Correspondence 0001445546-24-001775 from FT 11341 (CIK 0002006480)
FT 11341 (CIK 0002006480)
Date: March 6, 2024 · CIK: 0002006480 · Accession: 0001445546-24-001775
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File numbers found in text: 333-277135
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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
March 6, 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 11341
Dividend Growers and Tax-Advantaged Income Portfolio, Series 39
(the “Trust”)
CIK No. 0002006480 File No. 333-277135
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.Please
include additional disclosure on the percentage breakdown of the portfolio construction between the investments in ETFs and common stocks.
If the construction is intended to be flexible, please clarify.
Response:The
Trust believes that the current disclosure is accurate and appropriate for investor comprehension. The percentage breakdown of the portfolio
construction is available in the Trust’s Schedule of Investments.
2.Please
consider revising the “Additional Portfolio Contents Disclosure” to clarify the additional investments the Trust invests in,
and the investments the Trust has exposure to through the underlying ETFs it invests in.
Response:The
Trust confirms the disclosure has been modified to distinguish the different additional exposure the Trust has from its investments in
the underlying ETFs.
Risk Factors
3.If
the Trust will have material exposure to 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 distressed municipal bonds, 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