Correspondence 0001445546-25-000756 from FT 12027 (CIK 0002045988)
FT 12027 (CIK 0002045988)
Date: Jan. 31, 2025 · CIK: 0002045988 · Accession: 0001445546-25-000756
AI Filing Summary & Sentiment
File numbers found in text: 333-284329
Letter
Division of Investment Management Re: FT 12027 Tactical Income Portfolio, Series 84 (the “Trust”) CIK No. 2045988 File No. 333-284329
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
Risk Factors
1. 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 12027
Tactical Income Portfolio, Series 84
(the “Trust”)
CIK No. 2045988 File No. 333-284329
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
Risk Factors
1. 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