Correspondence 0001445546-24-008121 from FT 11913 (CIK 0002040177)
FT 11913 (CIK 0002040177)
Date: Nov. 27, 2024 · CIK: 0002040177 · Accession: 0001445546-24-008121
AI Filing Summary & Sentiment
File numbers found in text: 333-283137
Letter
Division of Investment Management Re: FT 11913 Convertible & Income Select Closed-End and ETF Portfolio, Series 15 (the “Trust”) CIK No. 2040177 File No. 333-283137
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
Portfolio
1.If the ETFs or Closed-End Funds that the portfolio invests in are affiliated, please include the conflict disclosure that was agreed upon in past filings.
Response:If the Trust has exposure to any ETFs or Closed-End Funds which are advised by First Trust Advisors L.P., an affiliate of the Trust’s Sponsor, appropriate disclosure will be added to the Trust’s prospectus.
Risk Factors
2.If the nature of the Trust's investments in distressed debt securities relate to certain of the ETFs or Closed-End Funds purchasing distressed debt securities directly (rather than from merely holding bonds that become distressed after purchase), please add related strategy disclosure as appropriate.
Response:The Trust notes that it does not anticipate investing in ETFs or Closed-End Funds that purchase distressed debt securities directly. The Trust further notes that distressed debt securities do not rise to a level of principal investment for the Trust. Nevertheless, the Trust believes the current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is substantially related to the high-yield securities risk disclosure. Therefore, the Trust respectfully declines to add distressed debt securities to the “Portfolio Selection Process” section.
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
Show Raw Text
CORRESP
1
filename1.htm
Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T 312.845.3000
F 312.701.2361
www.chapman.com
November 27, 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 11913
Convertible & Income Select Closed-End and ETF Portfolio, Series 15
(the “Trust”)
CIK No. 2040177 File No. 333-283137
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
Portfolio
1.If
the ETFs or Closed-End Funds that the portfolio invests in are affiliated, please include the conflict disclosure that was agreed upon
in past filings.
Response:If
the Trust has exposure to any ETFs or Closed-End Funds which are advised by First Trust Advisors L.P., an affiliate of the Trust’s
Sponsor, appropriate disclosure will be added to the Trust’s prospectus.
Risk Factors
2.If
the nature of the Trust's investments in distressed debt securities relate to certain of the ETFs or Closed-End Funds purchasing distressed
debt securities directly (rather than from merely holding bonds that become distressed after purchase), please add related strategy disclosure
as appropriate.
Response:The
Trust notes that it does not anticipate investing in ETFs or Closed-End Funds that purchase distressed debt securities directly. The Trust
further notes that distressed debt securities do not rise to a level of principal investment for the Trust. Nevertheless, the Trust believes
the current risk disclosure is adequate and necessary for investor comprehension as the distressed debt securities risk disclosure is
substantially related to the high-yield securities risk disclosure. Therefore, the Trust respectfully declines to add distressed debt
securities to the “Portfolio Selection Process” section.
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