Correspondence 0001445546-25-002456 from FT 12101 (CIK 0002050671)
FT 12101 (CIK 0002050671)
Date: April 4, 2025 · CIK: 0002050671 · Accession: 0001445546-25-002456
AI Filing Summary & Sentiment
File numbers found in text: 333-284897
Letter
Division of Investment Management Re: FT 12101 40/60 Strategic Allocation Port. 2Q ‘25 - Term 7/16/26 (the “Trust”) CIK No. 2050671 File No. 333-284897
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
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.
2.If the Funds held by the Trust invest significantly in subprime residential mortgage loans, please add appropriate risk disclosure.
Response:If, based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in subprime residential mortgage loans, appropriate risk 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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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T 312.845.3000
F 312.701.2361
www.chapman.com
April 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 12101
40/60 Strategic Allocation Port. 2Q ‘25 - Term 7/16/26
(the “Trust”)
CIK No. 2050671 File No. 333-284897
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
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.
2.If
the Funds held by the Trust invest significantly in subprime residential mortgage loans, please add appropriate risk disclosure.
Response:If,
based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in subprime residential mortgage loans, appropriate
risk 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