August 21, 2012 Via EDGAR ATTORNEYS AT LAW 777 East Wisconsin Avenue, Suite 3800 Milwaukee, Wisconsin 53202-5306 414.271.2400 TEL 414.297.4900 FAX www.foley.com WRITER’S DIRECT LINE 414.297.5596 pfetzer@foley.com Email CLIENT/MATTER NUMBER 090083-0101

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: IndexIQ Active ETF Trust

Ladies and Gentlemen:

On behalf of IndexIQ Active ETF Trust, a Delaware statutory trust (the “Trust”), we are transmitting for filing the Trust’s Registration Statement on Form N-1A (the “Registration Statement”), including the exhibits thereto, other than those exhibits to be filed by amendment, relating to the proposed issuance and sale of units of beneficial interest (such units of beneficial interest being hereinafter referred to as “Shares”) in the Trust representing Shares in the Trust’s series identified in the Registration Statement (the “Funds”), and the Trust’s proposed operation as an investment company. The Trust already filed today as a separate submission a Form N-8A (Notification of Registration filed pursuant to Section 8(a) of the Investment Company Act of 1940).

The Funds would like to commence operations as soon as possible. Both the Trust and we, as counsel to the Trust, will promptly respond to any requests for additional information and will cooperate to the fullest extent with the Staff in order to ensure a prompt effective date for the Registration Statement.

The consent of the Trust’s independent accountants, which is to be included as an exhibit to the Registration Statement, has been omitted from the Registration Statement being filed, but will be included in a subsequent amendment. The Bank of New York Mellon will act as administrator to the Funds.

Please call the undersigned at (414) 297-5596 should you have any questions regarding this filing. You may also call Patrick Daugherty at (312) 832-5178.

Very truly yours,

/s/ Peter D. Fetzer

Peter D. Fetzer

Boston Brussels CHICAGO Detroit JACKSONVILLE LOS ANGELES MADISON MILWAUKEE NEW YORK ORLANDO SACRAMENTO SAN DIEGO SAN DIEGO/DEL MAR SAN FRANCISCO SILICON VALLEY TALLAHASSEE TAMPA TOKYO WASHINGTON, D.C.