Correspondence 0001445546-23-004270 from FT 10879 (CIK 0001976491)
FT 10879 (CIK 0001976491)
Date: July 14, 2023 · CIK: 0001976491 · Accession: 0001445546-23-004270
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-272761
Letter
Division of Investment Management Re: FT 10879 ETF Growth and Income July ‘23 (the “Trust”) CIK No. 1976491 File No. 333-272761
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 the ETFs the portfolio invests in are affiliated, please include the conflict disclosure that was agreed upon in prior filings.
Response:If the Trust has exposure to any ETFs which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate disclosure will be added to the Trust’s prospectus.
Risk Factors
2.Please clarify whether the Trust will initially invest in distressed securities.
Response: The Trust notes that the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure. While distressed debt securities do not rise to a level of principal investment for the Trust, and the Trust does not anticipate initially investing in distressed debt securities, the Trust believes the current risk disclosure is necessary for investor comprehension.
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
July 14, 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 10879
ETF Growth and Income July ‘23
(the “Trust”)
CIK No. 1976491 File No. 333-272761
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
the ETFs the portfolio invests in are affiliated, please include the conflict disclosure that was agreed upon in prior filings.
Response:If
the Trust has exposure to any ETFs which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate
disclosure will be added to the Trust’s prospectus.
Risk Factors
2.Please
clarify whether the Trust will initially invest in distressed securities.
Response: The
Trust notes that the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure.
While distressed debt securities do not rise to a level of principal investment for the Trust, and the Trust does not anticipate initially
investing in distressed debt securities, the Trust believes the current risk disclosure is necessary for investor comprehension.
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