Correspondence 0001445546-24-000426 from FT 11253 (CIK 0001999697)
FT 11253 (CIK 0001999697)
Date: Jan. 19, 2024 · CIK: 0001999697 · Accession: 0001445546-24-000426
AI Filing Summary & Sentiment
Letter
Division of Investment Management Re: FT 11253 Balanced Income Equity and ETF Portfolio, Series 66 (the “Trust”) CIK No. 1999697 File No. 333- 276059
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.
2.The Staff notes that the disclosure in the section entitled “Portfolio Selection Process” states, “The Trust invests approximately 50% in common stocks of dividend-paying companies and approximately 50% in ETFs which invest in (i) U.S. corporate bonds, (ii) foreign corporate bonds and (iii) foreign government bonds.” Please clarify what percentages the additional investments may be in.
Response:With respect to the Staff’s comment, the Trust notes that the assets listed in the section entitled “Additional Portfolio Contents” are not included in the investment strategy. However, these assets are included in the “Additional Portfolio Contents” section because the Trust has exposure to them through the common stocks and ETFs described in the section entitled “Portfolio Selection Process.”
Risk Factors
3.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.
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
January 19, 2024
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 11253
Balanced Income Equity and ETF Portfolio, Series 66
(the “Trust”)
CIK No. 1999697 File No. 333- 276059
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.
2.The
Staff notes that the disclosure in the section entitled “Portfolio Selection Process” states, “The Trust invests approximately
50% in common stocks of dividend-paying companies and approximately 50% in ETFs which invest in (i) U.S. corporate bonds, (ii) foreign
corporate bonds and (iii) foreign government bonds.” Please clarify what percentages the additional investments may be in.
Response:With
respect to the Staff’s comment, the Trust notes that the assets listed in the section entitled “Additional Portfolio Contents”
are not included in the investment strategy. However, these assets are included in the “Additional Portfolio Contents” section
because the Trust has exposure to them through the common stocks and ETFs described in the section entitled “Portfolio Selection
Process.”
Risk Factors
3.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.
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