Correspondence 0001445546-25-000757 from FT 12029 (CIK 0002046031)
FT 12029 (CIK 0002046031)
Date: Jan. 31, 2025 · CIK: 0002046031 · Accession: 0001445546-25-000757
AI Filing Summary & Sentiment
File numbers found in text: 333-284373
Letter
Division of Investment Management Re: FT 12029 Income Strength Total Return Portfolio, Series 3 (the “Trust”) CIK No. 2046031 File No. 333-284373
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. The Staff notes the following disclosure, “Additionally, the Sponsor considers industry specific and geographic risk by evaluating if: (1) the industry in which the issuer is operating is subject to additional risk due to its specific industry; (2) there are systemic risks that are only applicable to the issuer; (3) the industry in which the issuer is operating is expecting a decline or elimination in business activity in the near future based upon known risks to the issuer's specific industry; (4) the issuer is at risk of catastrophic damage due to the geographic location of its facilities; and (5) the issuer mitigates risk by geographically diversifying its facilities.”
(a) Please describe how the sponsor evaluates these risks.
(b) If the Trust will be concentrated in any specific industry or geographic region, please add appropriate strategy and risk disclosure.
Response: Please refer to the Trust’s responses below:
(a) The Trust notes that each of the enumerated factors contribute towards the Sponsor’s consideration of industry specific and geographic risk and, therefore, the final portfolio selected by the Sponsor, but such factors are not weighted or considered in any determinative way. Rather, they are holistically considered in combination with each other to present a picture of an Exchange-Traded Corporate Debt Security’s risk profile and suitability for inclusion in the portfolio. The disclosure will be revised to clarify this.
(b) If, based on the Trust’s final portfolio, the Trust is concentrated in any specific industry or geographic region, appropriate disclosure will be added to the Trust’s prospectus.
Risk Factors
2. If the Trust will invest in emerging markets, please add relevant risk disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has exposure to emerging markets, appropriate disclosure will be added to the Trust’s prospectus.
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
Show Raw Text
CORRESP
1
filename1.htm
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 12029
Income Strength Total Return Portfolio, Series 3
(the “Trust”)
CIK No. 2046031 File No. 333-284373
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. The
Staff notes the following disclosure, “Additionally, the Sponsor considers industry specific and geographic risk by evaluating if:
(1) the industry in which the issuer is operating is subject to additional risk due to its specific industry; (2) there are systemic risks
that are only applicable to the issuer; (3) the industry in which the issuer is operating is expecting a decline or elimination in business
activity in the near future based upon known risks to the issuer's specific industry; (4) the issuer is at risk of catastrophic damage
due to the geographic location of its facilities; and (5) the issuer mitigates risk by geographically diversifying its facilities.”
(a) Please describe how the sponsor evaluates these risks.
(b) If the Trust will be concentrated in any specific industry or geographic region, please add appropriate
strategy and risk disclosure.
Response: Please
refer to the Trust’s responses below:
(a) The Trust notes that each of the enumerated factors contribute towards the Sponsor’s consideration
of industry specific and geographic risk and, therefore, the final portfolio selected by the Sponsor, but such factors are not weighted
or considered in any determinative way. Rather, they are holistically considered in combination with each other to present a picture of
an Exchange-Traded Corporate Debt Security’s risk profile and suitability for inclusion in the portfolio. The disclosure will be
revised to clarify this.
(b) If, based on the Trust’s final portfolio, the Trust is concentrated in any specific industry or
geographic region, appropriate disclosure will be added to the Trust’s prospectus.
Risk Factors
2. If
the Trust will invest in emerging markets, please add relevant risk disclosure.
Response: If,
based on the Trust’s final portfolio, the Trust has exposure to emerging markets, appropriate disclosure will be added to the Trust’s
prospectus.
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