Correspondence 0001445546-23-007465 from FT 11096 (CIK 0001989592)
FT 11096 (CIK 0001989592)
Date: Nov. 8, 2023 · CIK: 0001989592 · Accession: 0001445546-23-007465
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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T 312.845.3000
F 312.701.2361
www.chapman.com
November 8, 2023
Mark Cowan
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549
Re:
FT 11096
Cboe Vest Financials Buffered 20 Portfolio
(the “Trust”)
CIK No. 1989592 File No. 333- 274716
Dear Mr. Cowan:
We received your comments
regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comments.
Comments
Cover Page
1.Please
revise the “before” and “after” parentheticals relating to the cap and buffer amounts throughout the prospectus
to remove the reference to the Trust’s annual operating expenses.
Response:In accordance with
the Staff’s comment, the disclosure has been revised accordingly.
Portfolio
2.Please
include a statement the Trust’s portfolio is concentrated in investments that provide exposure to the financials sector.
Response:In accordance with
the Staff’s comment, the Trust has added the following disclosure to the “Objective” section of the prospectus:
The Trust is concentrated (i.e., invests 25% or
more of Trust assets) in investments that provide exposure to the financials sector.
Additionally, the Trust has added
the following risk factor immediately preceding the “Financial Sector Risk”:
Concentration Risk. When 25% or more of
a trust’s portfolio is invested in securities that provide exposure to companies within a single sector, the trust is considered
to be concentrated in that particular sector. A portfolio concentrated in one or more sectors may present more risks than a portfolio
broadly diversified over several sectors.
The Trust is concentrated in investments that
provide exposure to the financials sector.
3.The
Staff notes the disclosure states, “Under normal market conditions, the Trust will invest at least 80% of its net assets in investments
that provide exposure to financial companies.” Please include a definition of “financial companies.”
Response:In accordance with
the Staff’s comment, the disclosure has been revised as follows:
Under normal market conditions, the Trust will
invest at least 80% of its net assets in investments that provide exposure to financial companies, which are those companies included
in the Underlying Index (as defined below).
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 Brian D. Free at (312) 845-3017 or the undersigned at (312) 845-3721.
Very truly yours,
Chapman and Cutler llp
By:
/s/ Daniel J. Fallon
Daniel J. Fallon