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February 23, 2024

Kim McManus, Esq.

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review and Accounting Office

100 F Street NE

Washington, DC 20549

 Re: NEOS ETF Trust (the "Trust" or the "Registrant") File Nos. 811-23645, 333-253997

Dear Ms. McManus:

On December 5, 2023, NEOS ETF Trust (the
"Trust" or the "Registrant"), on behalf of its series, NEOS Enhanced Income Credit Select ETF (formerly NEOS Enhanced
Income High Yield Bond ETF) filed post-effective amendment number 97 to the Trust's registration statement (the “Amendment”).
The Amendment was filed pursuant to Rule 485(a)(2) under the Securities Act of 1933, as amended, to register shares of the Fund.

On January 16, 2024, you provided comments
to the Amendment by phone to Daniel Moler. Set forth below are your comments, as we understand them, followed by responses to those comments,
which the Fund has authorized Thompson Hine LLP to make on its behalf. Where applicable, revisions indicated in responses to your comments
will be reflected in an amendment to the registration statement to be filed subsequently to or concurrently with this letter. All capitalized
terms not defined herein have the meaning given to them in the registration statement. A marked copy of the prospectus or relevant sections
of the prospectus is attached to aid in your review.

GENERAL

Comment 1. We remind you that
the Fund and management are responsible for the accuracy and adequacy of the disclosure notwithstanding any review, comment, action, or
absence of action by the SEC staff.

Response. The Registrant
acknowledges the responsibility described above.

Comment 2. Please prepare
a response letter including SEC staff comments, the Registrant’s responses, and file it on EDGAR. Where a revision is contemplated
by a response, please provide the staff with the revised disclosure. Please allow at least 5 business days to review the completed fee
table and expenses.

Response. The Registrant
acknowledges the responsibilities described above.

    1

PROSPECTUS

Fees and Expenses

Comment 3. Please revise the
introductory language to mirror the language in Item 3 of Form N-1A.

Response. The Registrant
has revised the disclosure as follows:

This table describes the fees and
expenses that you may pay if you buy, hold, and sell shares of the Fund. You may be required to
pay other fees, such as brokerage commissions and other fees to financial intermediaries on
purchases and sales of Shares, which are not reflected in the tables or the example below. Please
contact your financial intermediary about whether such a commission may apply to your transactions.

Comment 4. Please remove the
last sentence of the first paragraph, as it is not in Form N-1A.

Response. Please see
the revised disclosure in response to Comment 3.

Comment 5. When you complete
the fee table, please ensure you include the accompanying explanation of annual fund operating expenses.

Response. The Registrant has
added the following disclosure in the fee table:

    Annual Fund Operating Expenses Shareholder Fees (expenses that you pay each year as a percentage of the value of your investment fees paid directly from your investment).

Comment 6. In the Expense
Example, please remove reference to the fee waiver to the extent is it expired.

Response. The Registrant has
revised the language before the expense examples as follows:

The Example also assumes that your
investment has a 5% return each year and that the Fund’s operating expenses remain the same, except
the contractual arrangement to waive Management Fees and reimburse expenses remains in effect only until January 1, 2024.

Principal Investment Strategies

Comment 7. Please specify
what securities are in the 20% bucket. If it includes derivatives, please ensure the strategy and risk are disclosed with specificity.

Response. The Registrant
has revised the Prospectus to include the following:

The Fund may invest from
time-to-time in short-term investments including money market funds.

In addition, the Registrant has revised
the Prospectus to clarify that derivatives linked to bonds count towards the 80% policy. The revised disclosure is as follows:

For purposes of the 80% policy, the
Fund may gain exposure to the Underlying Investments through derivatives such as forwards, options, and futures,
and the value of such forwards, options and futures contracts shall be determined on a daily mark-to-market basis.

    2

Comment 8. Please clarify
if the intent is to refer to total assets or net assets for purposes of 80% test.

Response. The Registrant
confirms the intent is to refer to “net assets” and has made corresponding revisions in the prospectus.

Comment 9. Please confirm
that the Fund will not invest in mutual funds or revise to clarify that it will invest in mutual funds.

Response. We confirm
that the Fund will not invest in shares of mutual funds.

Follow Up Comment to Response 9.
The response indicates that the Fund will not invest in shares of mutual funds; however, the disclosure in the prospectus on page
16 suggests it will invest in open-end and closed-end funds. In addition, we note that the predecessor fund’s N-CSR filed in November
includes a schedule of investments that shows 30% investments in open-end funds as of August 31, 2023. Please revise or advise.

Response. The Registrant
has revised the risk disclosure to remove references to “other investment companies” and clarify that the Fund will only be
investing in ETFs. Supplementally, the Registrant confirms that the predecessor fund’s current positions in mutual funds and/or
closed-end funds will be sold prior to the reorganization.

Comment 10. With respect to
the Fund being a “fund of funds”, if there will be an outsized investment (more than 25%) in affiliated fund, disclose fund
name, explain its main strategies, and disclose associated principal risks of the underlying fund. Also, confirm participation agreements
have been filed between the fund of funds and the acquired funds.

Response. The Registrant
does not anticipate the Fund investing in any affiliated ETFs. Therefore, the disclosure noted in the comment has not been added and no
participating agreements have or will be entered into.

Comment 11. Explain the concept
of duration and include a brief example in the prospectus.

Response. The Registrant has
added the following the disclosure to the Prospectus:

Duration is a measure
of price sensitivity relative to interest rates. For example, if interest rates changed by one percent, the value of a security having
an effective duration of two years would vary by two percent.

Comment 12. Will the Fund
invest in equities? If yes, disclose in the principal investment strategies. There is reference to equities and/or options on page 3 but
prior disclosure refers to investing in debt and options.

Response. The Fund will invest
in equities issued by ETFs that in turn will invest in debt securities.

Comment 13. Please revise
the 80% policy to tie to high yield investments consistent with the Fund’s name.

Response. The Registrant
has changed the name of the Fund to “NEOS Enhanced Income Credit Select ETF.” Accordingly, the Registrant no longer believes
there is a need to tie the 80% policy to high yield investments.

    3

Comment 14. With respect to
the ETF Risk in the Summary Prospectus, please disclose that purchases and redemptions of creation units primarily with cash rather than
through in-kind delivery of portfolio securities may cause the ETF to incur certain costs. Disclose that these costs could include brokerage
costs, or taxable gains or losses that it might not have incurred if it made redemption in kind. In addition, disclose that these costs
could be imposed on the ETF and therefore decrease the ETF's net asset value to the extent not offset by a transaction fee payable by
an AP.

Response. The Registrant
has amended the disclosure as follows:

Exchange Traded Funds (“ETFs”)
Risk: An investment in an ETF is subject to the risk that the general level of security prices, or that the prices of securities within
a particular sector, may increase or decline, thereby affecting the value of the shares of an ETF. In addition, ETFs are subject to the
following risks: (1) the market price of the ETF’s shares may trade at a discount to its net asset value (“NAV”) due
to the fact that the supply and demand in the market for ETF shares at any point in time is not always identical to the supply and demand
in the market for the ETF’s underlying basket of securities, accordingly, there may be times when an ETF trades at a premium (creating
the risk that the Fund pays more than NAV for an ETF when making a purchase) or discount (creating the risks that the Fund’s NAV
is reduced for undervalued ETFs it holds, and that the Fund receives less than NAV when selling an ETF); (2) an active trading market
for an ETF’s shares may not develop or be maintained; (3) trading of an ETF’s shares may be halted if the listing exchange
deems such action appropriate; (4) ETF shares may be delisted from the exchange on which they trade; and
(5) activation of “circuit breakers” by the exchange (which are tied to large decreases in stock prices) may
halt trading of the ETF temporarily; and (6) purchases and redemptions of creation units primarily with cash
rather than through in-kind delivery of portfolio securities may cause the Fund to incur certain costs, including brokerage costs or taxable
gains or losses that it might not have incurred if it made a redemption in-kind, and therefore decrease the Fund's NAV to the extent not
offset by a transaction fee payable by an AP.

Comment 15. Please include a derivatives
or options related risk. Alternatively explain why this risk is not material.

Response. The Registrant has
added “Options Risk” as a principal investment risk.

    4

Summary Prospectus

Options Risk. There
are risks associated with the sale and purchase of put options. As a seller (writer) of a put option, the Fund will tend to lose money
if the value of the reference index or security falls below the strike price. As the buyer of a put option, the Fund risks losing the
entire premium invested in the option if the Fund does not exercise the option.

Statutory Prospectus

Options Risk.
The Fund may lose the entire put option premium paid if the underlying security does not decrease in value at expiration. Put options
may not be an effective hedge because they may have imperfect correlation to the value of the Fund’s portfolio securities. Purchased
put options may decline in value due to changes in price of the underlying security, passage of time and changes in volatility. Written
call and put options may limit the Fund’s participation in equity market gains and may magnify the losses if the price of the written
option instrument increases in value between the date when the Fund writes the option and the date on which the Fund purchases an offsetting
position. The Fund will incur a loss as a result of a written options (also known as a short position) if the price of the written option
instrument increases in value between the date when the Fund writes the option and the date on which the Fund purchases an offsetting
position.

Performance Summary

Comment 16. Please provide an analysis
for why the shell fund would be the accounting survivor. Also, please provide supplemental response regarding the plans for filings related
to the merger. Supplementally, please explain the business purpose of the merger.

Response. The shell fund was
inadvertently named in the accounting survivor in the Amendment. The Registrant has revised the disclosure as follows:

As
a result of the acquisition, the The Fund will adopt the financial
statements of the Predecessor Fund, be the accounting survivor
successor of the Reorganization Predecessor
Fund.

The Registrant plans to file an N-14 with
respect to the reorganization. The reorganization is believed to be in the best interests of the Target Fund and its shareholders in light
of certain benefits to the Target Fund’s shareholders including (1) a substantially similar investment objective and similar investment
strategy with the addition of generating additional tax-efficient income via the options overlay; (2) the reputation, financial strength,
and resources of NEOS Investment Management LLC; (3) the Target Fund will not bear any direct expenses in connection with the Reorganization;
(4) lower total expenses anticipated for the Target Fund; (5) qualifying as a tax-free reorganization for U.S. federal income tax purposes;
and (6) the ETF structure, which generally includes intra-day trading, increased tax efficiency, greater transparency into portfolio holdings,
lower portfolio transaction costs, and less cash drag on performance.

Comment 17. Please confirm that year-to-date
performance will be updated.

Response. The Registrant has
updated the year-to-date performance as follows:

The 20223
year-to-date return of the Fund’s Institutional Shares through September 30, 20223
is 2.95% was 0.87%.

    5

Statutory Prospectus

Comment 18. “Exchange Traded
Funds (“ETFs”) Risk. Please review and revise the first paragraph for clarity. It is unclear whether the ETF is referring
to itself or to underlying ETFs. Also, the Registrant appears to be stating that it will be acting as an AP in discussing AP activities.
Please clearly delineate AP activities/risks in this risk or separately in another risk.

Response. The Registrant has
restated the risk factor as follows

Exchange Traded Funds (“ETFs”)
Risk: The Fund is structured as an ETF and will invest in underlying ETFs. As a result, the Fund is subject
to special risks, including:

 · Not Individually Redeemable. The Fund’s
shares (“Shares”) are not redeemable by retail investors and may be redeemed only by Authorized Participants at net asset
value (“NAV”) and only in Creation Units. A retail investor generally incurs brokerage costs when selling shares.

 · Trading Issues. Trading in Shares on CBOE
BZX Exchange, Inc. (the “Exchange”) may be halted due to market conditions or for reasons that, in the view of the Exchange,
make trading in Shares inadvisable, such as extraordinary market volatility. There can be no assurance that Shares will continue to meet
the listing requirements of the Exchange which may result in the Shares being delisted. An active trading market for the Shares may not
be developed or maintained. If the Shares are traded outside a collateralized settlement system, the number of financial institutions
that can act as Authorized Participants that can post collateral on an agency basis is limited, which may limit the market for the Shares.

 · Market Price Variance Risk. The market
prices of Shares will fluctuate in response to changes in NAV and supply and demand for Shares and will include a “bid-ask spread”
charged by the exchange specialists, market makers or other participants that trade the Shares. There may be times when the market price
and the NAV vary significantly. This means that Shares may trade at a discount to NAV.

 o In times of market stress, market makers may step
away from their role market making in the Shares and in executing trades, which can lead to differences between the market value of the
Shares and the Fund’s NAV.

 o The market price of the Shares may deviate from
the Fund’s NAV, particularly during times of market stress, with the result that investors may pay significantly more or significantly
less for the Shares than the Fund’s NAV, which is reflected in the bid and ask price for the Shares or in the closing price.

 o In stressed market conditions, the market for
the Shares may become less liquid in response to the deteriorating liquidity of the Fund’s portfolio. This adverse effect on the
liquidity of the Shares may, in turn, lead to differences between the market value of th