Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
September 13, 2013
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1079
Guggenheim Moderate Asset Allocation Portfolio of ETFs, Series 16
File Nos. 333-190245 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comments given during a telephone
conversation with our office regarding the registration statement on Form S-6
for Guggenheim Defined Portfolios, Series 1079, filed on July 30, 2013 with the
Securities and Exchange Commission (the "Commission"). The registration
statement offers the Guggenheim Moderate Asset Allocation Portfolio of ETFs,
Series 16 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Investment Strategy
1. The end of the sixth paragraph under this section mentions duration.
Please provide an example of the effect duration on interest rate changes and
bond prices.
Response: The following has replaced the third sentence of the sixth
paragraph: "In addition, the fixed-income ETFs included in the trust's portfolio
invest in fixed-income securities of short, medium and long-term durations. The
duration of a bond is a measure of its price sensitivity to changes in interest
rates based on the weighted average term to maturity of its interest and
principal cash flows. In general, rising interest rates may lead to a decline in
bond prices and declining interest rates may lead to a rise in bond prices. For
example, if a bond has a duration of 3 years and interest rates go up by 1%, it
can be expected that the bond price will move down by 3%." As discussed with the
staff of the Commission, the Trust does not have a policy as to duration and
does not have an expectation of any particular duration. As a result, a duration
of 3 years was used for the example.
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
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Morrison C. Warren