SEC Company Response from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2005 (CIK 0001791189) — May 27, 2020
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2005 (CIK 0001791189)
Date: May 27, 2020 · CIK: 0001791189 · Accession: 0001528621-20-001019
AI Filing Summary & Sentiment
File numbers found in text: 333-237377, 811-03763
Referenced dates: April 21, 2020, May 26, 2020
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2005 Blue Chip Dividend Portfolio, Series File Nos. 333-237377 and 811-03763
Dear Mr. Bartz:
This letter amends the response letter dated May 26, 2020, to revise a previous response given to comment 3 of your comment letter dated April 21, 2020, regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2005, filed on March 25, 2020 with the Securities and Exchange Commission (the “Commission”). The registration statement proposes to offer the Blue Chip Dividend Portfolio, Series 1 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
3. The first paragraph of this section states that the trust may invest in non-U.S. companies. Please explain to us whether the trust’s investments in non-U.S. companies will include emerging market issuers as a principal investment strategy and, if so, provide appropriate disclosure in this section and in the discussions of the trust’s principal risks. Alternatively, please explain to us why the requested disclosures are not necessary.
Response: The trust would like to retain its ability to invest in non-U.S. companies and will retain the language regarding non-U.S. companies that was originally filed on Form S-6. With regard to emerging market issuers, the trust will not invest in such issuers. As such, no additional language regarding emerging market issuers has been added to the investment strategies or risk sections.
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 the undersigned at (312) 845-3484.
Very truly
yours,
Chapman
and Cutler LLP
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CORRESP
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Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
May 27, 2020
Via EDGAR Filing
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 2005
Blue Chip Dividend Portfolio, Series
1
File Nos. 333-237377 and 811-03763
Dear Mr. Bartz:
This letter
amends the response letter dated May 26, 2020, to revise a previous response given to comment 3 of your comment letter dated April
21, 2020, regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2005, filed on March
25, 2020 with the Securities and Exchange Commission (the “Commission”). The registration statement proposes
to offer the Blue Chip Dividend Portfolio, Series 1 (the “trust”).
PROSPECTUS
Investment
Summary — Principal Investment Strategy
3. The
first paragraph of this section states that the trust may invest in non-U.S. companies. Please explain to us whether the trust’s
investments in non-U.S. companies will include emerging market issuers as a principal investment strategy and, if so, provide appropriate
disclosure in this section and in the discussions of the trust’s principal risks. Alternatively, please explain to us why
the requested disclosures are not necessary.
Response: The trust would like to retain
its ability to invest in non-U.S. companies and will retain the language regarding non-U.S. companies that was originally filed
on Form S-6. With regard to emerging market issuers, the trust will not invest in such issuers. As such, no additional language
regarding emerging market issuers has been added to the investment strategies or risk sections.
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 the undersigned at (312) 845-3484.
Very truly
yours,
Chapman
and Cutler LLP
By /s/
Morrison C. Warren
Morrison
C. Warren