Correspondence 0001445546-23-000267 from FT 10544 (CIK 0001951255)
FT 10544 (CIK 0001951255)
Date: Jan. 18, 2023 · CIK: 0001951255 · Accession: 0001445546-23-000267
AI Filing Summary & Sentiment
File numbers found in text: 333-268899
Letter
Division of Investment Management Re: FT 10544 Tactical Income Portfolio, Series 74 (the “Trust”) CIK No. 1951255 File No. 333-268899
Dear Mr. Cowan:
We received your comments regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comments.
Comments
Risk Factors
1. Please clarify whether the Trust initially invests in distressed securities.
Response: The Trust notes that the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure. While distressed debt securities do not rise to a level of principal investment for the Trust, and the Trust does not anticipate initially investing in distressed debt securities, the Trust believes the current risk disclosure is necessary for investor comprehension.
2. If the Trust will have material exposure to China, please disclose the risks associated with investments in China.
Response:If the Trust has material exposure to China based on its final portfolio, relevant risk disclosure will be added to the Trust’s 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
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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
January 18, 2023
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 10544
Tactical Income Portfolio, Series 74
(the “Trust”)
CIK No. 1951255 File No. 333-268899
Dear Mr. Cowan:
We received your comments
regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comments.
Comments
Risk Factors
1. Please
clarify whether the Trust initially invests in distressed securities.
Response:
The Trust notes that the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure.
While distressed debt securities do not rise to a level of principal investment for the Trust, and the Trust does not anticipate initially
investing in distressed debt securities, the Trust believes the current risk disclosure is necessary for investor comprehension.
2. If
the Trust will have material exposure to China, please disclose the risks associated with investments in China.
Response:If the Trust has
material exposure to China based on its final portfolio, relevant risk disclosure will be added to the Trust’s 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