Correspondence 0001445546-24-006505 from FT 11691 (CIK 0002026575)
FT 11691 (CIK 0002026575)
Date: Sept. 20, 2024 · CIK: 0002026575 · Accession: 0001445546-24-006505
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File numbers found in text: 333-281470
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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
September 20, 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 11691
FT Equity Allocation ETF Model Portfolio, 4Q ‘24
(the “Trust”)
CIK No. 2026575 File No. 333-281470
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
Risk Factors
1.If
the Trust will be concentrated in any of the listed sectors, please disclose and add a general risk factor regarding “Concentration
Risk.”
Response:For
purposes of determining whether the Trust is concentrated in any Global Industry Classification Standard (“GICS®”)
sector, the Trust will consider the investments of the underlying investment companies to the extent the Trust has sufficient information
about such investments. Therefore, to the extent practicable, if the Trust will be concentrated in any GICS sector based on the Trust’s
final portfolio, appropriate disclosure will be added to the Trust’s prospectus.
2.If
the Funds held by the Trust invest in emerging market issuers, please add relevant risk disclosure.
Response:If,
based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in emerging market companies, appropriate risk
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