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    ROPES & GRAY LLP

                                                                                PRUDENTIAL TOWER

                                                                                800 BOYLSTON STREET

                                                                                BOSTON, MA 02199-3600

                                                                                WWW.ROPESGRAY.COM

    December
    6, 2024
    Ali
R. Olia

        T
+1 617 951 7204

        ali.olia@ropesgray.com

Via
EDGAR

Securities
and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attn: Ashley Vroman-Lee

 Re: Thornburg
                                         ETF Trust (the “Trust” or “Registrant”)

                                         File Nos. 333-282372 and 811-24005

Dear
Ms. Vroman-Lee:

This
letter is being filed to respond to the comments received from you in writing on October 23, 2024 regarding the Trust’s
initial registration statement on Form N-1A (the “Registration Statement”) relating to Thornburg Core Plus Bond ETF,
Thornburg Flexible Bond ETF, Thornburg International Core Equity ETF and Thornburg International Growth ETF (each a “Fund”
and, collectively, the “Funds”), which was filed with the Securities and Exchange Commission (the “Commission”)
on September 27, 2024. The Staff’s comments, together with the Trust’s responses thereto, are set forth below. Capitalized
terms not defined in this letter have the same meaning as in the Trust’s Registration Statement.

COVER
PAGE

 1. Comment:
                                         Please include ticker symbols on the Cover Page.

Response:
The Registrant confirms that a ticker symbol for each Fund will be included on the Cover Page in a pre-effective amendment
to the Registration Statement.

PROSPECTUS

THORNBURG
CORE PLUS BOND ETF – FUND SUMMARY

 2. Comment:
                                         Please provide a completed fee table.

Response:
The Registrant confirms that a completed fee table for each Fund will be included in a pre-effective amendment to the Registration
Statement.

Securities and Exchange Commission - 2 - December 6, 2024

 3. Comment:
                                         Disclosure in the second paragraph on page 4 of the Fund’s principal investment
                                         strategy discusses investments denominated in foreign currencies. Please disclose under
                                         what circumstances the Fund may invest in foreign issuers or in debt denominated in foreign
                                         currencies.

Response:
The Registrant has revised the disclosure referenced in the Staff’s comment as follows:

The
Fund may invest in obligations of foreign or domestic issuers, but expects to invest primarily in obligations of domestic issuers
under normal circumstances. The Fund may invest in debt obligations denominated in foreign currencies,
but expects to invest principally in obligations denominated in U.S. dollars. The
Fund may invest in foreign issuers and debt obligations denominated in foreign currencies, as described herein, when the portfolio
management team believes conditions for such debt are favorable relative to similar obligations denominated in U.S. dollars.
The Fund may not, at the time of purchase, invest more than 25% of its net assets in debt obligations denominated in foreign currencies,
but this limitation does not apply to debt obligations issued by foreign issuers and denominated in U.S. dollars. The Fund does
not expect to invest, at the time of purchase, more than 15% of its net assets in debt obligations issued by issuers in emerging
markets, also known as developing countries.

 4. Comment:
                                         The disclosure on page 4 defines “net assets” 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.

Response:
The Registrant has revised the Fund’s 80% policy as shown below and deleted the disclosure on page 4 referenced in the
Staff’s comment.

Under
normal conditions, the Fund invests at least 80% of its net assets, plus the amount of any borrowings
for investment purposes, in debt obligations or investments that provide exposure to such debt obligations.

The
Registrant has made these changes with respect to Thornburg Flexible Bond ETF and Thornburg International Core Equity ETF as well.

Securities and Exchange Commission - 3 - December 6, 2024

 5. Comment:
                                         The disclosure on page 4 states that Thornburg Investment Management, Inc. (“Thornburg”
                                         or the “Adviser”) “will generally seek to construct a portfolio of investments
                                         with a dollar-weighted average duration that falls within two years of the dollar-weighted
                                         average duration of the Fund’s benchmark index, the Bloomberg US Aggregate Bond Index”.
                                         Please disclose under what circumstances the Fund will deviate more than 2 years from
                                         the duration of the Bloomberg US Aggregate Bond Index.

Response:
The Registrant has revised the disclosure referenced in the Staff’s comment as follows:

There
is no limitation on the duration or maturity of any specific debt obligation the Fund may purchase. While Thornburg has broad
discretion to modify the Fund’s duration within a wide range in the Adviser’s discretion
and based on its view of market conditions, Thornburg will generally seek to construct a portfolio of investments with
a dollar-weighted average duration that falls within two years of the dollar-weighted average duration of the Fund’s benchmark
index, the Bloomberg U.S. Aggregate Bond Index. The duration of the Fund’s portfolio may vary significantly from time to
time due to changes in overall market conditions, including changes in the rate of pre-payment
speeds, among other reasons, and may be outside the stated range at any time. Duration is a measure of estimated sensitivity
to interest rate changes, and a debt obligation or a portfolio of obligations with a higher duration will typically be more sensitive
to interest rate changes than an obligation or a portfolio with a lower duration. Duration is commonly expressed as a number,
which is the expected percentage change in an obligation’s price upon a 1% change in interest rates. For example, an obligation
with a duration of 0.5 would be expected to change in price by approximately 0.5% in response to a 1% change in interest rates.

The
Registrant has made these changes with respect to Thornburg Flexible Bond ETF as well.

Securities and Exchange Commission - 4 - December 6, 2024

 6. Comment:
                                         The disclosure on page 5 states that Thornburg expects to allocate investments across
                                         various fixed income sectors in response to “changing market, financial, economic,
                                         and other factors and events that the Fund’s portfolio managers believe may affect the
                                         values of the Fund’s investments”. Please more specifically disclose how Thornburg
                                         is considering and defining “changing market, financial, economic, and other factors
                                         and events”.

Response:
The Registrant has revised the disclosure referenced in the Staff’s comment as follows:

Thornburg
seeks to achieve the Fund’s investment objective by allocating actively among various market sectors in the fixed income
markets, such as those listed above, and through security selection within the selected market sectors. Thornburg
allocates the Fund’s assets among a range of sectors based on strategic positioning and other tactical considerations.
In buying and selling investments for the Fund, Thornburg looks for market sectors and securities that it believes will
have more favorable relative performance over time. Thornburg expects to allocate
the Fund’s assets across various fixed income market sectors in response to changing market, financial, economic, and other
factors and events that the Fund’s portfolio managers believe may affect the values of the Fund’s investments. The
Fund may invest significantly in one or more sectors, and may at times invest primarily in a single sector, such as asset-backed
securities or mortgage-backed securities of private issuers.

The
Registrant has made these changes with respect to Thornburg Flexible Bond ETF as well.

 7. Comment:
                                         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.

Response:
The Registrant has revised the disclosure referenced in the Staff’s comment as follows:

Each
of the Fund’s investments is determined by individual issuer and industry analysis, including Thornburg’s evaluation,
based on, among other things, proprietary or third-party analysis and reports, of domestic and international economic
developments, outlooks for securities markets, interest rates and inflation, and the supply and demand for debt obligations.

 8. Comment:
                                         The principal investment strategy 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.

Response:
The Registrant has added the following disclosure to the Principal Risks section:

Risks
of Bank Loans, Loan Assignments, Loan Participations and Similar Obligations. The Fund may invest in bank loans, loan assignments
and loan participations and similar obligations. These obligations are subject to unique risks, including (i) the possible avoidance
of an investment transaction as a “preferential transfer,” “fraudulent conveyance” or “fraudulent transfer,”
among other avoidance actions, under relevant bankruptcy, insolvency and/or creditors’ rights laws; (ii) so-called “lender
liability” claims by the issuer of the obligations; (iii) environmental liabilities that may arise with respect to collateral
securing the obligations; (iv) limitations on the ability of the Fund to directly enforce its rights with respect to participations;
and (v) the contractual nature of participations where the Fund takes on the credit risk of the agent bank rather than the actual
borrower. In addition, because bank loans are not typically registered under the federal securities laws like stocks and bonds,
investors in loans have less protection against improper practices than investors in registered securities.

Securities and Exchange Commission - 5 - December 6, 2024

The
Registrant has made this change with respect to Thornburg Flexible Bond ETF as well.

 9. Comment:
                                         The principal investment strategy 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.

Response:
The Registrant has added the following disclosure to the Principal Risks section:

Risks
of Investing in U.S. Government Obligations. U.S. government obligations are subject to the same risks affecting other debt
obligations. Although securities backed by the full faith credit of the U.S. government are commonly regarded as having relatively
less risk of default, it is possible that the U.S. government may be unwilling or unable to repay principal and interest when
due, and may require that the terms for payment be renegotiated. Further obligations that are backed by the full faith and credit
of the U.S. government remain subject to the other general risks applicable to debt obligations, such as market risks, liquidity
risks, and interest rate risks, and may be subject to ratings downgrades. U.S. government obligations also include obligations
of U.S. government agencies, instrumentalities, and government-sponsored enterprises, commonly referred to as “agency obligations.”
Some agency obligations are backed by the full faith and credit of the U.S. government, but other agency obligations have no specific
backing or only limited support from the agency’s authority to borrow from the U.S. government or the discretionary authority
of the Treasury to purchase obligations of the issuing agency.

Securities and Exchange Commission - 6 - December 6, 2024

Risks
of Debt Issued by Foreign Governments. Debt obligations may be issued by foreign governments and their agencies and instrumentalities,
including the governments of developing countries and “supra-national” entities such as the International Bank for
Reconstruction and Development. The Fund’s investments in these foreign debt obligations may be denominated in U.S. dollars
or in foreign currencies. These securities, even if denominated in U.S. dollars, may be affected significantly by fluctuations
in the value of foreign currencies, and the value of these securities in U.S. dollars may decline even if the securities increase
in value in their home country. The governmental issuers of these debt obligations may be less willing or able than the U.S. to
repay principal and interest when due, and may require that the terms for payment be renegotiated. In some countries there may
be political instability or insufficient government supervision of markets, and the legal protections for the Fund’s investments
could be subject to unfavorable judicial or administrative changes. These risks may be more pronounced for the Fund’s investments
in debt obligations issued by developing countries.

The
Registrant has made these changes with respect to Thornburg Flexible Bond ETF as well.

 10. Comment:
                                         Please confirm whether securities underlying 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 be