Correspondence 0001445546-24-005226 from FT 11630 (CIK 0002023008)
FT 11630 (CIK 0002023008)
Date: July 26, 2024 · CIK: 0002023008 · Accession: 0001445546-24-005226
AI Filing Summary & Sentiment
File numbers found in text: 333-280482
Letter
Division of Investment Management Re: FT 11630 Balanced Income Equity and ETF Portfolio, Series 70 (the “Trust”) CIK No. 2023008 File No. 333-280482
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 Common Stock portion of the portfolio is comprised of 15 approximately equally weighted, sector-diverse equity income stocks. The Staff notes that 15 equity securities are less likely to be diversified if held in large, mid and small capitalization companies (as opposed to just large capitalization companies). Please consider adding diversification risk disclosure if the Trust is ultimately a 15-stock portfolio with mixed capitalization.
Response:With respect to the Staff’s comment, the Trust believes that the existing risk disclosure is appropriate for the Trust’s investments. The Trust notes that several of the ETFs in the portfolio invest in equity securities. However, the Sponsor intends to consider adding diversification risk disclosure where a future trust invests in a relatively small number of securities or has outsized exposure to a small number of securities.
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.
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 11630
Balanced Income Equity and ETF Portfolio, Series 70
(the “Trust”)
CIK No. 2023008 File No. 333-280482
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
Common Stock portion of the portfolio is comprised of 15 approximately equally weighted, sector-diverse equity income stocks. The Staff
notes that 15 equity securities are less likely to be diversified if held in large, mid and small capitalization companies (as opposed
to just large capitalization companies). Please consider adding diversification risk disclosure if the Trust is ultimately a 15-stock
portfolio with mixed capitalization.
Response:With
respect to the Staff’s comment, the Trust believes that the existing risk disclosure is appropriate for the Trust’s investments.
The Trust notes that several of the ETFs in the portfolio invest in equity securities. However, the Sponsor intends to consider adding
diversification risk disclosure where a future trust invests in a relatively small number of securities or has outsized exposure to a
small number of securities.
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.
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