Guggenheim Defined Portfolios, Series 2005
Filed: 27 May 20, 12:00am
Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
May 27, 2020
Via EDGAR Filing
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 2005
Blue Chip Dividend Portfolio, Series 1
File Nos. 333-237377 and 811-03763
Dear Mr. Bartz:
This letter amends the response letter dated May 26, 2020, to revise a previous response given to comment 3 of your comment letter dated April 21, 2020, regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2005, filed on March 25, 2020 with the Securities and Exchange Commission (the “Commission”). The registration statement proposes to offer the Blue Chip Dividend Portfolio, Series 1 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
3. The first paragraph of this section states that the trust may invest in non-U.S. companies. Please explain to us whether the trust’s investments in non-U.S. companies will include emerging market issuers as a principal investment strategy and, if so, provide appropriate disclosure in this section and in the discussions of the trust’s principal risks. Alternatively, please explain to us why the requested disclosures are not necessary.
Response: The trust would like to retain its ability to invest in non-U.S. companies and will retain the language regarding non-U.S. companies that was originally filed on Form S-6. With regard to emerging market issuers, the trust will not invest in such issuers. As such, no additional language regarding emerging market issuers has been added to the investment strategies or risk sections.
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