Correspondence 0001445546-24-004598 from FT 11510 (CIK 0002014383)
FT 11510 (CIK 0002014383)
Date: June 26, 2024 · CIK: 0002014383 · Accession: 0001445546-24-004598
AI Filing Summary & Sentiment
File numbers found in text: 333-279361
Letter
Division of Investment Management Re: FT 11510 FT Equity Allocation ETF Model Portfolio, 3Q ‘24 (the “Trust”) CIK No. 2014383 File No. 333-279361
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. The Staff notes the following disclosure, “While not a part of the Trust's portfolio selection process, through the Trust's investment in the Funds, the Trust has principal risk exposure to foreign securities (including American Depositary Receipts, Global Depositary Receipts and New York Registry Shares).” The Staff notes this paragraph should focus on the types of investments the Trust will be exposed to, not the principal risk exposure of these investments. Accordingly, please delete the phrase “principal risk” from the above disclosure.
Response: In accordance with the Staff’s comment, “principal risk” will be removed from the above referenced disclosure.
Risk Factors
2. If the Funds held by the Trust invest in emerging markets, please add relevant risk disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in emerging market companies, appropriate risk disclosure will be added to the Trust’s prospectus.
3. With respect to the Funds selected for investment by the Trust that are advised by affiliates of the Trust’s Sponsor, consider whether a separate risk factor should be included.
Response: The Trust has considered the Staff’s comment and has revised the disclosure in the section entitled “Portfolio Selection Process” relating to the Trust’s investments in ETFs advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, as the Trust believes the placement of the revised disclosure is appropriate for investor comprehension. To the extent the Fund invests significantly in a single affiliated ETF, additional disclosure will be added to the “Principal Risks” section. The following disclosure has been added to the prospectus:
The Sponsor may invest in an affiliated ETF even in circumstances where an unaffiliated ETF may have lower fees or better performance over certain time periods.
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
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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
June 26, 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 11510
FT Equity Allocation ETF Model Portfolio, 3Q ‘24
(the “Trust”)
CIK No. 2014383 File No. 333-279361
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. The
Staff notes the following disclosure, “While not a part of the Trust's portfolio selection process, through the Trust's investment
in the Funds, the Trust has principal risk exposure to foreign securities (including American Depositary Receipts, Global Depositary Receipts
and New York Registry Shares).” The Staff notes this paragraph should focus on the types of investments the Trust will be exposed
to, not the principal risk exposure of these investments. Accordingly, please delete the phrase “principal risk” from the
above disclosure.
Response: In
accordance with the Staff’s comment, “principal risk” will be removed from the above referenced disclosure.
Risk Factors
2. If
the Funds held by the Trust invest in emerging markets, please add relevant risk disclosure.
Response: If,
based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in emerging market companies, appropriate risk
disclosure will be added to the Trust’s prospectus.
3. With
respect to the Funds selected for investment by the Trust that are advised by affiliates of the Trust’s Sponsor, consider whether
a separate risk factor should be included.
Response: The
Trust has considered the Staff’s comment and has revised the disclosure in the section entitled “Portfolio Selection Process”
relating to the Trust’s investments in ETFs advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, as
the Trust believes the placement of the revised disclosure is appropriate for investor comprehension. To the extent the Fund invests significantly
in a single affiliated ETF, additional disclosure will be added to the “Principal Risks” section. The following disclosure
has been added to the prospectus:
The Sponsor may invest in an affiliated ETF even
in circumstances where an unaffiliated ETF may have lower fees or better performance over certain time periods.
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