Guggenheim Funds Distributors, LLC
2455 Corporate West Drive
Lisle, Illinois 60532
April 29, 2016
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1450
US Low Volatility Strategy Portfolio, Series 15
File Nos. 333-210352 and 811-03763
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Dear Mr. Bartz:
This letter is in response to your comments regarding the registration
statement on Form S-6 for Guggenheim Defined Portfolios, Series 1450, filed on
March 23, 2016, with the Securities and Exchange Commission (the "Commission").
The registration statement proposes to offer the US Low Volatility Strategy
Portfolio, Series 15 (the "Trust").
PROSPECTUS
Investment Summary -- Security Selection
1. The Trust states that it will invest at least 80% of the value of its
assets in common stocks of U.S. companies. Because the S&P 500 includes foreign
securities, please include a step that will ensure that the Trust will invest at
least 80% of the value of its assets in common stocks of U.S. companies.
Response: The disclosure will be revised as stated in the response to
comment 2.
2. In step 4, please provide the source for the standard deviation of
daily returns for the previous trailing year. In addition, please disclose how
many securities will be selected in this step.
Response: Step 4 will be replaced with the following:
4. Selection: Select from the sub-universe the 30 securities with
the lowest volatility, as measured by standard deviation of daily
returns as sourced from FactSet for the previous trailing year, and
equally weight these securities as of Security Selection Date.
Selected securities must adhere to following portfolio limits:
o Maximum 25% weight in any sector (as defined by Global
Industry Classification Standard).
o Maximum 10% weight in any industry (as defined by Global
Industry Classification Standard).
o Maximum 20% weight in non-US countries (as defined by Russell
index methodology for country categorization).
Once any of the investment limitations has been reached, additional
securities of that kind will not be included in the trust and the
next lowest volatility security will be used.
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