June 17, 2022

Filed via EDGAR

David Irving, Sharon Blume,

Tonya Aldave and John Dana Brown

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C.  20549

Subject:	Franklin Responsibly Sourced Gold ETF (the “Fund”)
	Franklin Templeton Holdings Trust (the “Registrant” or the “Trust”)
	Registration Statement on Form S-1
	CIK No. 0001858258

Dear Mr. Irving, Ms. Blume, Ms. Aldave and Mr. Brown:

Submitted herewith under the EDGAR system are the Fund’s updated responses to two comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) previously conveyed via written correspondence to Craig S. Tyle dated May 20, 2021.  Each comment from the Staff is summarized below, followed by the Fund’s response to the comment.

General

1.	Comment:  If applicable, as requested in our prior comment 18, please provide us with supplemental copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf, have presented or expect to present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not you retained, or intend to retain, copies of those communications.
	Response:  The Registrant reaffirms that no written communications, as defined in Rule 405 under the Securities Act, have been presented to potential investors in reliance on Section 5(d) of the Securities Act by the Registrant or anyone authorized on its behalf, and the Registrant does not intend to present, or authorize anyone on its behalf to present, such communications to potential investors in reliance on Section 5(d) of the Securities Act.
2.	Comment:  As requested in our prior comment 20, please provide a copy of any fact sheet the Fund intends to use for our review if applicable.
	Response:  Please see Exhibit A attached hereto. The Registrant notes that the proposed fact sheet is not intended to be published on the Fund’s website until after September 30, 2022, following the Fund’s first full calendar quarter of operations. Accordingly, the

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attached is an example of the fact sheet content in draft form which omits certain performance and other information that is not yet available as the Fund has not yet commenced operations.

Please do not hesitate to contact Steve Feinour at (215) 564-8521 or Miranda Sturgis at (215) 564-8131 if you have any questions or wish to discuss any of the responses presented above.

Very truly yours,

/s/ Navid Tofigh                                                                    

Navid Tofigh

Vice President and Secretary of Franklin Holdings, LLC,

Sponsor of the Registrant

Cc:	J. Stephen Feinour, Jr., Stradley Ronon Stevens & Young, LLP
	Miranda Sturgis, Stradley Ronon Stevens & Young, LLP

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EXHIBIT A

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