Correspondence 0001445546-23-000962 from FT 10570 (CIK 0001953062)
FT 10570 (CIK 0001953062)
Date: Feb. 1, 2023 · CIK: 0001953062 · Accession: 0001445546-23-000962
AI Filing Summary & Sentiment
File numbers found in text: 333-269034
Letter
Division of Investment Management Re: FT 10570 FT Income Portfolio, Series 19 (the “Trust”) CIK No. 1953062 File No. 333-269034
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
Portfolio
1.The Staff notes the disclosure states that the research department emphasizes Funds that have exposure to convertible securities. If, based on the Trust’s final portfolio, the Trust has exposure to contingent convertible securities (“CoCos”), please revise the disclosure to include CoCos and provide a definition.
Response:The Trust respectfully points the Staff to the parenthetical after the above-referenced disclosure which states “convertible securities (including contingent convertible securities).” The Trust has added the defined term “CoCos” to the parenthetical.
Risk Factors
2.The Staff notes that the disclosure states, “These measures have included, among other policy responses, a $700 billion quantitative easing program, a reduction of the Federal funds rate to near-zero, and numerous economic stimulus packages. The impact of these and additional measures taken in the future, and whether they will be effective in mitigating economic and market disruptions, including upward pressure on prices, will not be known for some time.” Please clarify whether this is necessary and if the second sentence is still accurate.
Response:The disclosure has been revised as follows:
“As a result of the COVID-19 pandemic, governments and central banks, including the Federal Reserve, took extraordinary and unprecedented actions to support local and global economies and financial markets. These measures included, among other policy responses, a $700 billion quantitative easing program, a reduction of the Federal funds rate to near-zero, and numerous economic stimulus packages, which largely ended in mid-2022.”
Additionally, given the proximity of the measures taken by governments and central banks to today’s current market climate, the Trust believes the disclosure, as currently presented, is accurate. The impact of such measures has yet to be seen given current volatility in the market and the uncertainty surrounding a potential recession.
3.If the Funds held by the Trust invest in subprime residential mortgage loans, please add relevant risk disclosure.
Response:In accordance with the Staff’s comment, if the Trust’s final portfolio has exposure to funds that invest in subprime residential mortgage loans, appropriate disclosure will be added to the Trust’s prospectus.
4.If the Funds held by the Trust invest in bonds that reference LIBOR, please add relevant risk disclosure.
Response:If the Trust’s final portfolio has exposure to Funds that invest in bonds that reference LIBOR, appropriate 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
February 1, 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 10570
FT Income Portfolio, Series 19
(the “Trust”)
CIK No. 1953062 File No. 333-269034
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
Portfolio
1.The
Staff notes the disclosure states that the research department emphasizes Funds that have exposure to convertible securities. If, based
on the Trust’s final portfolio, the Trust has exposure to contingent convertible securities (“CoCos”), please revise
the disclosure to include CoCos and provide a definition.
Response:The
Trust respectfully points the Staff to the parenthetical after the above-referenced disclosure which states “convertible securities
(including contingent convertible securities).” The Trust has added the defined term “CoCos” to the parenthetical.
Risk Factors
2.The
Staff notes that the disclosure states, “These measures have included, among other policy responses, a $700 billion quantitative
easing program, a reduction of the Federal funds rate to near-zero, and numerous economic stimulus packages. The impact of these and additional
measures taken in the future, and whether they will be effective in mitigating economic and market disruptions, including upward pressure
on prices, will not be known for some time.” Please clarify whether this is necessary and if the second sentence is still accurate.
Response:The
disclosure has been revised as follows:
“As a result of the COVID-19 pandemic,
governments and central banks, including the Federal Reserve, took extraordinary and unprecedented actions to support local and global
economies and financial markets. These measures included, among other policy responses, a $700 billion quantitative easing program, a
reduction of the Federal funds rate to near-zero, and numerous economic stimulus packages, which largely ended in mid-2022.”
Additionally, given the proximity
of the measures taken by governments and central banks to today’s current market climate, the Trust believes the disclosure, as
currently presented, is accurate. The impact of such measures has yet to be seen given current volatility in the market and the uncertainty
surrounding a potential recession.
3.If
the Funds held by the Trust invest in subprime residential mortgage loans, please add relevant risk disclosure.
Response:In
accordance with the Staff’s comment, if the Trust’s final portfolio has exposure to funds that invest in subprime residential
mortgage loans, appropriate disclosure will be added to the Trust’s prospectus.
4.If
the Funds held by the Trust invest in bonds that reference LIBOR, please add relevant risk disclosure.
Response:If the Trust’s
final portfolio has exposure to Funds that invest in bonds that reference LIBOR, appropriate 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