Correspondence 0001445546-23-002207 from FT 10623 (CIK 0001957593)
FT 10623 (CIK 0001957593)
Date: March 24, 2023 · CIK: 0001957593 · Accession: 0001445546-23-002207
AI Filing Summary & Sentiment
File numbers found in text: 333-269793
Letter
Division of Investment Management Re: FT 10623 FT High Income Model Portfolio, 2Q ‘23 (the “Trust”) CIK No. 1957593 File No. 333-269793
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 that the disclosure states that the ETFs included in the portfolio have been selected to have exposure to different non-traditional fixed income asset types. Please consider if the word “predominately” or a similar qualifier should be added to the disclosure. Without a qualifier, there is no indication of what the principal investments are. Please revise for clarity.
Response: In accordance with the Staff’s comment, the disclosure will be revised as follows:
“The ETFs included in the portfolio have been selected by the First Trust Advisors Model Investment Committee (the “Committee”) to primarily have exposure to different non-traditional fixed income asset types, including mortgage-backed securities, high-yield bonds, senior loans, ultra-short maturity bonds (bonds with a maturity of less than one year), and exposure to non-U.S. markets.”
Risk Factors
2. If the Funds held by the Trust invest in emerging markets, 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 emerging markets, appropriate disclosure will be added to the Trust’s prospectus.
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.
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
March 24, 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 10623
FT High Income Model Portfolio, 2Q ‘23
(the “Trust”)
CIK No. 1957593 File No. 333-269793
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 that the disclosure states that the ETFs included in the portfolio have been selected to have exposure to different non-traditional
fixed income asset types. Please consider if the word “predominately” or a similar qualifier should be added to the disclosure.
Without a qualifier, there is no indication of what the principal investments are. Please revise for clarity.
Response: In
accordance with the Staff’s comment, the disclosure will be revised as follows:
“The ETFs included in the portfolio
have been selected by the First Trust Advisors Model Investment Committee (the “Committee”) to primarily have exposure to
different non-traditional fixed income asset types, including mortgage-backed securities, high-yield bonds, senior loans, ultra-short
maturity bonds (bonds with a maturity of less than one year), and exposure to non-U.S. markets.”
Risk Factors
2. If
the Funds held by the Trust invest in emerging markets, 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 emerging markets,
appropriate disclosure will be added to the Trust’s prospectus.
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.
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