Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
February 9, 2021
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 2094
Diversified Credit Portfolio of ETFs, Series 18
File Nos. 333-251580 and 811-03763
Dear Mr. Bartz:
This letter responds to your comments given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2094, filed on December 22, 2020 with the Securities and Exchange Commission (the “Commission”). The registration statement proposes to offer the Diversified Credit Portfolio of ETFs, Series 18 (the “trust”).
PROSPECTUS
Investment Summary — Principal Investment Strategy
1. The “Principal Investment Strategy” section states that the trust may invest in exchange-traded funds that may invest in convertible securities. Please disclose whether these exchange-traded funds will substantially invest in contingent convertible securities. If so, please disclose this in the principal investment strategies and provide the corresponding risk disclosures.
Response: The exchange-traded funds that the trust may invest in do not currently invest substantially in contingent convertible securities.
2. The “Principal Investment Strategy” section states that the trust may invest in preferred exchange-traded funds. If the trust invests in preferred exchange-traded funds, please provide the corresponding risk disclosures.
Response: If the trust invests in preferred exchange-traded funds, the trust will add the corresponding risk disclosures to the appropriate risk section(s).
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
