SecProbe.io

CORRESP
1
filename1.htm

The Atlantic Building

950 F Street, NW

Washington, DC 20004-1404

202-239-3300 | Fax: 202-239-3333

    David J. Baum
    Direct Dial:  202-239-3346
    Email:  David.Baum@alston.com

October 3, 2025

VIA EDGAR

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Kim McManus

    Re:

    Kurv ETF Trust (the “Trust” or “Registrant”)

    Post-Effective Amendment No. 34 to the Trust’s
    Registration Statement on Form N-1A filed on July 25, 2025 – Kurv High Income ETF

    File Numbers 333-233633; 811-23473

Ladies and Gentlemen:

This letter is in response
to the comments provided by the staff of the U.S. Securities and Exchange Commission (the “Staff”) via video-call (the “Comments”)
on September 9, 2025, relating to Post-Effective Amendment No. 34 (“PEA No. 34”) to the Trust’s Registration Statement
on Form N-1A filed on July 25, 2025, regarding the Kurv High Income ETF (the “Fund”), a series of the Trust. The prospectus
(the “Prospectus”) and statement of additional information (“SAI,” and together with the Prospectus, the “Documents”)
contained in the Registration Statement will be updated in response to the Staff’s Comments and a revised post-effective amendment
to the Registration Statement reflecting these changes will be filed subsequent to this correspondence.

General Comments

Comment #1

The Staff provides the
following standard comments:

 a. Where a comment is made in one location it is applicable to all similar disclosures appearing elsewhere
in the same registration statement.

 b. The Staff reminds the Registrant that the company and its management are responsible for the accuracy
and adequacy of its disclosures not withstanding any review, comments, action or absence of action by the Staff.

    Alston & Bird LLP
    www.alston.com

Atlanta | Beijing
| Brussels | Charlotte | Dallas | Los Angeles | New York | Research Triangle | San Francisco | Silicon Valley | Washington, D.C.

    October 3, 2025
 Page 2

 c. The Staff asks the Registrant to please file the responses to comments on EDGAR at least 5 days in advance
of the effectiveness.

Response #1

The Registrant acknowledges
the Staff’s comments above and will respond as requested.

Prospectus

Summary Section: Fund Fees and Expenses

Comment #2

With respect to the “Expense Example”
section on page three of the Prospectus, please revise to remove the last sentence of the second paragraph the “Expense Example”
section of the Prospectus.

Response #2

The Registrant has revised
the second paragraph of the “Expense Example” section to remove the last sentence of the paragraph. Please see the revision
below:

 Example

This Example is intended to help you
compare the cost of investing in the Gold Fund with the cost of investing in mutual funds and other exchange-trade 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.1
The figures shown would be the same whether or not you
sold your Shares at the end of each period.

Comment #3

The footnote under the
“Expense Example” section on page three of the Prospectus appears to have been included in error. Please remove or explain
how Fund has an expiring expense limitation agreement.

Response #3

The Registrant confirms
that the footnote in the “Expense Example” section on page three of the Prospectus will be removed.

Summary Section: Principal Investment
Strategies

Comment #4

In the “Principal
Investment Strategies” section of the Prospectus, please revise to clarify if the Fund will invest primarily in high income paying
stock, ETFs, and ETPs or if it will focus on derivatives to generate high income or will use some combination of these measures or other
means to generate high income.

    October 3, 2025
 Page 3

Response #4

The Registrant confirms
that it will use a combination of Listed Securities and derivative instruments on Listed Securities to generate income for the Fund. That
combination will vary from time to time and may range up to 100% or down to 0% for either such instrument. Please see the revised disclosure
below.

Principal Investment Strategies

The
Fund is an actively managed exchange-traded fund (“ETF”) that primarily invests its assets in U.S. and non-U.S. listed securities,
including equity securities of U.S. and non-U.S. companies and ETFs,
with an options market (“Listed Securities”), or derivative instruments (e.g. options) on such
Listed Securities, as well as derivative instruments of indices. Listed Securities may also include other types of U.S. listed
exchange-traded products (e.g., closed-end funds and commodity pools)(“ETPs”).

The
Fund seeks to generate income primarily from a combination of the options strategies described below, the short-dated fixed income instruments
it holds as collateral in connection with the options strategies, and dividends from the Listed Securities it holds directly. The Fund
may invest up to 100% of its assets in Listed Securities, up to 100% of its assets in derivative instruments (e.g., options) on such
Listed Securities, or invest in any combination of such securities and derivative instruments.

The
Adviser seeks a portfolio of Listed Securities and derivative instruments on Underlyingsuch
Listed Securities based on favorable outlooks, examining characteristics of a particular issuer, such as growth or momentum, as
well as the implied volatility of the derivative instruments of Listed Securities. Implied volatility reflects the market’s expectations
of future price movements, derived from option prices. Higher implied volatility is an indicator of the potential for significant price
swings and higher potential options premiums, allowing the Fund to generate current income.

The
Fund will primarily invest in Listed Securities, or derivative instruments (e.g., options) on Listed Securities.

Cash
and/or Synthetic Long Exposure

The
Fund may gain exposure to a Listed Security directly by holding it or indirectly through synthetic exposure. To achieve a synthetic long
exposure, the Fund buys call options of a Listed Security and, simultaneously, sells put options of the same security with the same expiries
and strike prices to try to replicate the price movements of the underlying Listed Security. The combination of the long call options
and sold put options seek to provide the Fund with investment exposure to the underlying Listed Security for the duration of the application
option exposure. The total net notional exposure to option positionsof
the synthetic long position will not exceed 200% of net asset value.

    October 3, 2025
 Page 4

As part of its strategy,
the Fund may employ one or more options strategies on a Listed Security or index to achieve its investment objectives. The strategies
that may be employed are:

Covered
Call Writing

As
part of its strategy, the Fund may write (sell) call option contracts on Listed Securities or on indices to generate income. If the Fund
gains long exposure synthetically, since the Fund does not directly own shares of the Listed Securities or the index, these written call
options will be sold short (i.e., selling a position it does not currently own).

It
is important to note that the sale of a company’s call option contracts will limit the Fund’s participation in the appreciation
in the company’s stock price. If the stock price of the company increases, the above-referenced synthetic and/or holding the underlying
stock directly would allow the Fund to experience similar percentage gains. However, if the company’s stock price appreciates beyond
the strike price of one or more of the sold (short) call option contracts, the Fund will lose money on those short call positions, and
the losses will, in turn, limit the upside return of the Fund’s synthetic and long stock exposure. As a result, the Fund’s
overall strategy (i.e., the combination of the synthetic and/or long stock exposure to the company and the sold (short) the company’s
call positions) will limit the Fund’s participation in gains in the company’s stock price beyond a certain point.

When
the Fund engages in covered call writing with respect to an underlying stocka
Listed Security, it receives cash from the buyer of the call option who in exchange for that cash obtains the right to purchase
the company Listed Security
on or before the expiration date at a predetermined price called the strike price. Writing covered call options is also considered
long short. Generally, the notional principal amount of written covered call options will not exceed the principal amount of the synthetic
or long stock position in the company, however, the Fund may write call options for an amount in excess of the value of a company’s
position in the Fund’s portfolio.

Uncovered Call and/or
Put Writing

The
Fund may also write (i.e., sell) uncovered call options on Listed Securities or instruments in which it may invest but that are
not currently held by the Fund. The principal reason for writing uncovered call options is to realize income without committing
capital to the ownership of the underlying Listed Securities or instruments. When writing uncovered call options, the
Fund must deposit and maintain sufficient margin with the broker-dealer through which it made the uncovered call option as
collateral to ensure that the Listed Securities can be purchased for delivery if and when the option is exercised. During periods
of declining securities prices or when prices are stable, writing uncovered calls can be a profitable strategy to increase the Fund’s
income with minimal capital risk. Uncovered calls are riskier than covered calls because there is no underlying security held by
the Fund that can act as a partial hedge. Uncovered calls have speculative characteristics and the potential for loss is unlimited.
When an uncovered call is exercised, the Fund must purchase the underlying security to meet its call obligation. There
is also a risk, especially with preferred and debt securities that lack sufficient liquidity, that the Listed Securities may not
be available for purchase. If the purchase price exceeds the exercise price, the Fund will lose the difference.

    October 3, 2025
 Page 5

The
Fund also may write (i.e., sell) uncovered put options on Listed Securities or instruments in which it may invest but with respect
to which the Fund does not currently have a corresponding short position or has not deposited as collateral cash equal to the exercise
value of the put option with the broker-dealer through which it made the uncovered put option. The principal reason for writing uncovered
put options is to receive premium income and to acquire such underlying Listed Securities or instruments at a net cost below the
current market value. The Fund has the obligation to buy the underlying Listed Securities or instruments at an agreed upon price
if the price of the Listed Securities or instruments decreases below the exercise price. If the price of the underlying Listed Securities
or instruments increases during the option period, the option will expire worthless and the Fund will retain the premium and will
not have to purchase the underlying Listed Securities or instruments at the exercise price.

Call
or Put Spreads

The
Fund may write (sell) call or put spreads rather than stand-alone call option contracts to seek increased participation in the potential
appreciation of an underlying Listed Security or instrument’s share price, while still generating net premium income. In a call
option spread, the Fund may sell (write) an out-of-the-money call option (above the current market price) while also purchasing another
call option that is further out of the money. Similarly, in a put option spread, the Fund may sell (write) an out-of-the-money put option
(below the current market price) while purchasing a further out-of-the-money put option.

Risk
Reversals or Protective Collars

The
Fund may write (sell) risk reversals rather than stand-alone call option contracts to seek to limit loss from an underlying Listed Security
or instrument’s share price. The cost of this protection would be offset by the premiums earned from a written call option. In
a risk reversal, the Fund may sell (write) an out-of-the-money call option (above the current market price) call
option while simultaneously purchasing an out-of-the-money
put option.

    October 3, 2025
 Page 6

Protective
Put

The
Fund may purchase out-of-the-money protective put options to seek to limit loss from its underlying share price. The cost of protection
may reduce the income generated in the portfolio.

Call
Purchase

The
Fund may purchase call options to seek to gain price appreciation from its underlying share price. The cost of the purchase may reduce
the income generated in the portfolio.

Short-dated
Fixed Income and Foreign Exchange Instruments

When
writing options, the Fund is required to post collateral to assure its performance to the option buyer. The Fund will hold cash and cash-like
instruments or high-quality short-term fixed income securities (collectively, “Collateral”). The Collateral may consist of
(1) U.S. Government securities, such as bills, notes and bonds issued by the U.S. Treasury; (2) government securities issued by G-10 countries
(Belgium, Canada, France, Germany, Italy, Japan, the Netherlands, Sweden, Switzerland, the United Kingdom, and the United States); (3)
money market funds; (4) fixed income ETFs; and/or (5) corporate debt securities, such as commercial paper and other short-term unsecured
promissory notes issued by companies that are rated investment grade or of comparable quality. The Adviser considers an unrated security
to be of comparable quality to a security-rated investment grade if it believes it has a similar low risk of default. The Fund expects
to invest in fixed income securities with low duration to minimize interest rate risk and the Fund’s exposure to foreign exchange
to be less than 5% of its net assets. Kurv actively manages the Collateral held by the Fund with a view toward enhancing the Fund’s
total return.

The
Adviser will endeavor to optimize tax losses.

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

See
“Additional Information About the Fund” below for a more detailed description of the synthetic covered call strategy.

Comment #5

In the second paragraph
of the “Principal Investment Strategies” section of the Prospectus, please define the term Underlying Securities or revise
if you intended to refer to Listed Securities.

    October 3, 2025
 Page 7

Response #5

The Registrant has revised
the disclosure in response to the comment by removing Underlying Securities as a defined term and referring to Listed Securities. Please
see the revised disclosure in the response to Comment #4 above.

Comment #6

In the third paragraph
of the subsection “Covered Call Writing” in “Principal Investment Strategies” on page five of the Prospectus,
please confirm if “company” should be replaced with “stock”?

Response #6

The Registrant has revised
the disclosure in response to the comment replacing “company” with “stock.” Please see the revised disclosure
in the response to Comment #4 above.

Comment #7

Please review and confirm
the second sentence in the third paragraph of the subsection “Covered Call Writing” in “Principal Investment Strategies”
on page five of the Prospectus. There appears to be something missing.

Response #7

The Registrant has revised
the disclosure in response to the comment. “Please see the revised disclosure in the response to Comment #4 above.

Comment #8

Please delete the repeated
reference to “call option” in subsection “Risk Reversals or Protective Collars” in “Principal Investment
Strat