Chapman and Cutler LLP 111 West Monroe Street
Chicago, Illinois 60603
March 30, 2020
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 8663
Municipal Advantage Closed-End and ETF Portfolio, Series 59
(the "Trust")
CIK No. 1799247 File No. 333-236936
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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
Registration Statement
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1. BECAUSE THE FINAL REGISTRATION STATEMENT FOR THE TRUST WILL BE FILED
AFTER APRIL 1, 2020, PLEASE INCLUDE HYPERLINKS FOR THE EXHIBITS AND OTHER
INFORMATION INCORPORATED BY REFERENCE IN THE REGISTRATION STATEMENT, IF PUBLICLY
AVAILABLE ON EDGAR. SEE RULES 411 UNDER THE SECURITIES ACT OF 1933 AND 0-4 UNDER
THE INVESTMENT COMPANY ACT OF 1940. THE STAFF NOTES THAT ALL EXHIBIT LISTS
(INCLUDING THE ONE REQUIRED IN PART C) MUST INCLUDE LINKS TO EVERY EXHIBIT FILED
WITH THE REGISTRATION STATEMENT OR INCORPORATED BY REFERENCE. SEE INSTRUCTION 5
TO ITEM 28 OF FORM N-1A AND RULE 102(D) AND RULE 105(D) OF REGULATION S-T.
Response: The final Registration Statement for the Trust will be updated
in accordance with this comment.
Risk Factors
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2. IF THE TRUST WILL HAVE MATERIAL EXPOSURE TO THE MUNICIPAL BONDS ISSUED
BY ANY JURISDICTION EXPERIENCING FINANCIAL DISTRESS, PLEASE IDENTIFY THAT
JURISDICTION AND ADD RELEVANT RISK DISCLOSURE.
Response: The Trust does not expect to have material exposure to municipal
securities issued by any jurisdiction experiencing financial distress.
3. THE STAFF NOTES THAT SIGNIFICANT MARKET EVENTS HAVE OCCURRED SINCE THIS
REGISTRATION STATEMENT WAS FILED AS A RESULT OF THE COVID-19 PANDEMIC. PLEASE
CONSIDER WHETHER THE TRUST'S DISCLOSURES, INCLUDING RISK DISCLOSURES, SHOULD BE
REVISED BASED ON HOW THESE EVENTS ARE AFFECTING BOTH DEBT AND EQUITY MARKETS. IF
THE TRUST BELIEVES THAT NO ADDITIONAL DISCLOSURE IS WARRANTED, PLEASE EXPLAIN
WHY NOT SUPPLEMENTALLY.
Response: The following disclosure will be included as the second
paragraph of the "Current Economic Conditions" risk:
Local, regional or global events such as war, acts of terrorism, spread of
infectious diseases or other public health issues, recessions, or other
events could have a significant negative impact on the Trust and its
investments. Such events may affect certain geographic regions, countries,
sectors and industries more significantly than others. Such events could
adversely affect the prices and liquidity of the Trust's portfolio
securities and could result in disruptions in the trading markets. Any
such circumstances could have a materially negative impact on the value of
the Trust's Units and result in increased market volatility. The recent
outbreak of a respiratory disease designated as COVID-19 was first
detected in China in December 2019. The global economic impact of the
COVID-19 outbreak is impossible to predict but is expected to disrupt
manufacturing, supply chains and sales in affected areas and negatively
impact global economic growth prospects. The COVID-19 outbreak has also
caused significant volatility and declines in global financial markets,
which have caused losses for investors. The impact of the COVID-19
outbreak may be short term or may last for an extended period of time, and
in either case could result in a substantial economic downturn or
recession.
Additionally, the following disclosure will be included as the final
paragraph of the "Municipal Bonds" risk:
The costs associated with combatting the COVID-19 pandemic and the
negative impact on tax revenues has adversely affected the financial
condition of many states and political subdivisions. The effects of this
pandemic could affect the ability of states and political subdivisions to
make payments on debt obligations when due and could adversely impact the
value of their bonds, which could negatively impact the performance of the
Trust.
4. PLEASE CONSIDER WHETHER "INTEREST RATE RISK" SHOULD BE UPDATED IN LIGHT
OF CURRENT EVENTS.
Response: The Trust believes that the risks related to current events have
been disclosed in the "Current Economic Conditions" risk.
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