111 West Monroe Street Chicago, Illinois 60603-4080
T 312.845.3000 F 312.701.2361 www.chapman.com |
August 23, 2021
VIA EDGAR CORRESPONDENCE
John F. Kernan
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | First Trust Exchange-Traded AlphaDEX® Fund | |
Registration Nos. 333-140895 and 811-22019 |
Dear Mr. Kernan:
This letter responds to comments provided by the staff of the Securities and Exchange Commission (the “Staff”) via telephone, pursuant to Section 408 of the Sarbanes-Oxley Act of 2002 regarding the First Trust Exchange-Traded AlphaDEX® Fund (the “Trust”). The review covered the funds listed in Exhibit A attached hereto (each, a “Fund” and collectively, the “Funds”). The Funds are each a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Funds’ Annual Reports.
Comment 1
For the First Trust Health Care AlphaDEX® Fund, the Staff notes the Trust’s Form N-CEN, for the period ending July 31, 2020, reported in Item C.3(b)(ii)(1)-(2) that the annualized difference between the Fund’s total return and the index’s return during the reporting period before and after taking into account fees and expenses was 1.20% and (0.86%), respectively. Please confirm that the disclosure for Item C.3(b)(ii)(1) is accurate with an explanation of the basis for the divergence, and if not, please explain how the issue will be corrected.
Response to Comment 1
The disclosure for Item C.3(b)(ii)(1) was not correct. An amended Form N-CEN for First Trust Exchange-Traded AlphaDEX® Fund was filed on August 23, 2021, which corrects the disclosure for Item C.3(b)(ii)(1) for all funds.
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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
File Number | Fund Name | FYE Reviewed |
811-22019 | First Trust Large Cap Core AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Mid Cap Core AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Small Cap Core AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Large Cap Value AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Large Cap Growth AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Multi Cap Value AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Multi Cap Growth AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Consumer Discretionary AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Consumer Staples AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Energy AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Financials AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Health Care AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Industrials/Producer Durables AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Materials AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Technology AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Utilities AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Mid Cap Growth AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Mid Cap Value AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Small Cap Growth AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Small Cap Value AlphaDEX® Fund | 7/31/2020 |
811-22019 | First Trust Mega Cap AlphaDEX® Fund | 7/31/2020 |