Correspondence 0001445546-23-003481 from FT 10780 (CIK 0001969538)
FT 10780 (CIK 0001969538)
Date: May 22, 2023 · CIK: 0001969538 · Accession: 0001445546-23-003481
AI Filing Summary & Sentiment
File numbers found in text: 333-271492
Letter
Division of Investment Management Re: FT 10780 Balanced Income Equity and ETF Portfolio, Series 62 (the “Trust”) CIK No. 1969538 File No. 333-271492
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.If a principal investment of the Trust, please also add distressed debt securities to the list of investment types that the ETF portion of the Trust invests in (consistent with the risk disclosure).
Response:The Trust notes that while distressed debt securities do not rise to a level of principal investment for the Trust, the Trust believes the current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure. As such, the Trust respectfully declines to add distressed debt securities to the Portfolio Selection Process section.
Risk Factors
2.If using the language “companies with various market capitalizations” in the Additional Portfolio Contents section is accurate, please consider whether principal risks associated with investing in small and/or mid capitalization companies should be included (rather than as non-principal risks).
Response:If, based on its final portfolio, the Trust has exposure to small and/or mid-capitalization companies either directly or through the underlying Funds, relevant risk disclosure will be added to the Trust’s prospectus. Otherwise, the “Additional Portfolio Contents” section will be revised.
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
May 22, 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 10780
Balanced Income Equity and ETF Portfolio, Series 62
(the “Trust”)
CIK No. 1969538 File No. 333-271492
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.If
a principal investment of the Trust, please also add distressed debt securities to the list of investment types that the ETF portion of
the Trust invests in (consistent with the risk disclosure).
Response:The
Trust notes that while distressed debt securities do not rise to a level of principal investment for the Trust, the Trust believes the
current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially
related to the high-yield securities risk disclosure. As such, the Trust respectfully declines to add distressed debt securities to the
Portfolio Selection Process section.
Risk Factors
2.If
using the language “companies with various market capitalizations” in the Additional Portfolio Contents section is accurate,
please consider whether principal risks associated with investing in small and/or mid capitalization companies should be included (rather
than as non-principal risks).
Response:If,
based on its final portfolio, the Trust has exposure to small and/or mid-capitalization companies either directly or through the underlying
Funds, relevant risk disclosure will be added to the Trust’s prospectus. Otherwise, the “Additional Portfolio Contents”
section will be revised.
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