Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
June 5, 2014
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1186
BulletShares High Yield Low Duration 2016-2019 Bond Ladder Portfolio of
ETFs, Series 4
File Nos. 333-195358 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 1186, filed on April 17, 2014 with the
Securities and Exchange Commission (the "Commission"). The registration
statement offers the BulletShares High Yield Low Duration 2016-2019 Bond Ladder
Portfolio of ETFs, Series 4 (the "Trust"). Please note that the Trust has
changed its name from "BulletShares High Yield Low Duration 2015-2019 Bond
Ladder Portfolio of ETFs, Series 4" to "BulletShares High Yield Low Duration
2016-2019 Bond Ladder Portfolio of ETFs, Series 4."
PROSPECTUS
Investment Summary -- Investment Objective
1. Please revise the investment objective to state: "The trust seeks to
provide current income."
Response: The disclosure has been revised as requested.
Investment Summary -- Principal Investment Strategy
2. The second paragraph states that the underlying exchange-traded funds
will hold bonds with effective maturities for the same year as the
exchange-traded fund is scheduled to mature. Please confirm that the
exchange-traded funds terminate during the year the bonds mature.
Response: We confirm that the exchange-traded funds will terminate during
the year the bonds mature.
3. Please confirm that the average duration of the exchange-traded funds is
three years or less.
Response: We note that the Commission has given guidance that generally
states that short-term funds should have dollar-weighted average maturities of
three years or less. However, there is no equivalent standard for duration.
Instead, the Commission's guidance states a fund may use any reasonable
definition of a term suggesting a particular duration and should explain its
definition in its discussion of its investment objectives and strategies in the
fund's prospectus. The sponsor believes that an appropriate definition for low
duration is a fund with an average duration of four years or less.
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