Correspondence 0001528621-24-000285 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2390 (CIK 0001983243)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2390 (CIK 0001983243)
Date: March 5, 2024 · CIK: 0001983243 · Accession: 0001528621-24-000285
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File numbers found in text: 333-276689, 811-03763
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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
March 5, 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 2390
Income & Treasury Portfolio of Funds, Series
79
File Nos. 333-276689 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 2390, filed on January 25, 2024, with the Securities and Exchange Commission. The registration statement
proposes to offer the Income & Treasury Portfolio of Funds, Series 79 (the “trust”).
PROSPECTUS
Investment
Summary — Security Selection
1. Please disclose
how the Fund is describing the term “long-term average” and “strong relative performance”.
Response: In
response to this comment, the second and fourth bullet points in the third paragraph under “Security Selection” section will
be replaced with the following, respectively:
“Premium/Discount.
The sponsor favors funds that are trading at a discount relative to their peers and relative to such fund’s average net asset value
over a five year period.”
“Performance. The
sponsor favors funds that have a history of strong performance (based on market price and net asset value) when compared to their peers
and an applicable index.”
2. This section
states, “The sponsor considers the duration of the funds relative to their peers...” Please disclose how the fund is
considering the duration of funds relative to their peers and how the fund is defining “peers”.
Response: In
response to this comment, the fifth bullet points in the third paragraph under “Security Selection” section will be replaced
with the following:
“Duration. The sponsor
considers the duration of the funds (with the sponsor favoring funds with a shorter duration) relative to their peers (the
sponsor considers peer funds to be be closed-end funds that invest substantially in income-oriented securities) as well as the
overall portfolio.”
3.
Please reconcile the statement, “The sponsor considers the duration of the funds relative to their peers...” and the
previous statement that the sponsor seeks to select Closed-End Funds that hold securities that have limited durations, meaning five
years or less.
Response: The trust does not see a conflict between
these two statements and believes they are complimentary. The sponsor seeks to select closed-end funds that hold securities that have
a duration of five years or less. Therefore in the selection process, the sponsor considers the duration of closed-end funds relative
to their peers, with a preference for funds with a duration of five years or less.
Part
B — Financial Sector Risks
4. There
are references contained in this section to proposed changes by bank regulatory authorities to the Community Reinvestment Act and fair
lending laws that may need to be updated. Please update this section as appropriate. Additionally, reference is made to the EESA. Please
define what EESA is in reference to.
Response: In response
to this comment, the Financial Sector Risks section in Part B will be updated as appropriate. Additionally, the EESA will be defined
as the “Emergency Economic Stabilization Act of 2008”.
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