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Correspondence 0001445546-25-001778 from FT 12080 (CIK 0002049047)

FT 12080 (CIK 0002049047)
Date: March 4, 2025 · CIK: 0002049047 · Accession: 0001445546-25-001778

AI Filing Summary & Sentiment

File numbers found in text: 333-284682

Date
March 4, 2025
Author
Not clearly detected
Form
CORRESP
Company
FT 12080 (CIK 0002049047)

Letter

Division of Investment Management Re: FT 12080 ETF Growth and Income Mar. ’25 (the “Trust”) CIK No. 2049047 File No. 333-284682

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.If any of the ETFs in the Trust’s portfolio are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, please add disclosure addressing the potential conflicts arising from and benefits to First Trust Advisors L.P. from the Trust’s investment in such ETFs.

Response:If the Trust has exposure to any ETFs which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate disclosure will be added to the Trust’s prospectus.

Risk Factors

2.If the Funds held by the Trust invest in subprime residential mortgage loans, please add relevant risk disclosure to the Trust’s prospectus.

Response:In accordance with the Staff’s comment, if the Trust’s final portfolio has exposure to funds that invest in subprime residential mortgage loans, 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

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CORRESP
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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

March 4, 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 12080

    ETF Growth and Income Mar. ’25

    (the “Trust”)

    CIK No. 2049047  File No. 333-284682

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.If
any of the ETFs in the Trust’s portfolio are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, please
add disclosure addressing the potential conflicts arising from and benefits to First Trust Advisors L.P. from the Trust’s investment
in such ETFs.

Response:If
the Trust has exposure to any ETFs which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate
disclosure will be added to the Trust’s prospectus.

Risk Factors

2.If
the Funds held by the Trust invest in subprime residential mortgage loans, please add relevant risk disclosure to the Trust’s prospectus.

Response:In
accordance with the Staff’s comment, if the Trust’s final portfolio has exposure to funds that invest in subprime residential
mortgage loans, 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