Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
August 8, 2019
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1927
Total Income Portfolio, Series 18
File Nos. 333-232223 and 811-03763
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Dear Mr. Bartz:
This letter responds to your comments given during a telephone conversation
with our office regarding the registration statement on Form S-6 for Guggenheim
Defined Portfolios, Series 1927, filed on June 20, 2019 with the Securities and
Exchange Commission (the "Commission"). The registration statement proposes to
offer the Total Income Portfolio, Series 18 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Risks
1. The duration example in the seventh bullet under the "Principal Risks"
section uses a duration of five years. Please confirm that the average weighted
duration of the underlying securities is approximately five years or less. If
not, please revise this example to reflect the average weighted duration of the
underlying securities.
Response: The sponsor confirms that the average weighted duration of the
underlying securities is approximately five years or less and, therefore, the
example does not need to be revised.
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