Chapman and Cutler llp
111 West Monroe Street
Chicago, Illinois 60603
April 23, 2018
VIA EDGAR CORRESPONDENCE
David Orlic
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: First Trust Exchange-Traded Fund VI (the“Trust”)
File Nos. 811-22717 and 333-182308
Dear Mr. Orlic:
This letter responds to your comments, provided by telephone, regarding Post-Effective Amendment No. 93 under the Investment Company Act of 1940 (the“1940 Act”) and Amendment No. 95 under the Securities Act of 1933 (the“1933 Act”) to the registration statement of First Trust Exchange-Traded Fund VI (the“Trust”) filed on Form N-1A with the U.S. Securities and Exchange Commission (the“Commission”) on February 23, 2018 (the“Registration Statement”). The Registration Statement relates to the First Trust Dorsey Wright DALI 1 ETF (the“Fund”), a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement. The Fund’s revised prospectus, incorporating the Commission’s comments, is set forth on Exhibit A.
Comment 1 – Exemptive Order
Please confirm that the exemptive order pursuant to which the Fund’s shares will be issued permits affiliated funds to pass on expenses to the Fund.
Response to Comment 1
Pursuant to the Commission’s request, the Fund confirms that the exemptive order pursuant to which its shares will be issued permits affiliated funds to pass on expenses to the Fund.
Comment 2 – Exemptive Order
Please confirm that the exemptive order pursuant to which the Fund’s shares will be issued permits creations and redemptions of Creation Unit Aggregations to be done in exchange for cash.
Response to Comment 2
Pursuant to the Commission’s request, the Fund confirms that the exemptive order pursuant to which its shares will be issued permits creations and redemptions of Creation Unit Aggregations to be done in exchange for cash.
Comment 3 – Fees and Expenses of the Fund
Please remove the reference to distribution and service (12b-1) fees from footnote (1) to the Annual Fund Operating Expenses Table and the expense example.
Response to Comment 3
Pursuant to the Commission’s request, the requested deletion has been made.
Comment 4 – Principal Investment Strategies
Please revise the disclosure to include a prominent and concise statement regarding the frequency with which the Index will be rebalanced and reconstituted.
Response to Comment 4
Pursuant to the Commission’s request, the following disclosures have been added to the section entitled “Principal Investment Strategies”:
The Index evaluates four broad asset classes (U.S. equity securities, international equity securities, fixed income securities and commodities) and seeks to determine which of the four is most likely to experience the best investment performance until the next Index evaluation date (generally the second and fourth Friday of each month).
The point and figure relative strength comparison is generally used to determine the highest scoring asset class on a bi-monthly basis. The Index will reconstitute to reflect the asset class exhibiting the highest levels of relative strength.
Comment 5 – Principal Investment Strategies
The first sentence of the second paragraph notes that the Index evaluates the four asset classes to determine the asset classbest positioned to outperform the market generally (emphasis added). Please consider revising the sentence to provide additional clarity regarding what measure is used to determine market outperformance.
Response to Comment 5
Pursuant to the Commission’s request, the section entitled “Principal Investment Strategies” has been revised, as set forth onExhibit A.
Comment 6 – Principal Investment Strategies
Please consider revising the second sentence of the second paragraph to remove the word “proxy” from the disclosure as this word has multiple meanings and may be confusing to investors.
Response to Comment 6
Pursuant to the Commission’s request, the referenced disclosure has been revised.
Comment 7 – Principal Investment Strategies
The Commission notes that the second sentence of the second paragraph includes disclosure that each of the four asset classes is composed of a “roster of indices and/orone or more exchange-traded funds.” The methodology set forth in the Index White Paper includes disclosure that the four asset classes are composed of a roster of indices and/orone more exchange-traded products. Please confirm that the Fund intends to invest in exchange-traded funds registered as investment companies pursuant to the 1940 Act.
Response to Comment 7
Pursuant to the Commission’s request, the Fund confirms that it intends to invest in in exchange-traded funds registered as investment companies pursuant to the 1940 Act.
Comment 8 – Principal Investment Strategies
Please revise the disclosure contained in the second, third and fourth paragraphs in plain English to more fully and clearly explain the Index methodology. In particular, please more clearly describe what is meant by: (1) the relative strength calculation and how it is performed; (2) point and figure charting; (3) number of wins; and (4) the greatest outperformance potential. Please consider adding an example of the operation of the methodology in selecting the Index components.
Response to Comment 8
Pursuant to the Commission’s request, the section entitled “Principal Investment Strategies” has been revised, as set forth onExhibit A.
Comment 9 – Principal Investment Strategies
Please revise the disclosure to include a prominent and concise statement regarding the fact that 90% of the Fund’s assets will be invested in only one of the asset classes at any given time.
Response to Comment 9
Pursuant to the Commission’s request, the following disclosure has been added to the section entitled “Principal Investment Strategies”:
The Index provides exposure to a single asset class at a time.
Comment 10 – Principal Investment Strategies
In the disclosure relating to the four asset classes, please consider identifying the ETFs that comprise each asset class. Additionally, in “Additional Information on the Fund’s Investment Objectives and Strategies,” please list all of the affiliated ETFs in which the Fund may invest and set forth their principal investment strategies and principal risks.
Response to Comment 10
Pursuant to the Commission’s request, the Fund has provided a list of all eligible ETFs, and a brief description of each ETF’s investment objective and principal investment strategy on Appendix A to the prospectus. Given the length of the disclosure, the Fund felt it would be most appropriate to include this disclosure in an appendix rather than in the section entitled “Additional Information on the Fund’s Investment Objectives and Strategies.”
In addition, the Fund has added the following disclosure to the section entitled “Principal Investment Strategies”:
Each ETF that is currently eligible for inclusion in the Index is set forth on Appendix A. The ETFs eligible for inclusion in the Index pursuant to the U.S. equity securities, international equity securities and commodities asset allocation are advised by First Trust Advisors, L.P., the investment advisor to the Fund. The ETFs eligible for inclusion in the Index pursuant to the fixed income asset allocation are not advised by First Trust Advisors, L.P. The list of ETFs eligible for inclusion in the Index may change from time to time pursuant to the methodology of the Index.
Lastly, the Fund has revised the section entitled “Principal Risks” to include additional risk disclosure regarding the risks posed to investors by the Fund’s investments in the underlying ETFs.
Comment 11 – Principal Risks
To the extent applicable, please consider including risk disclosure regarding the fact that the Index Provider is not well known and/or is inexperienced.
Response to Comment 11
The Fund respectfully disagrees with the Commission’s assessment of Nasdaq, Inc. and therefore declines to add the suggested disclosure.
Comment 12 – Principal Risks
“Asset Concentration Risk” alludes to the possibility that the Fund’s performance may be disproportionately harmed by the poor performance of those ETFs to which it has significant exposure. Please revise the disclosure to include the principal risks of such ETFs.
Response to Comment 12
Pursuant to the Commission’s request, the Fund has revised the section entitled “Principal Risks” to include additional risk disclosure regarding the risks posed to investors by the Fund’s investments in the underlying ETFs.
Comment 13 – Principal Risks
Please revise the disclosure to clarify which risks apply to the Fund generally and which risks apply to the ETFs in which it intends to invest.
Response to Comment 13
Pursuant to the Commission’s request, the section entitled “Principal Risks” has been revised accordingly.
Comment 14 – Principal Risks
Please revise “ETF Risk” to include disclosure that when the Fund purchases the shares of other ETFs it may pay significantly more or receive significantly less than the underlying net asset value of such ETFs and that this may be reflected as a spread between the bid and ask price of the ETF’s shares.
Response to Comment 14
Pursuant to the Commission’s request, the following disclosure has been added as the last sentence of “ETF Risk”:
Additionally, because ETFs trade on an exchange, their shares may trade at a premium or discount to their net asset value.
Comment 15 – Principal Risks
Please revise “Floating Rate Loan Risk” to emphasize the inherent liquidity risk in an underlying fund’s investment in such securities. For example, trades involving bank loans may take longer than seven days to settle.
Response to Comment 15
Pursuant to the Commission’s request, the following disclosure has been added as the third sentence sentence of “Floating Rate Loan Risk”:
Investments in floating rate loans, especially bank loans, may take significantly longer than seven days to settle, which can adversely affect an underlying ETF’s ability to timely honor redemptions.
Comment 16 – Principal Risks
To the extent that the Fund’s investments are concentrated in the securities of companies operating in a specific sector, please include risk disclosure regarding the principal risks of such a concentration.
Response to Comment 16
Pursuant to the Commission’s request, the Fund represents that, to the extent the Fund is concentrated in a particular sector, it will include the appropriate risk disclosure in the section entitled “Principal Risks.”
Comment 17 – Principal Risks
Please revise “Interest Rate Risk” to include an example of duration.
Response to Comment 17
Pursuant to the Commission’s request, the following disclosure has been added to “Interest Rate Risk”:
For example, the price of a security with a three-year duration would be expected to drop by approximately 3% in response to a 1% increase in interest rates.
Comment 18 – Principal Risks
Please revise “Trading Issues Risk” to include disclosure regarding the possibility that there may be greater variance between the Fund’s net asset value and market price should market makers stop making a market in the Fund’s shares or if authorized participants cease submitting purchase and redemption orders for the Fund’s creation units.
Response to Comment 18
Pursuant to the Commission’s request, the following disclosure has been added to “Trading Issues Risk”:
In the event market makers cease making a market in the Fund’s shares or authorized participants stop submitting purchase or redemption orders for Creation Units, Fund shares may trade at a larger premium or discount to their net asset value.
Comment 19 – Additional Information on the Fund’s Investment Objective and Strategies
Please include the following as the first second of the second paragraph.
Accordingly, other funds investing in the Fund must adhere to the limits set forth in Section 12(d)(1) of the 1940 Act.
Response to Comment 19
Pursuant to the Commission’s request, the referenced disclosure has been added as the first sentence of the second paragraph of the section entitled “Additional Information on the Fund’s Investment Objective and Strategies.”
Comment 20 – Additional Information on the Fund’s Investment Objective and Strategies
Please revise the fourth paragraph to provide additional clarity as to the “various circumstances” in which it may not be possible or practicable for the Fund to purchase all of the securities comprising the Index and thus will undertake to “sample” the securities comprising the Index. Additionally, please revise to include additional clarity as to when the Fund will use derivatives in order to track the Index and confirmation that such derivatives will not be included when determining the Fund’s compliance with its 90% investment policy.
Response to Comment 20
The Fund has no current intention to engage in sampling or utilize derivatives to track the Index. However, as the Fund is permitted, and wishes to reserve the right, to engage in such activities, the Fund respectfully declines to revise the disclosure. Additionally, the Fund confirms that the use of derivatives will not be included when determining compliance with its 90% investment policy.
Comment 21 – Additional Information on the Fund’s Investment Objective and Strategies
Please confirm that the Fund’s Index Sub-License Agreement and Authorized Participant Agreement will be filed as exhibits to the Registration Statement.
Response to Comment 21
The Fund confirms that it will file the Index Sub-License Agreement as an exhibit to the Registration Statement. The Registrant filed a Form of Participant Agreement on August 30, 2016 that the Fund will incorporate by reference.
Comment 22 – Management of the Fund
Please revise the following sentence to clarify that the Fund has not yet launched.
A discussion regarding the Board’s approval of the Investment Management Agreement is available in the Fund’s Semi-Annual Report to Shareholders for the period ended ___________, 2018.
Response to Comment 22
Pursuant to the Commission’s request, the referenced disclosure has been revised as follows:
A discussion regarding the Board’s approval of the Investment Management Agreement will be available in the Fund’s Semi-Annual Report to Shareholders for the period ended June 30, 2018.
Comment 23 – Share Trading Prices
Please revise the disclosure contained in the section to specifically address the following:
a) | How is the IOPV calculated? Is it based on the Index, the Fund’s portfolio or on the contents of the creation basket? |
b) | What does the IOPV calculation include and not include? For example, does it include operating fees and/or other accruals? |
c) | What types of values are used for underlying holdings? |
d) | Please disclose whether the Fund may use stale values under certain circumstances or any other element that may adversely affect the use of IOPV as an indicator of the current market value of Fund shares. If so, please consider noting that potential as a principal risk. |
Response to Comment 23
Pursuant to the Commission’s request, the following disclosures have been added to the section entitled “How to Buy and Sell Shares – Share Trading Prices”:
The IOPV is based on the current market value of the securities or other assets and/or cash required to be deposited in exchange for a Creation Unit.
The IOPV does not necessarily reflect the precise composition of the current portfolio of securities or other assets held by the Fund at a particular point in time or the best possible valuation of the current portfolio.
The IOPV is generally determined by using current market quotations.
Comment 24 – Statement of Additional Information
Please revise fundamental investment policy #7 as follows:
The Fund may not invest 25% or more of the value of its total assets in securities of issuers in any one industry or group of industries, except to the extent that the Fund’s Index is concentrated in an industry or group of industries.
Response to Comment 24
Pursuant to the Commission’s request, the requested revisions have been made.
Comment 25 – Statement of Additional Information
Please consider deleting the last two sentences in the sub-section entitled “Portfolio Turnover.”
Response to Comment 25
Pursuant to the Commission’s request, the requested deletions have been made.
Comment 26 – Statement of Additional Information
The first sentence of the second paragraph of “Lending of Portfolio Securities” includes disclosure that for purposes of lending the Fund’s portfolio securities, the Fund may accept as collateral “cash, U.S. government securities orother high-grade debt obligations.” Please explain how this is consistent with the Staff’s position that collateral must be in the form of cash, cash equivalents or U.S. government securities.
Response to Comment 26
The reference to “other high-grade debt obligations” is intended to reference other permitted collateral, including bank letters of credit, which have been viewed as acceptable by the Staff. See, for instance, Adams Express Co., SEC No-Act. (pub. avail. Oct. 9, 1974).
Comment 27 – Statement of Additional Information
Given that the Fund intends to invest primarily in U.S.-listed ETFs, please confirm that the disclosure contained in “Authorization, Custody and Settlement Risk for Non-U.S. Securities” is applicable.
Response to Comment 27
Pursuant to the Commission’s request, the referenced disclosure has been deleted.
Comment 28 – Index White Paper
The first sentence states that the Index is “quantitatively enabled.” Please describe how this methodology is rules-based and confirm that the Index Provider maintains only limited discretion with regard to the operation of the Index.
Response to Comment 28
The referenced disclosure is an attempt to reinforce the notion that the Index is entirely quantitatively driven. Pursuant to the Commission’s request, the Fund confirms that the Index Provider maintains only limited discretion with regard to the operation of the Index.
Comment 29 – Index White Paper
Please clarify what is meant by the following:
It aims tominimize drawdowns during periods when the macro-market environment is transitioning from bullish to bearish, and protects assets during a bearishly configured market.
Response to Comment 29
The referenced disclosure means that during market downturns, the Index will typically rotate to the fixed income allocation.
Comment 30 – Index White Paper
Please confirm that the disclosure regarding the frequency with which the Index will be rebalanced and reconstituted matches with what is disclosed in the prospectus.
Response to Comment 30
Pursuant to the Commission’s request, the Fund confirms that the disclosure regarding the frequency with which the Index will be rebalanced and reconstituted matches with what is disclosed in the prospectus.
Comment 31 – Index White Paper
The Commission notes that the Index White Paper states the the Index may be “100% allocated to a broad-commodity ETF.” Please confirm that the Fund invest in “securities,” as such term is defined in the 1940 Act.
Response to Comment 31
Pursuant to the Commission’s request, the Fund confirms that it will invest in “securities,” as such term is defined in the 1940 Act.
***
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours, Chapman and Cutler llp | ||
By: | /s/ Morrison C. Warren | |
Morrison C. Warren |
Exhibit A
First Trust Exchange-Traded Fund VI |
SUBJECT TO COMPLETION
Ticker Symbol: | DALI |
Exchange: | Nasdaq |
(fees paid directly from your investment)
Maximum Sales Charge (Load) Imposed on Purchases (as a percentage of offering price) | None |
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees | ___% |
Distribution and Service (12b-1) Fees | 0.00% |
Other Expenses(1) | 0.00% |
Acquired Fund Fees and Expenses(1) | ___% |
Total Annual Fund Operating Expenses | ___% |
(1) | "Other Expenses" and "Aquired Fund Fees and Expenses" are estimates based on the expenses the Fund expects to incur for the current fiscal year. |
1 Year | 3 Years |
$___ | $___ |
• | 65% of the Fund’s assets will be equally weighted among the constituents of the Dorsey Wright Focus Five Index (an index of ETFs designed to select the five sector/industry-based First Trust ETFs exhibiting the greatest relative strength). |
• | 35% of the Fund’s assets will be equally weighted among the First Trust Large Cap Growth AlphaDEX Fund (an ETF that provides exposure to large capitalization U.S. issuers that have exhibited higher levels of growth potential) and First Trust Small Cap Growth AlphaDEX Fund (an ETF that provides exposure to small capitalization U.S. issuers that have exhibited higher levels of growth potential) |
• | The Index will re-balance back to the 65% and 35% target weights quarterly. The Index may re-constitute periodically in response to changes in the composition of the Dorsey Wright Focus Five Index. |
• | 65% of the Fund’s assets will be equally weighted among the constituents of the Dorsey Wright Focus Five Index Dorsey Wright International Focus Five Index (an index of ETFs designed to select the five country/region-based First Trust ETFs exhibiting the greatest relative strength). |
• | 35% of the Fund’s assets will be equally weighted among the First Trust Emerging Markets AlphaDEX Fund (an ETF that provides exposure to equity securities issued by companies operating in emerging markets) and First Trust Developed Markets ex-US AlphaDEX Fund (an ETF that provides exposure to equity securities issued by companies operating in non-U.S. developed markets). |
• | The Index will re-balance back to the 65% and 35% target weights quarterly. The Index may re-constitute periodically in response to changes in the composition of the Dorsey Wright International Focus Five Index. |
• | 65% of the Fund’s assets will be equally weighted among three ETFs that seek broad exposure to the U.S. investment grade fixed income securities market. |
• | 35% of the Fund’s assets will be equally weighted among the constituents of the Dorsey Wright Fixed Income Model (a model that seeks to select four ETFs that invest principally in fixed income securities exhibiting the greatest relative strength). |
• | The Index will re-balance back to the 65% and 35% target weights quarterly. The Index may re-constitute periodically in response to changes in the composition of the Dorsey Wright Fixed Income Model. |
• | First Trust Global Tactical Commodity Strategy Fund (an ETF that invests in a combination of exchange-listed commodity futures contracts and commodity-linked instruments through a wholly-owned Cayman subsidiary with the objective of providing investors with commodity exposure) is included in the Index and given a weight of 100%. |
• | Daniel J. Lindquist, Chairman of the Investment Committee and Managing Director of First Trust |
• | Jon C. Erickson, Senior Vice President of First Trust |
• | David G. McGarel, Chief Investment Officer, Chief Operating Officer and Managing Director of First Trust |
• | Roger F. Testin, Senior Vice President of First Trust |
• | Stan Ueland, Senior Vice President of First Trust |
• | Chris A. Peterson, Senior Vice President of First Trust |
Cocoa
Cotton / 1-1/16”
Feeder Cattle
Coffee ‘C’ / Colombian
Soybeans / No. 2 Yellow
Soybean Meal / 48% Protein
Soybean Oil / Crude
Corn / No. 2 Yellow
Wheat / No. 2 Hard Winter
Wheat / No. 2 Soft Red
Sugar #11 / World Raw
Hogs, Lean / Average Iowa/S Minn
Crude Oil, WTI / Global Spot
Crude Oil, Brent / Global Spot
NY Harbor ULSD (Heating Oil)
Gas-Oil-Petroleum
Natural Gas, Henry Hub
Gasoline, Blendstock (RBOB)
Gold
Silver
Platinum
Copper High Grade / Scrap No. 2 Wire
Lead, LME Primary 3 Month Rolling Forward
Nickel, LME Primary 3 Month Rolling Forward
Tin, LME Primary 3 Month Rolling Forward
Zinc, LME Primary 3 Month Rolling Forward
• | Limited Voting Rights. Generally, holders of preferred securities (such as an underlying ETF) have no voting rights with respect to the issuing company unless preferred dividends have been in arrears for a specified number of periods, at which time the preferred security holders may elect a number of directors to the issuer’s board. Generally, once the issuer pays all the arrearages, the preferred security holders no longer have voting rights. |
• | Special Redemptions Rights. In certain circumstances, an issuer of preferred securities may redeem the securities prior to a specified date. For instance, for certain types of preferred securities, a redemption may be triggered by a change in federal income tax or securities laws. As with call provisions, a special redemption by the issuer may negatively impact the return of the security held by an underlying ETF. |
• | Deferral. Preferred securities may include provisions that permit the issuer, at its discretion, to defer distributions for a stated period without any adverse consequences to the issuer. If an underlying ETF owns a preferred security that is deferring its distributions, the underlying ETF may be required to report income for federal income tax purposes although it has not yet received such income in cash. |
• | Subordination. Preferred securities are subordinated to bonds and other debt instruments in a company’s capital structure in terms of priority to corporate income and liquidation payments and therefore will be subject to greater credit risk than those debt instruments. |
• | Liquidity. Preferred securities may be substantially less liquid than many other securities, such as common stocks or U.S. government securities. |
• | Mr. Lindquist is Chairman of the Investment Committee and presides over Investment Committee meetings. Mr. Lindquist is responsible for overseeing the implementation of the Fund’s investment strategy. Mr. Lindquist was a Senior Vice President of First Trust and FTP from September 2005 to July 2012 and is now a Managing Director of First Trust and FTP. |
• | Mr. Erickson joined First Trust in 1994 and is a Senior Vice President of First Trust and FTP. As the head of First Trust’s Equity Research Group, Mr. Erickson is responsible for determining the securities to be purchased and sold by funds that do not utilize quantitative investment strategies. |
• | Mr. McGarel is the Chief Investment Officer, Chief Operating Officer and a Managing Director of First Trust and FTP. As First Trust’s Chief Investment Officer, Mr. McGarel consults with the other members of the Investment Committee on market conditions and First Trust’s general investment philosophy. Mr. McGarel was a Senior Vice President of First Trust and FTP from January 2004 to July 2012. |
• | Mr. Testin is a Senior Vice President of First Trust and FTP. Mr. Testin is the head of First Trust’s Portfolio Management Group. Mr. Testin has been a Senior Vice President of First Trust and FTP since November 2003. |
• | Mr. Ueland joined First Trust as a Vice President in August 2005 and has been a Senior Vice President of First Trust and FTP since September 2012. At First Trust, he plays an important role in executing the investment strategies of each portfolio of exchange-traded funds advised by First Trust. |
• | Mr. Peterson is a Senior Vice President and head of First Trust’s strategy research group. He joined First Trust in January of 2000. Mr. Peterson is responsible for developing and implementing quantitative equity investment strategies. Mr. Peterson received his B.S. in Finance from Bradley University in 1997 and his M.B.A. from the University of Chicago Booth School of Business in 2005. He has over 19 years of financial services industry experience and is a recipient of the Chartered Financial Analyst designation. |
Aggregate Adjusted Market Value/Divisor
(Market Value after Adjustments/Market Value before Adjustments) X Divisor before Adjustments
• | The price return index (Nasdaq: NQDALI) is ordinarily calculated without regard to cash dividends on Index component securities. |
• | The total return index (Nasdaq: NQDALIT) reinvests cash dividends on the ex-date. |
• | The net total return index (Nasdaq: NQDALIN) reinvests cash dividends on the ex-date. |
• | US Equity Securities: 35% core holding equally distributed between exposure to a Large Cap Growth ETF and a Small Cap Growth ETF; 65% tactical holding tracking the Dorsey Wright Focus Five Index. |
• | International Equity Securities: 35% core holding equally distributed between Developed Markets ex-US and Emerging Markets ETF; 65% tactical holding tracking the Dorsey Wright International Focus Five Index. |
• | Fixed Income: 65% core holding to broad based aggregate bond funds; 35% tactical holding of 4 of the strongest relative strength ETFs from a universe of about 12. |
• | Commodities: 100% allocated to a broad commodity ETF |
(1) | For purposes of this document, Last Sale Price refers to the last regular way trade reported on such security’s Index Market. The Index Market is the listing market for which prices are received and used by Nasdaq in the Index calculation and generally will represent the most liquid trading market of the Index Security. If a security does not trade on its Index Market on a given day or the Index Market has not opened for trading, the most recent last sale price from the Index Market (adjusted for corporate actions, if any) is used. For securities where Nasdaq is Index Market, the Last Sale Price may be the Nasdaq Official Closing Price (NOCP) when Nasdaq is closed. |
Asset Class Review | Review Schedule |
Standard Frequency of Review | Review will skip the 2nd Friday in January, April, July and October. |
International moving in or out of #1 Asset Class | Review will skip the 4th Friday in February, May, August and November if the First Trust Nifty Fifty Equal Weight ETF (NFTY) is a component of the Dorsey Wright International Focus Five Index. |
Tactical Sleeve Name | Review Schedule |
Dorsey Wright Focus Five Index | 2nd and 4th week containing a Friday |
Dorsey Wright International Focus Five Index | 1st and 3rd week containing a Friday |
Tactical Fixed Income | Monthly on the 4th week containing a Friday |
Rebalance Back to Target 65%/35% Allocations | Quarterly on the 4th week containing a Friday in January, April, July and October |
as of the Date of this Prospectus
First Trust Exchange-Traded Fund VI |
120 East Liberty Drive, Suite 400
Wheaton, Illinois 60187
(800) 621-1675
www.ftportfolios.com