SecProbe.io

VIA E-MAIL
September 30, 2024Joshua R. Diggs
Counsel, Fund Business Management GroupCapital Research and Management Company
333 South Hope StreetLos Angeles, CA 90071-1406
Re: Capital Group U.S. Sm all and Mid Cap ETF
File Nos. 333-281924 and 811-24000
Dear Mr. Diggs,
On September 4, 2024, you filed the above-referenced  registration statement on Form N-1A with
respect to Capital Group U.S. Sma ll and Mid Cap ETF (the “Fund”).  We have reviewed the registration
statement and our comments are set forth below.  Where a comment is made with respect to disclosure in one location of the filing, it app lies to all similar disclosures found el sewhere.  Capitalized terms not
otherwise defined have the same mean ing as in the registration statement.
GENERAL 1. Please complete or update all information that is currently in brackets or missing in the registration
statement ( e.g., fee table, expense example, manageme nt, portfolio manage rs, seed financial
statements, auditor's report, consent, information in the statement of additional information, and
exhibits).  We may have additi onal comments on such portions when you complete them in pre-
effective amendments, on disclo sures made in response to this  letter, on information supplied
supplementally, or on exhibits added in any pre-effective amendment.
2. Please confirm the Fund will file  a fidelity bond under Form 40-17G.
3. Please provide the principal trad ing market (exchange) for the Fund.
PROSPECTUSFees and Expenses, page 1
4. Please confirm that there are no fee waiver/reimbursement arrangements.

Mr. Joshua R. Diggs
September 30, 2024
Page 2

5. The prospectus indicates that the Fund may invest in Central Funds (certain  other funds managed by
the investment adviser or its a ffiliates). If acquired fund fees a nd expenses (“AFFEs”) from such
investments will exceed 0.01% of the average net asse ts of the Fund, please disclose these fees and
expenses as a separate line item in the fee table.  See Item 3, Instruction 3(f)(i) of Form N-1A.
Principal Investment Strategies, page 2

6. The first sentence of the first paragraph states that, “Under no rmal market conditions, the fund
invests at least 80% of its net assets in common stocks and other equity-type securities of small and mid-capitalization companies in the United States.”  Please disclose with specificity any other equity investments that the Fund may invest in as the disclosure refers to “other equity-type securities,” and disclose any associated risks.
7. Please disclose what instruments will be held principally as part of the Fund’s 20% basket of
securities.
Principal Risks, pages 3-4
 8. Please consider adding a risk factor  discussing the principal risks asso ciated with investing in a new
fund ( e.g., the fund may have higher expe nses, may not grow to an economically viable size, and
may cease operations and investors may be required to liquidate or transfer their investments at a
loss).

9. If applicable, please consider adding risk factor for investing in grow th-oriented stocks, that growth-
oriented common stocks and other equity type securities (such as  preferred stocks) may involve
larger price swings and greater potential fo r loss than other types of investments.

10. Please disclose the risk that an active trading mark et for shares of the ETF may not develop or be
maintained. Please also note that in times of market stress, market makers or authorized participants may step away from their respective roles in making a market in shares of the ETF and in executing purchase or redemption orders, and that this coul d in turn lead to wider bid/ask spreads and
variances between the market price of the ETF’s shares and the underlying value of those shares.

11. Please disclose that, in stressed market conditions, the market for an  ETF’s shares may become less
liquid in response to deteriorating liquidity in  the markets for the ETF’s underlying portfolio
holdings.  Please also note that this adverse effect on liquidity for the ETF’s shares in turn could lead
to wider bid/ask spreads and differences between the market price of the ETF’s shares and the
underlying value of those shares.
 Investment Objective, Strate gies and Risks, pages 8-15

12. On page 10, the disclosure states, “The investment  adviser may consider en vironmental, social and
governance (“ESG”) factors that, depending on the fact s and circumstances, are material to the value

Mr. Joshua R. Diggs
September 30, 2024
Page 3

of an issuer or instrument. ESG factors may include, but are not limited to, environmental issues
(e.g., water use, emission levels , waste, environmental remedia tion), social issues (e.g., human
capital, health and safety, changing customer  behavior) or governance issues (e.g., board
composition, executive compensation, shareholder dilution).”  (a) Please disclose whether the investment adviser applies the criteria it uses with respect to
environmental, social or governance factors with respect to every investme nt it makes or only to
some of its investments.
(b) Explain whether an investment could be made in a company th at scores poorly on ESG if it
scores strongly on other non-ESG factors.
(c) Consider whether an ESG specific risk disclosure may be a ppropriate or explain supplementally
why such a risk factor is not appropriate.

13. On page 12, under the risk titled, ”Market trading,” the first paragraph discloses that, “While the
fund shares are listed for trading on an exchange, there can be no assurance that an active trading
market for such shares will develop or be maintained by market makers or Authorized Participants, or that the fund’s shares will continue to m eet the requirements for listing or trading on any
exchange or in any market. Trading in shares on the exchange may be halted due to market
conditions or for reasons that, in the view of the exchange make trading in the fund shares
inadvisable.”  Please consider including this desc ription under the risk, “Market Trading,” in the
Principal Risks section as well (pages 3-4).

14. The Fund includes a risk factor titled, “Exposure to  country, region, industry or sector.”  The
disclosure states that the Fund inve sts at least 80% of its net assets in the securities of companies in
the United States.  However, pl ease supplementally confirm that the Fund does not currently
anticipate significant exposure to any specific region, industry or sector  or, alternatively, add
appropriate disclosure to the investment strategy.

15. On page 14, the disclosure includes a risk factor titled, “Cash transactions,”  concerning creations and
redemptions for cash rather than in-kind securities.  Please consider including this risk in the summary prospectus as well.
Financial Highlights Information
 16. Please include a heading and disclosure of the Fund ’s financial highlights stating that the Fund is
newly organized and does not have a ny financial history as of the date  of this prospectus, but that

Mr. Joshua R. Diggs
September 30, 2024
Page 4

financial information will be ava ilable in the Fund’s in subsequent  periodic reports such as annual
and semiannual reports.
 STATEMENT OF ADDITIONAL INFORMATION (“SAI”)  Exchange listing and trading, page 3
 17. The first paragraph on page 3 states, “The fund sh ares may also be liste d on certain foreign (non-
U.S.) exchanges.”  Please confirm whether the cu rrent Fund may be listed on foreign exchanges and
if so, please disclose corresponding risk factors.

Temporary Defensive Position

18. Please include a heading and disclosure of  the Fund’s temporary defensive position.  See Item 16(d)
of Form N-1A.
 Fund Policies, pages 19-20
 19. Regarding the Fund’s concentration policies, plea se note that a fund and its  adviser may not ignore
the investments of affiliated a nd unaffiliated underlying investment  companies when determining
whether the fund is in compliance with its concentr ation policies.  Please confirm that the Fund will
consider the investments of its underlying inve stment companies when determining the Fund’s
compliance with its concentration policies.
 Management of the Trust
 20. In the section regarding the Board of Trustees starting on page 23 of the SAI, key information
regarding the trustees and officers has not yet been  included.  Please provide that information to the
staff for review as soon as practicable.
21. On page 25, in the table under the section, “Fund shares owned by trustees as of [ x]:” footnote 2
references “December 31, 2023.”  Please provide a more recent date and accompanying narrative.
 Financial Statements, Exhibits, and Other Information

22. Any financial statements, exhibits , and other required disclosure not  included in these registration
statements must be filed in a pre-effective amendment to the registration statement.
23. Please include all exhibits that are marked “to be provided by amendment.”

Undertakings
 24. You indicated “n/a.”  Please revise or expl ain in correspondence why an undertaking is not
necessary for this initial registration statement.  See Item 35 of Form N-1A.

Mr. Joshua R. Diggs
September 30, 2024
Page 5

*****
 Responses to this letter should be  made in a letter to me filed on EDGAR and in the form of pre-
effective amendments filed pursuan t to rule 472 under the Securitie s Act. Where no change will be
made in a filing in response to a co mment, please indicate this fact in th e letter to us and briefly state the
basis for your position.  Please advise us if you have sub mitted or expect to submit any exem ptive applications or no-action
requests in connection with your registration statement. The sta ff may have additional comments.
  We remind you that the Fund is responsible for the ac curacy and adequacy of its disclosure in the
registration statements, notwithstandi ng any review, comments, action, or ab sence of action by the staff.
Should you have any questions, pl ease contact me at (202) 880-1783, imtangso@sec.gov , or Jeffrey
Long, Staff Accountant, at (202) 551-6983, LongJW@SEC.GOV.

Sincerely,
               / s /  S o o  I m - T a n g
               S o o  I m - T a n g         A t t o r n e y - A d v i s e r    cc:   Jeffrey W. Long, Staff Accountant   Keith A. OConnell, Branch Chief   Michael J. Spratt, Assistant Director