Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
August 14, 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 1929
Quality Core Equity Portfolio, Series 4
File Nos. 333-232537 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 1929, filed on July 3, 2019 with the
Securities and Exchange Commission (the "Commission"). The registration
statement proposes to offer the Quality Core Equity Portfolio, Series 4 (the
"Trust").
PROSPECTUS
Investment Summary -- Principal Investment Strategy
1. Because the name of the Trust has the term "core equity," please
explain what constitutes core equity securities.
Response: In response to this comment, the following has been added as the
third sentence under the "Principal Investment Strategy" section: "Core equity
securities are securities that the sponsor believes are central investments for
an equity portfolio."
2. The second bullet under the "Security Selection" section states that
securities must have a market capitalization of $3 billion or more. Please state
in the "Principal Investment Strategy" section that the Trust may invest in
small- and mid-capitalization securities.
Response: In response to this comment, the following has been added to the
first paragraph under the "Principal Investment Strategy" section: "The trust
may invest in U.S.-listed common stocks of any market capitalization."
3. The "Principal Investment Strategy" section states that the Trust may
invest in U.S.-listed foreign securities. Does this include any emerging market
issuers? If so, please disclose and provide corresponding risk disclosures.
Response: The Trust may invest in securities issued by companies located
in emerging markets. As a result, the second to last sentence under the
"Principal Investment Strategy" section has been revised to the following: "The
U.S.-listed common stocks may include U.S.-listed foreign securities, including
the securities of issuers located in emerging markets." If the Trust invests
significantly in securities issued by emerging market issuers, the following
disclosure will be included in the "Principal Risks" section:
The trust includes securities issued by companies headquartered or
incorporated in countries considered to be emerging markets. Emerging
markets are generally defined as countries with low per capita income in
the initial stages of their industrialization cycles. Risks of investing
in developing or emerging countries include the possibility of investment
and trading limitations, liquidity concerns, delays and disruptions in
settlement transactions, political uncertainties and dependence on
international trade and development assistance. Companies headquartered in
emerging market countries may be exposed to greater volatility and market
risk.
If the Trust invests in securities issued by emerging market issuers, the
following disclosure will be included in the "Investment Risks" section:
Emerging markets risk. The trust invests in securities issued by
companies headquartered or incorporated in countries considered to be
emerging markets. Emerging markets are generally defined as countries with
low per capita income in the initial stages of their industrialization
cycles. Risks of investing in developing or emerging countries include the
possibility of investment and trading limitations, liquidity concerns,
delays and disruptions in settlement transactions, political uncertainties
and dependence on international trade and development assistance. In
addition, emerging market countries may be subject to overburdened
infrastructures, obsolete financial systems and environmental problems.
For these reasons, investments in emerging markets are often considered
speculative.
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