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SEC Company Response from Abacus FCF ETF Trust (CIK 0001604813) — Jan 9, 2026

Abacus FCF ETF Trust (CIK 0001604813)
Date: Jan. 9, 2026 · CIK: 0001604813 · Accession: 0002071844-26-000085

AI Filing Summary & Sentiment

File numbers found in text: 333-198603, 811-22995

Date
January 9, 2026
Author
/s/ Joel D Corriero
Form
CORRESP
Company
Abacus FCF ETF Trust (CIK 0001604813)

Letter

Via EDGAR Transmission Division of Investment Management Washington, D.C. 20549 Re: Abacus FCF ETF Trust (the “Trust”) File Nos. 333-198603 and 811-22995

Dear Ms. Miller:

I am writing in response to comments you provided to me during a telephone conversation on January 6, 2026, with respect to the Trust’s Form N-CSR filed with the U.S. Securities and Exchange Commission on October 9, 2025. The Staff’s comments as we understand them from our telephone call are set forth below and are followed by the Trust’s responses.

1.

COMMENT: In the Trust’s Statement of Operations, please update the caption to state that the securities lending is presented net of any rebates or fees paid to borrowers.

RESPONSE: The Trust will update the caption as requested in its next Form N-CSR filing.

2.

COMMENT: The Staff noted that certain series of the Trust (“Funds”) held real estate investment trusts (“REITs”). Please consider adding disclosure to the Notes to Financial Statements to state that the distributions received from REITs may be classified as dividends, capital gains and/or return of capital.

RESPONSE: The Trust will add the requested disclosure to the Notes to Financial Statements in its next Form N-CSR filing to the extent any of the Funds hold REITs.

* * *

Thank you for your comments. Please feel free to contact me at 215-564-8528 or, in my absence, Fabio Battaglia at 215-564-8077, if you have any additional questions or comments.

Best regards,
/s/ Joel D Corriero

Show Raw Text
CORRESP
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filename1.htm

                2005 Market Street

                Suite 2600

                Philadelphia, PA 19103

                T: 215.564.8000

                Joel Corriero

                Partner

                jcorriero@stradley.com

                215.564.8528

      January 9, 2026

      Via EDGAR Transmission

      Megan Miller

      Division of Investment Management

      U.S. Securities and Exchange Commission

      100 F Street, N.E.

      Washington, D.C. 20549

              Re:

              Abacus FCF ETF Trust (the “Trust”)

              File Nos. 333-198603 and 811-22995

      Dear Ms. Miller:

      I am writing in response to comments you provided to me during a telephone conversation on January 6, 2026, with respect to the Trust’s Form N-CSR filed with the U.S. Securities and Exchange Commission on October 9,
        2025. The Staff’s comments as we understand them from our telephone call are set forth below and are followed by the Trust’s responses.

              1.

              COMMENT: In the Trust’s Statement of Operations, please update the caption to state that the securities lending is presented net of any rebates or fees paid to
                borrowers.

              RESPONSE: The Trust will update the caption as requested in its next Form N-CSR filing.

             2.

              COMMENT: The Staff noted that certain series of the Trust (“Funds”) held real estate investment trusts (“REITs”). Please consider adding disclosure to the Notes to
                Financial Statements to state that the distributions received from REITs may be classified as dividends, capital gains and/or return of capital.

              RESPONSE: The Trust will add the requested disclosure to the Notes to Financial Statements in its next Form N-CSR filing to the extent any of the Funds hold REITs.

      * * *

      Thank you for your comments.  Please feel free to contact me at 215-564-8528 or, in my absence, Fabio Battaglia at 215-564-8077, if you have any additional questions or comments.

      Best regards,

      /s/ Joel D Corriero

      Joel D Corriero

      Partner

              cc:

              Derin Cohen

              Fei Xue

              Fabio Battaglia

        Stradley Ronon Stevens
            & Young, LLP  |  stradley.com

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