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Correspondence 0001445546-23-002762 from FT 10701 (CIK 0001966151)

FT 10701 (CIK 0001966151)
Date: April 25, 2023 · CIK: 0001966151 · Accession: 0001445546-23-002762

AI Filing Summary & Sentiment

File numbers found in text: 333-270736

Date
April 25, 2023
Author
Not clearly detected
Form
CORRESP
Company
FT 10701 (CIK 0001966151)

Letter

Division of Investment Management Re: FT 10701 FT Income Portfolio, Series 20 (the “Trust”) CIK No. 1966151 File No. 333-270736

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 underlying ETFs invest in bonds that reference LIBOR, please add risk disclosure.

Response:If, based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in bonds that reference LIBOR, appropriate disclosure will be added to the Trust’s prospectus.

2.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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CORRESP
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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

April 25, 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 10701

    FT Income Portfolio, Series 20

    (the “Trust”)

    CIK No. 1966151 File No. 333-270736

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 underlying ETFs invest in bonds that reference LIBOR, please add risk disclosure.

Response:If,
based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in bonds that reference LIBOR, appropriate disclosure
will be added to the Trust’s prospectus.

2.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