Correspondence 0001445546-25-002405 from FIRST TRUST EXCHANGE-TRADED FUND VI (CIK 0001552740)
FIRST TRUST EXCHANGE-TRADED FUND VI (CIK 0001552740)
Date: April 2, 2025 · CIK: 0001552740 · Accession: 0001445546-25-002405
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 comments 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 February 27, 2025 (the “Registration Statement”). The Registration Statement relates to the First Trust Small Cap BuyWrite Income 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 notes that the Fund pursues its investment objectives by investing primarily in small cap equity securities listed on U.S. exchanges and by utilizing a buy-write “option strategy” consisting of writing (selling) U.S. exchange-traded call options on the Russell 2000 Index or small cap equity exchange-traded funds. The Staff requests additional disclosure be added to the Fund’s prospectus regarding how the Fund selects the underlying small cap equity securities.
Response to Comment 1
In accordance with the Staff’s comment, the below disclosure will be added to the section of the prospectus entitled “Principal Investment Strategies” at the annual update to the Fund’s Registration Statement:
“The selected portfolio of equity securities will seek to provide a return reasonably correlated to the Russell 2000 Index over the course of a full market cycle.”
Comment 2 – General
The Staff notes that the Fund’s website does not disclose any options positions, but the disclosure in the Registration Statement states that the Fund will utilize a buy-write option strategy consisting of writing call options on the Russell 2000® Index or small cap equity exchange-traded funds. Please reconcile the discrepancy.
Response to Comment 2
The Registrant notes that the Fund was in its initial invest-up period when the Staff viewed the holdings of the Fund publicly available on the Fund’s website. The Registrant confirms that the options trades have subsequently been placed and the holdings of the Fund available on the Fund’s website reflect that the Fund is currently invested in options.
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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
April 2, 2025
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 comments 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 February 27,
2025 (the “Registration Statement”). The Registration Statement relates to the First Trust Small Cap BuyWrite Income
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 notes that
the Fund pursues its investment objectives by investing primarily in small cap equity securities listed on U.S. exchanges and by utilizing
a buy-write “option strategy” consisting of writing (selling) U.S. exchange-traded call options on the Russell 2000 Index
or small cap equity exchange-traded funds. The Staff requests additional disclosure be added to the Fund’s prospectus regarding
how the Fund selects the underlying small cap equity securities.
Response
to Comment 1
In accordance with
the Staff’s comment, the below disclosure will be added to the section of the prospectus entitled “Principal Investment Strategies”
at the annual update to the Fund’s Registration Statement:
“The
selected portfolio of equity securities will seek to provide a return reasonably correlated to the Russell 2000 Index over the course
of a full market cycle.”
Comment
2 – General
The Staff notes that
the Fund’s website does not disclose any options positions, but the disclosure in the Registration Statement states that the Fund
will utilize a buy-write option strategy consisting of writing call options on the Russell 2000® Index or small cap equity
exchange-traded funds. Please reconcile the discrepancy.
Response
to Comment 2
The Registrant notes
that the Fund was in its initial invest-up period when the Staff viewed the holdings of the Fund publicly available on the Fund’s
website. The Registrant confirms that the options trades have subsequently been placed and the holdings of the Fund available on the Fund’s
website reflect that the Fund is currently invested in options.
********
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