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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

Date
May 11, 2020
Author
Not clearly detected
Form
CORRESP
Company
FT 8713 (CIK 0001803645)

Letter

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

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>