Correspondence 0001528621-24-000068 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2387 (CIK 0001983240)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2387 (CIK 0001983240)
Date: Jan. 23, 2024 · CIK: 0001983240 · Accession: 0001528621-24-000068
AI Filing Summary & Sentiment
File numbers found in text: 333-276190, 811-03763
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2387 Total Income Portfolio, Series 31 File Nos. 333-276190 and 811-03763
Dear Mr. Brodsky:
This letter responds to the comment given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2387, filed on December 21, 2023, with the Securities and Exchange Commission. The registration statement proposes to offer the Total Income Portfolio, Series 31 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
1. Please disclose the Fund’s actual investments as of the date of deposit in the section entitled “Principal Investment Strategy” and confirm that the risks set forth in the section entitled “Principal Risks” reflect such investments.
Response: Once the portfolio is selected, a sentence will be added to the section entitled “Principal Investment Strategy” stating the types of investments that represent a significant amount of the trust’s assets as of the date of deposit. The section entitled “Principal Risks” will be revised to match this list, as appropriate.
Investment Summary — Principal Risks
2. On page 6 there is a discussion of the risks associated with ETFs that are concentrated in the financial sector. The Principal Investment Strategy section does not appear to explicitly mention any particular focus in the financial sector. Please either update the strategy section or remove this disclosure from the principal risks.
Response: The appropriate risk disclosures will be included in the final prospectus based upon the trust’s portfolio. If the trust, or the ETFs in which the trust invests, are concentrated in the financials sector, disclosure will be added to the Principal Investment Strategy section noting this concentration.
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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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
January 23, 2024
Via EDGAR Filing
Mr. Aaron Brodsky
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 2387
Total Income Portfolio, Series 31
File Nos. 333-276190 and 811-03763
Dear Mr. Brodsky:
This letter responds to
the comment given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim
Defined Portfolios, Series 2387, filed on December 21, 2023, with the Securities and Exchange Commission. The registration statement
proposes to offer the Total Income Portfolio, Series 31 (the “trust”).
PROSPECTUS
Investment
Summary — Principal Investment Strategy
1.
Please disclose the Fund’s actual investments as of the date of deposit in the section entitled “Principal Investment Strategy”
and confirm that the risks set forth in the section entitled “Principal Risks” reflect such investments.
Response: Once
the portfolio is selected, a sentence will be added to the section entitled “Principal Investment Strategy” stating the types
of investments that represent a significant amount of the trust’s assets as of the date of deposit. The section entitled “Principal
Risks” will be revised to match this list, as appropriate.
Investment Summary — Principal Risks
2.
On page 6 there is a discussion of the risks associated with ETFs that are concentrated in the financial sector. The Principal Investment
Strategy section does not appear to explicitly mention any particular focus in the financial sector. Please either update the strategy
section or remove this disclosure from the principal risks.
Response: The
appropriate risk disclosures will be included in the final prospectus based upon the trust’s portfolio. If the trust, or the ETFs
in which the trust invests, are concentrated in the financials sector, disclosure will be added to the Principal Investment Strategy section
noting this concentration.
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