Correspondence 0001445546-23-004107 from FT 10800 (CIK 0001970984)
FT 10800 (CIK 0001970984)
Date: June 27, 2023 · CIK: 0001970984 · Accession: 0001445546-23-004107
AI Filing Summary & Sentiment
File numbers found in text: 333-271756
Letter
Division of Investment Management Re: FT 10800 FT High Income Model Portfolio, 3Q '23 (the “Trust”) CIK No. 1970984 File No. 333-271756
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 the disclosure states that ETFs included in the portfolio provide exposure to non-U.S. markets. Please clarify this (i.e., does the Trust intend to invest in foreign sovereign debt and/or debt securities issued by corporations located outside the United States).
Response:The Trust notes that it will only hold ETFs in its portfolio and as such will not directly invest in foreign sovereign debt or debt securities issued by corporations located outside the United States. Further, the Trust only seeks exposure to non-U.S. markets through the underlying ETFs held by the Trust, certain of which may invest in foreign sovereign debt and/or debt securities issued by foreign corporations. The disclosure will be revised accordingly.
Risk Factors
2.If the Funds held by the Trust invest in emerging markets, 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 emerging markets, appropriate disclosure will be added to the Trust’s prospectus.
3.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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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T 312.845.3000
F 312.701.2361
www.chapman.com
June 27, 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 10800
FT High Income Model Portfolio, 3Q '23
(the “Trust”)
CIK No. 1970984 File No. 333-271756
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 the disclosure states that ETFs included in the portfolio provide exposure to non-U.S. markets. Please clarify this (i.e.,
does the Trust intend to invest in foreign sovereign debt and/or debt securities issued by corporations located outside the United States).
Response:The
Trust notes that it will only hold ETFs in its portfolio and as such will not directly invest in foreign sovereign debt or debt securities
issued by corporations located outside the United States. Further, the Trust only seeks exposure to non-U.S. markets through the underlying
ETFs held by the Trust, certain of which may invest in foreign sovereign debt and/or debt securities issued by foreign corporations. The
disclosure will be revised accordingly.
Risk Factors
2.If
the Funds held by the Trust invest in emerging markets, 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 emerging markets,
appropriate disclosure will be added to the Trust’s prospectus.
3.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