Correspondence 0001445546-24-001471 from FT 11313 (CIK 0002003348)
FT 11313 (CIK 0002003348)
Date: Feb. 20, 2024 · CIK: 0002003348 · Accession: 0001445546-24-001471
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File numbers found in text: 333-276925
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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
February 20, 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 11313
FT High Income Municipal Model Portfolio, Series 6
(the “Trust”)
CIK No. 2003348 File No. 333-276925
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.The
Staff notes that the “High-Yield Securities” risk factor includes disclosure relating to distressed debt securities. If investment
in distressed municipal bonds is a principal investment for the Trust, please add appropriate disclosure.
Response:The
Trust notes that the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure
and certain of the Funds held by the Trust invest in high-yield securities, which may include distressed debt securities. If, based on
the Trust’s final portfolio, the Trust has material exposure to distressed municipal bonds, relevant disclosure will be added to
the Trust’s prospectus.
Risk Factors
2.If
the Trust will have material exposure to the municipal bonds issued by any jurisdiction experiencing financial distress, please identify
that jurisdiction and add relevant risk disclosure.
Response:If,
based on the Trust’s final portfolio, the Trust has material exposure to any jurisdiction experiencing financial distress, relevant
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