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 21, 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 June 29, 2023 (the “Registration
Statement”). The Registration Statement relates to the First Trust Intermediate Duration Investment Grade Corporate 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 – General

Please
supplementally provide a completed fee table and expense examples for the Fund.

Response
to Comment 2

A
completed fee table and expense examples have been attached hereto as Exhibit A.

Comment
3 – Principal Investment Strategies

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

The corporate debt
securities in which the Fund may invest also include senior loans and covenant-lite loans.

Please consider revising
this disclosure to state that such loans are expected to be covenant-lite loans.

Response
to Comment 3

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

The corporate debt
securities in which the Fund may invest also include senior loans and covenant-lite loans, substantially all of which are expected
to be covenant-lite loans. (emphasis added)

Comment
4 – Principal Investment Strategies

Please disclose in
the section entitled “Principal Investment Strategies” that the Fund will invest in U.S. and foreign debt securities. Please
also disclose that a portion of the Fund’s investments will be denominated in a foreign currency.

Response
to Comment 4

The Fund’s investments
in foreign debt securities does not constitute a principal investment strategy. The disclosure has been revised accordingly.

Comment
5 – Principal Investment Strategies

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

The fundamental credit
analysis of the Fund’s investment advisor involves the evaluation of the macro-economy, industry trends, consistency of cash flows,
valuation and management quality, among other considerations. The investment process favors companies that produce relatively stable cash
flows through an economic cycle, companies that have valuations supportive of the debt balances and companies that have management teams
with a sound track record. The key considerations of portfolio construction include yield curve management, relative value, portfolio
diversification, issuer liquidity and continuous monitoring.

Please revise this
paragraph in plain English to more clearly disclose the criteria that will be used for selecting investments, particularly with respect
to “yield curve management” and “relative value.”

    -2-

Response
to Comment 5

Pursuant to the Staff’s
comment, the referenced disclosures have been revised as follows:

The Fund’s
investment advisor’s fundamental credit analysis of the Fund’s investment advisor involves the evaluation
of the macro-economy, industry trends, consistency of company cash flows, and valuation and
management quality, among other considerations. The investment process favors companies that produce relatively stable cash flows through
an economic cycle, companies that have valuations supportive of the debt balances and companies that have management teams with a sound
track record. The Fund’s investment advisor’s key considerations of portfolio construction include yield curve
management (i.e., monitoring macro factors that drive interest rates), relative value assessments (i.e., an internal
process of evaluating investment opportunities on a relative basis), portfolio diversification, issuer liquidity and continuous
monitoring. (emphasis added)

Comment
6 – Principal Investment Strategies

The Staff notes that
the Fund disclosed a fulsome description regarding when the Fund decides to sell investments in the Item 9 section entitled “Additional
Information on the Fund’s Investment Objectives and Strategies.” Please add a short discussion regarding the same to the Item
4 section entitled “Principal Investment Strategies.”

Response
to Comment 6

Pursuant to the Staff’s
comment, the following disclosures have been added to the section entitled “Principal Investment Strategies”:

Securities in the
portfolio may be sold for several reasons, including, but not limited to, meeting cash needs of the Fund, deterioration in the fundamental
credit quality of an issuer or a change in the relative attractiveness (relative value) of a security.

    -3-

Comment
7 – Principal Investment Strategies

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

Under normal market
conditions, the Fund seeks to construct a portfolio that has a weighted average duration of +/- 1.5 years of the Bloomberg Barclays U.S.
Credit Corp 5-10 Year Index.

Please consider revising
“weighted average duration” to “dollar weighted average duration” or otherwise define such term.

Response
to Comment 7

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

Under normal market
conditions, the Fund seeks to construct a portfolio that has a dollar weighted average duration of +/- 1.5 years of the
Bloomberg Barclays U.S. Credit Corp 5-10 Year Index. (emphasis added)

Comment
8 – Principal Investment Strategies

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

Duration is a mathematical
calculation of the average life of a debt security (or portfolio of debt securities) that serves as a measure of its price risk.

Please revise
this disclosure to read in plain English.

Response
to Comment 8

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

Duration measures
the price sensitivity of a debt security (or portfolio of debt securities) to relative changes in interest rates.

    -4-

Comment
9 – Principal Investment Strategies

Please summarize in
the Item 4 section entitled “Principal Investment Strategies,” and disclose in greater detail in the Item 9 section entitled
“Additional Information on the Fund’s Investment Strategies and Objectives,” that the Fund will engage in active and
frequent trading of portfolio securities to achieve its principal investment strategies. With
respect to the Item 9 disclosure, please add an explanation of the tax consequences of increased portfolio turnover and how trading costs
can effect fund performance. Alternatively, if the Fund will not engage in active and frequent trading of portfolio securities,
please remove such discussion from the Registration Statement, including any related risk disclosures.

Response
to Comment 9

Pursuant to the Staff’s
comment, the following disclosure has been added to the section entitled “Principal Investment Strategies”:

The Fund’s active trading strategy
may lead to higher levels of portfolio turnover.

The Registrant respectfully
declines to include the additional suggested disclosure in the section entitled “Principal Investment Strategies” as such
concepts are already disclosed in “Portfolio Turnover Risk” in the section entitled “Principal Risks,” which is
the more appropriate location for such disclosure.

Comment
10 – 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 10

The Registrant respectfully
declines to revise the disclosure as requested by the Staff. Ultimately, the Registrant 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 Registrant continues to evaluate its approach to the ordering of risk factors in light of recent Securities and Exchange
Commission guidance.

    -5-

Comment
11 – Principal Risks

The Staff notes “Interest
Rate Risk” set forth in the section entitled “Principal Risks.” Please update this risk factor in light of the current
interest rate environment.

Response
to Comment 11

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

Comment
12 – Principal Risks

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

Response
to Comment 12

The Fund has included
disclosure in the sections entitled “Principal Investment Strategies” and “Principal Risks” regarding its anticipated
investments in debt securities issued by financial companies.

Comment
13 – Principal Risks

The
Staff notes “Trading Issues Risk” set forth in the section entitled “Principal Risks.” Please disclose
that where all or a portion of the Fund’s underlying securities trade in a market that is closed when the domestic market in which
the Fund’s shares are listed and trading is open, there may be changes between the last quote from the closed foreign market and
the value of such securities during the Fund’s domestic trading day. In addition, please note that this in turn could lead to differences
between the market price of the Fund’s shares and the underlying value of such shares.

Response
to Comment 13

Pursuant to the Staff’s
comment, disclosure entitled “International Closed Market Trading Risk” has been added to the section entitled “Additional
Risks of Investing in the Fund – Non-Principal Risks.”

Comment
14 – Performance

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

Response
to Comment 14

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

    -6-

Comment
15 – Additional Information on the Fund’s Investment Objectives and Strategies

Please
carry forward the applicable changes from the Item 4 disclosures set forth
in the section entitled “Principal Investment Strategies” to the Item 9 disclosures set forth in the section entitled “Additional
Information on the Fund’s Investment Objectives and Strategies.”

Response
to Comment 15

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

Comment
16 – Additional Information on the Fund’s Investment Objectives and Strategies

The Staff notes the
following disclosure set forth in the section entitled “Additional Information on the Fund’s Investment Objectives and Strategies”:

In addition, although
the Fund intends to invest primarily in investment grade corporate debt securities, for temporary defensive purposes, the Fund may depart
from its principal investment strategy and invest part or all of its assets in cash and cash equivalents.

Pursuant to Item 9
of Form N-1A, please disclose the effect of taking such temporary defensive positions (e.g., the Fund may not achieve its investment
objectives).

Response
to Comment 16

Pursuant to the Staff’s
comment, the referenced disclosure has been revised as follows:

In addition, although
the Fund intends to invest primarily in investment grade corporate debt securities, for temporary defensive purposes, the Fund may depart
from its principal investment strategy and invest part or all of its assets in cash and cash equivalents. The Fund may not achieve
its investment objectives as a result of taking actions for temporary defensive purposes. (emphasis added)

Comment
17 – Additional Information on the Fund’s Investment Objectives and Strategies

Please delete the
following disclosure set forth in the section entitled “Additional Information on the Fund’s Investment Objectives and Strategies”:

The Fund’s investments
will not be concentrated (i.e., invest more than 25% of Fund assets) in an industry or group of industries.

Response
to Comment 17

Pursuant to the Staff’s
comment, the referenced disclosure has been deleted in the prospectus but will remain a fundamental policy in the statement of additional
information.

    -7-

Comment
18 – Fund Investments

The Staff notes the
following disclosures under “Mortgage-Related Investments” set forth in the subsection entitled “Non-Principal Investments”
set forth in the section entitled “Fund Investments”:

The Fund may also
invest in TBA Transactions. A TBA Transaction is a method of trading mortgage-backed securities. In a TBA Transaction, the buyer and the
seller agree on general trade parameters such as agency, settlement date, par amount and price. The actual pools delivered generally are
determined two days prior to the settlement date.

The Fund notes TBA
Transactions are discussed here as a non-principal investment and in the section entitled “Principal Risks” set forth in the
summary prospectus. Please reconcile the discrepancy.

Response
to Comment 18

The referenced disclosure
has been removed from the summary prospectus and is now set forth in the section entitled “Additional Risks of Investing in the
Fund – Non-Principal Risks.”

Comment
19 – 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 19

The Registrant and
the Advisor have considered the Staff’s comment and respectfully decline to make the requested changes. The Registrant and the Advisor
believe that the disclosure, as currently presented, is appropriate for investor comprehension.

Comment
20 – Statement of Additional Information

Regarding the disclosure
on fiduciary duties, the Staff reiterates in full the comments provided on the Declaration of Trust disclosure for the FT Cboe Vest Rising
Dividend Achievers Target Income ETF.

    -8-

Response
to Comment 20

The Registrant notes
that the Declaration contains a provision that clarifies that the Trustees of the Trust are not subject to the law in Massachusetts or
other states relating to the duties and liabilities of trustees of donative trusts (a trust that establishes a gift of an interest in
property to a beneficiary) or probate trusts (a trust which allows a person to place an asset into trust and retain control and access)
or similar common law trusts, but are subject only to the law in Massachusetts relating to the trus