Correspondence 0001445546-25-000403 from FT 11964 (CIK 0002043076)
FT 11964 (CIK 0002043076)
Date: Jan. 15, 2025 · CIK: 0002043076 · Accession: 0001445546-25-000403
AI Filing Summary & Sentiment
File numbers found in text: 333-283374
Letter
Division of Investment Management Re: FT 11964 FT Moderate Buffer ETF Allocation Portfolio, Series 2 (the “Trust”) CIK No. 2043076 File No. 333-283374
Dear Mr. Cowan:
We received your comment regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comment.
Comment
Portfolio
1. Please confirm the following disclosure is bolded (as in the prior series). It is not clear whether the text will show as bolded in the final printing.
Unlike the ETFs, the Trust itself does not pursue a target outcome strategy. You may experience significant losses on investments in the Trust. The buffer is only provided by the ETFs and the Trust itself does not provide any stated buffer against losses. The Trust will likely not receive the full benefit of the ETF buffers and could have limited upside potential (as described below). The Trust's returns are limited by the caps of the ETFs.
Response: The Trust confirms the above referenced disclosure will be bolded in the final prospectus.
We appreciate your prompt attention to this Registration Statement. If you have any questions or comment 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
January 15, 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 11964
FT Moderate Buffer ETF Allocation Portfolio, Series 2
(the “Trust”)
CIK No. 2043076 File No. 333-283374
Dear Mr. Cowan:
We received your comment
regarding the Registration Statement for the above captioned Trust. This letter serves to respond to your comment.
Comment
Portfolio
1. Please
confirm the following disclosure is bolded (as in the prior series). It is not clear whether the text will show as bolded in the final
printing.
Unlike the ETFs, the Trust itself does
not pursue a target outcome strategy. You may experience significant losses on investments in the Trust. The buffer is only provided by
the ETFs and the Trust itself does not provide any stated buffer against losses. The Trust will likely not receive the full benefit of
the ETF buffers and could have limited upside potential (as described below). The Trust's returns are limited by the caps of the ETFs.
Response: The
Trust confirms the above referenced disclosure will be bolded in the final prospectus.
We appreciate your prompt attention
to this Registration Statement. If you have any questions or comment 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