Correspondence 0001445546-23-005261 from FT 10934 (CIK 0001980040)
FT 10934 (CIK 0001980040)
Date: Aug. 23, 2023 · CIK: 0001980040 · Accession: 0001445546-23-005261
AI Filing Summary & Sentiment
Letter
Division of Investment Management Re: FT 10934 Tactical Income Portfolio, Series 77 (the “Trust”) CIK No. 1980040 File No. 273339
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
Risk Factors
1.If the Trust will initially invest in distressed securities as a principal strategy, please add appropriate disclosure.
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.
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
August 23, 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 10934
Tactical Income Portfolio, Series 77
(the “Trust”)
CIK No. 1980040 File No. 273339
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
Risk Factors
1.If
the Trust will initially invest in distressed securities as a principal strategy, please add appropriate disclosure.
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.
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