Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
April 2, 2018
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1727
Advisory Series: Guggenheim Investment Grade Corporate Trust 3-7 Year, Series 1
File Nos. 333-222401 and 811-03763
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Dear Mr. Bartz:
This letter responds to your comment made during a telephone conversation
with our office regarding amendment no. 1 to the registration statement on Form
S-6 for Guggenheim Defined Portfolios, Series 1727, filed on March 8, 2018 with
the Securities and Exchange Commission (the "Commission"). The registration
statement proposes to offer the Advisory Series: Guggenheim Investment Grade
Corporate Trust 3-7 Year, Series 1 (the "Trust").
PROSPECTUS
Investment Summary -- Fees and Expenses
1. Please explain how the presentation of the annual deferred sales fee
complies with the sponsor's exemptive relief relating to deferred sales charges.
Response: The sponsor has received exemptive relief from the Commission
(Release No. IC-23515 (Notice); Release No. IC-23574 (Order)) permitting it to
collect a deferred sales charge subject to certain conditions (the "Exemptive
Relief"). One such condition of the Exemptive Relief is that the sponsor must
include in the Trust's prospectus the disclosure required in Form N-1A relating
to deferred sales charges, modified as appropriate to reflect the differences
between unit investment trusts and open-end investment companies. In order to
comply with the Exemptive Relief, the sponsor has revised the Fees and Expenses
table and the related disclosure in the prospectus for the Trust to disclose the
annual deferred sales fee each year in tabular form and include the maximum
amount of deferred sales fees an investor could pay as a percentage of the
public offering price per unit. Please see attached Appendix A. In addition, the
table also now includes a line for "Initial sales fee" in order to make clear to
investors that there is no front-end sales load. The sponsor believes that the
presentation of the Trust's fee structure in this manner conforms with the
conditions of the Exemptive Relief and offers the clearest explanation of the
amount of fees that an investor may incur if they purchase units.
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