October 11, 2024

VIA E-mail

Beau Yanoshik
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004-2541

         Re: SSGA Active Trust
             Post-Effective Amendment on Form N-1A
             File Nos. 333-173276, 811-22542

Dear Mr. Yanoshik:

         On September 10, 2024, you filed a post-effective amendment pursuant
to Rule 485(a)
under the Securities Act, on behalf of SSGA Active Trust (the    Trust   ), to
register the SPDR
SSGA Apollo IG Public & Private Credit ETF (   the Fund   ) as a new series of
the Trust. 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
disclosure appearing elsewhere in the registration statement. All capitalized
terms not otherwise
defined herein have the meaning given to them in the registration statement.

           Due to the novel nature of the Fund and significant factual and
legal questions related
to the structure and operations of the Fund, please be prepared to delay
scheduled effectiveness
of the Fund   s registration statement until all questions and issues raised by
the Staff are resolved.
Please provide your responses to the Staff   s comments by filing
correspondence on Edgar.
Please also notify the Staff of such filing via email and include a blacklined
copy of the
registration statement showing any changes from the initial filing of the
registration statement.

Supplemental Questions and Requests for Information

1. Please provide us with a copy of the Liquidity Agreement. To the extent the
agreement does
   not, please also describe:
           a. how the parties will determine the actual price at which Apollo
would buy the
              AOS Investments and how the intra-day executable bid is
determined;
           b. what will be the daily limit(s) of Apollo   s obligation to
provide executable
              quotations and/or repurchase AOS Investments, how such daily
limit(s) will be
              determined, and what advance notice of the daily limit(s) the
Adviser will receive;
           c. any qualifying circumstances under which Apollo would be exempt
or excused
              from its obligation to buy (or sell) the AOS Investments; and
 Beau Yanoshik
Morgan, Lewis & Bockius LLP
Page 2

           d. if intra-day, executable bids represent a guarantee or commitment
by the liquidity
              provider to purchase such investments. Is the contractual
arrangement a credit
              enhancement on the AOS Investment for purposes of determination
of
                 investment grade   ?
2. Please discuss whether the Liquidity Agreement might be prohibited by
Section 12(d)(3) of
   the Investment Company Act of 1940 (the    1940 Act   ).
3. Please provide or describe any additional written or oral agreement (and any
other
   arrangement) between the Fund or the Adviser (or any of their affiliates)
and Apollo (or any
   of its affiliates) related to the Fund.
4. The registration statement notes that    if Apollo is unable to meet its
contractual obligation to
   provide firm bids for AOS Investments, the Fund   s assets that were deemed
liquid by the
   Adviser may become illiquid.
           a. Assuming for purposes of this question that Apollo   s
contractual commitment can
              render the AOS investments liquid under rule 22e-4 of the 1940
Act, and
              considering the concentration of liquidity risk in a single
counterparty that such an
              approach would raise, what remedial measures does the Fund   s
Liquidity Risk
              Management Program under rule 22e-4 contemplate for situations
where Apollo
              is not able to meet its contractual obligation to provide
executable firm bids?
           b. Please also provide us with a copy of the Fund   s Liquidity Risk
Management
              Program.
5. We note the Fund   s name includes a reference to Apollo. Given Apollos
role as a liquidity
   provider to the Fund, please address why it is appropriate to include Apollo
in the name of
   the Fund, including how the use of Apollo in the Fund   s name is not
misleading under
   section 35(d) of the Investment Company Act. Please also provide us with a
copy of the
   licensing agreement for the Fund   s use of Apollo   s name.
6. Please describe all of the services, roles and functions that Apollo (or any
of its affiliates)
   will perform, or have, with respect to the Fund. Does the Fund plan to
engage with any other
   service provider that would serve a role similar to Apollo   s, including
originating deals and
   committing to purchase portfolio securities?
7. Please describe any direct or indirect compensation that Apollo or its
affiliates will provide
   or receive from the Fund, the Adviser, or any of their affiliates in
relation to the Fund.
8. Please describe any communication between Apollo, the Adviser, or any of
their affiliates
   regarding the launch of the Fund. Among others, we are interested in the
topic of the
   communications, who initiated them, and when. Also, is Apollo (or any of its
affiliates)
   bearing any of the expenses related to the launch of the Fund?
9. What percentage of the Fund   s Portfolio does the Adviser anticipate will
be comprised of
   AOS Investments? Does Apollo have a contractual obligation to identify and
make available
   AOS Investments for the Fund to buy?
10. With respect to AOS Investments, please describe the process for Apollo
sharing the
    investment opportunities with the Adviser. In particular:
 Beau Yanoshik
Morgan, Lewis & Bockius LLP
Page 3

           a. What type of information will Apollo or its affiliates share?
Will Apollo or its
              affiliates provide any view to the Adviser, the Fund or their
affiliates regarding
              the investment opportunities or otherwise discuss the
opportunities with them?
              Or would they only provide a list of the opportunities and their
terms?
           b. Who will negotiate the terms under which the Fund will
participate in these
              investment opportunities? Will the Fund receive the same terms as
Apollo, or its
              affiliated persons and Apollo   s clients, to the extent they
also participate in the
              opportunities?

           c. Does Apollo perform a similar role for other investment vehicles
with which it
              does not have an advisory or sub-advisory relationship?
11. Will any personnel of Apollo or its affiliates serve in any capacity for
the Adviser, the Fund
    or their affiliates?
12. In terms of the Fund   s investments in AOS Investments that are not
publicly traded, what
    form will they take?
           a. How will these investments be structured and what instruments
will the Fund
              hold? For example, will investments be originated by Apollo or an
affiliate of
              Apollo? Will the Fund use an SPV? Will it invest in bank loans
through
              assignments or participants? Please provide specific examples and
a
              representative list of possible investments.
           b. Will AOS Investments be customized specifically for the Fund?
           c. Will Apollo negotiate or determine specific terms for the AOS
investments it
              sources (e.g., debt covenants)?
13. We note that the Fund intends to invest in private funds, closed-end
investment companies
    (   CEFs   ) structured as    interval funds,    or business development
companies (   BDCs   ) and
    to limit such investments to 15% of the Fund   s net assets. Will any of
these private funds,
    CEFs or BDCs be managed or sponsored by Apollo or its affiliates?

14. We have the following initial questions on valuation:

           a. Will the board of the Fund designate a valuation designee, as
permitted by rule
              2a-5 under the 1940 Act, to perform fair value determination? If
so, who will the
              designee be? In addition, if so, what records will be kept (and
by whom) for
              purposes of compliance with Rule 31a-4 under the 1940 Act?
           b. Will Apollo or any of its affiliates be involved in the Fund   s
valuation process,
              and if so, how?
           c. Please describe the procedures for the Fund   s valuation of the
AOS Investments.
              To the extent the Fund relies on valuation inputs from Apollo and
its affiliates,
              will the Fund supplement those inputs with inputs coming from
others? If the
              Fund obtains other valuation inputs for AOS Investments, how will
differences in
              valuation from that process will be resolved?
 Beau Yanoshik
Morgan, Lewis & Bockius LLP
Page 4

           d. The registration statement notes that    [s]ome portfolio
holdings, potentially a
              large portion of the Fund   s investment portfolio, may be valued
on the basis of
              factors other than market quotations.    Considering that the
Fund is required to
              strike NAV every day, and considering the Fund   s daily
portfolio disclosure
              pursuant to rule 6c-11 under the 1940 Act, please address how the
Fund will fair
              value these positions daily.
           e. Given the nature of the asset class in which the Fund will
invest, has the Fund
              considered that it might experience significant premiums or
discounts as a result
              of uncertainties in the value of the Fund   s portfolio
securities?
               Please describe if the intra-day, executable bids provided by
Apollo will be
               utilized in the valuation of investments held by the Fund.
Please also describe
               how the nature of these quotes will be evaluated consistent with
ASC 820-10-35-
               54M.
15. For Fund investments in private credit, please explain the Adviser   s/Fund
  s processes for
    monitoring the financial trends of each borrower on an ongoing basis to
determine if it is
    meeting its respective business plan and to assess the appropriate course
of action for each
    borrower, including (but not limited to):
           a. A description of the loan review and/or loan rating system and
controls that
              identify, monitor, and manage asset quality problems in an
accurate and timely
              manner;
           b. A description of the systems and controls in place to monitor
loan covenants;
           c. Policies and procedures for placing loans on nonaccrual status;
and
           d. Policies and procedures for charging off loans.

16. Please describe precisely how the Fund plans to disclose its positions in
AOS Investments on
    its website, as required under Rule 6c-11.
17. Will Apollo have any direct relationship with the Fund   s authorized
participants, given its
    sourcing obligations? If so, please describe any such relationship.
18. The Commission has taken the position that under rule 6c-11 (see
Exchange-Traded Funds,
    Release No. 33-10695, at p.59 (Sep. 25, 2019)), an ETF can suspend
creations only under
    extraordinary circumstances and only for a limited period of time. Have you
considered
    whether there could be situations where the Fund will reach capacity with
respect to its
    investment strategies (e.g., because of capacity issues in the markets for
the Fund   s portfolio
    securities or because of liquidity constraints applicable to the Fund), so
that it might need to
    deviate from its investment strategies to avoid suspending creations?
19. The registration statement discloses that the Fund intends to invest in
derivatives. Does the
    Fund intend to be a limited derivatives user under rule 18f-4 under the
Investment Company
    Act or will the Fund otherwise rely on rule 18f-4to invest to a greater
extent in derivatives?
    If the latter, what reference portfolio will the Fund use to measure
compliance with the
    relative VaR limit under the rule?
 Beau Yanoshik
Morgan, Lewis & Bockius LLP
Page 5

20. What relevant experience do the intended portfolio managers of the Fund
have in making
    investment decisions with respect to AOS Investments? In addition to
relevant experience,
    what involvement will the portfolio managers for the Fund (and the Adviser
in general) have
    in the determination of which AOS Investments would be suitable for the
Fund?
21. The registration statement states:    The Fund   s purchase and sale of AOS
Investments will be
    with Apollo as the counterparty for each AOS Investment, and the Adviser
has the ability to
    determine whether to purchase and/or sell and therefore execute any or all
AOS Investments
    with Apollo in its sole discretion.
           a. Please further elaborate on any limitations of the Fund   s
ability to transfer an
              AOS Investment to anyone other than Apollo. In particular, does
this mean that
              the Fund will only be able to divest AOS Investments in a
transaction with
              Apollo? If so:
                   i. How would the Fund divest a position if it could not
agree on a price with
                      Apollo?
                  ii. How will the Adviser comply with its best execution
obligations with
                      respect to AOS Investments?
22. Do you anticipate Apollo, its affiliated persons or clients may also buy or
redeem Creation
    Units from the Fund in exchange for Deposit Securities, or Redemption
Securities,
    respectively? Could such in-kind transactions be preferrable from a tax or
other perspective
    for Apollo (or its affiliated persons or clients) or for the Fund, when
compared to buying or
    selling the same securities via portfolio transactions with the Fund?
23. Would the Adviser undergo a best execution analysis for in-kind transfers
of securities to and
    from the Fund as part of the sale or redemption of Creation Units?
24. Does the Adviser expect AOS Investments to ever serve as Deposit Securities
or Redemption
    Securities? If so, would this happen only for purchases or redemptions of
Creation Units by
    Apollo or its affiliates or clients (via an authorized participant), or
also by other persons?
25. Will Apollo receive non-public information related to the Fund   s
portfolio? If so, how will
    the Fund and the Adviser ensure that Apollo will not trade on such
information, including via
    creations and redemptions with the Fund, portfolio transactions with the
Fund, and in
    transactions with other parties?
Prospectus

Fund Summary     page 3

Fees and Expenses of the Fund (page 3)

26. Please supplementally provide a completed expense table and example for the
Fund.
 Beau Yanoshik
Morgan, Lewis & Bockius LLP
Page 6

The Fund   s Principal Investment Strategy (page 3)
27. The last two sentences of the final paragraph discuss duration. Please
clarify what is meant
    by    intermediate duration    and include an example of duration here, as
is provided in
    response to Item 9(c) (e.g., the value of a security with a duration of
five years would
    generally be expected to decrease by 5% for every 1% increase in interest
rates).
Principal Risks of Investing in the Fund (page 4)
28. Given the Fund   s intended investments, please consider including a risk
factor focused on
    private credit.
29. In Fluctuation of Net Asset Value, Share Premiums and Discounts Risk,
please also disclose
    that bid/ask spreads may widen depending on market conditions and the
liquidity of the
    Fund   s holdings. Similarly, please revise the discussion of Authorized
Participants, Market
    Makers and Liquidity Providers Concentration Risk in the Non-Principal
Risks section on
    page 24 to also address the risk of widening bid-ask spreads.
30. We note the Portfolio Turnover Risk and Non-Diversification Risk disclosure
in this section.
    Please confirm these will be principal risks of the Fund and if so,
disclose in the Principal
    Strategies section that the Fund may engage in active and frequent trading
of portfolio
    securities to achieve its principal investment strategy and that the fund
is non-diversified
    fund and what that means for the Fund with respect to its investments.
Fund Performance (page 11)
31. Please supplementally identify the appropriate broad-based securities
market index
    (   AMMSBI   ) that the Fund will utilize. Please note that the Fund will
be required to comply
    with the new definition of ABBSMI found in Instruction 6 to Item 27A(d)(2)
of Form N-1A.
Additional Strategies Information     page 12
32. The first sentence of this section states:    Please see    The Fund   s
Principal Investment
    Strategy    section under    Fund Summary    above for a complete
discussion of its principal
    investment strategies.    Please provide in this section the information
required by Item 9(b)
    of Form N-1A, including descriptions of how the Fund intends to achieve its
investment
    objective, the principal investment strategies of the Fund, and the
particular type or types of
    securities in which the Fund will principally invest. Please ensure that
the principal
    strategies discussed in this section are summarized in the summary
prospectus in response to
    Item 4(a) of Form N-1A.
Non-Principal Strategies (page 12)
33. The fourth sentence under Lending of Securities states that, to the extent
the Fund receives
    cash collateral, the Adviser expects to invest it in a fund managed by the
Adviser that invests
    in, among other thing, asset-backed securities and mortgage-related
securities. Please revise
    to reflect that cash collateral will only be invested in short-term,
highly-liquid instruments.
    We note that the discussion of Securities Lending Risk in the Non-Principal
Risks section of
    the prospectus states that the Fund will limit the investment of cash
collateral to high quality
    instruments of short maturity.
 Beau Yanoshik
Morgan, Lewis & Bockius LLP
Page 7

Additional Risk Information     page 13
Principal Risks (page 13)
34. A number of risks are included in this section as standalone principal
risks, including
    Call/Prepayment Risk, Interest Rate Risk, Leveraging Risk, Reinvestment
Risk, and
    Settlement Risk but are not included as standalone risks in the summary
section of the
    prospectus. While we acknowledge that the concept of these risks may be
broadly discussed
    within other principal risks, for clarity and consistency, please include
these risks in the Fund
    Summary section if they are principal risks.
35. Please consider including Extension Risk as a sub-risk within
Collateralized Debt
    Obligations Risk and Interval Fund Risk as a sub-risk within Closed-End
Fund and BDC
    Investing Risk in this section to match their presentation in the Fund
Summary section.
Part C

36. Please attach the Liquidity Agreement, and any similar agreements with
other potential
    liquidity providers, as exhibits to the registration statement. See Item
28(h) of Form N-1A.


                                          *       *      *


Closing

        A response to this letter should be in the form of a supplemental
correspondence filed on
EDGAR. If no change will be made in the filing in response to a comment, please
indicate this
fact in your supplemental letter and 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) 551-6765.

                                                      Sincerely,

                                                      /s/ Mark Cowan

                                                      Mark Cowan

cc:      Matthew Williams, Branch Chief
         Andrea Ottomanelli Magovern, Assistant Director
         Division of Investment Management - Chief Counsel   s Office
         Division of Investment Management - Analytics Office