Correspondence 0001445546-24-008535 from FT 11890 (CIK 0002038364)
FT 11890 (CIK 0002038364)
Date: Dec. 20, 2024 · CIK: 0002038364 · Accession: 0001445546-24-008535
AI Filing Summary & Sentiment
File numbers found in text: 333-282852
Letter
Division of Investment Management Re: FT 11890 FT Equity Allocation ETF Model Portfolio, 1Q ‘25 (the “Trust”) CIK No. 2038364 File No. 333-282852
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 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.
2.The Staff notes the following disclosure in the Portfolio Selection Process, “The remaining approximately 30% of the portfolio invests in approximately five narrowly focused First Trust(R) ETFs that invest in common stocks of internet, health care and information technology companies, which we believe will outperform the overall market over the life of the Trust.” If the Trust will be concentrated in any of the internet, health care, or technology 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.
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,
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
December 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 11890
FT Equity Allocation ETF Model Portfolio, 1Q ‘25
(the “Trust”)
CIK No. 2038364 File No. 333-282852
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 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.
2.The
Staff notes the following disclosure in the Portfolio Selection Process, “The remaining approximately 30% of the portfolio invests
in approximately five narrowly focused First Trust(R) ETFs that invest in common stocks of internet, health care and information technology
companies, which we believe will outperform the overall market over the life of the Trust.” If the Trust will be concentrated in
any of the internet, health care, or technology 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.
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,
Very truly yours,
Chapman and Cutler llp
By:
/s/ Daniel J. Fallon
Daniel J. Fallon