Correspondence 0001445546-23-007188 from FT 11103 (CIK 0001989599)
FT 11103 (CIK 0001989599)
Date: Oct. 31, 2023 · CIK: 0001989599 · Accession: 0001445546-23-007188
AI Filing Summary & Sentiment
File numbers found in text: 333-274948
Letter
Division of Investment Management Re: FT 11103 Balanced Income Equity and ETF Portfolio, Series 65 (the “Trust”) CIK No. 1989599 File No. 333-274948
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
Portfolio
1.If a principal investment of the Trust, please also add distressed debt securities to the list of investment types that the ETF portion of the Trust invests in (consistent with the risk disclosure).
Response:The Trust notes that while distressed debt securities do not rise to a level of principal investment for the Trust, the Trust believes the current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure. As such, the Trust respectfully declines to add distressed debt securities to the Portfolio Selection Process section.
Risk Factors
2.With respect to “companies with various market capitalizations,” if the Trust has exposure to small and/or mid capitalization companies, please include a risk factor for small and/or mid capitalization companies.
Response:If the Trust has exposure to small and/or mid capitalization companies, appropriate risk disclosure will be added to the Trust’s prospectus. If the Trust does not have exposure to small and/or mid capitalization companies, the “Additional Portfolio Contents” disclosure will be revised accordingly.
3.With respect to the “Interest Rate Risk,” please delete “recently” to be consistent with the “Market Risk” disclosure, which notes “. . . the Federal Reserve has raised interest rates and expects to continue to do so . . . .”
Response:In accordance with the Staff’s comment, the word “recently” in the fourth sentence of the “Interest Rate Risk” will be removed and the sentence will be replaced in its entirety with the following:
“The Federal Reserve has raised interest rates and expects to continue to do so in response to inflation.”
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
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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
October 31, 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 11103
Balanced Income Equity and ETF Portfolio, Series 65
(the “Trust”)
CIK No. 1989599 File No. 333-274948
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
Portfolio
1.If
a principal investment of the Trust, please also add distressed debt securities to the list of investment types that the ETF portion of
the Trust invests in (consistent with the risk disclosure).
Response:The
Trust notes that while distressed debt securities do not rise to a level of principal investment for the Trust, the Trust believes the
current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially
related to the high-yield securities risk disclosure. As such, the Trust respectfully declines to add distressed debt securities to the
Portfolio Selection Process section.
Risk Factors
2.With
respect to “companies with various market capitalizations,” if the Trust has exposure to small and/or mid capitalization companies,
please include a risk factor for small and/or mid capitalization companies.
Response:If
the Trust has exposure to small and/or mid capitalization companies, appropriate risk disclosure will be added to the Trust’s prospectus.
If the Trust does not have exposure to small and/or mid capitalization companies, the “Additional Portfolio Contents” disclosure
will be revised accordingly.
3.With
respect to the “Interest Rate Risk,” please delete “recently” to be consistent with the “Market Risk”
disclosure, which notes “. . . the Federal Reserve has raised interest rates and expects to continue to do so . . . .”
Response:In
accordance with the Staff’s comment, the word “recently” in the fourth sentence of the “Interest
Rate Risk” will be removed and the sentence will be replaced in its entirety with the following:
“The Federal Reserve has raised interest
rates and expects to continue to do so in response to inflation.”
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