Correspondence 0001445546-24-004189 from FIRST TRUST EXCHANGE-TRADED FUND VI (CIK 0001552740)
FIRST TRUST EXCHANGE-TRADED FUND VI (CIK 0001552740)
Date: June 6, 2024 · CIK: 0001552740 · Accession: 0001445546-24-004189
AI Filing Summary & Sentiment
File numbers found in text: 333-182308, 811-22717
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 VI (the “Trust”) File Nos. 333-182308; 811-22717
Dear Ms. Rowland:
This letter responds to your additional comment regarding the registration statement filed on Form N-1A for First Trust Exchange-Traded Fund VI (the “Registrant” or “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”) on March 26, 2024 (the “Registration Statement”). The Registration Statement relates to the First Trust SMID Capital Strength ETF (formerly Mid Cap US Equity Select ETF) (the “Fund”), a series of the Trust. References herein to the “Prior Correspondence Letter” refer to the correspondence filed by the Trust with the Staff on May 29, 2024. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.
Comment 1 – Principal Investment Strategies
The Staff reiterates its comment set forth as Comment 2 of the Prior Correspondence Letter, which was as follows:
The Staff notes the references to “According to the Index Provider” set forth in the second third and fourth paragraphs of the section entitled “Principal Investment Strategies.” Please delete such references from the disclosure as the Staff believes the disclosure contained in the Principal Investment Strategies section should be the disclosure of the Fund.
Response to Comment 1
The Registrant respectfully declines to revise the disclosure as requested. The Registrant has determined that the use of such disclosure is appropriate because the Advisor relies exclusively on information provided by the Index Provider with respect to the Index methodology, calculation and constitution and therefore such statements are factually accurate. However, the Registrant will continue to evaluate the appropriateness of the referenced disclosure and notes that the Adviser maintains oversight of service providers.
********
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
June 6, 2024
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 VI (the “Trust”)
File Nos. 333-182308; 811-22717
Dear Ms. Rowland:
This letter responds
to your additional comment regarding the registration statement filed on Form N-1A for First Trust Exchange-Traded Fund VI (the “Registrant”
or “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”) on March 26,
2024 (the “Registration Statement”). The Registration Statement relates to the First Trust SMID Capital Strength
ETF (formerly Mid Cap US Equity Select ETF) (the “Fund”), a series of the Trust. References herein to the “Prior
Correspondence Letter” refer to the correspondence filed by the Trust with the Staff on May 29, 2024. Capitalized terms used herein,
but not otherwise defined, have the meanings ascribed to them in the Registration Statement.
Comment
1 – Principal Investment Strategies
The Staff reiterates
its comment set forth as Comment 2 of the Prior Correspondence Letter, which was as follows:
The Staff notes the
references to “According to the Index Provider” set forth in the second third and fourth paragraphs of the section entitled
“Principal Investment Strategies.” Please delete such references from the disclosure as the Staff believes the disclosure
contained in the Principal Investment Strategies section should be the disclosure of the Fund.
Response
to Comment 1
The Registrant respectfully
declines to revise the disclosure as requested. The Registrant has determined that the use of such disclosure is appropriate because the
Advisor relies exclusively on information provided by the Index Provider with respect to the Index methodology, calculation and constitution
and therefore such statements are factually accurate. However, the Registrant will continue to evaluate the appropriateness of the referenced
disclosure and notes that the Adviser maintains oversight of service providers.
********
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
-2-