Correspondence 0001445546-24-006768 from FT 11737 (CIK 0002029362)
FT 11737 (CIK 0002029362)
Date: Oct. 8, 2024 · CIK: 0002029362 · Accession: 0001445546-24-006768
AI Filing Summary & Sentiment
File numbers found in text: 333-281703
Letter
Division of Investment Management Re: FT 11737 Diversified Fixed Income ETF Portfolio, Series 61 (the “Trust”) CIK No. 2029362 File No. 333-281703
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.Please consider the continuing accuracy of the “Market Risk” disclosure in light of the Federal Reserve’s Federal Open Market Committee meeting, and subsequent interest rate cuts, on September 18, 2024.
Response:In accordance with the Staff’s comment, the “Market Risk” has been revised as follows:
Market Risk. Market risk is the risk that a particular security, or Units of the Trust in general, may fall in value or underperform other investments. Securities are subject to market fluctuations caused by such factors as economic, political, regulatory or market developments, changes in interest rates and perceived trends in securities prices. The Federal Reserve has recently lowered interest rates and may continue to do so in the future. Recent and potential future bank failures could result in disruption to the broader banking industry or markets generally and reduce confidence in financial institutions and the economy as a whole, which may also heighten market volatility and reduce liquidity. In addition, local, regional or global events such as war, acts of terrorism, spread of infectious diseases or other public health issues, recessions, political turbulence or other events could have a significant negative impact on the Trust and its investments. For example, the COVID-19 global pandemic and the ensuing policies enacted by governments and central banks have caused and may continue to cause significant volatility and uncertainty in global financial markets, negatively impacting global growth prospects. While vaccines have been developed, there is no guarantee that vaccines will be effective against future variants of the disease. The impact of the COVID-19 pandemic, or any future public health crisis, may be short term or may last for an extended period of time, and in either case could result in a substantial economic downturn or recession. Ongoing armed conflicts between Russia and Ukraine in Europe and among Israel, Hamas and other militant groups in the Middle East have caused and could continue to cause significant market disruptions and volatility within the markets in Russia, Europe, the Middle East and the United States. The hostilities and sanctions resulting from those hostilities could have a significant impact on certain Trust investments as well as Trust performance. Such events may affect certain geographic regions, countries, sectors and industries more significantly than others. Such events could adversely affect the prices and liquidity of the Trust’s portfolio securities and could result in disruptions in the trading markets. Any such circumstances could have a materially negative impact on the value of the Trust’s Units and result in increased market volatility.
2.If certain Funds held by the Trust invest in distressed debt securities and such investment would be considered a principal investment for the Trust, please add appropriate risk disclosure.
Response:If, based on the Trust’s final portfolio, the Trust has material exposure to distressed debt securities, appropriate risk disclosure will be added to the Trust’s prospectus.
3.If the Funds held by the Trust invest significantly in subprime residential mortgage loans, please add appropriate risk disclosure.
Response:If, based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in subprime residential mortgage loans, 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
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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
October 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 11737
Diversified Fixed Income ETF Portfolio, Series 61
(the “Trust”)
CIK No. 2029362 File No. 333-281703
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.Please
consider the continuing accuracy of the “Market Risk” disclosure in light of the Federal Reserve’s Federal Open Market
Committee meeting, and subsequent interest rate cuts, on September 18, 2024.
Response:In
accordance with the Staff’s comment, the “Market Risk” has been revised as follows:
Market Risk. Market risk is the risk
that a particular security, or Units of the Trust in general, may fall in value or underperform other investments. Securities are subject
to market fluctuations caused by such factors as economic, political, regulatory or market developments, changes in interest rates and
perceived trends in securities prices. The Federal Reserve has recently lowered interest rates and may continue to do so in the future.
Recent and potential future bank failures could result in disruption to the broader banking industry or markets generally and reduce confidence
in financial institutions and the economy as a whole, which may also heighten market volatility and reduce liquidity. In addition, local,
regional or global events such as war, acts of terrorism, spread of infectious diseases or other public health issues, recessions, political
turbulence or other events could have a significant negative impact on the Trust and its investments. For example, the COVID-19 global
pandemic and the ensuing policies enacted by governments and central banks have caused and may continue to cause significant volatility
and uncertainty in global financial markets, negatively impacting global growth prospects. While vaccines have been developed, there is
no guarantee that vaccines will be effective against future variants of the disease. The impact of the COVID-19 pandemic, or any future
public health crisis, may be short term or may last for an extended period of time, and in either case could result in a substantial economic
downturn or recession. Ongoing armed conflicts between Russia and Ukraine in Europe and among Israel, Hamas and other militant groups
in the Middle East have caused and could continue to cause significant market disruptions and volatility within the markets in Russia,
Europe, the Middle East and the United States. The hostilities and sanctions resulting from those hostilities could have a significant
impact on certain Trust investments as well as Trust performance. Such events may affect certain geographic regions, countries, sectors
and industries more significantly than others. Such events could adversely affect the prices and liquidity of the Trust’s portfolio
securities and could result in disruptions in the trading markets. Any such circumstances could have a materially negative impact on the
value of the Trust’s Units and result in increased market volatility.
2.If
certain Funds held by the Trust invest in distressed debt securities and such investment would be considered a principal investment for
the Trust, please add appropriate risk disclosure.
Response:If,
based on the Trust’s final portfolio, the Trust has material exposure to distressed debt securities, appropriate risk disclosure
will be added to the Trust’s prospectus.
3.If
the Funds held by the Trust invest significantly in subprime residential mortgage loans, please add appropriate risk disclosure.
Response:If,
based on the Trust’s final portfolio, the Trust has exposure to Funds that invest in subprime residential mortgage loans, 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