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June 18, 2024

VIA EDGAR TRANSMISSION

Ashley Vroman-Lee,
Esq.

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0506

Re: NEOS ETF Trust - File Nos. 811-23645, 333-253997

Dear Ms. Vroman-Lee:

The purpose of this letter is to respond to
comments the NEOS ETF Trust (the “Registrant”) received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission on May 10, 2024 regarding Post-Effective Amendment No. 123 on Form N-1A filed on April 8, 2024 for the purpose of
registering the shares of a new series of the Registrant called NEOS Russell 2000 High Income ETF (the “Fund”). The Staff’s
comments are summarized in below followed by the Registrant’s responses.

PROSPECTUS

Investment Objective

Comment 1. Please include in the
Principal Investment Strategies of the Fund section how the Fund intends to achieve its objective of equity appreciation while generating
high monthly income?

Response. The Registrant has revised
the first sentence of the principal investment strategy as follows:

The Fund is an actively-managed exchange-traded
fund (“ETF”) that seeks to achieve its investment objective by (i) investing in one or more equity ETFs
that seeks to tracks the Russell 2000® Index ("Russell 2000 Underlying ETFs") or,
a portfolio of stocks that make up the Russell 2000® Index (the “Russell 2000” or the “Reference Index”),
or a combination thereof; and (ii) Russell 2000 Underlying ETFs and direct investments in constituents, and a
utilizing a call options strategy to provide high monthly income, that which primarily consists
of writingten (soldselling) call options on the Russell 2000® Index (“RUT
call options”). The Fund seeks to generate high monthly income from the premiums earned from the RUT call options as well as the
dividends received from the Fund’s equity holdings.”

The Registrant notes that the following sentence
has been added to the first paragraph of the principal investment strategy, which the Registrant believes adequately discusses the potential
for equity appreciation:

“The Fund seeks equity appreciation through
its investments in Russell 2000 Underlying ETFs and/or a portfolio of stocks that make up the Russell 2000® Index.”

Fund Fees and Expenses

Comment 2. Please provide the
fees and expenses for the Fund in the draft prospectus sent via the correspondence filing.

Response. The fees and expenses for the
Fund will be provided at least five business days before the Fund seeks to go effective.

Comment 3. Please include AFFE
in the fee table as a separate line if necessary.

Response. The estimated AFFE for
the Fund have been provided in the fee table of the draft prospectus that accompanies this correspondence filing.

Principal Investment Strategies of the Fund

Comment 4. In the Principal Investment
Strategies of the Fund section of the Prospectus, the Fund states that it will seek to generate income from its call option strategies.
Please disclose under what circumstances the Fund will use the various disclosed call option strategies. Note, this disclosure may appear
in the Item 9 section of the Prospectus.

Response. The disclosure under
the “Additional Information About Investment Strategies” section of the Prospectus has been revised to clarify that the Fund
will either write call options or enter a call spread strategy. Clarifying revisions have been made to the Item 4 strategy disclosure,
and the Item 9 disclosure has been revised to read as follows:

“The Fund’s options strategy consists of the following: (i) writing (selling) call options on the Russell 2000® Index
on up to 100% of the value of the equity securities held by the Fund, which will generate income in the form of premium from writing such
options; or (ii) entering into a call spread strategy where the Fund purchases long (bought) calls in addition to the written (sold) call
options, which may generate income in the form of a net-credit in the call spread.”

Comment 5. Please place a period
after the phrase “and 40% short term gains”.

Response. The requested edit has
been made.

Comment 6. Please disclose what
derivatives the Fund will use as part of its principal investment strategy.

Response. The Registrant has disclosed
the only derivatives the Fund will use are options on the Russell 2000.

Comment 7. Please disclose as
of a recent date the market cap range of the companies in the Russell 2000 Index.

Response. The requested disclosure
has been made.

Comment 8. Please disclose that
the replication strategy that the Fund will use will be the default strategy and that the representative sampling strategy will be used
only in certain situations like those set forth in the parenthetical.

Response. The Fund has modified
the sentences referred to in the comment as follows with additions in bold and deletions struck through:

The Fund, while not an index fund, will
generally use a “replication” strategy to invest in the Russell 2000, meaning the Fund will generally
most often invest in one or more Russell 2000 Underlying ETFs or, all of the component securities of the Russell
2000 (or a combination thereof) in the same approximate proportions as in the Russell 2000® Index,
(often called a “replication strategy) or a combination thereof." However, the Fund
may in limited circumstances use a “representative sampling” strategy, meaning it may invest in a sample of the securities
in the Russell 2000 whose risk, return, and other characteristics closely resemble the risk, return, and other characteristics of the
Russell 2000 as a whole, when NEOS Investment Management, LLC, the Fund’s investment adviser (the “Adviser”), believes
it is in the best interests of the Fund (e.g., when replicating the Russell 2000® Index involves practical difficulties or substantial
costs, a Russell 2000 constituent becomes temporarily illiquid, unavailable, or less liquid, or as a result of legal restrictions or limitations
that apply to the Fund but not to the Russell 2000).

Comment 9.  At the end of
the Principal Investment Strategies of the Fund section of the Prospectus, the last sentence duplicates the following sentence:

“The Fund may engage in active and frequent
trading of portfolio securities in implementing its principal investment strategies.”

Response. The sentence referred to in
your comment has been deleted.

Comment 10. In the Covered Call
Option Writing Risk section of the Fund’s Risk Section, the following sentence is included as the first sentence:

“By writing covered call options, in return
for the receipt of premiums, the Fund will give up the opportunity to benefit from potential increases in the value of the Russell 2000
above the exercise prices of such options, but will continue to bear the risk of declines in the value of the Russell 2000.”

Please add disclosure in the Principal Investment
Strategies of the Fund section discussing the potential for no increase in value or a decrease in value if the written covered call options
remain out of the money or written calls do not offset the decline in the Russell 2000.

Response. The following disclosure
has been added:

“The Fund’s writing (selling) of
call options on the Russell 2000® will limit the Fund’s ability to participate in increases in value of the Russell
2000® beyond a certain point. If the value of the Russell 2000® Index increases, the Fund’s exposure
to the Russell 2000® would allow the Fund to experience similar percentage gains. However, if the value of the Russell
2000® Index appreciates beyond the strike price of one or more of the call option contracts that the Fund has sold to generate
income, the Fund will lose money on those short call positions, and the losses will, in turn, limit the upside return of the Fund’s
exposure to the Russell 2000®. As a result, the Fund’s overall strategy (i.e., the combination of the long exposure
to the Russell 2000® and the call options sold on the Russell 2000® Index) will limit the Fund’s participation
in gains of Russell 2000® beyond a certain point. This strategy effectively converts a portion of the potential upside
of the Russell 2000® into current income.”

Comment 11. In the Covered
Call Option Writing Risk section of the Fund’s Risk Section, the following sentence is included:

The Fund expects the total value of the written
call options and the total value of the purchased call options to each be up to 100% of the Fund’s net assets.

There is separate risk disclosure about covered
call option risk.

Please clarify if the Fund will only write covered
calls and if so please supplementally explain that the Fund will only write options on securities it holds.

Response. The Fund has revised
the Principal Investment Strategy section of the Prospectus to clarify that the Fund’s covered call option strategy entails writing
(selling) covered RUT call options, and that such RUT call options are covered because the Fund owns shares of the Russell 2000 Underlying
ETFs and/or a portfolio of stocks that make up the Russell 2000 at the time it sells the call options.

Comment 12. Please disclose
whether the Russell 2000 Index is currently concentrated in any industry or groups of industries.

Response. The requested disclosure
has been added.

Comment 13. The Principal
Risks section of the Prospectus contains the “Large Shareholder and Large-Scale Redemption Risk” section. Please disclose
the Principal Investment Strategy section of the Prospectus that the Fund may have large shareholders.

Response. The Registrant has deleted
the “Large-Scale Redemption Risk” section.

Comment 14.  The “Management
Risk” section states that the Fund it is subject to the risk that the Adviser’s investment strategy may not produce the intended
results if the Fund will not fully replicate the Russell 2000® Index. Please revise this section to note that the
Fund may not meet its investment objective even if it fully replicates the Russell 2000 Index.

Response. The disclosure has been
revised as follows with additions in bold:

“As the Fund will not fully replicate
the Russell 2000® Index or even it fully replicate the Russell 2000® Index, it is subject
to the risk that the Adviser’s investment strategy may not produce the intended results or achieve the Fund’s objective.”

Comment 15. Please consider
tailoring the “Market and Geopolitical Risk” section to reflect the fact that the Fund will be investing in US. Small cap
securities.

Response. The Registrant respectfully
declines to revise the “Market and Geopolitical Risk” section, as the risk factor pertains to markets generally. The Registrant
notes that a separate risk disclosure exists for Small Capitalization Companies.

Comment 16. Please include
in the Principal Investment Strategies of the Fund a statement that the Fund may invest in mid-cap companies.

Response. The Fund will not be
investing in mid-cap companies and has removed the risk disclosure. requested disclosure has been added.

Comment 17. Please note
that sector risk is not included in the “Fund’s Principal Risks” but included in the “Additional Information About
the Fund’s Principal Risks” section. If sector risk is a principal risk, it should also be included in “Fund’s
Principal Risks” section and, if not, it should be moved from the “Additional Information About the Fund’s Principal
Risks” section to the “Other Risks” section.

Response. Sector risk has been
added to the “Fund’s Principal Risks” section.

Comment 18. Under Portfolio
Managers section, please disclose whether the portfolio managers are “jointly and primarily responsible” for the day to day
management of the Fund. See Item 5 of N-1A.

Response. The requested disclosure
has been added.

Comment 19. In the “Other
Risks” section of the Prospectus, please clarify that these risks are non-principal risks if that is the case.

Response. The requested disclosure
has been added.

STATEMENT OF ADDITIONAL INFORMATION

Comment 20. With respect
to the Investment Restrictions and Policies section in the Statement of Additional Information, please add that the Fund is diversified.
See Section 16(c) of Form N-1A.

Response. The Registrant notes
that the following disclosure is included under “GENERAL DESCRIPTION OF THE TRUST”

“The Fund is a diversified management investment
company under the Investment Company Act of 1940, as amended…”

Comment 21. Please revise
number 7 of the Fund’s fundamental investment restriction re concentration to state that the Fund will consider the portfolio securities
owned by investment companies that the Fund may own in complying with its concentration policy.

Response. The Registrant has added
the following to the end of its fundamental policy number 7:

“To the extent that the Fund invests in
underlying investment companies, the Fund will consider the concentration of the underlying investment companies individual securities
for purposes of determining compliance with its own concentration policy.”

Comment 22. Please include
in the Statement of Additional Information how many times each committee of the Board met in 2023.

Response. The following disclosures
have been added:

“In 2023, the Trust’s Audit Committee
met two times” and “In 2023, the Nominating Committee met one time.”

PART C

Comment 23. In Part C of
the Trust’s Registration Statement, please include indemnification language required by Rule 484 of the Securities Act of 1933,
as amended.

Response. The requested language has
been added.

*        *        *        *        *        *        *

Please contact the undersigned at 202.973.2727 or bibb.strench@thompsonhine.com
with any questions about the responses.

    /s/ Bibb L. Strench

    Bibb L. Strench