Correspondence 0001445546-24-003373 from FT 11473 (CIK 0002014645)
FT 11473 (CIK 0002014645)
Date: May 3, 2024 · CIK: 0002014645 · Accession: 0001445546-24-003373
AI Filing Summary & Sentiment
File numbers found in text: 333-278520
Letter
Division of Investment Management Re: FT 11473 Dividend Growers and Tax-Advantaged Income Portfolio, Series 40 (the “Trust”) CIK No. 2014645 File No. 333-278520
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.Please explain supplementally the reason the Trust only uses one- and two-year examples in the fee table. The Staff notes that the Sponsor uses fee table examples of one, three, five and ten years in other trusts.
Response:The Trust notes that the fee table shows one- and two-year expense example numbers for Trusts with a maturity of two years. Trusts with maturities less than two years typically have portfolios selected through the application of a strategy and Unit holders have the ability to reinvest maturity proceeds from the Trust into the next available series of that Trust and because of that ability, the Trust shows one-, three-, five- and ten-year expense example numbers as to show the expenses associated with a continued investment in the strategy.
2.Please include additional disclosure on the percentage breakdown of the portfolio construction between the investments in ETFs and common stocks. If the construction is intended to be flexible, please clarify.
Response:The Trust believes that the current disclosure is accurate and appropriate for investor comprehension. The percentage breakdown of the portfolio construction is available in the Trust’s Schedule of Investments.
3.Please consider revising the “Additional Portfolio Contents Disclosure” to clarify the additional investments the Trust invests in, and the investments the Trust has exposure to through the underlying ETFs it invests in.
Response:The Trust confirms the disclosure has been modified to distinguish the different additional exposure the Trust has from its investments in the underlying ETFs.
Risk Factors
4.If the Trust will have material exposure to municipal bonds issued by any jurisdiction experiencing financial distress, please identify that jurisdiction and add relevant risk disclosure.
Response:If, based on the Trust’s final portfolio, the Trust has material exposure to distressed municipal bonds, relevant disclosure will be added to the Trust’s prospectus.
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
May 3, 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 11473
Dividend Growers and Tax-Advantaged Income Portfolio, Series 40
(the “Trust”)
CIK No. 2014645 File No. 333-278520
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.Please
explain supplementally the reason the Trust only uses one- and two-year examples in the fee table. The Staff notes that the Sponsor uses
fee table examples of one, three, five and ten years in other trusts.
Response:The
Trust notes that the fee table shows one- and two-year expense example numbers for Trusts with a maturity of two years. Trusts with maturities
less than two years typically have portfolios selected through the application of a strategy and Unit holders have the ability to reinvest
maturity proceeds from the Trust into the next available series of that Trust and because of that ability, the Trust shows one-, three-,
five- and ten-year expense example numbers as to show the expenses associated with a continued investment in the strategy.
2.Please
include additional disclosure on the percentage breakdown of the portfolio construction between the investments in ETFs and common stocks.
If the construction is intended to be flexible, please clarify.
Response:The
Trust believes that the current disclosure is accurate and appropriate for investor comprehension. The percentage breakdown of the portfolio
construction is available in the Trust’s Schedule of Investments.
3.Please
consider revising the “Additional Portfolio Contents Disclosure” to clarify the additional investments the Trust invests in,
and the investments the Trust has exposure to through the underlying ETFs it invests in.
Response:The
Trust confirms the disclosure has been modified to distinguish the different additional exposure the Trust has from its investments in
the underlying ETFs.
Risk Factors
4.If
the Trust will have material exposure to municipal bonds issued by any jurisdiction experiencing financial distress, please identify that
jurisdiction and add relevant risk disclosure.
Response:If,
based on the Trust’s final portfolio, the Trust has material exposure to distressed municipal bonds, relevant disclosure will be
added to the Trust’s prospectus.
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