Correspondence 0001528621-24-000380 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2400 (CIK 0002008055)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2400 (CIK 0002008055)
Date: April 16, 2024 · CIK: 0002008055 · Accession: 0001528621-24-000380
AI Filing Summary & Sentiment
File numbers found in text: 333-277263, 811-03763
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2400 Balanced Income Builder Portfolio, Series 47 File Nos. 333-277263 and 811-03763
Dear Ms. Vroman-Lee:
This letter responds to the comments given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2400, filed on February 22, 2024, with the Securities and Exchange Commission. The registration statement proposes to offer the Balanced Income Builder Portfolio, Series 47 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
1. In the second paragraph under the “Principal Investment Strategy” section, please define how the trust is defining small-, mid- and large capitalization companies.
Response: In response to this comment, the third sentence of the second paragraph under the “Principal Investment Strategy” section will be revised to the following: “The U.S.-listed common stocks held by the trust may include the common stocks of U.S. and non-U.S. companies of small-, mid- or large-capitalizations (capitalizations are as determined by FTSE Russell).”
2. In the third paragraph under the “Principal Investment Strategy” section, please define how the trust is defining “strong financial strength” and “positive performance relative to their peers.”
Response: In response to this comment, the first sentence of the third paragraph under the “Principal Investment Strategy” section will be revised to the following: “The sponsor and GPIM believe that companies that distribute significant dividends on a consistent basis generally demonstrate strong financial strength (such as positive sustainable cash flow and the ability to return capital to investors) and positive performance relative to their peers (i.e., exhibit capital appreciation and income for a total return that is higher than their peers).”
3. Please disclose concretely the trust’s actual investments. Alternatively, please supplement the open-ended list by also disclosing additional detail about the trust’s actual investments as of the date of deposit. Please ensure that the “Principal Risks” section only covers risks associated with the trust’s principal investments as of the date of deposit.
Response: Once the portfolio is selected, a sentence will be added to the section entitled “Principal Investment Strategy” stating the types of investments that represent a significant amount of the trust’s assets as of the date of deposit. The section entitled “Principal Risks” will be revised to match this list, as appropriate.
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 the undersigned at (312) 845-3484.
Very truly yours,
Chapman
and Cutler LLP
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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
April 16, 2024
Via EDGAR Filing
Ms. Ashley Vroman-Lee
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 2400
Balanced Income Builder Portfolio, Series 47
File Nos. 333-277263 and 811-03763
Dear Ms. Vroman-Lee:
This letter responds to
the comments given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim
Defined Portfolios, Series 2400, filed on February 22, 2024, with the Securities and Exchange Commission. The registration statement
proposes to offer the Balanced Income Builder Portfolio, Series 47 (the “trust”).
PROSPECTUS
Investment
Summary — Principal Investment Strategy
1.
In the second paragraph under the “Principal Investment Strategy” section, please define how the trust is defining small-,
mid- and large capitalization companies.
Response: In
response to this comment, the third sentence of the second paragraph under the “Principal Investment Strategy” section will
be revised to the following: “The U.S.-listed common stocks held by the trust may include the common stocks of U.S. and non-U.S.
companies of small-, mid- or large-capitalizations (capitalizations are as determined by FTSE Russell).”
2.
In the third paragraph under the “Principal Investment Strategy” section, please define how the trust is defining “strong
financial strength” and “positive performance relative to their peers.”
Response: In
response to this comment, the first sentence of the third paragraph under the “Principal Investment Strategy” section will
be revised to the following: “The sponsor and GPIM believe that companies that distribute significant dividends on a consistent
basis generally demonstrate strong financial strength (such as positive sustainable cash flow and the ability to return capital to investors)
and positive performance relative to their peers (i.e., exhibit capital appreciation and income for a total return that is higher than
their peers).”
3. Please
disclose concretely the trust’s actual investments. Alternatively, please supplement the open-ended list by also disclosing additional
detail about the trust’s actual investments as of the date of deposit. Please ensure that the “Principal Risks” section
only covers risks associated with the trust’s principal investments as of the date of deposit.
Response: Once
the portfolio is selected, a sentence will be added to the section entitled “Principal Investment Strategy” stating the types
of investments that represent a significant amount of the trust’s assets as of the date of deposit. The section entitled “Principal
Risks” will be revised to match this list, as appropriate.
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 the undersigned at (312) 845-3484.
Very truly yours,
Chapman
and Cutler LLP
By /s/ Morrison
C. Warren
Morrison C. Warren