Correspondence 0001445546-23-002211 from FT 10656 (CIK 0001960243)
FT 10656 (CIK 0001960243)
Date: March 24, 2023 · CIK: 0001960243 · Accession: 0001445546-23-002211
AI Filing Summary & Sentiment
File numbers found in text: 333-269854
Letter
Division of Investment Management Re: FT 10656 FT High Income Municipal Model Portfolio, Series 2 (the “Trust”) CIK No. 1960243 File No. 333-269854
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 distressed debt securities is a principal risk factor. If investment in distressed municipal bonds is a principal investment for the Trust, please add appropriate disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has material exposure to distressed municipal bonds, relevant disclosure will be added to the Trust’s prospectus.
Risk Factors
2. If the Trust will have material exposure to the municipal bonds issued by any jurisdiction experiencing financial distress, please identify that jurisdiction and add relevant risk disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has material exposure to any jurisdiction experiencing financial distress, relevant 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 10656
FT High Income Municipal Model Portfolio, Series 2
(the “Trust”)
CIK No. 1960243 File No. 333-269854
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 distressed debt securities is a principal risk factor. If investment in distressed municipal bonds is a principal investment
for the Trust, please add appropriate disclosure.
Response: If,
based on the Trust’s final portfolio, the Trust has material exposure to distressed municipal bonds, relevant disclosure will be
added to the Trust’s prospectus.
Risk Factors
2. If
the Trust will have material exposure to the municipal bonds issued by any jurisdiction experiencing financial distress, please identify
that jurisdiction and add relevant risk disclosure.
Response: If,
based on the Trust’s final portfolio, the Trust has material exposure to any jurisdiction experiencing financial distress, relevant
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