M&A - FIRST TRUST EXCHANGE-TRADED FUND

Form Type: CORRESP

Filing Date: 2024-08-09

Corporate Action: Merger

Type: Update

Accession Number: 000144554624005629

Filing Summary: This document is a response letter to the SEC regarding comments on the registration statement filed for the First Trust WCM Developing World Equity ETF. It confirms that new shares will not be sold until the proposed merger is consummated and details various comments and responses concerning regulatory disclosures, portfolio strategies, principal risks, and fee structures. The responses include adjustments based on SEC feedback, particularly related to the clarity on investment strategies and risk disclosures. Key adjustments include recognition that the Fund’s past performance is not necessarily indicative of future performance, despite similarities to a predecessor fund. The letter reiterates the commitment to compliance with SEC requirements and outlines corrections made to several areas of the disclosure, addressing concerns about risk factors, fee representations, and clarifications on investment policies. Overall, the communication reflects a precise regulatory dialogue focused on ensuring transparency and investor comprehension in light of the merger and related filings.

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