SecProbe.io

CORRESP
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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

 July 11, 2023

VIA EDGAR
CORRESPONDENCE

Emily Rowland

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    First Trust Exchange-Traded Fund IV (the “Trust”)

    (File Nos. 333-174332; 811-22559)

Dear Ms. Rowland:

This letter responds
to your comments regarding the registration statement filed on Form N-1A for First Trust Exchange-Traded Fund IV (the “Trust”)
with the Staff of the Securities and Exchange Commission (the “Staff”) on May 5, 2023 (the “Registration Statement”).
The Registration Statement relates to the First Trust Intermediate Government Opportunities 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

The Staff reminds
the Registrant and its management that they are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review,
comments, action or absence of action by the Staff. Where a comment is made in one location, it is applicable to all similar disclosures
appearing elsewhere in the Registration Statement. Please ensure that corresponding changes are made to all similar disclosure.

Please provide responses
to all of the Staff’s comments on EDGAR at least five days before the effective date of the Registration Statement.

Response
to Comment 1

The Registrant confirms
that corresponding changes made in response to the Staff’s comments have been made to any similar disclosure throughout the Registration
Statement and that it will provide the Staff with a response letter in the form of correspondence at least five days before effectiveness.

Comment
2 – Principal Investment Strategies

Please add a summary
to the section entitled “Principal Investment Strategies” regarding how the Advisor determines when to sell an investment.

Response
to Comment 2

Pursuant to the Staff’s
comment, the third paragraph of the section entitled “Principal Investment Strategies” has been revised as set forth below.

In managing the Fund’s portfolio,
the Fund’s portfolio managers utilize a top-down, bottom-up analytical investment process. The portfolio managers will first conduct
a top-down review of the available mortgage-backed and U.S. Treasury securities to determine position weights based on its evaluation
of market fundamentals. The portfolio managers then perform a bottom-up analysis of individual securities to determine in which asset
types the portfolio will be over, neutral and underweight. Based upon this process, the portfolio managers decide when to buy and
sell securities. The portfolio managers analyze the Fund’s holdings on a systematic basis to monitor any changes in security
and portfolio performance, in addition to looking for meaningful changes in risk factors. (emphasis added)

Comment
3 – Principal Investment Strategies

The
Staff notes that the Fund may invest in exchange-traded funds pursuant to its principal investment strategy;
however, the Fund discloses in response to Item 9 of Form N-1A that it does not expect to invest in the securities of other investment
companies. Please reconcile this discrepancy.

Additionally, if the
fees and expenses relating to the Fund’s investments in exchange-traded funds are greater than one basis point, please add a separate
line item to the “Annual Fund Operating Expenses” table set forth under the section entitled “Fees and Expenses of the
Fund” to reflect such acquired fund fees and expenses (AFFE) or supplementally confirm to the Staff that such AFFE will be reflected
in the other expenses.

Response
to Comment 3

Pursuant to the Staff’s
comment, the expense table has been revised accordingly.

    -2-

Comment
4 – Principal Investment Strategies

The
Staff notes that derivatives are part of the Fund’s principal investment strategy. Please disclose that such
instruments will be valued on a mark-to-market basis for purposes of complying with the Fund’s 80% investment policy set forth in
the first paragraph of the section entitled “Principal Investment Strategies.”

Response
to Comment 4

Pursuant
to the Staff’s comment, the referenced disclosure has been revised accordingly.

Comment
5 – Principal Investment Strategies

The Staff notes that
the Fund will use a weighted average effective duration methodology for purposes of its investment strategy and thinks that “duration”
should be added to the name of the Fund. Please consider revising the name of the Fund to incorporate the term “duration.”

Response
to Comment 5

The Fund respectfully
declines to revise its name as it has determined that the name complies with Section 35(d) of the 1940 Act and the accompanying Rule 35d-1.

Comment
6 – Principal Investment Strategies

The Staff notes the
following disclosures set forth in the section entitled “Principal Investment Strategies”:

In
managing the Fund’s portfolio, the Fund’s portfolio managers utilize a top-down, bottom-up analytical investment process.
The portfolio managers will first conduct a top-down review of the mortgage-backed security and Treasury fixed income sectors to determine
sector position weights based on its evaluation of market fundamentals. The portfolio managers then perform a bottom-up analysis
of individual securities to determine in which sub-sectors the portfolio will be over, neutral and underweight. The portfolio managers
analyze the Fund’s holdings on a systematic basis to monitor any changes in security and
portfolio performance, in addition to looking for meaningful changes in risk factors.

Please explain in
plain English which sectors “mortgage-backed security” and “Treasury fixed income” relate to, as such are not
commonly referred to as specific sectors.

Please also revise
the referenced disclosures to disclose in plain English the Advisor’s criteria for selecting investments.

Response
to Comment 6

Pursuant to the Staff’s
comment, the third paragraph of the section entitled “Principal Investment Strategies” has been revised as set forth below.

In managing the Fund’s
portfolio, the Fund’s portfolio managers utilize a top-down, bottom-up analytical investment process. The portfolio managers
will first conduct a top-down review of the available mortgage-backed and U.S. Treasury securities to determine position weights based
on its evaluation of market fundamentals. The portfolio managers then
perform a bottom-up analysis of individual securities to determine in which asset types the portfolio will be over, neutral and underweight.
Based upon this process, the portfolio managers decide when to buy and sell securities. The portfolio managers analyze the Fund’s
holdings on a systematic basis to monitor any changes in security and portfolio performance, in addition to looking for meaningful changes
in risk factors. (emphasis added)

    -3-

Comment
7 – Principal Investment Strategies

The Staff notes the
paragraph set forth in the section entitled “Principal Investment Strategies” beginning with “[u]nder normal market
conditions, the portfolio managers will manage the Fund’s portfolio to have a weighted average effective duration of three to eight
years.” Please consider combining this paragraph with the immediately preceding paragraph to avoid repetitive disclosures.

Response
to Comment 7

Pursuant to the Staff’s
comment, the referenced disclosure has been revised accordingly.

Comment
8 – Principal Investment Strategies

Please consider deleting
“and cash and cash equivalents” set forth in the section entitled “Principal Investment Strategies” if such investments
are not part of the Fund’s principal investment strategy.

Response
to Comment 8

The Fund has relocated
the disclosure entitled “Cash Equivalents and Short-Term Investments” from “Non-Principal Investments” to “Principal
Investments” in the section entitled “Fund Investments.”

Comment
9 – Principal Investment Strategies

Please supplementally
confirm that expenses relating to short sale transactions are included in the “Annual Fund Operating Expenses” table set forth
under the section entitled “Fees and Expenses of the Fund” or otherwise revise such fee table to include such expenses.

Response
to Comment 9

The Fund currently
intends to obtain short exposure through the use of derivatives contracts that do not generate the type of short sale expenses typically
associated with obtaining short positions in equity securities and are reflected in the “Annual Fund Operating Expenses” table.
Nonetheless, to the extent that the Fund obtains short positions in a manner that does incur expenses properly reflected in the “Annual
Fund Operating Expenses” table, the Fund represents that such table will be revised to properly reflect such expenses.

    -4-

Comment
10 – Principal Investment Strategies

The Staff notes the
penultimate paragraph set forth under the section entitled “Principal Investment Strategies.” Please confirm whether the Fund
may hold distressed and/or defaulted securities as part of its principal investment strategy. If so, please disclose that along with the
corresponding risks.

Response
to Comment 10

The Fund does not
currently intend to invest in distressed or defaulted securities as part of its principal investment strategy.

Comment
11 – Principal Risks

The Staff notes that
the principal risks appear in alphabetical order. Please order the risks to prioritize the risks that are most likely to adversely affect
the Fund’s net asset value, yield and total return.

Response
to Comment 11

The Fund respectfully
declines to revise the disclosure as requested by the Staff. Ultimately, the Fund has reached the same conclusion as many other industry
participants and declines to make the requested revisions as it believes the disclosure is compliant with the requirements of Form N-1A.
The Fund continues to evaluate its approach to the ordering of risk factors in light of recent Securities and Exchange Commission guidance.

Comment
12 – Principal Risks

The Staff notes “Asset-Backed
Securities Risk” set forth in the section entitled “Principal Risks.” Please consider revising the risk to make clear
that the asset-backed securities in which the Fund invests are privately-issued, non-agency sponsored asset-backed securities.

Response
to Comment 12

The Registrant respectfully
declines to revise the disclosure as the Fund already includes “Non-Agency Securities Risk” and is compliant with the requirements
of Form N-1A.

    -5-

Comment
13 – Principal Risks

The
Staff notes “Floating Rate Debt Securities Risk” set forth in the section entitled “Principal Risks.” Please
disclose in the prospectus that it may take longer than seven days for transactions in the floating rate loans to settle, which means
it could take the Fund significant time to receive money after selling its investments.

Please also address
how the Fund intends to meet short-term liquidity needs which may arise as a result of such lengthy settlement period.

If the Fund holds
a significant amount of covenant lite loans, please revise the risk to include the heightened risks associated with such loans.

Response
to Comment 13

The referenced disclosure
has been replaced with “Floating Rate Securities Risk” which more precisely describes the relevant risks of the floating rate
securities in which the Fund intends to invest. The Fund does not currently intend to invest in loans, including covenant lite loans,
as part of its principal investment strategy.

Comment
14 – Principal Risks

The Staff notes “Interest
Rate Risk” set forth in the section entitled “Principal Risks.” Please update this risk with respect to current interest
rates.

Response
to Comment 14

Pursuant to the Staff’s
comment, the referenced disclosure has been revised accordingly.

Comment
15 – Principal Risks

The Staff notes “Significant
Exposure Risk” set forth in the section entitled “Principal Risks.” If the Fund intends to invest significantly in a
particular industry, jurisdiction or sector, please disclose such industry, jurisdiction or sector along with the corresponding risks.

Response
to Comment 15

The Fund does not
currently intend to invest significantly in a particular industry, jurisdiction or sector that is otherwise undisclosed.

    -6-

Comment
16 – Principal Risks

The Staff notes “U.S.
Government Securities Risk” set forth in the section entitled “Principal Risks.” Please revise the risk to distinguish
between the securities backed by the full faith and credit of the U.S. government and those which are not.

Response
to Comment 16

The Registrant has
thoughtfully considered the Staff’s comment and upon its examination of “U.S. Government Securities Risk” in the section
entitled “Principal Risks” and “Additional Risks of Investing in the Fund” has determined that the risk that the
Fund may invest in certain Government Securities that are not backed by the full faith and credit of the U.S. government is adequately
disclosed, as reproduced below. The Registrant does not believe it is either appropriate or necessary to include additional detail regarding
the specifics of which securities are and are not backed by the full faith and credit of the U.S. government beyond what is currently
disclosed.

U.S. Government Securities Risk.
… While securities issued or guaranteed by U.S. federal government agencies (such as Ginnie Mae) are backed by the full faith and
credit of the U.S. Department of the Treasury, securities issued by government sponsored entities (such as Fannie Mae and Freddie Mac)
are solely the obligation of the issuer and generally do not carry any guarantee from the U.S. government.

Additionally, the
possibility that the Fund is exposed to credit risk with regard to the issuer of certain securities it intends to purchase is further
disclosed in “Credit Risk” and “Debt Securities Risk.” Accordingly, the Registrant has determined that the risks
associated with its investments in U.S. government securities is adequately described and compliant with the requirements of Form N-1A.

Comment
17 – Performance

Please
disclose the broad-based securities market index that the Fund intends
to use.

Response
to Comment 17

The Fund’s
broad-based securities market index will be the Bloomberg Barclays Aggregate Bond Index.

Comment
18 – Additional Information on the Fund’s Investment Objective and Strategies

Please
carry forward the applicable changes from Item 4 to the Item 9 disclosures.

Response
to Comment 18

Pursuant to the Staff’s
comment, the referenced disclosures have been revised accordingly.

    -7-

Comment
19 – Additional Information on the Fund’s Investment Objective and Strategies

If
not applicable to the Fund’s investment strategy, please delete
the second paragraph set forth in the section entitled “Additional Information on the Fund’s Investment Objective and Strategies.”

Response
to Comment 19

Pursuant to the Staff’s
comment, the disclosure has been revised accordingly.

Comment
20 – Additional Information on the Fund’s Investment Objective and Strategies

Please disclose in
the section entitled “Additional Information on the Fund’s Investment Objective and Strategies” a more fulsome discussion
regarding how the Advisor decides which securities to buy and sell, as required by Item 9(b)(2) of Form N-1A.

Please also disclose
the specific credit ratings of the Fund’s investments in investment grade securities.

Response
to Comment 20

Pursuant to the Staff’s
comment, the disclosure has been revised accordingly.

Comment
21 – Statement of Additional Information

Regarding the disclosure
on derivative actions, the Staff reiterates in full the comments provided on the Declaration of Trust disclosure for the First Trust Multi-Manager
International ETF.

Response
to Comment 21

The Fun