December 10, 2020

Via Electronic Transmission

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

RE: Davis Fundamental ETF Trust. File Nos.: 811‑23181, 333‑213073

Dear Ms. Lithotomos:

On behalf of Davis Fundamental ETF Trust (the “Registrant”), transmitted herewith for filing with the Securities and Exchange Commission (the “SEC”), is Post-Effective Amendment No. 10 (the “Amendment”) to the Registrant’s Registration Statement on Form N‑1A (the “Registration Statement”) under the Securities Act of 1933 and Amendment No. 13 to the Registrant’s Registration Statement under the Investment Company Act of 1940, as amended (the “1940 Act”).

For your reference, the Registrant is filing this Registration Statement in order to increase the disclosure relating to the Funds’ investments when allocated within select market sectors. Except for this change in the copy of the Registration Statement, the disclosure in the Registration Statement is materially the same to the disclosure in the currently effective Registration Statement. For this reason we would respectfully request selective review pursuant to Investment Company Act Release No. 13768. I have included a comparison of this filing to the Registration Statement that is currently effective.

As indicated on the facing page of the Amendment, the Registrant has specified that it is to become effective on February 26, 2021 pursuant to the provisions of Rule 485(a) under the Securities Act of 1933.

We would be happy to provide you with any additional information you may require or with copies of any of the materials referred to above. Please direct any communications relating to this filing to:

Ryan Charles

Davis Selected Advisers, L.P.

2949 E. Elvira Road, Suite 101

Tucson, AZ 85756

520-806-7600

Sincerely,

/s/ Ryan Charles              

Ryan Charles

Vice President and General Counsel