Correspondence 0001445546-24-004842 from FT 11604 (CIK 0002020844)
FT 11604 (CIK 0002020844)
Date: July 10, 2024 · CIK: 0002020844 · Accession: 0001445546-24-004842
AI Filing Summary & Sentiment
File numbers found in text: 333-280163
Letter
Division of Investment Management Re: FT 11604 Senior Loan and Limited Duration ETF Portfolio, Series 11 (the “Trust”) CIK No. 2020844 File No. 333-280163
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 covenant-lite loans, floating-rate securities, high-yield securities and investment grade securities.” 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 final portfolio of the Trust holds Funds that will employ leverage in their portfolios, please add appropriate risk disclosure.
Response: If, based on the Trust’s final portfolio, the Trust has exposure to Funds that employ leverage, appropriate disclosure will be added to the 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 10, 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 11604
Senior Loan and Limited Duration ETF Portfolio, Series 11
(the “Trust”)
CIK No. 2020844 File No. 333-280163
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 covenant-lite loans, floating-rate securities, high-yield securities and investment
grade securities.” 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 final portfolio of the Trust holds Funds that will employ leverage in their portfolios, please add appropriate risk disclosure.
Response:
If, based on the Trust’s final portfolio, the Trust has exposure to Funds that employ leverage, appropriate disclosure will be added
to the 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