SecProbe.io

October 23, 2024
VIA E-MAIL
Ali R. Olia, Esq.
Ropes & Gray LLP1211 Avenue of the AmericasNew York, NY 11036
Re: Thornburg ETF Trust
File Nos.  333-282372 and 811-24005
Dear Mr. Olia:
On September 27, 2024, you filed a regist ration statement on Form N-1A for
Thornburg ETF Trust (the “Trust”) to register  shares of Thornburg Core Plus Bond ETF,
Thornburg Flexible Bond ETF, Thornburg Inte rnational Core Equity ETF, and Thornburg
International Growth ETF (each a “Fund” and, collectively, the “Funds”).  Our comments
are set forth below.  For convenience, we generally organized our comments using the
headings, defined terms and page numbers from the registration statement.  Where a
comment is made with respect to the disclosure in one location of the filing, it applies to all similar disclosure found elsewhere.
COVER PAGE
1. Please include ticker symbols on the Cover Page.PROSPECTUS
Thornburg Core Plus Bond ETF - Fund Summary
2. Please provide a completed fee table.
3. Disclosure in the second paragraph on pa ge 4 of the Fund’s principal investment
strategy discusses inve stments denominated in foreign currencies.  Please disclose
under what circumstances the Fund may inve st in foreign issuers or in debt
denominated in foreign currencies.
4. The disclosure on page 4 defines "net a ssets" to include "any borrowings made by the
Fund for investment purposes".  Please revise this disclosure, as well as the disclosure
regarding the Fund's 80% policy, to conform to the definition of "assets" under rule
35d-1(g).  Specifically, please revise the 80% policy to reference "net assets, plus the
amount of borrowings for investment purposes" and revise the definition of "net assets"
to exclude borrowings for investment purposes.
5. The disclosure on page 4 states that  Thornburg Investment  Management, Inc.
(“Thornburg” or the “Adviser”) "will genera lly seek to construct a portfolio of
investments with a dollar-weighted average dur ation that falls within two years of the

Ali R. Olia, Esq.
October 23, 2024
Page 2
  Page 2 of 9  dollar-weighted average duration of the F und's benchmark index, the Bloomberg US
Aggregate Bond Index".  Please disclose  under what circumstances the Fund will
deviate more than 2 years from the dura tion of the Bloomberg US Aggregate Bond
Index.
6. The disclosure on page 5 states that Thornbur g expects to allocate investments across
various fixed income sectors in response to  "changing market, fi nancial, economic, and
other factors and events that the Fund's por tfolio managers belie ve may affect the
values of the Fund's investments".  Please more specifically disc lose how Thornburg is
considering and defining "changing market, fi nancial, economic, and other factors and
events".
7. Please more specifically disclose how  Thornburg is evaluating domestic and
international economic  developments and outlooks for securities markets which is
referenced in the second paragraph on page 5.
8. The principal investment strate gy section states that the Fund will invest in bank loans,
loan assignments, loan participants and similar obligations.  Please include applicable risk disclosure in the principal risk section.
9. The principal investment strate gy section states that the Fund will invest in obligations
issued or guaranteed by U.S. and non-U. S. governments and their agencies or
instrumentalities.  Please include applicable risk disclosure in  the principal risk section.
10. Please confirm whether securities underlyi ng the Fund are traded outside of a
collateralized settlement system. If so, please disclose in the principal risk section that there are a limited number of financial institutions that may act as authorized participants that post collateral for certain trades on an agency basis ( i.e., on behalf of
other market participants). Please also disclose that, to the extent that those authorized participants exit the business or are unable to  process creation and/or redemption orders
and no other authorized participant is able to step forward to do so, there may be a
significantly diminished trading market for the Fund’s shares. In addition, please note
that this could in turn lead to differences between the market price of the Fund’s shares
and the underlying value of those shares.
11. The principal investment stra tegy section states that the Fund will invest in emerging
markets.  Please include applicable risk di sclosure in the principal risk section.
12. Please disclose in the principal risk sec tion 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 unde rlying 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.
13. Please supplementally identify the broad-ba sed index against which performance will
be measured.  See Instruction 2 to Item 4 of Form N-1A.

Ali R. Olia, Esq.
October 23, 2024
Page 3
  Page 3 of 9  Thornburg Flexible Bond ETF – Fund  Summary
14. Disclosure in the first paragraph on page 11 states that the Fund will make investments
“from throughout the world”.  Please describe  how the Fund will invest its assets in
investments that are tied to a numbe r of countries throughout the world.
15. The principal investment stra tegy section states that the Fund will invest in emerging
markets, bank loans, loan assignments, loan participants and similar obligations, zero coupon bonds and “stripped” s ecurities, and convertible debt obligations.  Please
include applicable risk disclosure  in the principal risk section.
Thornburg International Core Equity ETF – Fund Summary
16. The Fund’s name includes the term “interna tional”. Please expressly describe how the
Fund is defining "international". The Fund should describe the specific criteria the
Fund uses to determine that an inves tment is tied to a country or region.
17. The Fund's 80% policy refers to investments that provide "exposure to them".  Please
specifically define "them" in the 80% policy.
18. Please disclose how the Fund is defining "unfavorable market perceptions" of
companies on page 18.
19. Please disclose how the Fund is defi ning "promising companies" on page 18.
20. Will the Fund principally invest in small a nd mid-cap companies?  If yes, please
disclose in the principal investment strategy and principal risk sections.
21. Please disclose how the Fund is defining "bottom-up fundamental analysis" on page
18.
22. The principal investment stra tegy section states that the Fund will invest in depositary
receipts and derivatives.  Please include applicable risk disclosure in the principal risk section.
Thornburg International Growth ETF – Fund Summary
23. The Fund’s name includes the term “interna tional”. Please expressly describe how the
Fund is defining "international". The Fund should describe the specific criteria the
Fund uses to determine that an inves tment is tied to a country or region.
24. The disclosure on page 23 states that th e Thornburg International Growth ETF expects
to "invest primarily" in equ ity securities or depositary receipts of non-US developed
market issuers..."
a. Please disclose how the Fund is defining "primarily".  We ma y have additional
comments.
b. Please also disclose how the Fund is  defining "non-US developed market
issuers".

Ali R. Olia, Esq.
October 23, 2024
Page 4
  Page 4 of 9  25. The principal investment stra tegy section states that the Fund will invest in companies
that have “growth characteristics”.  Please include applicable risk disclosure in the
principal risk section.
26. The principal investment stra tegy section states that the Fund will invest in non-U.S.
developed market issuers, depositary re ceipts, emerging growth markets, and
derivatives.  Please include a pplicable risk disclosure in  the principal risk section.
27. The disclosure on page 23 describes a "focused portfolio" as one limited to investing in
up to 50 issuers across diversified countries a nd sectors.  However, the principal risk
disclosure regarding "focused investment ri sk" refers to investing in a particular
market, industry, sector, or country rather  than a limited number of issuers.  Please
reconcile.
28. Please disclose the Fund’s concentra tion policy in Item 4 disclosure.
Additional Information – Item 9
29. Per the requirements of Form N-1A, risks disclosed as principal risks in Item 9
disclosure should, likewise, be listed in the prospectus’ Item 4 disclosure.  The same
applies to principal strategy disclosure ( i.e., where a risk is listed as a principal risk, it
should correspondingly be disclosed in principa l strategy disclosure, as to both Items 4
and 9).  Please revise Items 4 and 9 accordingly.
30. The disclosure on page 27 under Item 9 stat es the following: "[p] lease note that each
fund may also use strategies and invest in securities that are not described in this
Prospectus, but that are described in the Statement of Additional Information (the
'SAI')".  Please revise this di sclosure to clarify that the pr incipal strategies of the Funds
are reflected in the Prospectus.  See Items 4(a) and 9(b) of Form N-1A.
31. The first paragraph under the heading, "I nvesting in Stocks and Other Equity
Securities" identifies various types of equity investments.  If such equity investments are part of the principal inve stment strategies for the Funds, then please ensure all
equity securities listed are included in each Fund’s' principal investment strategy sections under Item 4.  The equity inves tments identified in th is paragraph do not
appear to align with the equity securities disclosed in each Fund’s Item 4 disclosure
regarding their principal investment strategies.
32. There is a reference to the "International E quity ETF" in the third, fourth and fifth
paragraphs under "Investing in  Stocks and Other Equity Securities" starting on page
27, and multiple places later in the disclosu re.  However, the “International Equity
ETF” is not located in the prospectus.  Please revise throughout the document to
reference the appropriate Fund.
33. The disclosure on page 27 in the fifth paragr aph states that the International Equity and
International Growth ETFs may invest in securities that exhibit the characteristics of "predictable growth; predictable profitability; predictable cash flow; or predictable levels of dividends".  Pleas e disclose how the Funds are defining "predictable" and
supplementally explain how use of the term “predictable” is not misleading.

Ali R. Olia, Esq.
October 23, 2024
Page 5
  Page 5 of 9  34. Disclosure on page 27 in the sixth paragraph states that the International Equity ETF
and International Growth ETF ma y invest in issuers that ope rate in industries which are
newer than issuers in "the other two categor ies discussed above".  Please clarify what
the "other two categories" is refe rring to throughout this paragraph.
35. Under the heading “General Risks of Equ ity Securities” on page 28, the disclosure
indicates that the Fund may "invest in a co mpany's equity secur ities through an initial
public offering ("IPO").  Please disclose such investments in the Fund’s Item 4
principal strategy secti on and principal risk se ctions, as applicable.
36. Under the heading “Risks of Investing in Publicly Traded Real Estate Investment
Trusts (“REITs”)” on page 30, the disclosure  indicates that the Fund may invest in
REITs. Please disclose such investments in the Fund’s Item 4 principal strategy section
and principal risk sec tions, as applicable.
37. Under the heading “Developing Country Ri sks” on pages 34-35, the disclosure
indicates that the Fund may invest in de veloping countries. The disclosure also
includes separate risk disclo sure about investments in Ch ina.  Please disclose such
investments in the Fund’s Item 4 principal st rategy section and prin cipal risk sections,
as applicable.
38. Disclosure under the heading “Developing C ountries Risk” contains inconsistent
descriptions regarding how Thornburg is de fining developing countri es.  For example,
the disclosure states that Thornburg consid ers developing countries to include most
Asian nations.  However, Thornburg also cons iders whether the issuer is a developing
country if the country is included in the MSCI Emerging Markets Index, and there is
separate disclosure indicati ng that Thornburg designates a number of countries outside
of Asia as developing countries.  Please clarify and reconcile.
39. Under the heading “Risks of Debt Issued  by Foreign Governments” on page 35, the
disclosure indicates that the Fund may invest  “in debt issued by foreign governments”.
Please disclose such investments in the F und’s Item 4 principal strategy section and
principal risk sections, as applicable.
40. The disclosure on pages 36-37 indicates th at the Fund may invest in municipal
obligations and municipal leases. Please disclo se such investments in the Fund’s Item 4
principal strategy secti on and principal risk se ctions, as applicable.
41. The disclosure on page 39 indicates that  the Fund may invest in REMICs.  Please
disclose such investments in the Fund’s Item  4 principal strategy section and principal
risk sections, as applicable.
42. The disclosure on page 40 indicates th at the Fund may enga ge in short selling.
a. Please disclose any short-se lling strategy in the Fund’s Item 4 principal strategy
section and principal risk sections, as applicable.
b. Please also include fees associated with short selling in the fee table.
43.  The disclosure on page 42 indicates that the Fund may invest in other investment
companies.

Ali R. Olia, Esq.
October 23, 2024
Page 6
  Page 6 of 9  a. Please disclose such investments in the Fund’s Item 4 principal strategy section
and principal risk sec tions, as applicable.
b. If the fees and expenses incurred indirectly by the Fund as a result of
investments in shares of one or more acquired funds exceed one basis point of
average net assets of the Fund, then please disclose in the fee table.
44. Please disclose, if applicable, that the Fund may, from time to time, take temporary
defensive positions that are inconsistent with  the Fund's principal i nvestment strategies,
as well as the effects of taking such temporary defensive positions. See Form N-1A,
Item 9(b)(1), Instruction 6.
45. Section 11.2 of the Declaration of Trust includes an exclusive forum provision for
shareholder claims to be brought in state and federal courts in  the Commonwealth of
Massachusetts.
a. Please disclose in an appropriate locati on in the Prospectus this provision and
corresponding risks of such a provision ( e.g., that shareholders may have to
bring suit in an inconvenient and less favorable forum).  We note that such
disclosure is currently located in the Statement of Additional Information (“SAI”).
b. Please also disclose in an appropriate location in the Prospectus that there is a
question regarding the enforceability of this provision since the Securities Act of 1933 (“Securities Act”) and Inves tment Company Act of 1940 (“1940 Act”)
permit shareholders to bring claims arising from these Acts in both state and federal courts.
STATEMENT OF ADDITIONAL INFORMATION
General Information About the Trust
46. On page 3, in the eighth paragraph, please mo re specifically disclose that there is a
question regarding the enforceability of the exclusive forum provision in the Declaration of Trust since the Securities Ac t and l940 Act permit sh areholders to bring
claims arising from these Acts in both state and federal courts.
47. Please revise the heading “Temporary Investme nts” on page 28. An investment is made
pursuant to a principal strategy, non-principa l, or as a temporary defensive position
strategy.  See Item 16 of Form N-1A.
Investment Limitations
48. Investment Limitation 4 re