Correspondence 0001445546-23-004108 from FT 10801 (CIK 0001970985)
FT 10801 (CIK 0001970985)
Date: June 27, 2023 · CIK: 0001970985 · Accession: 0001445546-23-004108
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-271757
Letter
Division of Investment Management Re: FT 10801 FT Short Duration Fixed Income Model Portfolio, 3Q '23 (the “Trust”) CIK No. 1970985 File No. 333-271757
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 one factor the Committee considers in determining ETF allocations is “credit fundamentals (metrics impacting overall credit risk for a fixed income asset type, including rate of default and trends in earnings).” Please explain how prioritizing ETFs with lower rates of default is tied to credit ratings and how it is measured.
Response:The Trust notes that securities with lower credit ratings, such as high yield securities, typically have higher rates of default than investment grade securities. While the Trust does not have a specific metric used to measure credit fundamentals, the Committee considers the trailing 12-month default rate for the securities held by the underlying ETFs, as well as the expectation for default rates going forward, to make the determination of how much to allocate to each ETF held by the Trust. 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 10801
FT Short Duration Fixed Income Model Portfolio, 3Q '23
(the “Trust”)
CIK No. 1970985 File No. 333-271757
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 one factor the Committee considers in determining ETF allocations is “credit fundamentals
(metrics impacting overall credit risk for a fixed income asset type, including rate of default and trends in earnings).” Please
explain how prioritizing ETFs with lower rates of default is tied to credit ratings and how it is measured.
Response:The
Trust notes that securities with lower credit ratings, such as high yield securities, typically have higher rates of default than investment
grade securities. While the Trust does not have a specific metric used to measure credit fundamentals, the Committee considers the trailing
12-month default rate for the securities held by the underlying ETFs, as well as the expectation for default rates going forward, to make
the determination of how much to allocate to each ETF held by the Trust. 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