Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
October 9, 2015
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1370
Guggenheim Balanced Income Builder Portfolio, Series 13
File Nos. 333-206613 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comment given during a telephone
conversation with our office regarding the registration statement on Form S-6
for Guggenheim Defined Portfolios, Series 1370, filed on August 27, 2015 with
the Securities and Exchange Commission (the "Commission"). The registration
statement proposes to offer the Guggenheim Balanced Income Builder Portfolio,
Series 13 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Risks
1. The "Principal Investment Strategy" section states that the Trust will
invest in real estate investment trusts. Please includes the risks of investing
in real estate investment trusts in the "Principal Risks" section.
Response: The following will be added to the "Principal Risks" section:
The trust includes real estate investment trusts ("REITs"). REITs may
concentrate their investments in specific geographic areas or in specific
property types, such as, hotels, shopping malls, residential complexes and
office buildings. The value of the REITs and other real estate securities
and the ability of such securities to distribute income may be adversely
affected by several factors, including: rising interest rates; changes in
the global and local economic climate and real estate conditions;
perceptions of prospective tenants of the safety, convenience and
attractiveness of the properties; the ability of the owner to provide
adequate management, maintenance and insurance; increased competition from
new properties; the impact of present or future environmental legislation
and compliance with environmental laws; changes in real estate taxes and
other operating expenses; adverse changes in governmental rules and fiscal
policies; adverse changes in zoning laws; declines in the value of real
estate; the downturn in the subprime mortgage lending market and the real
estate market in the United States; and other factors beyond the control of
the issuer of the security.
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