Correspondence 0001445546-23-005850 from FT 10982 (CIK 0001981805)
FT 10982 (CIK 0001981805)
Date: Sept. 18, 2023 · CIK: 0001981805 · Accession: 0001445546-23-005850
AI Filing Summary & Sentiment
File numbers found in text: 333-274065
Letter
Division of Investment Management Re: FT 10982 California Municipal Income Closed-End and ETF Portfolio, Series 3 (the “Trust”) CIK No. 1981805 File No. 333-274065
Dear Mr. Cowan:
We received your comment regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comment.
Comment
Portfolio
1.Please specify how much of the portfolio of the Trust is closed-end funds versus exchange-traded funds.
Response:The Trust notes that the Schedule of Investments lists out the percentage of the Trust that consists of closed-end funds and the percentage of the Trust that consists of exchange-traded funds. Therefore, the Trust respectfully declines to add any additional disclosure.
2.The Staff notes the disclosure states, “The Closed-End Funds and ETFs were selected by our research department based on a number of factors including, but not limited to, the size and liquidity of the Closed-End Fund or ETF (requiring a minimum market capitalization of $50,000,000) and the current dividend yield of the Closed-End Fund or ETF (prioritizing Closed-End Funds or ETFs with the highest dividend yields). All other factors being equal, the Sponsor will select the Closed-End Fund or ETF with lower expense ratios, while attempting to limit the overlap of the securities held by the Closed-End Fund or ETF.” Please clarify if criteria are applied separately to the closed-end funds and separately for the exchange-traded funds or if the research department picks the closed-end funds or exchange-traded funds in the universe that have the highest yield and lowest expenses.
Response:The disclosure has been revised to clarify that the criteria is applied separately to the closed-end funds and the exchange-traded funds.
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
September 18, 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 10982
California Municipal Income Closed-End and ETF Portfolio, Series 3
(the “Trust”)
CIK No. 1981805 File No. 333-274065
Dear Mr. Cowan:
We received your comment
regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comment.
Comment
Portfolio
1.Please
specify how much of the portfolio of the Trust is closed-end funds versus exchange-traded funds.
Response:The
Trust notes that the Schedule of Investments lists out the percentage of the Trust that consists of closed-end funds and the percentage
of the Trust that consists of exchange-traded funds. Therefore, the Trust respectfully declines to add any additional disclosure.
2.The
Staff notes the disclosure states, “The Closed-End Funds and ETFs were selected by our research department based on a number
of factors including, but not limited to, the size and liquidity of the Closed-End Fund or ETF (requiring a minimum market
capitalization of $50,000,000) and the current dividend yield of the Closed-End Fund or ETF (prioritizing Closed-End Funds or ETFs
with the highest dividend yields). All other factors being equal, the Sponsor will select the Closed-End Fund or ETF with lower
expense ratios, while attempting to limit the overlap of the securities held by the Closed-End Fund or ETF.” Please clarify if
criteria are applied separately to the closed-end funds and separately for the exchange-traded funds or if the research department
picks the closed-end funds or exchange-traded funds in the universe that have the highest yield and lowest expenses.
Response:The
disclosure has been revised to clarify that the criteria is applied separately to the closed-end funds and the exchange-traded funds.
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