Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
April 28, 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 2121
Floating Rate & Dividend Growth Portfolio, Series 23
File Nos. 333-253251 and 811-03763
Dear Mr. Bartz:
This letter responds to your comment given during a telephone conversation with our office regarding the registration statement on Form S-6 for Guggenheim Defined Portfolios, Series 2121, filed on February 18, 2021, with the Securities and Exchange Commission. The registration statement proposes to offer the Floating Rate & Dividend Growth Portfolio, Series 23 (the “trust”).
PROSPECTUS
Investment Summary — Principal Risks
1. The duration example in the seventh bullet under the “Principal Risks” section uses a duration of three years. Please confirm that the average weighted duration of the underlying closed-end funds and exchange-traded funds is approximately three years or less. If not, please revise this example to reflect the average weighted duration of the underlying funds.
Response: The sponsor confirms that the average weighted duration of the underlying closed-end funds and exchange-traded funds is approximately three years or less and, therefore, the example does not need to be revised.
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