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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

 January 28, 2025

VIA EDGAR
CORRESPONDENCE

Ellie Quarles

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. Quarles:

This
letter responds to your comments regarding the registration statements filed on Form N-1A for First Trust Exchange-Traded Fund IV (the
“Registrant” or “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”)
on November 18, 2024 (each, a “Registration Statement” and collectively, the “Registration Statements”).
The Registration Statements relate to the FT Vest High Yield & Target Income ETF, FT Vest Investment Grade & Target Income
ETF and FT Vest 20+ Year Treasury & Target Income ETF (each, a “Fund”
and collectively, the “Funds”), each a series of the Trust. Capitalized terms used herein, but not otherwise defined,
have the meanings ascribed to them in the Registration Statements.

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 Statements. 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 business days before the effective date of the Registration Statements. Once
the correspondence is filed, please provide notice by email and include a redline showing any changes.

Please note that where
a comment is made in one Fund such comment should be addressed in all other Funds where it applies in the respective 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
Statements and that it will provide the Staff with a response letter in the form of correspondence at least five business days before
effectiveness. The Registrant further confirms it will provide a copy of the correspondence and corresponding redline of the Registration
Statements to the Staff once filed.

Comment
2 – General

Please update each
Fund’s ticker symbol in EDGAR. See Items 1(a)(2) and 14(a)(2) of Form N-1A and Regulation S-T, Rule 313(b)(1).

Response
to Comment 2

The Registrant confirms
the ticker symbols will be updated on EDGAR, and the cover pages of the Prospectuses and the Statements of Additional Information have
been revised to include each Fund’s ticker symbol.

Comment
3 – Fees and Expenses of the Fund

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

Response
to Comment 3

A completed fee table
and expense examples applicable to each Fund has been attached hereto as Exhibit A.

Comment
4 – Principal Investment Strategies

Please revise the
first paragraph of the “Principal Investment Strategies” section to include a discussion that the options strategy also involves
selling put options to gain synthetic exposure to the Underlying ETF.

Response
to Comment 4

The Registrant notes
that, at the present time, the Fund will create the synthetic long exposure to the Underlying ETF by primarily utilizing purchased call
options on the Underlying ETF. Therefore, the Registrant respectfully declines to the revise the disclosure.

Comment
5 – Principal Investment Strategies

The Staff notes the
disclosure states, “While the Fund seeks to make distributions that are above the current annual income yield of the Underlying
ETF, there is no guarantee that the Fund’s distribution target will be achieved.” Please add disclosure that the Advisor will
periodically assess whether the Fund’s distribution target remains reasonable as market conditions change.

    2

Response
to Comment 5

In accordance with
the Staff’s comment, the following disclosure has been added to the “Principal Investment Strategies” section:

“The Advisor
will periodically assess whether the Fund’s distribution target remains reasonable as market conditions change.”

Comment
6 – Additional Information on the Fund's Investment Objectives and Strategies

Please include a table
for clarity that discusses the Fund’s portfolio holdings (i.e., purchased call option, purchased U.S. Treasury securities
and sold call options), including investment terms and the expected target maturity of each investment. This table should include options
terminology with investment terms that describe whether the Fund will purchase options in-the-money, near-the-money, or out-of-the-money
at the time of purchase or sale and the purpose of each investment.

Response
to Comment 6

In accordance with
the Staff’s comment, the following disclosure has been added to the “Additional Information on the Fund's Investment Objectives
and Strategies” section. The Registrant has added a cross-reference to the table in the “Principal Investment Strategies”
section.

The below chart
represents the Fund’s portfolio holdings, investment terms/function and expected target maturity for each component:

    Portfolio Holding
    Investment Terms
    Investment Function
    Expected Target Maturity

    Purchased Call Option on the Underlying ETF*
    European style, in-the-money call option
    Synthetic long exposure to the price return of the Underlying ETF
    Approximately 3-12 months

    Sold Call Options on the Underlying ETF
    European style, at-the-money call options
    Call selling strategy to generate premium income for annualized target distribution
    Approximately 1 week

    U.S. Treasury Bills
    Laddered portfolio of U.S. Treasury Bills
    Cash management
    Approximately 3-12 months

* In lieu of the
options strategy outlined above, the Fund may utilize a combination of options in order to create the synthetic long exposure to the Underlying
ETF, whereby the Fund may purchase a call option and sell a put option at the same strike price with similar expected target maturities.

    3

Comment
7 – Principal Investment Strategies

The Staff notes the
disclosure states, “The long portion of the Fund’s portfolio consists of synthetic exposure to the Underlying ETF, which measures
the performance of the largest and most actively traded high yield bonds of U.S. companies.” Please disclose prominently that an
investment in the Fund is not an investment in an index or in the securities that make up the Underlying ETF and that the Fund only has
synthetic exposure to the Underlying ETF. Please also disclose prominently that the Fund’s strategy is subject to all potential
losses if the Underlying ETF loses value which may not be offset by income received by the Fund.

Response
to Comment 7

In accordance with
the Staff’s comment, the following disclosure has been added to the “Principal Investment Strategies” section (in bold):

“An investment
in the Fund is not an investment in an index or in the securities that make up the Underlying ETF. As such, the Fund only has synthetic
exposure to the Underlying ETF. The Fund is subject to all potential losses if the Underlying ETF loses value which may not be offset
by the income received by the Fund.”

Comment
8 – Principal Investment Strategies

Please disclose that
the options used to create the long synthetic exposure to the Underlying ETF are not fully covered and disclose the risk of loss.

Response
to Comment 8

In accordance with
the Staff’s comment, the following disclosure has been added to the “Principal Investment Strategies” section:

“When the Fund
sells a call option on the Underlying ETF (as discussed below), the option is “uncovered” (i.e., the Fund does not
own the underlying security), therefore the Fund may be required to acquire shares of the Underlying ETF in order to satisfy its obligation
on the call option, which could result in additional costs to the Fund.”

Comment
9 – Principal Investment Strategies

Please address in
the disclosure any impact on income by selling call options that is offset by purchasing call options to create synthetic exposure to
the Underlying ETF.

    4

Response
to Comment 9

The Registrant notes
the Fund obtains synthetic long exposure to the Underlying ETF and also sells call options, as necessary, to generate the target income
to be distributed. Notably, the income that the Fund generates from selling call options is independent from its synthetic long exposure
to the Underlying ETF and is not offset or reduced by the synthetic long exposure. Therefore, the Registrant acknowledges this comment
and respectfully declines to make changes to the disclosure.

Comment
10 – Principal Investment Strategies

Please add disclosure
that discusses why the Advisor will buy and sell portfolio securities frequently.

Response
to Comment 10

The Registrant respectfully
notes the disclosure surrounding the statement that the Fund’s strategy may involve frequently buying and selling portfolio securities.
The surrounding disclosure states that the Fund will engage in a partial call selling strategy to convert a portion of the growth potential
of the Fund into current income. The disclosure continues to state, “Each week, the Fund compares the FLEX Option Discount on the
synthetic exposure to the Underlying ETF against the Fund’s distribution target and looks to bridge that difference with the premiums
that come from selling call options.” Further, the disclosure later states, “The call options written by the Fund will generally
have expirations of approximately one week.” Therefore, the Registrant believes the disclosure, as currently presented, accurately
describes why the Advisor will buy and sell portfolio securities frequently.

Comment
11 – Principal Risks

With respect to the
“Call Options Risk,” please disclose the risks of purchasing call options, which is part of the Fund’s principal investment
strategies in creating synthetic exposure to the Underlying ETF.

    5

Response
to Comment 11

In accordance with
the Staff’s comment, the “Call Options Risk” has been revised as follows:

“CALL OPTIONS
RISK. The use of call options involves risks different from those associated with ordinary portfolio securities transactions and depends
on the ability of the Fund’s portfolio managers to forecast market movements correctly. As the seller (writer) of a call option,
the Fund will lose money if the value of the reference index or security rises above the strike price and the buyer exercises the option;
however, such loss will be partially offset by any premium received from the sale of the option. As the purchaser of a call option, the
Fund will generally only exercise the option if the value of the reference index or security rises above the strike price. If the value
of the reference index or security does not rise above the level of the strike price, the option is likely to expire worthless. When writing
a call option, the Fund will have no control over the exercise of the option by the option holder. A number of factors may influence the
option holder’s decision to exercise the option, including the value of the underlying security or index, price volatility, currency
exchange rates, dividend yield and interest rates. To the extent that these factors increase the value of the call option, the option
holder is more likely to exercise the option, which may negatively affect the Fund. The effective use of options also depends on the Fund’s
ability to terminate option positions at times deemed desirable to do so. There is no assurance that the Fund will be able to effect closing
transactions at any particular time or at an acceptable price. In addition, there may at times be an imperfect correlation between the
movement in values of options and their reference index or security and there may at times not be a liquid secondary market for certain
options. Additionally, the options on the Underlying ETF may perform differently than options on the reference index due to differences
in the performance of the Underlying ETF itself due to cash drag, differences between the portfolio of the ETF and the components of the
reference index, expenses and other factors. Options may also involve the use of leverage, which could result in greater price volatility
than other securities.”

Comment
12 – Principal Risks

With respect to the
“Distribution Tax Risk,” please add risk disclosure to the effect that distributions constituting return of capital should
not be considered the dividend yield or total return of an investment in the Fund. Shareholders who receive a payment of a distribution
consisting of a return of capital may be under the impression that they are receiving that as income or capital gains when they are not,
and as such, shareholders should not assume the source of a distribution from the Fund is income or capital gain.

    6

Response
to Comment 12

In accordance with
the Staff’s comment, the “Distribution Tax Risk” has been revised as follows:

“DISTRIBUTION
TAX RISK. The Fund currently expects to make distributions on a regular basis. While the Fund will normally pay its income as distributions,
the Fund’s distributions may exceed the Fund’s income and gains for the Fund’s taxable year. The Fund may be required
to reduce its distributions if it has insufficient income. Additionally, there may be times the Fund needs to sell securities when it
would not otherwise do so and could cause the distributions from that sale to constitute return of capital. Distributions in excess of
the Fund’s current and accumulated earnings and profits will be treated as a return of capital. Return of capital distributions
do not represent income or gains generated by the Fund’s investment activities and should not be interpreted by shareholders as
such. Distributions in excess of the Fund’s minimum distribution requirements, but not in excess of the Fund’s earnings
and profits, will be taxable to Fund shareholders and will not constitute nontaxable returns of capital. A return of capital distribution
generally will not be taxable but will reduce the shareholder’s cost basis and will result in a higher capital gain or lower capital
loss when those Fund shares on which the distribution was received are sold. Once a Fund shareholder’s cost basis is reduced to
zero, further distributions will be treated as capital gain, if the Fund shareholder holds shares of the Fund as capital assets. Additionally,
any capital returned through distributions will be distributed after payment of Fund fees and expenses. Because the Fund’s distributions
may consist of return of capital, the Fund may not be an appropriate investment for investors who do not want their principal investment
in the Fund to decrease over time or who do not wish to receive return of capital in a given period. In the event that a shareholder purchases
shares of the Fund shortly before a distribution by the Fund, the entire distribution may be taxable to the shareholder even though a
portion of the distribution effectively represents a return of the purchase price.”

Comment
13 – Principal Risks

Please discuss the
risk of selling put options, including the risk of substantial losses.

Response
to Comment 13

The Registrant notes
that, at the present time, the Fund will create the synthetic long exposure to the Underlying ETF by primarily utilizing purchased call
options on the Underlying ETF. Nevertheless, in the future, the Fund may employ a combination strategy of purchasing call options and
selling put options at the same strike price with similar expected target maturities to gain synthetic long exposure to the Under