SEC Company Response from FT 8713 (CIK 0001803645) — May 11, 2020
FT 8713 (CIK 0001803645)
Date: May 11, 2020 · CIK: 0001803645 · Accession: 0001445546-20-002428
AI Filing Summary & Sentiment
File numbers found in text: 333-237602
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Chapman and Cutler LLP 111 West Monroe Street
Chicago, Illinois 60603
May 11, 2020
Mark Cowan
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549
Re: FT 8713
Merrill 2020 Quality Opportunities Portfolio
(the "Trust")
CIK No. 1803645 File No. 333-237602
--------------------------------------------------------------------------------
Dear Mr. Cowan:
We received your additional comments regarding the Registration Statement
for the above captioned Trust. This letter serves to respond to your comments.
COMMENTS
General
-------
1. PLEASE CLARIFY THAT UNITS ARE FOR SALE ONLY TO MERRILL LYNCH
("MERRILL") CUSTOMERS.
Response: Pursuant to the Staff's request, the following disclosure will
be added to the end of the first paragraph under the section entitled "The FT
Series Defined:" Units are available exclusively through Merrill Lynch, Pierce,
Fenner & Smith Incorporated.
Portfolio
---------
2. PLEASE PROVIDE MORE INFORMATION ON HOW SECURITIES ARE SELECTED FOR THE
TRUST.
Response: Pursuant to the Staff's request, the first paragraph of the
section entitled "Portfolio Selection Process" will be replaced with the
following:
The stocks included in the portfolio were selected by First Trust,
the Sponsor of the Trust, from a universe of stocks included in a research
report published by BofA Global Research on March 23, 2020. The stocks
included in the report are considered by BofA Global Research to be likely
to fare better in a recessionary environment and in a volatile market. The
report includes stocks that BofA Global Research believes could benefit
from social distancing measures currently underway or stocks with an
outlook that does not materially rely on China's demand or supply. In
generating the final list of stocks included in the report, BofA Global
Research analysts explored the ramifications of travel bans, as well as
broader "stay at home" mandates, and highlighted areas which might endure
balance sheet stress in case of prolonged travel restrictions. BofA Global
Research publishes its research report without regard to the Trust or its
Unit holders. BofA Global Research has no obligation or liability in
connection with the investment decisions made by the Sponsor of the Trust
in connection with the Trust.
In determining the final portfolio for the Trust, the Sponsor
reviewed each stock included in the report to determine if it can support
the buying and selling of the anticipated number of shares on any given
day to meet the Trust's purchases and/or redemption requirements. The
Sponsor looked at the size of the market as well as the volume of trading
that occurs in each stock on a daily basis. The Sponsor also made sure
each stock being considered is suitable to be included in a unit
investment trust. The selected stocks come from various market sectors and
market capitalizations and might not include every stock included in the
research report.
3. PLEASE TAILOR THE DISCLOSURE IN THE LAST PARAGRAPH OF THE SECTION
ENTITLED "PORTFOLIO SELECTION PROCESS," TO THIS PARTICULAR TRUST AND ITS
INVESTMENTS.
Response: The second and third paragraphs in the section entitled
"Portfolio Selection Process" will be removed from the prospectus. Additionally,
once the Trust's final portfolio is determined, any significant exposure to
companies in a specific market capitalization range (e.g., large-cap companies)
will be disclosed and the relevant risk disclosure will be included in the
prospectus.
We appreciate your prompt attention to this Registration Statement. If you
have any questions or comments or would like to discuss our responses to your
questions please feel free to contact Brian D. Free at (312) 845-3017 or the
undersigned at (312) 845-3721.
Very truly yours,
CHAPMAN AND CUTLER LLP
By /s/ Daniel J. Fallon
________________________
Daniel J. Fallon
</TEXT>
</DOCUMENT>