Correspondence 0001445546-24-004800 from FT 11600 (CIK 0002020840)
FT 11600 (CIK 0002020840)
Date: July 8, 2024 · CIK: 0002020840 · Accession: 0001445546-24-004800
AI Filing Summary & Sentiment
File numbers found in text: 333-280031
Letter
Division of Investment Management Re: FT 11600 Limited Duration Fixed Income ETF Portfolio, Series 59 (the “Trust”) CIK No. 2020840 File No. 333-280031
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 floating-rate securities, high-yield securities, investment grade securities, senior loans and covenant-lite loans.” 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.
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 8, 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 11600
Limited Duration Fixed Income ETF Portfolio, Series 59
(the “Trust”)
CIK No. 2020840 File No. 333-280031
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 floating-rate securities, high-yield securities, investment grade securities, senior
loans and covenant-lite loans.” 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.
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