Correspondence 0001445546-24-003834 from FT 11521 (CIK 0002016532)
FT 11521 (CIK 0002016532)
Date: May 24, 2024 · CIK: 0002016532 · Accession: 0001445546-24-003834
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File numbers found in text: 333-278946
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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 24, 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 11521
Balanced Income Equity and ETF Portfolio, Series 69
(the “Trust”)
CIK No. 2016532 File No. 333-278946
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
Risk Factors
1.The
Common Stock portion of the portfolio is comprised of 15 approximately equally weighted, sector-diverse equity income stocks. The Staff
notes that 15 equity securities are less likely to be diversified if held in large, mid and small cap companies. Please consider adding
diversification risk disclosure if the Trust is ultimately a 15-stock portfolio with mixed capitalization.
Response:With
respect to the Staff’s comment, the Trust believes that the existing risk disclosure is appropriate for the Trust’s investments;
however, the Sponsor intends to consider adding diversification risk disclosure where a future trust invests in a relatively small number
of securities or has outsized exposure to a small number of securities.
2.Given
that the universe of common stocks may include companies with a market capitalization of over $5 billion, please include disclosure in
the Portfolio Selection Process and Risk Factors sections as appropriate if the Trust has exposure to small and/or mid capitalization
companies.
Response:In
accordance with the Staff’s comment, if the Trust’s final portfolio has exposure to small and/or mid capitalization companies,
appropriate 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