Correspondence 0001445546-24-004600 from FT 11512 (CIK 0002016521)
FT 11512 (CIK 0002016521)
Date: June 26, 2024 · CIK: 0002016521 · Accession: 0001445546-24-004600
AI Filing Summary & Sentiment
File numbers found in text: 333-279362
Letter
Division of Investment Management Re: FT 11512 FT High Income Municipal Model Portfolio, Series 7 (the “Trust”) CIK No. 2016521 File No. 333-279362
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 investment grade securities.” 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.
2. The Staff notes that distressed debt securities is a principal risk factor. If investment in distressed municipal bonds is a principal investment for the Trust, please add appropriate 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.
Risk Factors
3. If the Trust will have material exposure to the 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 any jurisdiction experiencing financial distress, 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
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 11512
FT High Income Municipal Model Portfolio, Series 7
(the “Trust”)
CIK No. 2016521 File No. 333-279362
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 investment grade securities.” 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.
2. The
Staff notes that distressed debt securities is a principal risk factor. If investment in distressed municipal bonds is a principal investment
for the Trust, please add appropriate 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.
Risk Factors
3. If
the Trust will have material exposure to the 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 any jurisdiction experiencing financial distress, 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