SEC Company Response from FTP 1 (CIK 0002087889) — Dec 17, 2025
FTP 1 (CIK 0002087889)
Date: Dec. 17, 2025 · CIK: 0002087889 · Accession: 0001445546-25-008214
AI Filing Summary & Sentiment
File numbers found in text: 333-291813
Letter
Division of Investment Management Re: FTP 1 Vest 2-Year S&P 500(R) Deep Buffered 100 Portfolio (the “Trust”) CIK No. 2087889 File No. 333-291813
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.The Staff notes that in the blackline provided it appears that there is no heading for the section entitled “Risk Factors.” Please add such heading or otherwise confirm that such heading is included in the Registration Statement.
Response:The Trust confirms that the Registration Statement includes a heading for the section entitled “Risk Factors.”
2.The Staff notes some of the risk factors in the Registration Statement include the term “Risk” in the name of the risk factor, while others do not. Consider adding “risk” to the end of each listed risk factor for consistency and clarity.
Response:Pursuant to the Staff’s comment, the Trust will update the Registration Statement to add the term “Risk” to the end of each listed risk factor.
3.Starting with the risk factor entitled “Absence of an Active Market Risk,” please clarify, either by grouping under a heading (e.g., Investments in Underlying ETFs Risk) or in the name of the risk itself (see, e.g., Underlying ETF Market Risk) that the “Absence of an Active Market Risk” and the next two risk factors are Underlying ETF Risks.
Response:Pursuant to the Staff’s comment, the Trust will update the names of the above referenced risk factors to clarify that such risk factors address risks relating to the Underlying ETFs.
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
December 17, 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:
FTP 1
Vest 2-Year S&P 500(R) Deep Buffered 100 Portfolio
(the “Trust”)
CIK No. 2087889 File No. 333-291813
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.The
Staff notes that in the blackline provided it appears that there is no heading for the section entitled “Risk Factors.” Please
add such heading or otherwise confirm that such heading is included in the Registration Statement.
Response:The
Trust confirms that the Registration Statement includes a heading for the section entitled “Risk Factors.”
2.The
Staff notes some of the risk factors in the Registration Statement include the term “Risk” in the name of the risk factor,
while others do not. Consider adding “risk” to the end of each listed risk factor for consistency and clarity.
Response:Pursuant
to the Staff’s comment, the Trust will update the Registration Statement to add the term “Risk” to the end of each listed
risk factor.
3.Starting
with the risk factor entitled “Absence of an Active Market Risk,” please clarify, either by grouping under a heading (e.g.,
Investments in Underlying ETFs Risk) or in the name of the risk itself (see, e.g., Underlying ETF Market Risk) that the “Absence
of an Active Market Risk” and the next two risk factors are Underlying ETF Risks.
Response:Pursuant
to the Staff’s comment, the Trust will update the names of the above referenced risk factors to clarify that such risk factors address
risks relating to the Underlying ETFs.
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