Seward & Kissel LLP
901 K Street, NW
Suite 800
Washington, DC 20001
Telephone: (202) 737-8833
Facsimile: (202) 737-5184
www.sewkis.com
| May 16, 2023 |
Via EDGAR CORRESPONDENCE
Scott Lee
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | AB Active ETFs, Inc. - AB US Large Cap Strategic Equities ETF Post-Effective Amendment No. 4 File Nos. 333-264818 and 811-23799 |
Dear Mr. Lee:
This letter responds to an additional comment of the staff (the “Staff”) of the Securities and Exchange Commission (“SEC”) regarding (1) the above-referenced post-effective amendment to the registration statement filed on February 3, 2023 (the “Post-Effective Amendment”), on Form N-1A for AB US Large Cap Strategic Equities ETF (the “Fund”), a series of AB Active ETFs, Inc. (“Registrant”) and (2) Registrant’s initial response letter to Staff comments on the Post-Effective Amendment, which was filed via EDGAR correspondence on May 10, 2023 (“Initial Letter”). You provided an additional comment to me by telephone on May 12, 2023.
The Staff’s comment and our response thereto on behalf of Registrant and the Fund are set forth below. The changes referenced in the response will be reflected in a Rule 485(b) filing.
| Comment 1: | As a follow-up to Comment 6 from the Initial Letter, please clarify what type of corporate behavior is measured and incorporated into the Fund’s strategy. |
| Response: | Registrant will revise the Prospectus in response to this comment. |
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If you have any additional comments or questions, please contact Paul M. Miller or the undersigned at (202) 737-8833 or Alexandra K. Alberstadt at (212) 574-1217.
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Sincerely,
/s/ Lauren A. Clise Lauren A. Clise |
| cc: | Nancy E. Hay, Esq. Paul M. Miller, Esq. Alexandra K. Alberstadt, Esq. |
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