Correspondence 0001445546-24-005224 from FT 11589 (CIK 0002020653)
FT 11589 (CIK 0002020653)
Date: July 26, 2024 · CIK: 0002020653 · Accession: 0001445546-24-005224
AI Filing Summary & Sentiment
File numbers found in text: 333-280289
Letter
Division of Investment Management Re: FT 11589 Diversified Assets Portfolio, Series 13 (the “Trust”) CIK No. 2020653 File No. 333-280289
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.If any of the ETFs in the Trust’s portfolio are advised by First Trust Advisors L.P., an affiliate of the Trust’s sponsor, please add disclosure addressing the potential conflicts arising from and benefits to First Trust Advisors L.P. from the Trust’s investment in such ETFs.
Response:If the Trust has exposure to any ETFs which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate disclosure will be added to the Trust’s prospectus.
2.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, foreign securities (including American Depositary Receipts, Global Depositary Receipts and New York Registry Shares) 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
3.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.
4.The Staff notes that the Trust, through the Trust’s investment in the Funds, has exposure to companies with various market capitalizations. If investment in small and/or mid capitalization companies is a principal investment for the Trust, please add appropriate risk disclosure for investment in Small and/or Mid Capitalization Companies.
Response:If, based on the Trust’s final portfolio, the Trust has material exposure to Small and/or Mid Capitalization Companies, 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
July 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 11589
Diversified Assets Portfolio, Series 13
(the “Trust”)
CIK No. 2020653 File No. 333-280289
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.If
any of the ETFs in the Trust’s portfolio are advised by First Trust Advisors L.P., an affiliate of the Trust’s sponsor, please
add disclosure addressing the potential conflicts arising from and benefits to First Trust Advisors L.P. from the Trust’s investment
in such ETFs.
Response:If
the Trust has exposure to any ETFs which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate
disclosure will be added to the Trust’s prospectus.
2.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, foreign securities (including American Depositary
Receipts, Global Depositary Receipts and New York Registry Shares) 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
3.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.
4.The
Staff notes that the Trust, through the Trust’s investment in the Funds, has exposure to companies with various market capitalizations.
If investment in small and/or mid capitalization companies is a principal investment for the Trust, please add appropriate risk disclosure
for investment in Small and/or Mid Capitalization Companies.
Response:If,
based on the Trust’s final portfolio, the Trust has material exposure to Small and/or Mid Capitalization Companies, 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