Correspondence 0001445546-23-001735 from FT 10638 (CIK 0001959264)
FT 10638 (CIK 0001959264)
Date: March 2, 2023 · CIK: 0001959264 · Accession: 0001445546-23-001735
AI Filing Summary & Sentiment
File numbers found in text: 333-269678
Letter
Division of Investment Management Re: FT 10638 Tactical Income Portfolio, Series 75 (the “Trust”) CIK No. 1959264 File No. 333-269678
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. If the Trust will initially invest in distressed securities as a principal strategy, please add appropriate disclosure.
Response: The Trust notes that 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 as the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure.
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
CORRESP
1
filename1.htm
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 2, 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 10638
Tactical Income Portfolio, Series 75
(the “Trust”)
CIK No. 1959264 File No. 333-269678
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. If
the Trust will initially invest in distressed securities as a principal strategy, please add appropriate disclosure.
Response: The
Trust notes that 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 as the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure.
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