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CORRESP
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Lauren A. Engel

Associate

215.963.5503

July 23, 2024

FILED AS EDGAR CORRESPONDENCE

Ms. Ellie Quarles

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

 Re: Response letter to comments on Post-Effective
                                            Amendment No. 3 to the Registration Statement of SEI Exchange Traded Funds (File Nos.
                                            333-260611 and 811-23754)

Dear Ms. Quarles:

On behalf of our
client, SEI Exchange Traded Funds (the “Trust” or “SETF”), this letter responds to the comments and questions
you provided via telephone on June 27, 2024, regarding the Trust’s Post-Effective Amendment No. 3, under the Securities
Act of 1933, as amended (the “1933 Act”), and Amendment No. 5, under the Investment Company Act of 1940, as amended
(the “1940 Act”), to its Registration Statement filed with the SEC on May 15, 2024 pursuant to Rule 485(a)(2) under
the 1933 Act (the “Amendment”), for the purpose of adding three new funds, the SEI Select Small Cap ETF, SEI Select International
Equity ETF and SEI Select Emerging Markets Equity ETF (each, a “Fund,” and together, the “Funds”). Below, we
have briefly summarized your comments and questions, followed by our responses. Capitalized terms not defined herein should be given
the meaning provided in the Amendment.

Prospectus:

 1. Comment.         Where
                                            a comment is made with regard to disclosure in one location, it is applicable to all similar
                                            disclosure appearing elsewhere in the Registration Statement. Please make conforming changes
                                            as necessary.

Response.         The
Trust acknowledges the Staff’s comment and has made conforming changes throughout the Registration Statement, as applicable.

 2. Comment.         Please
                                            update the ticker symbols on EDGAR once available.

Response.         The
Trust confirms that the ticker symbols will be updated on EDGAR once available.

 3. Comment.          Please
                                            supplementally provide a completed fee table and expense examples for each Fund. Please file
                                            this on EDGAR with the response letter or separately.

Response.         The
completed fee tables and expenses examples are as follows:

    Ms. Ellie Quarles, Esq.
 July 23, 2024
 Page 2

SEI
Select Small Cap ETF

    Management Fees1
    0.55%

    Distribution and/or Service (12b-1) Fees
    None

    Other Expenses1,2
    0.00%

    Total Annual Fund Operating Expenses
    0.55%

1  
    The investment advisory agreement between SEI Exchange Traded Funds (the Trust) and SEI Investments
Management Corporation (SIMC), the Fund’s adviser (the Investment Advisory Agreement) provides that SIMC will pay
all operating expenses of the Fund, except the management fees, interest expenses, dividend and other expenses on securities sold short,
taxes, expenses incurred with respect to the acquisition and disposition of portfolio securities and the execution of portfolio transactions
(including brokerage commissions), acquired fund fees and expenses, distribution fees or expenses paid by the Trust under any distribution
plan adopted pursuant to Rule 12b-1 under the 1940 Act (if any), fees and expenses of the Board of Trustees, litigation expenses
and any extraordinary expenses.

2     Other Expenses are based
on estimated amounts for the current fiscal year and rounded to 0.00%.

    1 Year
    $56

    3 Years
    $176

SEI
Select International Equity ETF

    Management Fees1
    0.50%

    Distribution and/or Service (12b-1) Fees
    None

    Other Expenses1,2
    0.00%

    Total Annual Fund Operating Expenses
    0.50%

1    
The investment advisory agreement between SEI Exchange Traded Funds (the Trust) and SEI Investments Management Corporation
(SIMC), the Fund’s adviser (the Investment Advisory Agreement) provides that SIMC will pay all operating expenses
of the Fund, except the management fees, interest expenses, dividend and other expenses on securities sold short, taxes, expenses incurred
with respect to the acquisition and disposition of portfolio securities and the execution of portfolio transactions (including brokerage
commissions), acquired fund fees and expenses, distribution fees or expenses paid by the Trust under any distribution plan adopted pursuant
to Rule 12b-1 under the 1940 Act (if any), fees and expenses of the Board of Trustees, litigation expenses and any extraordinary
expenses.

2     Other Expenses are based
on estimated amounts for the current fiscal year and rounded to 0.00%.

    1 Year
    $51

    3 Years
    $160

    Ms. Ellie Quarles, Esq.
 July 23, 2024
 Page 3

SEI
Select Emerging Markets Equity ETF

    Management Fees1
    0.60%

    Distribution and/or Service (12b-1) Fees
    None

    Other Expenses1,2
    0.00%

    Total Annual Fund Operating Expenses
    0.60%

1
    The investment advisory agreement between SEI Exchange Traded Funds (the Trust) and SEI Investments Management Corporation
(SIMC), the Fund’s adviser (the Investment Advisory Agreement) provides that SIMC will pay all operating expenses
of the Fund, except the management fees, interest expenses, dividend and other expenses on securities sold short, taxes, expenses incurred
with respect to the acquisition and disposition of portfolio securities and the execution of portfolio transactions (including brokerage
commissions), acquired fund fees and expenses, distribution fees or expenses paid by the Trust under any distribution plan adopted pursuant
to Rule 12b-1 under the 1940 Act (if any), fees and expenses of the Board of Trustees, litigation expenses and any extraordinary
expenses.

2    Other Expenses are based
on estimated amounts for the current fiscal year and rounded to 0.00%.

    1 Year
    $61

    3 Years
    $192

 4. Comment.     In
                                            the “Principal Investment Strategies” section of the SEI Select Small Cap ETF,
                                            please consider clarifying that investments in mid-capitalization companies do not qualify
                                            as investments for purposes of the Fund’s 80% policy and instead fall into the 20%
                                            bucket.

Response.          In
response to the Staff’s comment, we have revised the disclosure to state (new text is bold and underlined): “The
Fund may also invest in securities of mid capitalization companies, which will not be considered “small companies”
to the extent they fall outside the market capitalization range of the Index.”

 5. Comment.     In
                                            the “Principal Investment Strategies” section of the SEI Select Small Cap ETF,
                                            please disclose whether the Fund will have principal investments in equity securities other
                                            than common stock. If so, please discuss the other types of equity securities and provide
                                            related risk disclosure.

Response.          The
Trust confirms that the Fund currently expects to only principally invest in common stock.

 6. Comment.     In
                                            the “Principal Investment Strategies” section of the SEI Select Small Cap ETF,
                                            please clarify whether the Russell 2000 Index will be used solely as a reference for the
                                            size of the companies that the Fund may invest in or whether the Fund’s investments
                                            will be limited to those companies included in the Russell 2000 Index.

Response.          In
response to the Staff’s comment, we have revised the disclosure to state (new text is bold and underlined): “The
market capitalization range and the composition of the Index are subject to change, and the Fund is not limited to
investing only in companies within the Index.”

    Ms. Ellie Quarles, Esq.
 July 23, 2024
 Page 4

 7. Comment.     In
                                            the “Principal Investment Strategies” section of the SEI Select Small Cap ETF,
                                            please update the market capitalization information as of the most recent date practicable
                                            and provide market capitalization data for mid-capitalization companies.

Response.          In
response to the Staff’s comment, the market capitalization information has been updated as of June 30, 2024. However, we
have determined to not add market capitalization data for mid-capitalization companies because: (i) investors can discern a
general definition by negative inference from the definition of “small companies” included in the disclosure,
(ii) mid capitalization companies will only be, at most, 20% of the ETF’s portfolio under normal circumstances,
(iii) including multiple capitalization ranges within the principal investment strategies could be confusing to investors, and
(iv) adding a second capitalization range would require additional ongoing monitoring for disclosure updates and potentially
require new or expanded licensing arrangements with an index provider, which would increase costs ultimately borne by
shareholders.

 8. Comment.     In
                                            each Fund’s “Principal Risks” section, please delete the following statement:
                                            “[t]he order of the below risk factors does not indicate the significance of any particular
                                            risk factor.” And reorder the risks to prioritize the risks that are most likely to
                                            adversely affect the Fund’s NAV, yield and total return. (see the SEC’s
                                            Accounting and Disclosure Information Guidance 2019-08).

Response.          In
response to the Staff’s comment, the statement has been removed and the risks have been confirmed to be ordered by priority.

 9. Comment.     In
                                            the Investment Advisers and Portfolio Managers table and the Sub-Advisers and Portfolio Managers
                                            table for each Fund, please update the “Experience with the Fund” column to provide
                                            the month and year of the Fund’s inception.

Response.          The
requested change has been made.

 10. Comment.     In
                                            the “Principal Risks” section of the SEI Select International Equity ETF, please
                                            consider including Liquidity Risk.

Response.          In
response to the Staff’s comment, we have added Liquidity Risk to the Fund’s “Principal Risks” disclosure.

 11. Comment.     Please
                                            supplementally identify the broad-based securities market index expected to be used by each
                                            of the Funds in the average annual total returns table.

Response.          Each
of the Funds currently expects to use the index listed in the table below as the broad-based securities market index in the average annual
total returns table. We note that these index selections are subject to change.

Fund
Broad-Based Securities Market Index

SEI Select Small Cap ETF
S&P 500 Index

SEI Select International Equity ETF
MSCI ACWI ex-USA Index (Net)

SEI Select Emerging Markets Equity ETF
MSCI ACWI ex-USA Index (Net)

    Ms. Ellie Quarles, Esq.
 July 23, 2024
 Page 5

 12. Comment.     The
                                            “Principal Investment Strategies” for the SEI Select Emerging Markets Equity
                                            ETF states that “it is expected that China will generally constitute a significant
                                            exposure in the Fund.” Please add to the corresponding country specific risk disclosure
                                            from the risk disclosure in Item 9 and provide additional disclosure, such as disclosure
                                            about investment types or other considerations relevant to these investments (e.g., risks
                                            related to China A-Shares, Stock Connect, shares or American depository receipts (“ADRs”)
                                            that are subject to the Holding Foreign Companies Accountable Act (“HFCAA”) or
                                            others). Please also add corresponding principal strategy disclosure regarding the types
                                            of investments in China that the Fund intends to make.

Response.          In
response to the Staff’s comment, we have enhanced the Fund’s risk disclosure to include further discussion of risks related
to investments in Chinese companies.

 13. Comment.     In
                                            the “More Information About the Funds” section, please disclose whether each
                                            Fund’s 80% policy may be changed without shareholder approval upon 60 days’ prior
                                            written notice to shareholders.

Response.          In
response to your comment, the Trust has added disclosure stating that each Fund’s 80% policy is non-fundamental and may be changed
by the Board of Trustees without shareholder approval upon 60 days’ notice to shareholders.

 14. Comment.     In
                                            the “More Information About the Funds” section, please disclose whether each
                                            of the Funds may engage in active and frequent trading of portfolio securities to achieve
                                            its principal investment strategies. If so, please disclose the associated tax consequences
                                            of the increased portfolio turnover rate and how the tax consequences of, or trading costs
                                            associated with, a Fund’s portfolio turnover may affect the Fund’s performance.
                                            (see Instruction 7 to Item 9(b)(1) of Form N-1A).

Response.          Particularly
in light of the in-kind creation and redemption basket transactions that will permit the Fund to adjust its portfolio without incurring
transaction costs or tax, the Trust confirms that the Funds do not plan to engage in active and frequent trading of portfolio securities
to achieve its principal investment strategies. Accordingly, we have not made any changes to the disclosure in this regard.

 15. Comment.     In
                                            the final paragraph under “Models and Optimizer,” please discuss how the Sub-Advisers’
                                            recommendations are taken into consideration using this approach.

Response.          The
requested change has been made.

 16. Comment.     Please
                                            revise the Current Market Conditions Risk in the “More Information About Principal
                                            Risks” section to update expectations for the Federal Reserve and certain foreign central
                                            banks with respect to plans to continue to raise rates.

Response.          The
requested change has been made.

 17. Comment.     Please
                                            clarify that the Currency Risk, Depositary Receipts Risk and Foreign Investment/Emerging