Correspondence 0001445546-23-007950 from FT 11114 (CIK 0001990323)
FT 11114 (CIK 0001990323)
Date: Nov. 21, 2023 · CIK: 0001990323 · Accession: 0001445546-23-007950
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File numbers found in text: 333-275064
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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 21, 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 11114
Tactical Income Portfolio, Series 78
(the “Trust”)
CIK No. 1990323 File No. 333-275064
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
Risk Factors
1.The
fourth sentence of “Interest Rate Risk” states, “The Federal Reserve has recently raised interest rates and expects
to continue to do so in response to inflation.” Please delete “recently” to be consistent with the Market Risk disclosure
above, 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 may
continue to do so in response to inflation.”
2.If
the Trust will initially invest in distressed securities as a principal strategy, please add appropriate disclosure.
Response:In
accordance with the Staff’s comment, if the Trust’s final portfolio has exposure to Funds that invest in distressed securities,
appropriate disclosure will be added to the Trust’s prospectus.
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