Correspondence 0001445546-23-004776 from FT 10898 (CIK 0001977585)
FT 10898 (CIK 0001977585)
Date: Aug. 1, 2023 · CIK: 0001977585 · Accession: 0001445546-23-004776
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File numbers found in text: 333-272856
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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
August 1, 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 10898
Inflation Hedge Portfolio, Series 54
(the “Trust”)
CIK No. 1977585 File No. 333-272856
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
any of the ETFs or ETPs in the Trust’s portfolio are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor,
please add disclosure addressing the potential conflicts arising from and benefits to First Trust Advisors L.P. from the Trust’s
investment in such ETFs.
Response: If
the Trust has exposure to any Funds 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.
2.The
Staff notes that the disclosure states that dividend yield is not a consideration for the ETP’s in the Trust’s portfolio;
however, other disclosure states that the research department considers the consistency and reliability of the dividend. Please clarify
that this does not apply to the ETPs in the Trust’s portfolio.
Response:In
accordance with the Staff’s comment, the disclosure will be revised as follows:
“…the quality and
character of the securities held by the Fund and ETP (considering the consistency and reliability of the dividend of the Fund and focusing
on whether a Fund or ETP is efficient in offsetting the effects of inflation);”
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