Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
October 1, 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 1947
Balanced Income Builder Portfolio, Series 29
File Nos. 333-233488 and 811-03763
--------------------------------------------------------------------------------
Dear Mr. Bartz:
This letter responds to your comment given during a telephone conversation
with our office regarding the registration statement on Form S-6 for Guggenheim
Defined Portfolios, Series 1947, filed on August 28, 2019 with the Securities
and Exchange Commission (the "Commission"). The registration statement proposes
to offer the Balanced Income Builder Portfolio, Series 29 (the "Trust").
PROSPECTUS
Investment Summary -- Principal Investment Strategy
1. The "Principal Risks" section states that that the Trust invests in
exchange-traded funds that invest in mortgage-backed securities. Please disclose
the Trust's strategy with regard to these securities in the principal investment
strategies section.
Response: In response to this comment, the following sentence will be added
to the last paragraph under the "Principal Investment Strategy" section:
"Additionally, the fixed-income securities that the ETFs included in the
portfolio may invest in include mortgage-backed securities, among other
securities with a fixed income."
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
----------------------
Morrison C. Warren