May
28, 2020




Walter L. Draney, Esq.
Chapman and Cutler LLP
111 West Monroe Street
Chicago, IL 60603


Re:    First Trust High Yield Opportunities 2027 Term Fund
       File Nos. 333-237878 and 811-23565

Dear Mr. Draney:

        On April 28, 2020, you filed on behalf of First Trust High Yield
Opportunities 2027
Term Fund (the "Fund") a registration statement on Form N-2 under the
Securities Act of 1933
(the "Securities Act") and the Investment Company Act of 1940 (the "Investment
Company
Act"), to register common shares of the Fund. We have reviewed the filing, and
have the
following comments. For convenience, we generally organized our comments using
headings,
defined terms, and page numbers from the registration statement. Where a
comment is made in
one location, it is applicable to all similar disclosure appearing elsewhere in
the registration
statement.

PROSPECTUS

1.      Please confirm in your response letter that FINRA has reviewed the
proposed
underwriting terms and arrangements for the transactions described in the
registration statement,
including the amount of compensation to be allowed or paid to the underwriters
and any other
arrangements among the Fund, the underwriters, and other broker dealers
participating in the
distribution, and that FINRA has issued a statement expressing no objections to
the
compensation and other arrangements.

Cover Page   Investment Strategies

2.      This section states that the Fund's investments in debt securities will
have "varying
maturities." Please provide a more specific description of the Fund's maturity
policy in this
section, or clarify that the Fund will invest in debt securities of any
maturity.
 Walter L. Draney, Esq.
May 28, 2020
Page 2


3.      This section also states that the Fund will invest in U.S. and non-U.S.
securities. Please
also disclose, as disclosed on page 31 of the prospectus, that the Fund's
non-U.S. securities will
include emerging market securities.

Cover Page   Offering Table

4.     Footnote (3) to the offering table states that the Advisor has agreed to
pay all
organizational expenses of the Fund and all offering costs associated with the
offering. Please
provide an estimate of the organizational expenses and offering costs in this
footnote, and in
footnote (2) to the fee table on page 12 of the prospectus.

Inside Cover Page   Distributions

5.      This section states that the Fund intends to pay monthly distributions
to shareholders out
of legally available funds. Please disclose in this section, as disclosed in
the "Distributions"
section on page 46 of the prospectus, that the Fund's distributions may include
a return of
capital. Please also disclose here and throughout the prospectus that a return
of capital is a return
to shareholders of a portion of their original investment in the Fund, and
should not be
considered as a dividend yield, total return, or net profit. Please also
briefly describe the tax
implications for shareholders of a return of capital distribution.

Prospectus Summary   Investment Policies and Strategies (Page 6)

6.      The first paragraph of this section states that the Fund will invest at
least 80% of its
Managed Assets in high yield debt securities. Please include the term "junk
bonds" or "junk
securities" in this description.

7.      The first paragraph of this section also discloses that the Fund's
investments will include
derivatives. Please confirm to us that, for purposes of the Fund's 80% policy,
the Fund's
derivative investments will be valued at their market value, rather than their
notional value.

8.     The third paragraph of this section states that the Fund will treat all
Senior Loans in
which it invests as below investment grade securities for purposes of the
Fund's 80% policy.
Please explain to us the basis for this statement. We may have additional
comments after
reviewing your response.

9.      The fourth paragraph of this section states that high yield debt
securities in which the
Fund may invest may include preferred stocks and convertible securities. Since
preferred stocks
are an equity investment rather than a debt investment, please delete preferred
stocks from this
description of the Fund's investments in debt securities. Also, since
"convertible securities"
could include convertible preferred stock, which is an equity security, please
clarify that the
Fund's debt securities may include convertible bonds rather than convertible
securities.
 Walter L. Draney, Esq.
May 28, 2020
Page 3


10.    If the Fund's convertible securities will include contingent convertible
bonds, please
disclose in this section, and provide appropriate risk disclosure in the
discussions of the Fund's
risks.

11.     The seventh paragraph of this section states that, during the period in
which the Fund is
approaching its Termination Date, the Fund may deviate from its investment
policies and
objective, and may invest up to 100% of its Managed Assets in short-term
investments. Please
confirm that if the Fund determines to deviate from its policy to invest at
least 80% of its
Managed Assets in high yield debt securities, it will, in accordance with Rule
35d-1 under the
Investment Company Act, notify shareholders and change the 80% policy and the
Fund's name.

12.      Please also disclose in this section that, as disclosed in the
"Restrictive Loan Covenants
Risk" section on page 27 of the prospectus, the Fund will invest in
"covenant-lite" loans, and
briefly describe the characteristics of covenant-lite loans.

13.     The last paragraph of this section states that, unless otherwise
specified, the investment
policies and limitations of the Fund are not considered to be fundamental by
the Fund and can be
changed without a vote of shareholders. Please disclose what notice
shareholders will be given
regarding changes to the Fund's non-fundamental policies and limitations (e.g.,
60 days' notice).

Prospectus Summary   Seven-Year Term (Page 8)

14.     This section states that the Fund's seven-year term may be extended up
to six months by
a vote of the Board, and may be extended for any length of time upon
shareholder approval. A
fund with a limited term (i.e., "2027 Term") in its name would be expected to
terminate at the
end of the named period. Accordingly, please delete the provision in the
Declaration of Trust
and the prospectus that provides that the term may be extended beyond 2027 upon
board
approval (i.e., six months) and indefinitely upon shareholder approval, or
explain to us how the
Fund's name is not potentially misleading in light of this provision.

Prospectus Summary   Use of Leverage (Page 9)

15.     This section states that the Fund will seek to limit its overall
"effective leverage" to 40%
of its Managed Assets. Please clarify the disclosure in this section by
explaining what is meant
by "effective leverage." Also, please explain to us whether the Fund's use of
derivatives will be
subject to Section 18 of the Investment Company Act.

16.     The last paragraph of this section states that, "because the management
fee received by
the Advisor is based on Managed Assets (which includes assets attributable to
the Fund's
borrowings), there is a financial incentive for the Advisor to cause the Fund
to use leverage."
Please also disclose that other forms of leverage, such as the Fund's
derivative investments, are
also included in Managed Assets.
 Walter L. Draney, Esq.
May 28, 2020
Page 4


Prospectus Summary   Special Risk Considerations (Page 11)

17.    Please revise this section to provide a brief description of the
principal risk factors
associated with an investment in the Fund.

Summary of Fund Expenses (Page 12)

18.    Please provide us with a completed fee table and example as soon as
possible.

19.    Please revise footnote (5) to the fee table to clarify that interest on
borrowed funds is
estimated based upon the assumed borrowing as described.

Use of Proceeds (Page 13)

20.    This section states that the Fund expects it will be able to invest
substantially all of the
net proceeds of the offering in accordance with its investment objective and
policies "within __
to __ days after completion of the offering." If the Fund expects this
investment period to
exceed three months, please disclose the reasons for this expected delay. See
Guide 1 to Form
N-2.

Portfolio Composition   Below Investment Grade Securities (Page 17)

21.     The third paragraph of this section states that the Fund's investments
may include
defaulted or distressed securities, including securities of companies whose
financial condition is
troubled or uncertain and that may be involved in bankruptcy proceedings,
reorganizations or
financial restructurings. Please add this disclosure to the "Investment
Policies and Strategies"
section in the prospectus summary.

Use of Leverage   Borrowings (Page 19)

22.    Please let us know if the terms of the credit facility are expected to
be finalized before the
requested date of acceleration. If so, please provide the material terms of the
credit facility
agreement, and include a copy of the agreement as an exhibit to the
registration statement.

23.    The first paragraph of this section states that the Fund expects that
any credit facility will
have "customary covenant" and "negative covenant" provisions. Please explain in
this section
the meanings of "customary covenant" and "negative covenant" provisions.

Risks (Page 20)

24.     Please revise this section to distinguish between and principal and
non-principal risks.
See Item 8.3.a of Form N-2. Also, we note that there are duplicate disclosures
of many risks in
this section (e.g., LIBOR and senior loans). Wherever possible, please
consolidate all similar
risks together.
 Walter L. Draney, Esq.
May 28, 2020
Page 5


Risks   Government Intervention in Financial Markets Risk (Page 21)

25.     The first paragraph of this section states that the "instability in the
financial markets in
the recent past led the U.S. government and foreign governments to take a
number of
unprecedented actions designed to support certain financial institutions and
segments of the
financial markets." Please provide more specific details in this section
regarding the
government's recent intervention in the financial markets (e.g., emergency
lending facilities, buy
back of bonds).

Risks   Interest Rate Risk (Page 25)

26.    Please discuss in this section that interest rates are at a historic
low, and describe the
impact of the current interest rate environment on the Fund's investments.

Risks   Shareholder Activism Risk (Page 26)

27.      The first paragraph of this section states that, "[w]hile the Fund is
currently not subject to
any shareholder activism," it may be in the future. Since this is a new fund
and therefore would
not be expected to be currently subject to any shareholder activism, please
delete the above
italicized segment of this sentence from this paragraph.

Risks   Duration Risk (Page 35)

28.     Please provide a numerical example of the meaning of duration in this
section, and ensure
that the example is reflective of the approximate expected duration of the
Fund's portfolio.

Risks   Portfolio Turnover Risk (Page 37)

29.     This section states that the Fund's portfolio turnover may vary greatly
from year to year.
Please disclose in the "Investment Policies and Strategies" section on page 6
of the prospectus
that the Fund's investment strategy may lead to a high level of portfolio
turnover.

Risks   Anti-takeover Provisions (Page 37)

30.  Please add the disclosure in this section, as well as the cross-reference,
to the prospectus
summary section. See Guide 3 to Form N-2.

Investment Management Agreement (Page 39)

31.     Please disclose in this section that, for purposes of calculating the
Fund's Managed
Assets, the Fund's derivative investments are valued at their market value, not
at their notional
value.
 Walter L. Draney, Esq.
May 28, 2020
Page 6


STATEMENT OF ADDITIONAL INFORMATION

Management of the Fund (Page 33)

32.      We note that much of the information required by this section has been
left blank. Please
ensure that the Fund's pre-effective amendment provides all of the information
required by Item
18 of Form N-2 for each Trustee, including the specific experience,
qualifications, attributes, or
skills that led to the conclusion that the person should serve as a Trustee of
the Fund. See Item
18.17 of Form N-2.

PART C   OTHER INFORMATION

Item 25: Financial Statements and Exhibits

33.    Please file the actual agreements listed as exhibits, rather than forms
thereof.

34.     Pursuant to the FAST Act, please include hyperlinks to each exhibit
identified in the
exhibit index and any other information incorporated by reference in the
registration statement, if
filed on EDGAR. See Rule 411 under the Securities Act and Rule 0-4 under the
Investment
Company Act.

Item 30: Indemnification

35.     Please include in this section the undertaking required by Rule
484(a)(3) under the
Securities Act.

DECLARATION OF TRUST

36.     Please delete "expressly granted" from the federal securities law
carve-out in section
11.4(c). We also note that the Fund's Declaration of Trust contains exclusive
jurisdiction and
waiver of jury trial provisions in sections 11.4(d) and (e). With respect to
the waiver of jury trial
provision, please revise the Declaration of Trust to carve out federal
securities law claims from
such waiver. In addition, please add disclosure in the prospectus that: (1)
clearly and
prominently describes each provision; (2) clearly describes any risks or other
impacts on
investors of each provision (e.g., increased costs to bring a claim and that
these provisions can
discourage claims or limit investors' ability to bring a claim in a judicial
forum that they find
favorable); and (3) addresses any uncertainty about enforceability.

GENERAL COMMENTS

37.    Please advise us whether you have presented or will present any "test
the waters"
materials to potential investors in connection with this offering. If so,
please provide us with
copies of such materials.
 Walter L. Draney, Esq.
May 28, 2020
Page 7


38.     We note that many portions of your filing are incomplete or will be
updated by
amendment. We may have additional comments on such portions when you complete
them in
pre-effective amendments, on disclosures made in response to this letter, on
information supplied
supplementally, or on exhibits added in any pre-effective amendment.

39.     If you intend to omit certain information from the form of prospectus
included with the
registration statement that is declared effective in reliance on Rule 430A
under the Securities
Act, please identify the omitted information to us supplementally, preferably
before filing the
pre-effective amendment.

40.    Please advise us if you have submitted or expect to submit any exemptive
applications or
no-action requests in connection with your registration statement.

41.     Response to this letter should be in the form of a pre-effective
amendment filed pursuant
to Rule 472 under the Securities Act. Where no change will be made in the
filing in response to
a comment, please indicate this fact in a supplemental letter and briefly state
the basis for your
position.
                                       *******

       In closing, we remind you that the Fund and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

        Should you have any questions prior to filing a pre-effective
amendment, please feel free
to contact me at 202-551-6959.




Sincerely,

                                                                         /s/
Edward P. Bartz


Edward P. Bartz

Senior Counsel




cc:    Andrea Ottomanelli Magovern, Assistant Director
       Sally Samuel, Branch Chief