Chapman and Cutler LLP
111 West Monroe Street
Chicago, Illinois 60603
February 11, 2020
VIA EDGAR FILING
Mr. Edward Bartz
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Guggenheim Defined Portfolios, Series 1989
Total Income Portfolio, Series 20
File Nos. 333-235846 and 811-03763
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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 1989, filed on January 8, 2020 with the Securities
and Exchange Commission (the "Commission"). The registration statement proposes
to offer the Total Income Portfolio, Series 20 (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 exchange-traded funds is approximately five years or
less. If not, please revise this example to reflect the average weighted
duration of the underlying exchange-traded funds.
Response: The sponsor confirms that the average weighted duration of the
underlying exchange-traded funds 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