Correspondence 0001528621-24-000457 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2405 (CIK 0002008060)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2405 (CIK 0002008060)
Date: April 26, 2024 · CIK: 0002008060 · Accession: 0001528621-24-000457
AI Filing Summary & Sentiment
File numbers found in text: 333-278089, 811-03763
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2405 Core Four 60/40 Allocation Portfolio, Series 27 File Nos. 333-278089 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 2405, filed on March 20, 2024, with the Securities and Exchange Commission. The registration statement proposes to offer the Core Four 60/40 Allocation Portfolio, Series 27 (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.
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 2405 Core Four 60/40 Allocation Portfolio, Series 27 File Nos. 333-278089 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 2405, filed on March 20, 2024, with the Securities and Exchange Commission. The registration statement proposes to offer the Core Four 60/40 Allocation Portfolio, Series 27 (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. 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