Correspondence 0001445546-24-004601 from FT 11513 (CIK 0002016522)
FT 11513 (CIK 0002016522)
Date: June 26, 2024 · CIK: 0002016522 · Accession: 0001445546-24-004601
AI Filing Summary & Sentiment
File numbers found in text: 333-279393
Letter
Division of Investment Management Re: FT 11513 FT Short Duration Fixed Income Model Portfolio, 3Q ‘24 (the “Trust”) CIK No. 2016522 File No. 333-279393
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 common stocks, covenant-lite loans, U.S. Treasury obligations, 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. If investment in distressed debt securities is a principal investment for the Trust, please add relevant risk disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has material exposure to distressed debt securities, appropriate risk disclosure will be added to the Trust’s prospectus.
4. If the Funds held by the Trust invest in subprime residential mortgage loans, please add relevant risk disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in subprime residential mortgage loans, appropriate risk 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 11513
FT Short Duration Fixed Income Model Portfolio, 3Q ‘24
(the “Trust”)
CIK No. 2016522 File No. 333-279393
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 common stocks, covenant-lite loans, U.S. Treasury obligations, 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. If
investment in distressed debt securities is a principal investment for the Trust, please add relevant risk disclosure.
Response: If,
based on the Trust’s final portfolio, the Trust has material exposure to distressed debt securities, appropriate risk disclosure
will be added to the Trust’s prospectus.
4. If
the Funds held by the Trust invest in subprime residential mortgage loans, please add relevant risk disclosure.
Response: If,
based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in subprime residential mortgage loans, appropriate
risk 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