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CORRESP
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 Putnam ETF Trust

 ROPES & GRAY LLP
 PRUDENTIAL TOWER
 800 BOYLSTON STREET
 BOSTON, MA 02199-3600
 WWW.ROPESGRAY.COM

 August 1, 2025

 James M. Forbes T +1 617 235 4765
 james.forbes@ropesgray.com

   

 VIA EDGAR
 Securities and Exchange Commission
 100 F Street, NE Washington, DC
20549 Attn: Sonny Oh

 Re:

 Comments to Registration Statement on Form N-14 of Putnam ETF Trust (the
“Registrant”), as filed on June 27, 2025 (SEC Accession No. 0001193125-25-151504) (the “Registration Statement”)
 Dear Mr. Oh:
 This letter responds to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) that you provided by teleconference to James Forbes and James Schwab of Ropes & Gray LLP, counsel to the Registrant, on July 24, 2025, on the Registration Statement relating to the proposed merger (each, a
“Merger” and, collectively, the “Mergers”) of each “Target Fund” listed in the table below with and into the corresponding “Acquiring ETF” listed in the table below.

 Target Fund

          Acquiring ETF

 Putnam California Tax Exempt Income Fund

 ®

 Franklin California Municipal Income ETF

 Putnam Massachusetts Tax Exempt Income Fund

 ®

 Franklin Massachusetts Municipal Income ETF

 Putnam Minnesota Tax Exempt Income Fund

 ®

 Franklin Minnesota Municipal Income ETF

 Putnam New Jersey Tax Exempt Income Fund

 ®

 Franklin New Jersey Municipal Income ETF

 Putnam New York Tax Exempt Income Fund

 ®

 Franklin New York Municipal Income ETF

 Putnam Ohio Tax Exempt Income Fund

 ®

 Franklin Ohio Municipal Income ETF

 Putnam Pennsylvania Tax Exempt Income Fund

 ®

 Franklin Pennsylvania Municipal Income ETF

 Putnam Short-Term Municipal Income Fund

 ®

 Franklin Short-Term Municipal Income ETF

 Putnam Tax Exempt Income Fund

 ®

 Franklin Municipal Income ETF

 Putnam Tax-Free High Yield Fund

 ®

 Franklin Municipal High Yield ETF
 For convenience, this letter summarizes the Staff’s comments before the Registrant’s
responses. These responses will be reflected in Pre-Effective Amendment No. 1 to the Registration Statement

under the Securities Act to be filed with the Commission on or around August 5, 2025 (the “Pre-Effective Amendment No. 1”). Capitalized
terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement. General Comments

 1.
 Comment: Please ensure that any disclosure changes made in response to the Staff’s comments to
Post-Effective Amendment No. 23 under the Securities Act of 1933, as amended, and Amendment No. 24 under the Investment Company Act of 1940, as amended (the “1940 Act”), to the Registration Statement on Form N-1A (File Nos. 333-253222 and 811-23643) of the Registrant, on behalf of each of the Acquiring ETFs, filed with the Commission on
May 30, 2025 (the “485(a) Amendment”) are reflected in Pre-Effective Amendment No. 1, as applicable.
 Response: The Registrant confirms that it has reviewed the disclosure changes expected to be made in response to the
Staff’s comments to the 485(a) Amendment and will reflect them in Pre-Effective Amendment No. 1 to the extent applicable.
 Part A: Prospectus/Information Statement

 2.
 Comment: The first sentence of the third paragraph in the letter to shareholders entitled “A
Message from the President and Chair” states that each Acquiring ETF “has the same investment objective, investment policies, investment strategies, and portfolio management team as the corresponding Target Fund.” Please add
disclosure briefly comparing the principal risks of each Acquiring ETF and the corresponding Target Fund to this section and elsewhere where similar statements are made in the Registration Statement.
 Response: The Registrant will revise the above-referenced sentence as follows to add a brief comparison of the
principal risks of each Acquiring ETF and the corresponding Target Fund as follows (additions denoted with underlined text):
 “Each Acquiring ETF is a newly created series of Putnam ETF Trust, a Delaware statutory trust (the “ETF
Trust”), that has the same investment objective, investment policies, investment strategies, and portfolio management team as the corresponding Target Fund and substantially similar principal risks (except that the Acquiring ETF is also
subject to risks related to its ETF structure) . The Registrant also will add similar disclosure elsewhere where
similar statements are made in the Registration Statement.

 3.
 Comment: The Staff notes that the fifth paragraph in the introduction to the Prospectus/Proxy
Statement references “the Board of Trustees of The Putnam Funds.” Please consider adding a definition of “The Putnam Funds” in this section, which represents the first use of that term in the Prospectus/Information Statement.

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 Response: For clarity, the Registrant will revise the
above-referenced paragraph as follows to eliminate the term “The Putnam Funds” (additions denoted with underlined text and deletions denoted with strikethrough text):
 “With respect to each Target Fund and Acquiring ETF (each, a “Fund”), the Board of Trustees of The
Putnam Funds (the “Board”), the board of directors trustees of each the Fund s (the “Board,” “Board of Trustees,” or “Trustees”) ,
unanimously approved the Merger and Plan and determined that participation in the applicable Merger is in the best interests of each Fund and that the interests of existing Fund shareholders will not be diluted as a result of the Merger.”
 The Registrant also will make similar revisions elsewhere in the Prospectus/Information Statement to avoid the use of the term
“The Putnam Funds.”

 4.
 Comment: The third sentence of the third paragraph under the heading “ 2. What will happen to
my shares of a Target Fund as a result of the Merger? ” in the section “I. Questions and Answers regarding the Mergers” states that, “Because Acquiring ETF Shares trade at market prices rather than at NAV, Acquiring ETF Shares
may trade at a price less than (discount) or greater than (premium) to the then-current pro rata value of an Acquiring ETF’s net assets.” Please consider whether there is simpler language that can be used in lieu of the phrase “the
then-current pro rata value of an Acquiring ETF’s net assets.” Response: For clarity,
the Registrant will revise this sentence as follows (additions denoted with underlined text and deletions denoted with strikethrough text):
 “Because Acquiring ETF Shares trade at market prices rather than at NAV per share , Acquiring ETF Shares may trade
at a price less than (discount) or greater than (premium) to the then-current pro rata value of an Acquiring ETF’s net assets then-current NAV per share .”

 5.
 Comment: The second sentence of the third paragraph under the heading “ 4. Why are the Mergers
happening ” in the section “I. Questions and Answers regarding the Mergers” states that, “The Trustees have determined that each Merger is in the best interests of shareholders of the participating Funds.” If accurate,
please note whether the Trustees’ determination was unanimous. If it was not, please clarify that in the disclosure.
 Response: The Registrant will revise the relevant sentence as follows to indicate that the Trustees’ determination
was unanimous (additions denoted with underlined text): “The Trustees have unanimously determined
that each Merger is in the best interests of shareholders of the participating Funds.”

 6.
 Comment: The first sentence of the first paragraph under the heading “ 7. Are there any
differences in risks between the Target Funds and the Acquiring ETFs? ” in the section “I. Questions and Answers regarding the Mergers” indicates that the risks associated with owning shares of an Acquiring ETF are
“similar” to the risks associated with owning shares of the corresponding Target Fund. Similar statements elsewhere in the Prospectus/Information Statement (for example, in the first sentence of the first paragraph

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under the heading “2. How do the principal investment risks of the Funds compare?” in the section “II. Comparison of Some Important Features of the Funds—Merger 1: Putnam
California Tax Exempt Income Fund into Franklin California Municipal Income ETF”) indicate that the risks are “substantially similar.” Please reconcile these statements for consistency.
 Response: The Registrant will revise the above-referenced statement under the heading “ 7. Are there any
differences in risks between the Target Funds and the Acquiring ETFs? ” as follows (additions denoted with underlined text). The Registrant notes that other anticipated updates that do not directly relate to this comment response also
have been reflected in the disclosure below. “Many of the principal risks associated with owning shares of
an Acquiring ETF are substantially similar to the risks associated with owning shares of the corresponding Target Fund (except that the Acquiring ETF is also subject to risks related to its ETF structure) .”
 The Registrant also will make similar revisions elsewhere in the Prospectus/Information Statement to indicate that many of the
principal risks associated with owning shares of an Acquiring ETF are substantially similar to the principal risks associated with owning shares of the corresponding Target Fund.

 7.
 Comment: In the response under the heading “ 8. Will the total expenses of the Acquiring ETFs
be lower than the total expenses of the Target Funds? ” in the section “I. Questions and Answers regarding the Mergers,” please also consider including disclosure comparing the management fees of each Acquiring ETF with the
corresponding Target Fund. If such a comparison is included, please also delete the word “total” where it appears in the heading.
 Response: The Registrant will revise the above-referenced response as follows (additions denoted with underlined
text and deletions denoted with strikethrough text): “ 8. Will the
 total expenses of the Acquiring ETFs be lower than the total expenses of the Target Funds?
 Yes. Following the Merger, each Acquiring ETF is expected to have a total expense ratio that is lower than that of each share
class of the corresponding Target Fund at all asset levels. In addition, the Acquiring ETFs will be subject to a unitary fee structure, whereby the Investment Manager bears substantially all operating expenses of the Acquiring ETFs. Each
Acquiring ETF’s contractual (unitary) management fee rate is lower than the corresponding Target Fund’s contractual management fee rate at all asset levels.
 For a more detailed comparison of the Funds’ fees and expenses, see the section of this Prospectus/Information Statement
relating to your Merger titled “ Question 4. How do the management fees and other expenses of the Funds compare, and what are they estimated to be following the Merger ?””
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 8.
 Comment: In the discussion of each Merger in the section “II. Comparison of Some Important
Features of the Funds,” please consider adding disclosure regarding how the Acquiring ETF and corresponding Target Fund compare in terms of (i) distribution and purchase procedures and exchange rights and (ii) redemption procedures,
as required by Item 3(b)(1) and 3(b)(2) of Form N-14.
 Response: The Registrant notes that a discussion of how the Acquiring ETF and corresponding Target Fund compare in
terms of distribution and purchase procedures, exchange rights, and redemption procedures in included under the headings “ What are the purchase, sale, and exchange procedures of the Target Funds and Acquiring ETFs? ” and
“ What are the distribution arrangements for the Target Funds and Acquiring ETFs? ” in the section “III. Comparison of Other Key Features of the Funds.” The Registrant believes that it is appropriate to include this
discussion in this section, rather than in the section “II. Comparison of Some Important Features of the Funds,” to avoid repetition given that the same comparison of distribution and purchase procedures, exchange rights, and redemption
rights applies to each set of Acquiring ETF and corresponding Target Fund.

 9.
 Comment: A footnote included in the “Annual Fund Operating Expenses” table under the
heading “ 4. How do the management fees and other expenses of the Funds compare, and what are they estimated to be following the Merger? ” in the discussion of each Merger in the section “II. Comparison of Some Important
Features of the Funds” refers to “non-recurring expenses related to the Merger.” Please clarify in the disclosure what is meant by “non-recurring
expenses” in this context. Response: The Registrant will revise the above-referenced
footnote text as follows to clarify the meaning of “non-recurring expenses” (additions denoted with underlined text):
 “Does not reflect non-recurring expenses related to the Merger. These
expenses may include legal and accounting expenses, portfolio transfer taxes (if any), the costs of printing and mailing this Prospectus/Information Statement, SEC filing fees, other similar expenses incurred in connection with the consummation of
the Merger and related transactions contemplated by the Plan, costs associated with the organization and registration of the Acquiring ETF, and transaction costs associated with liquidating portfolio securities that will not be acquired by the
Acquiring ETF as part of the Merger (“portfolio repositioning”), if any. The Investment Manager will bear all of these non-recurring expenses other than portfolio repositioning costs, and the
Investment Manager currently does not anticipate any significant portfolio repositioning or related transaction costs in connection with the Merger. If these expenses had been reflected, pro forma other expenses and total annual fund
operating expenses would have been the same.”

 10.
 Comment: The second sentence of the second paragraph under the heading “ 6. How does the
investment performance of the Funds compare? ” in the discussion of each Merger in the section “II. Comparison of Some Important Features of the Funds” states that the Acquiring ETF will adopt the historical accounting
records and performance of the Target Fund and, specifically, the Target Fund’s Class R6 shares. Given that approach, please provide information regarding the return after taxes on distributions and after taxes on

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distributions and sale of fund shares of Class R6 shares (rather than Class A shares) in the table “Average annual total returns for Target Fund after sales charges.”
 Response: The Registrant will provide the requested information for the Class R6 shares of
each Target Fund in Pre-Effective Amendment No. 1.

 11.
 Comment: The fourth paragraph under the heading “ 6. How does the investment performance of
the Funds compare? ” in the discussion of each Merger in the section “II. Comparison of Some Important Features of the Funds” states that, “The performance of the other classes, which is shown in the table below, will
differ because the classes pay potentially lower expenses.” Please confirm the accurate of this statement, and revise as appropriate, given that this sentence references classes other than Class R6 and that Class R6 appears to have
expenses that are lower than, or equal to, those of each other share class. Kindly confirm the accuracy of the sentence.
 Response: The Registrant will revise the above-referenced statement as follows to clarify that share classes other than
Class R6 bear potentially higher expenses than Class R6 (additions denoted with underlined and deletions denoted with strikethrough text):
 “The performance of the other classes, which is shown in the table below, will differ because the classes
 bear pay potentially lower higher expenses.”

 12.
 Comment: In the table identifying each Fund’s principal investment strategies appearing under
the heading “ What are the funds’ principal investment strategies and related risks? ” in the section “IV. Risk Factors,” in the rows addressing (i) Franklin Municipal Income ETF and Putn