Correspondence 0001528621-24-000833 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2423 (CIK 0002008079)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2423 (CIK 0002008079)
Date: Aug. 14, 2024 · CIK: 0002008079 · Accession: 0001528621-24-000833
AI Filing Summary & Sentiment
File numbers found in text: 333-280477, 811-03763
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2423 Diversified Credit Portfolio of ETFs, Series File Nos. 333-280477 and 811-03763
Dear Mr. Brodsky:
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 2423, filed on June 26, 2024, with the Securities and Exchange Commission (the “Commission”). The registration statement proposes to offer the Diversified Credit Portfolio, Series 25 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
1. Please disclose how the trust is defining the term “primary market” and the phrase “becoming more engaged with global markets.”
Response: In response to the comment, the second, third and fourth sentence of the fourth paragraph under “Principal Investment Strategy” will be removed and replaced with the following:
Whether a security is deemed to be foreign is generally determined by a combination of the security’s issuer’s country of incorporation and the primary listing of the security; however, if these two factors differ, the location of the issuer’s sales and assets is also considered. An emerging market country is generally defined as a developing country with low per capita income in the initial stages of its industrialization cycle.
2. Please disclose concretely the trust’s actual investments as of the date of deposit, ensuring that the Principal Risks section only covers risks associated with the trust’s actual investments at the date of deposit.
Response: Once the portfolio is selected, disclosure will be added that states 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.
3. The first paragraph under the “Principal Investment Strategy” section notes that the exchange-traded funds may invest in convertible securities. Please disclose whether the exchange-traded funds will substantially invest in contingent convertible securities. If so, please disclose this in the principal investment strategies and provide the corresponding risk disclosures.
Response: The exchange-traded funds that the trust may invest in do not currently invest substantially in contingent convertible 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 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
August 14, 2024
Via EDGAR Filing
Mr. Aaron Brodsky
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 2423
Diversified Credit Portfolio of ETFs, Series
25
File Nos. 333-280477 and 811-03763
Dear Mr. Brodsky:
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 2423, filed on June 26, 2024, with the Securities and Exchange Commission (the “Commission”).
The registration statement proposes to offer the Diversified Credit Portfolio, Series 25 (the “trust”).
PROSPECTUS
Investment
Summary — Principal Investment Strategy
1. Please disclose
how the trust is defining the term “primary market” and the phrase “becoming more engaged with global markets.”
Response: In response to
the comment, the second, third and fourth sentence of the fourth paragraph under “Principal Investment Strategy” will be removed
and replaced with the following:
Whether a security is
deemed to be foreign is generally determined by a combination of the security’s issuer’s country of incorporation and the
primary listing of the security; however, if these two factors differ, the location of the issuer’s sales and assets is also considered.
An emerging market country is generally defined as a developing country with low per capita income in the initial stages of its industrialization
cycle.
2. Please
disclose concretely the trust’s actual investments as of the date of deposit, ensuring that the Principal Risks section only covers
risks associated with the trust’s actual investments at the date of deposit.
Response: Once
the portfolio is selected, disclosure will be added that states 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.
3. The
first paragraph under the “Principal Investment Strategy” section notes that the exchange-traded funds may invest in convertible
securities. Please disclose whether the exchange-traded funds will substantially invest in contingent convertible securities. If so, please
disclose this in the principal investment strategies and provide the corresponding risk disclosures.
Response: The
exchange-traded funds that the trust may invest in do not currently invest substantially in contingent convertible 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 the undersigned at (312) 845-3484.
Very truly yours,
Chapman
and Cutler LLP
By /s/ Morrison
C. Warren
Morrison C. Warren