SecProbe.io

May 5, 2025
VIA E-mail
John Marten
Vedder Price P.C.
222 North Lasalle Street
Chicago, IL 60601jmarten@vedderprice.com
Re: Crossmark ETF Trust
File Nos. 333-286254, 811-24070
Dear Mr. Marten:
On March 31, 2025, you filed a regist ration statement on Form N-1A on behalf of
Crossmark ETF Trust (the “ Fund ”). We have reviewed the registration statement and have
provided our comments below.  Where a comment is made with regard to disclosure in one
location, it is applicable to all similar disclo sure appearing elsewhere in the registration
statement.  All capitalized terms not otherwise defi ned herein have the meaning given to them in
the registration statement.
GENERAL
1. Given the substantial similarities of the di sclosure for Crossmark Large Cap Growth
ETF and Crossmark Large Cap Value ETF (each, a “Fund, ” a together, “Funds”) we do
not repeat non-unique comments.  Therefore, you may assume that a comment pertaining to one Fund applies equally to both Funds, unless otherwise noted.
2. We note that material portions of the filing are incomplete at this time ( e.g., fee table,
expense example, distributor, Fund website UR L, exhibits, etc.).  Please complete or
update all information that is currently in brackets or missing in the registration
statement, including exhibits, or tell us why you are unable to do so and when you
expect to have this information. We may have additional comments on such portions when you complete them in pre-effective a mendments, on disclosures made in response
to this letter, on information supplied supple mentally, or on exhibits added in any pre-
effective amendment.

John Marten
Crossmark ETF Trust  Page 2

3. Please inform the staff if a party other than the Fund s’ sponsor or an affiliate is
providing the Funds with initial seed capital.  If so, supplementally identify the party
providing the seed capital and describe its relationship with the Funds.
        PROSPECTUS

CROSSMARK LARGE CAP GROWTH ETF
Fees and Expenses of the Fund, page 1

4. Please revise the Example below the Fee Ta ble to conform to the specific language of
Item 3 of Form N-1A.
Principal Investment Strategies
Value-based Screens , page 2

5. We note that the Fund will rely on data and ratings generated by multiple third-party
providers to implement the Fund ’s value-based screening. Please identify the primary
providers the Fund intends to use, if known.
6. Please also describe the Fund ’s due diligence practices in applying its values-based
screening criteria to portfolio companies —for example, directly engaging with
portfolio companies to better understand their relationship and activities with respect to
the categories of excluded activities, and the Fund ’s ongoing monitoring practices to
identify the need for divestment of securities that are later determined not to meet the screening criteria.
ADDITIONAL FUND DETAILS
Investment Objectives, Stra tegies and Risks, page 15

7. Please provide Item 9(b) disclosure with resp ect to principal investment strategies.
Please note that Item 9 should provide more detailed disclosure than Item 4. See IMGU
2014-08, available at https://www.sec.gov/investment/im-guidance-2014-08.pdf .  In
addition, Item 9 should not merely repeat Item 4 disclosure.
Exclusive Forum for Litigation, page 16

8. Please disclose that this provision does not apply to claims arising under the federal
securities laws.  In addition, please revise the provision in the Declaration of Trust to
state that the provision does not apply to claims arising under the federal securities
laws.

John Marten
Crossmark ETF Trust  Page 3

STATEMENT OF ADDITIONAL INFORMATION
INVESTMENT POLICIES AND LIMITATIONS

Investment Restrictions
Fundamental Investment Restr ictions of the Funds, page 11

9. With respect to item 3, please add “or group of industries” after the words “in a
particular industry” in this section per section 8(b)(1) of the  Investment Company Act
of 1940 and Item 16 of Form N-1A.
APPENDIX A
CROSSMARK GLOBAL INVESTMENTS, INC.
Proxy Voting Policy

10. The Funds should disclose, where appropriate, how they will approach relevant values-
based proxy issues for their portfolio co mpanies. Alternatively, the Funds should
explain in correspondence why they believ e such disclosure is not required.
Closing
A response to this letter should be in the form of a pre-effective amendment filed
pursuant to Rule 472 under the Securities Act.  The pre-effective amendment should be accompanied by a supplemental letter that includes your responses to each of these comments.  Where no change will be made in the filing in res ponse to a comment, please indicate this fact in
your supplemental letter a nd briefly state the basis for your position.
We remind you that the Fund and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action, or absence of action by the staff.
Should you have any questions regarding this  letter, please contact me at (202) 551-
3623.

       S i n c e r e l y ,          /s/ Daniel S. Greenspan

       Daniel S. Greenspan
 cc:  Ryan Sutcliffe, Branch Chief
 Christian Sandoe, Assistant Director