Correspondence 0001445546-24-005250 from FT 11619 (CIK 0002022996)
FT 11619 (CIK 0002022996)
Date: July 30, 2024 · CIK: 0002022996 · Accession: 0001445546-24-005250
AI Filing Summary & Sentiment
File numbers found in text: 333-280456
Letter
Division of Investment Management Re: FT 11619 Dividend Growers and Tax-Advantaged Income Portfolio, Series 41 (the “Trust”) CIK No. 2022996 File No. 333-280456
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.Please include additional disclosure on the percentage breakdown of the portfolio construction between the investments in ETFs and common stocks. If the construction is intended to be flexible, please state that the percentage breakdown of the portfolio construction is available in the Trust’s Schedule of Investments.
Response:The Sponsor does not intend to allocate specific percentages of the portfolio to investments in ETFs and Common Stocks. However, the Trust notes that the final portfolio holdings, broken down by investments in ETFs and Common Stocks, will be listed in the Schedule of Investments. Therefore, the Trust believes the disclosure, as currently presented, is sufficient for investor comprehension.
2.Given that the universe of common stocks may include those 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:If, based on the Trust’s final portfolio, the Trust has exposure to small and/or mid capitalization companies, appropriate disclosure will be added to the Portfolio Selection Process and Risk Factors sections of the Trust’s prospectus.
Risk Factors
3.If the Trust will have material exposure to the municipal bonds issued by any jurisdiction experiencing financial distress, please identify that jurisdiction and add 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
July 30, 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 11619
Dividend Growers and Tax-Advantaged Income Portfolio, Series 41
(the “Trust”)
CIK No. 2022996 File No. 333-280456
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.Please
include additional disclosure on the percentage breakdown of the portfolio construction between the investments in ETFs and common stocks.
If the construction is intended to be flexible, please state that the percentage breakdown of the portfolio construction is available
in the Trust’s Schedule of Investments.
Response:The
Sponsor does not intend to allocate specific percentages of the portfolio to investments in ETFs and Common Stocks. However, the Trust
notes that the final portfolio holdings, broken down by investments in ETFs and Common Stocks, will be listed in the Schedule of Investments.
Therefore, the Trust believes the disclosure, as currently presented, is sufficient for investor comprehension.
2.Given
that the universe of common stocks may include those 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:If,
based on the Trust’s final portfolio, the Trust has exposure to small and/or mid capitalization companies, appropriate disclosure
will be added to the Portfolio Selection Process and Risk Factors sections of the Trust’s prospectus.
Risk Factors
3.If
the Trust will have material exposure to the municipal bonds issued by any jurisdiction experiencing financial distress, please identify
that jurisdiction and add 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