Correspondence 0001528621-24-000456 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2401 (CIK 0002008056)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2401 (CIK 0002008056)
Date: April 26, 2024 · CIK: 0002008056 · Accession: 0001528621-24-000456
AI Filing Summary & Sentiment
File numbers found in text: 333-278051, 811-03763
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2401 Floating Rate & Dividend Growth Portfolio, Series File Nos. 333-278051 and 811-03763
Dear Mr. Rosenberg:
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 2401, filed on March 19, 2024, with the Securities and Exchange Commission. The registration statement proposes to offer the Floating Rate & Dividend Growth Portfolio, Series 30 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
1. Rather than providing and opened list of potential investments in the Principal Investment Strategy section, please disclose 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.
Investment Summary — Security Selection
2. Under “Security Selection” it states that the sponsor favors Closed-End Funds that are trading at a discount relative to their peers. Please address under the “Principal Risks” section the implications associated with Closed-End Funds that trade at a discount and the risks associated therewith.
Response: In response to the comment, the following risk disclosure will be added after the fourth sentence in the risk that begins “The trust invests in Closed-End Funds” under the “Principal Risks” section and at the end of the second paragraph under the “Closed-End Fund risk” is the back of the prospectus:
“If the trust has to sell a Closed-End Fund when it is trading at a discount, the trust will receive a price that is less than the Closed-End Fund’s net asset value.”
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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CORRESP 1 filename1.htm Chapman and Cutler LLP 320 South Canal Street, 27th Floor Chicago, Illinois 60606 April 26, 2024 Via EDGAR Filing Mr. Michael Rosenberg Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2401 Floating Rate & Dividend Growth Portfolio, Series 30 File Nos. 333-278051 and 811-03763 Dear Mr. Rosenberg: 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 2401, filed on March 19, 2024, with the Securities and Exchange Commission. The registration statement proposes to offer the Floating Rate & Dividend Growth Portfolio, Series 30 (the “trust”). PROSPECTUS Investment Summary — Principal Investment Strategy 1. Rather than providing and opened list of potential investments in the Principal Investment Strategy section, please disclose 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. Investment Summary — Security Selection 2. Under “Security Selection” it states that the sponsor favors Closed-End Funds that are trading at a discount relative to their peers. Please address under the “Principal Risks” section the implications associated with Closed-End Funds that trade at a discount and the risks associated therewith. Response: In response to the comment, the following risk disclosure will be added after the fourth sentence in the risk that begins “The trust invests in Closed-End Funds” under the “Principal Risks” section and at the end of the second paragraph under the “Closed-End Fund risk” is the back of the prospectus: “If the trust has to sell a Closed-End Fund when it is trading at a discount, the trust will receive a price that is less than the Closed-End Fund’s net asset value.” 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