Correspondence 0001445546-25-000755 from FT 12004 (CIK 0002045751)
FT 12004 (CIK 0002045751)
Date: Jan. 31, 2025 · CIK: 0002045751 · Accession: 0001445546-25-000755
AI Filing Summary & Sentiment
File numbers found in text: 333-284079
Letter
Division of Investment Management Re: FT 12004 Balanced Income Equity and ETF Portfolio, Series 73 (the “Trust”) CIK No. 2045751 File No. 333-284079
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. Given that the universe of common stocks may include those with a market capitalization of over $5 billion, please include disclosure in the Portfolio Selection Process and Risk Factors sections, as appropriate, if the Trust has exposure to small and/or mid capitalization companies.
Response: If, based on the Trust’s final portfolio, the Trust has exposure to small and/or mid capitalization companies, appropriate disclosure will be added to the Portfolio Selection Process and Risk Factors sections of the Trust’s prospectus.
Risk Factors
2. If the nature of the Trust’s investments in distressed debt securities relate to certain of the ETFs purchasing distressed debt securities directly (rather than from merely holding bonds that become distressed after purchase), please add related strategy disclosure as appropriate.
Response: The Trust notes that it does not anticipate investing in ETFs that purchase distressed debt securities directly. The Trust further notes that distressed debt securities do not rise to a level of principal investment for the Trust. Nevertheless, the Trust believes the current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure. Therefore, the Trust respectfully declines to add distressed debt securities to the “Portfolio Selection Process” section.
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
January 31, 2025
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 12004
Balanced Income Equity and ETF Portfolio, Series 73
(the “Trust”)
CIK No. 2045751 File No. 333-284079
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. Given
that the universe of common stocks may include those with a market capitalization of over $5 billion, please include disclosure in the
Portfolio Selection Process and Risk Factors sections, as appropriate, if the Trust has exposure to small and/or mid capitalization companies.
Response: If,
based on the Trust’s final portfolio, the Trust has exposure to small and/or mid capitalization companies, appropriate disclosure
will be added to the Portfolio Selection Process and Risk Factors sections of the Trust’s prospectus.
Risk Factors
2. If
the nature of the Trust’s investments in distressed debt securities relate to certain of the ETFs purchasing distressed debt securities
directly (rather than from merely holding bonds that become distressed after purchase), please add related strategy disclosure as appropriate.
Response: The
Trust notes that it does not anticipate investing in ETFs that purchase distressed debt securities directly. The Trust further notes that
distressed debt securities do not rise to a level of principal investment for the Trust. Nevertheless, the Trust believes the current
risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially
related to the high-yield securities risk disclosure. Therefore, the Trust respectfully declines to add distressed debt securities to
the “Portfolio Selection Process” section.
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