:	The
Adviser was founded in 2007 and manages over $1.1 billion in assets. The Fund’s Portfolio Manager for the Fund, Ethan Powell, is
a Principal and the Chief Investment Officer of the Adviser and has over 20 years of experience in managing alternative investment strategies,
including the management of liquid alternative investments offered through liquid fund wrappers including mutual funds, ETFs, closed
end funds and business development companies. The Sub-Adviser's investment team is composed of four seasoned professionals each with
over thirty years of expertise in both reinsurance and asset management. From 2019 to 2023, this team was instrumental in establishing
and managing PIMCO’s Insurance-Linked Securities (ILS) investment desk, overseeing all aspects of its operations. They were responsible
for investment decisions across two dedicated ILS funds at PIMCO and served as internal specialists to multiple PIMCO fixed income and
alternative asset funds seeking to allocate to the ILS space. Their responsibilities further included managing liquidity classifications
for all ILS positions within the organization and addressing valuation challenges related to pricing anom