Correspondence 0001445546-24-001472 from FT 11334 (CIK 0002006473)
FT 11334 (CIK 0002006473)
Date: Feb. 20, 2024 · CIK: 0002006473 · Accession: 0001445546-24-001472
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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 11334
Balanced Income Equity and ETF Portfolio, Series 67
(the “Trust”)
CIK No. 2006473 File No. 333- 276833
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 Trust invests in dividend-paying common stocks and ETFs. Please consider including a description of the ETFs in the
section entitled “Objectives.”
Response:In
accordance with the Staff’s comment, the Trust confirms that the disclosure in the section entitled “Objectives” has
been modified to note its investment in fixed income ETFs.
3.The
Staff notes that the order of disclosure in the section entitled “Portfolio Selection Process” is inconsistent with the order
of investments in the first paragraph of that section. Please consider revising.
Response:In
accordance with the Staff’s comment, the Trust confirms that the order of the disclosure in the section entitled “Portfolio
Selection Process” has been revised to match the order of investments in the first paragraph of that section.
4.Please
consider moving the last paragraph of the section entitled “Portfolio Selection Process” to the beginning of the section.
Response:In
accordance with the Staff’s comment, the Trust confirms that the last paragraph of the section entitled “Portfolio Selection
Process” has been moved to the beginning of the section.
Risk Factors
5.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.
6.Please
consider including a lack of diversification risk factor for the Trust’s investment in common stocks.
Response:With
respect to the Staff’s comment, the Trust believes that the existing risk disclosure is appropriate for the Trust’s investments;
however, the Sponsor intends to consider adding risk disclosure for lack of diversification where a future trust invests in a relatively
small number of securities, or has outsized exposure to a small number of securities.
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