[Letterhead of Cushing Asset Management, LP]

September 25, 2018

Board of Trustees

Cushing ETF Trust

8117 Preston Road, Suite 440

Dallas, Texas 75225

Re:  Initial Seed Capital Subscription Agreement

To the Board of Trustees:

In order to provide Cushing ETF Trust (the “Trust”) with initial capital so as to enable the public offering of shares of the Trust, Cushing Asset Management, LP (the “Investment Adviser”) hereby subscribes to purchase from the Trust 1,000 Shares of Cushing^® Energy & MLP ETF, 1,000 Shares of Cushing^® Utility & MLP ETF, 1,000 Shares of Cushing^® Transportation & MLP ETF and 1,000 Shares of Cushing^® Energy Supply Chain & MLP ETF (the “Shares”) at net asset value of $25.00 per Share for a total of $100,000.

The Investment Adviser represents and warrants that such purchase of Shares is being made for investment purposes and not with a view towards the distribution thereof; and without any present intention of selling such Shares.

Very truly yours,

CUSHING ASSET MANAGEMENT, LP

By:          /s/ Jerry V. Swank                       

Jerry V. Swank

Managing Partner

Accepted:
CUSHING ETF TRUST
By:	/s/ Barry Y. Greenberg
	Barry Y. Greenberg
	Secretary
September 25, 2018