Correspondence 0001528621-25-000278 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2478 (CIK 0002037674)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2478 (CIK 0002037674)
Date: March 7, 2025 · CIK: 0002037674 · Accession: 0001528621-25-000278
AI Filing Summary & Sentiment
File numbers found in text: 333-284548, 811-03763
Letter
Via EDGAR Filing Division of Investment Management Securities and Exchange Commission Washington, DC 20549 Re: Guggenheim Defined Portfolios, Series 2478 Income & Treasury Limited Duration Portfolio of Funds, Series 83 File Nos. 333-284548 and 811-03763
Dear Mr. Rosenberg:
This letter responds to the comment given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2478, filed on January 28, 2025, with the Securities and Exchange Commission (the “Commission”). The registration statement proposes to offer the Income & Treasury Limited Duration Portfolio of Funds, Series 83 (the “trust”).
PROSPECTUS
Investment Summary — Principal Risks
1. The staff of the Commission (the “Staff”) notes the risk “The trust includes an ETF” set forth in the “Principal Risks” section. Please add to the risk disclosure the risk of ETFs trading at a premium to their net asset value (e.g., the trust will pay more that the ETF’s net asset value).
Response: Pursuant to the Staff’s comment, the referenced disclosure has been revised accordingly.
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 the undersigned at (312) 845-3484.
Very truly yours,
Chapman
and Cutler LLP
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Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
March 7, 2025
Via EDGAR Filing
Mr. Michael Rosenberg
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 2478
Income & Treasury Limited Duration Portfolio
of Funds, Series 83
File Nos. 333-284548 and 811-03763
Dear Mr. Rosenberg:
This letter responds to
the comment given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim
Defined Portfolios, Series 2478, filed on January 28, 2025, with the Securities and Exchange Commission (the “Commission”).
The registration statement proposes to offer the Income & Treasury Limited Duration Portfolio of Funds, Series 83 (the “trust”).
PROSPECTUS
Investment
Summary — Principal Risks
1. The
staff of the Commission (the “Staff”) notes the risk “The trust includes an ETF” set forth in the “Principal
Risks” section. Please add to the risk disclosure the risk of ETFs trading at a premium to their net asset value (e.g., the
trust will pay more that the ETF’s net asset value).
Response: Pursuant
to the Staff’s comment, the referenced disclosure has been revised accordingly.
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 the undersigned at (312) 845-3484.
Very truly yours,
Chapman
and Cutler LLP
By /s/ Morrison
C. Warren
Morrison C. Warren