Correspondence 0001528621-25-000334 from GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2480 (CIK 0002037676)
GUGGENHEIM DEFINED PORTFOLIOS, SERIES 2480 (CIK 0002037676)
Date: March 27, 2025 · CIK: 0002037676 · Accession: 0001528621-25-000334
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File numbers found in text: 333-284550, 811-03763
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CORRESP
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Unassociated Document
Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
March 27, 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 2480
Global Balanced Income Builder Portfolio, Series
25
File Nos. 333-284550 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 2480, filed on January 28, 2025, with the Securities and Exchange Commission (the “Commission”).
The registration statement proposes to offer the Global Balanced Income Builder Portfolio, Series 25 (the “trust”).
PROSPECTUS
Investment
Summary — Principal Risks
1. The
staff of the Commission (the “Staff”) notes the risk “The trust invests in shares of ETFs” 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 will be 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