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Faegre Drinker Biddle & Reath LLP

320 South Canal Street, Suite 3300

Chicago, IL 60606

www.faegredrinker.com

June 5, 2023

Via EDGAR Transmission

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Karen Rossotto

Re: First Trust Hedged Strategies Fund (the “Fund”
or “Registrant”)

  Registration Statement on Form N-2

  File Nos. 333-270842 and 811-23857

Dear Ms. Rossotto:

The following responds to the comments provided
via email on April 26, 2023, in connection with the Securities and Exchange Commission (“SEC”) staff’s review of
a registration statement (the “Registration Statement”) filed by the Fund on Form N-2 under the Investment Company Act
of 1940, as amended (the “Investment Company Act”) and Securities Act of 1933, as amended (the “Securities Act”).
The changes to the Fund’s disclosure discussed below are reflected in Pre-Effective Amendment No. 1 to the Fund’s Registration
Statement (the “Revised Registration Statement”).

For your convenience, we have repeated each comment
below, and the Fund’s responses follow your comments. Capitalized terms not otherwise defined herein shall have the meaning ascribed
to them in the Registration Statement, unless otherwise indicated.

General Comments

 1. We note that portions of the registration statement are incomplete. We may have additional comments on such
portions when you complete them in a pre-effective amendment, on disclosures made in response to this letter, on information supplied
supplementally, or on exhibits added in any amendments.

Response:
The Registrant confirms that all missing information and all exhibits will be filed in a pre-effective amendment to the Registration Statement.
The Registrant further acknowledges that the Staff may have additional comments after such information and exhibits are provided.

 2. In addition to co-investment exemptive relief from the provisions of section 17(d) of the Investment
Company Act, please supplementally explain if the Fund has submitted or intends to submit any other exemptive applications or a no-action
request in connection with the registration statement. Please inform us of the anticipated timing of any applications or requests for
relief.

Response:
The Registrant has not submitted, and does not intend to apply for, any other exemptive application or a no-action request in addition
to co-investment exemptive relief.

 3. Please confirm that the Fund does not intend to issue debt securities or preferred shares within a year
from the effective date of the registration statement. If the Fund plans to issue preferred shares within a year from the effectiveness
of the registration statement, please include additional disclosure of risks to shareholders in the event of a preferred shares offering.

Response:
The Registrant confirms that it does not intend to issue debt securities or preferred shares within a year from the effective date of
the registration statement.

 4. The registration statement appears to contemplate a transaction with the Predecessor Fund that will occur
after your decision to become registered as an investment company.

Please tell us how this transaction
will be structured to comply with section 17 of the Investment Company Act, including any no-action relief upon which you intend to rely.

Response:
The Fund will be acquiring all of the assets of the Predecessor Fund pursuant to an Agreement and Plan of Exchange and Reorganization
(the “Plan”). The Plan provides that the reorganization will comply with the terms of paragraphs (b), (c), (d), (e), (f) and
(g) of Rule 17a-7 under the Investment Company Act and the provisions of Rule 17a-8 under the Investment Company Act (as these provisions apply to
a merger between an unregistered fund that is eligible to rely on that rule and a registered investment company), in accordance with
the GuideStone Financial, et al., SEC No-Action Letter (pub. avail. December 27, 2006). Consistent with the requirements set forth
in the GuideStone Financial no-action letter:

 1) The Fund will be a shell portfolio as of the time of the reorganization;

 2) The assets of the Predecessor Fund will consist of securities that are appropriate, in type and amount,
for investment by the Fund in light of its investment objectives and policies;

 3) The Predecessor Fund will transfer all of its portfolio securities at the time of the reorganization to
the Fund;

 4) The Fund has the same procedures for determining net asset value as the Predecessor Fund and will follow
those procedures in determining the amount of shares to be issued in the reorganization;

 5) The transfer of securities and shares between the Predecessor Fund and the Fund will be effected simultaneously;

 6) The Fund will comply with the recordkeeping requirements described in the GuideStone Financial no-action
letter;

 7) The Investment Adviser, consistent with its fiduciary duties, has disclosed to the independent trustees
of the  Fund the existence of, and all the material facts relating to, any conflicts of interest between the Adviser and the
Fund with regard to the reorganization to facilitate the ability of the independent trustees to evaluate and approve the reorganization;
and

 8) The Investment Adviser, not the Predecessor Fund or the Fund, will bear the costs associated with the
reorganization.

 5. Please tell us if you have presented or will present any "test the waters" materials to potential
investors in connection with this offering. If so, please provide us with copies of such materials.

Response:
The Registrant confirms that it has not presented, and will not present, any “test-the-water” materials to potential investors
in connection with this offering.

Prospectus

 6. In the third paragraph on the cover, the disclosure states that simultaneous with the commencement of the
Fund's operations, the Predecessor Fund will be reorganized into the Fund. Please disclose how the private fund holders' shares will be
valued for purposes of the reorganization. Will there be any dilution for other shareholders who purchase shares in the initial offering?
If so, please provide appropriate cover page and prospectus disclosure. Please explain in correspondence what information investors
will have available to them about the Predecessor Fund and its portfolio prior to purchasing Fund shares.

Response:
For purposes of the reorganization, the net asset value of the Predecessor Fund will be determined using the same valuation procedures
as the Fund. The Predecessor Fund will transfer all of its assets simultaneous with the Fund’s issuance of shares equal in net asset
value. Subsequently, the net asset value of the Fund’s shares will be determined daily as part of a continuous offering and other
shareholders will purchase at the net asset value per share next determined using the same valuation procedures. Also, with respect to
information investors will have available to them about the Predecessor Fund, the registration statement will contain audited financial
statements as of December 31, 2022, including the schedule of investments as of the same date. The Registrant respectfully notes
that the Predecessor Fund has substantially similar investment objectives and strategies as the Fund. Accordingly, the Registrant affirms
that there will be no dilution to other shareholders who purchase shares of the Fund after the reorganization.

 7. In footnote 1 to the table on the cover, the disclosure in the last two sentences states "The minimum
initial investment in Class A Shares by any investor is $[25,000] and the minimum initial investment in Class I Shares by any
investor is $[25,000]. However, the Fund, in its sole discretion, may accept investments below this minimum." Please explain to us
the circumstances under which the Adviser may reduce the stated minimum investment.

Response:
The Fund, in its sole discretion, may accept investments below this minimum in certain circumstances. For example, (i) Shares
may be purchased by Trustees of the Fund, their family members, and affiliates of the Investment Adviser, without being subject to
the minimum investment requirements, and (ii) investors subscribing through a given broker/dealer or registered investment
adviser may have interests aggregated to meet these minimums, so long as aggregated amounts are not less than $25,000.

 8. In Investment Objective and Strategies, please explain in the disclosure what a hedge fund is. Please
also specify the Fund's principal strategies that are speculative (e.g., use of leverage) and include a cross-reference to the
disclosure regarding the risks associated with these strategies. See Form N-2, Item 1.1.j. and the Guidelines to Form N-2.
Guide 6.

Response:
The Registrant has revised the disclosure as requested.

 9. In Interval Fund, please specify the intervals between deadlines for repurchase requests and pricing
and repayment. See Guide 10 to Form N-2.

Response:
The Registrant has revised the disclosure as requested.

Fund Summary

Fees
and Expenses (pages 3-4)

 10. In the last paragraph on page 4, regarding the Waiver, please disclose that the Adviser's recoupment
may not exceed the net expense ratio in place at the time amounts were waived, and may not exceed the Fund's current net expense ratio.

Response:
The Registrant has revised the disclosure as follows:

“For a period not to exceed three
years from the date on which a Waiver is made, the Investment Adviser may recoup amounts waived or assumed, provided the Fund is able
to effect such recoupment and remain in compliance with the expense limit in effect at the time of the Waiver and the expense limit in
effect at the time of the recoupment.”

Fund Fees and Expenses

 11. In the narrative preceding the fee table, please disclose the amount of Fund leverage assumed in making
the fee calculations.

Response:
The Registrant has revised the disclose as requested.

 12. Please revise the fee table footnotes to explain any material assumptions used in estimating expenses. To
the extent an estimate is materially different from what the Predecessor Fund would have disclosed, had it been registered previously,
please explain the reasons for the variance in correspondence.

Response: The Registrant has revised the fee table footnotes to reflect material assumptions used in estimating expenses. The Registrant has been
advised by the Investment Adviser that the estimates are not materially different from the estimates that the Predecessor Fund would have
been expected to disclose, had it been registered previously.

Investment Objective and Strategies

Investment Objective

 13. In the last line on page 9, the disclosure states "the Fund's investment objective is non-fundamental
and may be changed by the Board without the approval of shareholders." If shareholders will be given notice of a change in the Fund's
investment objective, please disclose so.

Response:
The Registrant affirms that Shareholders will be given notice and has added the requested disclosure.

Investment Strategies and Overview
of Investment Process

 14. On page 10, in Credit, the disclosure states that the Fund may invest in Investment Funds using
a "distressed and high-yield sub-strategy" that "involves investing in the securities of companies ... having below investment
grade credit ratings." Please disclose that such securities are commonly referred to as ''junk" and may be considered speculative.

Response:
The Registrant has revised the disclosure as follows (new language is underlined):

“The distressed and high-yield
sub-strategy involves investing in the securities of companies experiencing financial or operational difficulties or otherwise having
below investment grade credit ratings. These securities may trade at substantial discounts to par value and are commonly referred to
as “high yield” securities or “junk bonds.” The Fund’s exposure to below investment grade instruments involves
certain risks, including speculation with respect to the issuer’s capacity to pay interest and repay principal when due. See “PRINCIPAL
RISK FACTORS — LOW CREDIT QUALITY SECURITIES” below.

 15. On page 12, in Investment Process, the disclosure in the second sentence of the first paragraph
refers to the Investment Adviser's "operational due diligence" as part of its "multi-step Underlying Manager selection
process." Please disclose in this section how the Investment Adviser conducts its "operational due diligence" (i.e.,
what does the Investment Adviser's due diligence entail?).

Response:
The Registrant has added the following paragraph to the “Investment Process” section of the Prospectus in the Revised Registration
Statement:

“The investment selection
process is managed by the Investment Adviser’s Research Team, FT Alternative Investment Research, which maintains broad
coverage of all of the Investment Adviser’s investment portfolios. This dedicated team of roughly a dozen professionals spends
the vast majority of their time conducting investment due diligence and operational due diligence on prospective managers, as well
as oversight for existing managers with which the Fund has capital invested. The initial diligence process is highly iterative and
consists of several initial calls and meetings to better understand an Underlying Manager’s pedigree, investment strategy,
operating history, proprietary workflow, portfolio construction methodology, risk management philosophy, and broader business plan.
Those initial calls and meetings ultimately culminate with an exhaustive onsite meeting with the key front office team members from
an investment due diligence perspective, and mid/back-office resources from an operational due diligence perspective. Ultimately, if
an Underlying Manager makes it through each one of those iterations, it is presented to the Investment Adviser’s investment
committee for formal approval. Approved Underlying Managers will be considered for different products depending on their suitability
for the portfolios of each product as well as their correlation to other Underlying Managers that may already populate those
portfolios. The Fund seeks to     balance exposure across a varied subset of Underlying Managers that fit the
Fund’s investment strategies and objectives, as well as the Fund’s liquidity requirements.”

 16. On page 13, in the first paragraph of Investment Policies and Restrictions, the disclosure states
 "The Fund will continue to attempt to diversify its holdings in Investment Funds" and it "also expects to continue
to diversify its holdings among broad categories of investment strategies [emphasis added]." As the Fund is categorized as
non-diversified under the Investment Company Act, to avoid confusion, please either delete or replace the word "diversify" each
time it is used here.

Response:
The Registrant has revised the disclosure as requested.

 17. On page 13, in the penultimate sentence of No Restrictions on Investment Policies, the disclosure
states that "the Investment Adviser will seek to capitalize on attractive opportunities wherever they might be," and in the
following sentence, that "the Investment Adviser may employ other strategies or techniques that it considers appropriate and in the
best interest of the Fund." The Fund is conducting a continuous offering that requires it to consider the accuracy and completeness
of its disclosures - including its strategies and risks disclosures - on an on-going basis. We do not believe simply referencing "other
strategies or techniques" would be sufficient disclosures if such strategies constitute principal strategies. Please clarify whether
such "other strategies and techniques" are expected to constitute principal strategies and revise as necessary.

Response:
The Registrant has revised the disclosure to clarify that such “other strategies or techniques” are not expected to constitute
principal strategies.

Pri