SEC Company Response from FIRST TRUST EXCHANGE-TRADED FUND II (CIK 0001364608) — Mar 23, 2022
FIRST TRUST EXCHANGE-TRADED FUND II (CIK 0001364608)
Date: March 23, 2022 · CIK: 0001364608 · Accession: 0001445546-22-002180
AI Filing Summary & Sentiment
File numbers found in text: 333-143964, 811-21944
Letter
VIA EDGAR CORRESPONDENCE United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: First Trust Exchange-Traded Fund II (the “Trust”) File Nos. 333-143964; 811-21944
Dear Mr. Zapata:
This letter responds to your additional comments regarding the registration statement filed on Form N-1A for First Trust Exchange-Traded Fund II (the “Trust”) with the Staff of the Securities and Exchange Commission (the “Staff”) on December 7, 2021 (the “Registration Statement”). The Registration Statement relates to the First Trust Indxx Metaverse ETF (the “Fund”), a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.
Comment 1 – General
Please revise or remove the disclosure that states: “Continued Index membership of a constituent is not necessarily subject to the guidelines provided in the Index methodology.” The Staff believes that this implies that the Index Provider has discretion to deviate from the Index methodology.
Response to Comment 1
In accordance with the Staff’s comment, the above referenced disclosure has been removed.
Comment 2 – Principal Investment Strategies
Given that the Index only includes Primary Companies (as defined in the Registration Statement), please remove references to “Secondary Companies” or explain supplementally why such disclosure is relevant.
Response to Comment 2
In accordance with the Staff’s comment, the above referenced disclosure has been removed.
Comment 3 – Principal Investment Strategies
Please update the significant sector investment information as of a more recent date, if available.
Response to Comment 3
The prospectus has been revised in accordance with the Staff’s comment.
********
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
Chapman and Cutler
llp
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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T 312.845.3000
F 312.701.2361
www.chapman.com
March 23, 2022
VIA EDGAR
CORRESPONDENCE
Alberto Zapata
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
First Trust Exchange-Traded Fund II (the “Trust”)
File Nos. 333-143964; 811-21944
Dear Mr. Zapata:
This letter responds
to your additional comments regarding the registration statement filed on Form N-1A for First Trust Exchange-Traded Fund II (the
“Trust”) with the Staff of the Securities and Exchange Commission (the “Staff”) on December 7, 2021
(the “Registration Statement”). The Registration Statement relates to the First Trust Indxx Metaverse ETF (the “Fund”),
a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration
Statement.
Comment
1 – General
Please revise or remove
the disclosure that states: “Continued Index membership of a constituent is not necessarily subject to the guidelines provided in
the Index methodology.” The Staff believes that this implies that the Index Provider has discretion to deviate from the Index methodology.
Response
to Comment 1
In accordance with
the Staff’s comment, the above referenced disclosure has been removed.
Comment
2 – Principal Investment Strategies
Given that the Index
only includes Primary Companies (as defined in the Registration Statement), please remove references to “Secondary Companies”
or explain supplementally why such disclosure is relevant.
Response
to Comment 2
In accordance with
the Staff’s comment, the above referenced disclosure has been removed.
Comment
3 – Principal Investment Strategies
Please update the
significant sector investment information as of a more recent date, if available.
Response
to Comment 3
The prospectus has
been revised in accordance with the Staff’s comment.
********
Please call me at
(312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
Chapman and Cutler
llp
By:
/s/ Morrison C. Warren
Morrison C. Warren