Correspondence 0001445546-24-004242 from FT 11525 (CIK 0002016536)
FT 11525 (CIK 0002016536)
Date: June 12, 2024 · CIK: 0002016536 · Accession: 0001445546-24-004242
AI Filing Summary & Sentiment
File numbers found in text: 333-279312
Letter
Division of Investment Management Re: FT 11525 Tactical Income Portfolio, Series 81 (the “Trust”) CIK No. 2016536 File No. 333-279312
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, the Trust also invests in common stocks that are issued by foreign companies (including American Depositary Receipts and emerging and/or developing market companies) and in companies with various market capitalizations, and through the Trust’s investment in the Funds, the Trust has principal risk exposure to floating-rate securities, high-yield securities, covenant-lite loans, foreign securities (including American Depositary Receipts, Global Depositary Receipts, New York Registry Shares and emerging and/or developing market companies) and companies with various market capitalizations.” 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 investment in distressed municipal bonds is a principal investment for the Trust, please add the 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 12, 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 11525
Tactical Income Portfolio, Series 81
(the “Trust”)
CIK No. 2016536 File No. 333-279312
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, the Trust also invests in common
stocks that are issued by foreign companies (including American Depositary Receipts and emerging and/or developing market companies) and
in companies with various market capitalizations, and through the Trust’s investment in the Funds, the Trust has principal risk
exposure to floating-rate securities, high-yield securities, covenant-lite loans, foreign securities (including American Depositary Receipts,
Global Depositary Receipts, New York Registry Shares and emerging and/or developing market companies) and companies with various market
capitalizations.” 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
investment in distressed municipal bonds is a principal investment for the Trust, please add the 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