Correspondence 0001445546-25-000355 from FT 11956 (CIK 0002043068)
FT 11956 (CIK 0002043068)
Date: Jan. 13, 2025 · CIK: 0002043068 · Accession: 0001445546-25-000355
AI Filing Summary & Sentiment
File numbers found in text: 333-283324
Letter
Division of Investment Management 60/40 Strategic Allocation Port. 1Q ‘25 - Term 4/16/26 75/25 Strategic Allocation Port. 1Q ‘25 - Term 4/16/26 (the “Trust”) CIK No. 2043068 File No. 333-283324
Dear Mr. Cowan:
We received your comments regarding the Registration Statement for the above captioned Trusts. This letter serves to respond to your comments.
Comments
Risk Factors
1.If the nature of the Trusts’ investments in distressed debt securities relate to certain of the ETFs 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 Trusts note that they do not anticipate investing in ETFs that purchase distressed debt securities directly. The Trusts further note that distressed debt securities do not rise to a level of principal investment for the Trusts. Nevertheless, the Trusts believe 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 Trusts respectfully decline to add distressed debt securities to the “Portfolio Selection Process” section.
2.If the Funds held by the Trusts invest significantly in subprime residential mortgage loans, please add appropriate risk disclosure.
Response:If, based on a Trust’s final portfolio, a 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
January 13, 2025
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 11956
60/40 Strategic
Allocation Port. 1Q ‘25 - Term 4/16/26
75/25 Strategic Allocation Port. 1Q ‘25 - Term 4/16/26
(the “Trust”)
CIK No. 2043068 File No. 333-283324
Dear Mr. Cowan:
We received your comments
regarding the Registration Statement for the above captioned Trusts. This letter serves to respond to your comments.
Comments
Risk Factors
1.If
the nature of the Trusts’ investments in distressed debt securities relate to certain of the ETFs 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
Trusts note that they do not anticipate investing in ETFs that purchase distressed debt securities directly. The Trusts further note that
distressed debt securities do not rise to a level of principal investment for the Trusts. Nevertheless, the Trusts believe 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 Trusts respectfully decline to add distressed debt securities to
the “Portfolio Selection Process” section.
2.If
the Funds held by the Trusts invest significantly in subprime residential mortgage loans, please add appropriate risk disclosure.
Response:If,
based on a Trust’s final portfolio, a 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