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CHAPMAN AND CUTLER LLP 111 WEST MONROE STREET
CHICAGO, ILLINOIS 60603
June 5, 2018
VIA EDGAR CORRESPONDENCE
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United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: First Trust Series Fund
File Nos. 811-22452 and 333-168727
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Ladies and Gentlemen:
On behalf of First Trust Series Fund (the "Registrant"), we are requesting
template filing relief pursuant to Rule 485(b)(i)(vii) under the Securities Act
of 1933, as amended, (the "1933 Act") ("Template Filing Relief") for the
Registrant in relation to the disclosure changes made to the Registrant's
registration statement in Post-Effective Amendment No. 28 under the 1933 Act and
Amendment No. 29 under the Investment Company Act of 1940, as amended (the
"Template Filing"). The Template Filing relates to the First Trust AQA(R) Equity
Fund, a series of the Registrant.
The only change to the Registrant's registration statement in the Template
Filing was the addition of the section entitled "Morgan Stanley Smith Barney LLC
("Morgan Stanley") Class A Sales Charge Waivers" in the prospectus and statement
of additional information. We have previously requested selective review of the
inclusion of the above referenced disclosure pursuant to the Securities and
Exchange Commission's Division of Investment Management Guidance Update No.
2016-06 (December 2016). We are now requesting Template Filing Relief for the
other series of the Registrant set forth in Appendix A hereto (the "Replicate
Filings").
In connection with this request, we represent that:
o The disclosure changes in the Template Filing are substantially
identical to disclosure changes that will be made in the Replicate
Filings;
o The Replicate Filings will incorporate changes made to the
disclosure included in the Template filing to resolve any staff
comments thereon; and
United States Securities and Exchange Commission
June 5, 2018
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o The Replicate Filings will not include any other changes that would
otherwise render them ineligible for filing under rule 485(b).
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
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Morrison C. Warren
United States Securities and Exchange Commission
June 5, 2018
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APPENDIX A
First Trust/Confluence Small Cap Value Fund
First Trust Preferred Securities and Income Fund
First Trust Short Duration High Income Fund