GIOAX / Guggenheim Funds Trust - Guggenheim Macro Opportunities Fund A Class - SEC-arkivering, Årsberetning, Fuldmagtserklæring

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12 (b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 GUGGENHEIM FUNDS TRUST (Exact name of registra

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12 (b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 GUGGENHEIM FUNDS TRUST (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.R.S. Employer Identification No.) 702 King Farm Bouleva

Consent of Independent Registered Public Accounting Firm

Consent of Registered Public Accounting Firm Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Fund Service Providers”, “Financial Highlights”, “Representations and Warranties” and “Financial Highlights of the Funds” in the Combined Proxy Statement/Prospectus and “Independent Registered Public Accounting Firm” in the Preliminary Statement of Additional Information, each included in this Registration Statement (Form N-14) of Guggenheim Funds Trust.

AFFILIATED FUND OF FUNDS WAIVER AGREEMENT

Affiliated Fund of Funds Waiver Agreement AFFILIATED FUND OF FUNDS WAIVER AGREEMENT THIS AGREEMENT, dated as of February 26, 2026, is made and entered into by and between Guggenheim Partners Investment Management, LLC (the “Adviser”) and each of the registered investment companies set forth in Schedule A (each being referred to herein as a “Fund”), as may be amended from time to time.

POWER OF ATTORNEY

Powers of Attorney POWER OF ATTORNEY KNOW ALL PERSONS BY THESE PRESENTS, that the undersigned, in his or her capacity listed below and not individually, constitutes and appoints Amy J.

INVESTMENT MANAGEMENT AGREEMENT

Investment Management Agreement INVESTMENT MANAGEMENT AGREEMENT THIS AGREEMENT is made as of February 26, 2026, between GUGGENHEIM FUNDS TRUST, a Delaware statutory trust (hereinafter referred to as the “Trust”), and GUGGENHEIM PARTNERS INVESTMENT MANAGEMENT, LLC (hereinafter referred to as the “Investment Manager”), a Delaware limited liability company registered as an investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”).

DISTRIBUTION AGREEMENT

Distribution Agreement DISTRIBUTION AGREEMENT This Distribution Agreement is made as of February 26, 2026, between Guggenheim Funds Trust (the “Trust”), a Delaware statutory trust, on behalf of the exchange-traded fund series of the Trust (each, a “Fund” and collectively, the “Funds”), and Guggenheim Funds Distributors, LLC (the “Distributor”), a Delaware limited liability company.

TRANSFER AGENCY AND SERVICE AGREEMENT

Form of Transfer Agency Agreement TRANSFER AGENCY AND SERVICE AGREEMENT THIS AGREEMENT is made as of the     day of     , 20 , by and between each Trust (hereinafter each a “Trust”, and collectively the “Trusts” as applicable) listed on Appendix A hereto (as such Appendix be amended from time to time) and THE BANK OF NEW YORK MELLON, a New York corporation authorized to do a banking business having its principal office and place of business at 240 Greenwich Street, New York, New York 10286 (the “Bank”).

AMENDMENT TO FUND ADMINISTRATION AND ACCOUNTING AGREEMENT

Form of Amendment to Fund Administration and Accounting Agreement AMENDMENT TO FUND ADMINISTRATION AND ACCOUNTING AGREEMENT This AMENDMENT (“Amendment”) is made and entered into, as of the latest date on the signature page hereto (the “Effective Date”), by and between EACH INVESTMENT COMPANY LISTED ON EXHIBIT A HERETO (each a “Fund”, collectively the “Funds”) and THE BANK OF NEW YORK MELLON (“BNY”).

AMENDMENT TO CUSTODY AGREEMENT

Form of Amendment to Custody Agreement AMENDMENT TO CUSTODY AGREEMENT This AMENDMENT (“Amendment”) is made and entered into, as of the latest date on the signature page hereto (the “Effective Date”), by and between EACH INVESTMENT COMPANY LISTED ON APPENDIX 1 HERETO (“Customer”) and THE BANK OF NEW YORK MELLON (“BNY”).

As filed with the U.S. Securities and Exchange Commission on March 17, 2026

Guggenheim Funds Trust Table of Contents As filed with the U.S. Securities and Exchange Commission on March 17, 2026 File No. 333-[   ] UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. Post-Effective Amendment No. (Check appropriate box or boxes) GUGGENHEIM FUNDS TRUST (Exact Name o

Three Bryant Park

Form of Tax Opinion Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.

FORM OF AUTHORIZED PARTICIPANT AGREEMENT GUGGENHEIM FUNDS TRUST

Form of Authorized Participant Agreement FORM OF AUTHORIZED PARTICIPANT AGREEMENT GUGGENHEIM FUNDS TRUST This Authorized Participant Agreement (the “Agreement”) is entered into by and between Guggenheim Funds Distributors, LLC (the “Distributor”) and            (the “Participant” or “Authorized Participant”) and is subject to acceptance by The Bank of New York Mellon (the “Transfer Agent”) and agreement by Guggenheim Funds Trust, a Delaware statutory trust (the “Trust”) that is a series trust offering a number of portfolios of securities (each a “Fund” and collectively the “Funds”), solely with respect to Sections 4(c) and 13(c) herein.

DISTRIBUTION AND SERVICING PLAN Guggenheim Funds Trust

Distribution and Servicing Plan DISTRIBUTION AND SERVICING PLAN Guggenheim Funds Trust WHEREAS, Guggenheim Funds Trust (the “Trust”) engages in business as an open-end management investment company and is registered as such under the Investment Company Act of 1940, as amended (the “1940 Act”); WHEREAS, shares of beneficial interest of the Trust are currently divided into multiple series; and WHEREAS, Guggenheim Funds Distributors, LLC (the “Distributor”) serves as the distributor of the exchange-traded fund series of the Trust (each, a “Fund” and collectively, the “Funds”) pursuant to a Distribution Agreement dated February 26, 2026, as amended from time to time, between the Distributor and the Trust.

Dechert LLP

Opinion and consent of Dechert LLP Dechert LLP 1900 K Street, N.W. Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax March 17, 2026 Guggenheim Funds Trust 702 King Farm Boulevard, Suite 200 Rockville, MD 20850 Re: Opinion of Counsel regarding the Registration Statement filed on Form N-14 under the Securities Act of 1933 Dear Ladies and Gentlemen: We have acted as counsel for Gugge

AMENDMENT TO FOREIGN CUSTODY MANAGER AGREEMENT

Form of Amendment to Foreign Custody Manager Agreement AMENDMENT TO FOREIGN CUSTODY MANAGER AGREEMENT This AMENDMENT (“Amendment”) is made and entered into, as of the latest date on the signature page hereto (the “Effective Date”), by and between EACH ENTITY LISTED ON ANNEX I HERETO (“Fund”) and THE BANK OF NEW YORK MELLON (“BNY”).

October 3, 2024

October 3, 2024 Dear Shareholder, The Joint Special Meeting of Shareholders Guggenheim Funds Trust and Transparent Value Trust will be held at 115 South LaSalle Street, 34th Floor, Chicago, IL 60603 on October 24, 2024.

Reorganization of Actively Managed Equity Funds.

Reorganization of Actively Managed Equity Funds. Read FAQs. Reorganization of Actively Managed Equity Funds On June 5, 2024, Guggenheim Investments and New Age Alpha announced a definitive agreement under which New Age Alpha will acquire Guggenheim Investments’ actively managed equity funds business. New Age Alpha is an investment management firm offering strategies incorporating a proprietary met

Share

FAQs Reorganization of Guggenheim Investments’ Actively Managed Equity Funds On June 5, 2024, Guggenheim Investments and New Age Alpha announced a definitive agreement under which New Age Alpha will acquire Guggenheim Investments’ actively managed equity funds business.

Share

DEFA14A 1 f39311d1.htm REORGANIZATION FAQ FAQs Reorganization of Guggenheim Investments’ Actively Managed Equity Funds On June 5, 2024, Guggenheim Investments and New Age Alpha announced a definitive agreement under which New Age Alpha will acquire Guggenheim Investments’ actively managed equity funds business. The transaction affects 21 mutual funds, including variable insurance funds (each a “fu

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

Custom Basket Swap Agreements

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2023 Shares Value COMMON STOCKS† - 100.

6 Appendix A

August 5, 2024 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn:  Ms. Jaea Hahn Re:  Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Registrant”) Dear Ms. Hahn: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commission (the “SEC” or “Commiss

1

June 7, 2024 VIA EDGAR Ms. Shandy Pumphrey U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Guggenheim Funds Trust (File No. 811-01136) Guggenheim Variable Funds Trust (File No. 811-02753) (each, a “Registrant” and collectively, the “Registrants”) (each series of the Registrants, a “Fund” and collectively, the “Funds”) Dear Ms. P

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM MACRO OPPORTUNITIES FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM MARKET NEUTRAL REAL ESTATE FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & So

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,772 306,73

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM CAPITAL STEWARDSHIP FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM LIMITED DURATION FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,

Weighted

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM CORE BOND FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,772 306

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,772 306,73

Weighted

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM DIVERSIFIED INCOME FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,772 306,73

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,772 306,73

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM ULTRA SHORT DURATION FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc

Weighted

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM MUNICIPAL INCOME FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM SMID CAP VALUE FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,77

Weighted

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son, Inc. 3,772 306,73

Weighted

NPORT-EX 2 fp0081925-1nportex.htm GUGGENHEIM FLOATING RATE STRATEGIES FUND NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2022 Shares Value COMMON STOCKS† - 92.4% Consumer, Non-cyclical - 22.2% Quest Diagnostics, Inc. 2,071 $ 323,884 Ironwood Pharmaceuticals, Inc. — Class A* 25,669 318,039 Coca-Cola Co. 4,858 309,017 Hologic, Inc.* 4,109 307,394 John B Sanfilippo & Son,

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

NPORT-EX 2 fp0077688nportex.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.7% Consumer, Non-cyclical - 24.2% Conagra Brands, Inc. 9,942 $ 340,425 Kimberly-Clark Corp. 2,453 331,523 Bristol-Myers Squibb Co.1 4,231 325,787 Procter & Gamble Co.1 2,205 317,057 Vertex Pharmaceuticals, Inc.* 1,112 313,350 John B San

Contract

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2022 Shares Value COMMON STOCKS† - 85.

Investment Sub-Advisory Agreement with respect to Guggenheim Core Bond Fund and Guggenheim High Yield Fund – Filed herewith.

INVESTMENT SUB-ADVISORY AGREEMENT THIS INVESTMENT SUB-ADVISORY AGREEMENT (the ?Agreement?), made and entered into this 29th day of April 2022, between SECURITY INVESTORS, LLC, a Kansas limited liability company (hereinafter referred to as the ?Management Company?), and GUGGENHEIM PARTNERS ADVISORS, LLC, a Delaware limited liability company (hereinafter referred to as the ?Sub-Adviser?).

Investment Sub-Advisory Agreement with respect to Guggenheim Floating Rate Strategies Fund, Guggenheim Macro Opportunities Fund and Guggenheim Total Return Bond Fund – Filed herewith.

INVESTMENT SUB-ADVISORY AGREEMENT THIS INVESTMENT SUB-ADVISORY AGREEMENT (the ?Agreement?) is made as of April 29, 2022 between GUGGENHEIM PARTNERS INVESTMENT MANAGEMENT, LLC (hereinafter referred to as the ?Investment Adviser?), a Delaware limited liability company registered as an investment adviser under the Investment Advisers Act of 1940, as amended (?Advisers Act?), and GUGGENHEIM PARTNERS ADVISORS, LLC (hereinafter referred to as the ?Sub-Adviser?), a Delaware limited liability company.

Guggenheim Partners Advisors, LLC – Filed herewith.

Sponsor Guggenheim Partners Advisors, LLC Chief Compliance Officer Owner Guggenheim Investments Compliance Director of Policies & Procedures Contact Maria.

Investment Sub-Advisory Agreement with respect to Guggenheim Ultra Short Duration Fund – Filed herewith.

INVESTMENT SUB-ADVISORY AGREEMENT THIS INVESTMENT SUB-ADVISORY AGREEMENT (the ?Agreement?) is made as of April 29, 2022, between GUGGENHEIM PARTNERS INVESTMENT MANAGEMENT, LLC (hereinafter referred to as the ?Investment Adviser?), a Delaware limited liability company registered as an investment adviser under the Investment Advisers Act of 1940, as amended (?Advisers Act?), and GUGGENHEIM PARTNERS ADVISORS, LLC (hereinafter referred to as the ?Sub-Adviser?), a Delaware limited liability company.

As filed with the Securities and Exchange Commission on May 26, 2022

As filed with the Securities and Exchange Commission on May 26, 2022 Registration No.

Investment Sub-Advisory Agreement with respect to Guggenheim Municipal Income Fund – Filed herewith.

INVESTMENT SUB-ADVISORY AGREEMENT Between SECURITY INVESTORS, LLC and GUGGENHEIM PARTNERS ADVISORS, LLC INVESTMENT SUB-ADVISORY AGREEMENT, made as of the 29th day of April, 2022, between Security Investors, LLC (?Adviser?), a limited liability company organized and existing under the laws of the State of Kansas, and Guggenheim Partners Advisors, LLC (?Sub-Adviser?), a limited liability company organized and existing under the laws of the State of Delaware.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2021 Shares Value COMMON STOCKS† - 95.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2021 Shares Value COMMON STOCKS† - 101.

* * *

August 26, 2021 VIA EDGAR Mr. Tony Burak U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Guggenheim Funds Trust (File No. 811-01136) Guggenheim Variable Funds Trust (File No. 811-02753) Guggenheim Energy & Income Fund (File No. 811-23057) (collectively, the ?Registrants?) Dear Mr. Burak: On behalf of the Registrants, we wish to

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

GS — Goldman Sachs International

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2020 Shares Value COMMON STOCKS† - 107.

* * *

CORRESP 1 filename1.htm January 28, 2021 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Mr. Scott Lee Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Registrant”) Dear Mr. Lee: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commission

* * *

November 27, 2020 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Trust”) Ladies and Gentlemen: On behalf of the Trust, attached for filing via the EDGAR system pursuant to Rule 485(a) under the Securities Act of 1933, as amended, is Post-Effective Amendmen

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

Alpha Opportunity Fund

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2020 Shares Value COMMON STOCKS† - 99.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

plc — Public Limited Company

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) December 31, 2019 Shares Value COMMON STOCKS† - 102.

* * *

February 14, 2020 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the ?Registrant?) Ladies and Gentlemen: Pursuant to Rule 477 under the Securities Act of 1933, as amended (the ?1933 Act?), the Registrant, on behalf of its Class T shares, hereby respectfully req

SVUIX / Guggenheim Mid Cap Value Institutional Fund POS EX - - POS EX

As filed with the Securities and Exchange Commission on February 3, 2020 Registration No.

Amended and Restated Fund of Funds Waiver Agreement - Security Investors, LLC – Previously filed with Post-Effective Amendment No. 279 to Registration Statement 2-19458 (filed February 3, 2020).*

AMENDED AND RESTATED FUND OF FUNDS WAIVER AGREEMENT - SECURITY INVESTORS, LLC THIS AGREEMENT, dated as of November 13, 2019, is made and entered into by and between Security Investors, LLC (the “Adviser”) and each of the registered investment companies set forth in Schedule A (each being referred to herein as a “Fund”), as may be amended from time to time.

Amended and Restated Fund of Funds Waiver Agreement - Guggenheim Partners Investment Management, LLC – Previously filed with Post-Effective Amendment No. 279 to Registration Statement 2-19458 (filed February 3, 2020).*

EX-99.(H)(8) 2 gpimfofwaiveragreement.htm EXHIBIT 99.(H)(8) AMENDED AND RESTATED FUND OF FUNDS WAIVER AGREEMENT—GUGGENHEIM PARTNERS INVESTMENT MANAGEMENT, LLC THIS AGREEMENT, dated as of November 13, 2019, is made and entered into by and between Guggenheim Partners Investment Management, LLC (the “Adviser”) and each of the registered investment companies set forth in Schedule A (each being referre

Appendix A Series and Classes

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.

SVUIX / Guggenheim Mid Cap Value Institutional Fund POS EX - - POS EX

As filed with the Securities and Exchange Commission on January 30, 2020 Registration No.

Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.dechert.com _________________________

Three Bryant Park 1095 Avenue of the Americas New York, NY 10036-6797 +1 212 698 3500 Main +1 212 698 3599 Fax www.

SVUIX / Guggenheim Mid Cap Value Institutional Fund POS EX - - POS EX

As filed with the Securities and Exchange Commission on January 3, 2020 File No. 333-233876 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 Form N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. [ ] Post-Effective Amendment No. 1 (Check appropriate box or boxes) GUGGENHEIM FUNDS TRUST (Exact Name of Registrant as Specified in Charter)

POWER OF ATTORNEY

POWER OF ATTORNEY KNOW ALL PERSONS BY THESE PRESENTS, that the undersigned constitutes and appoints Amy J.

GIBRX / Guggenheim Total Return Bond Fund CORRESP - -

December 26, 2019 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Mr. DeCarlo McLaren Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Registrant”) Dear Mr. McLaren: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commission (the “SEC” o

SVUIX / Guggenheim Mid Cap Value Institutional Fund CORRESP - -

October 18, 2019 VIA EDGAR Ms. Christina Fettig U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Guggenheim Funds Trust (File No. 333-233876) (the “Registrant”) – Accounting Disclosures Comments Dear Ms. Fettig: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commissi

SVUIX / Guggenheim Mid Cap Value Institutional Fund CORRESP - -

October 17, 2019 VIA EDGAR Ms. Christina Fettig U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Guggenheim Funds Trust (File No. 333-233876) (the “Registrant”) – Accounting Disclosures Comments Dear Ms. Fettig: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commissi

SVUIX / Guggenheim Mid Cap Value Institutional Fund CORRESP - -

October 17, 2019 VIA EDGAR Mr. DeCarlo McLaren U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Guggenheim Funds Trust (File No. 333-233876) (the “Registrant”) Dear Mr. McLaren: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commission (“SEC”) staff conveyed via tele

POWER OF ATTORNEY

EX-99.16 4 gft-poaxnx14august2019exx9.htm EXHIBIT 99.16 POWER OF ATTORNEY KNOW ALL PERSONS BY THESE PRESENTS, that the undersigned constitutes and appoints Amy J. Lee, Mark E. Mathiasen and Michael P. Megaris to act as attorney-in-fact and agent with full power of substitution and resubstitution of them in their name, place, and stead, to sign any and all registration statements on Form N-14, and

Guggenheim Funds Trust N-14 - - N-14

As filed with the Securities and Exchange Commission on September 20, 2019 File No.

Consent of Independent Registered Public Accounting Firm

Consent of Independent Registered Public Accounting Firm We consent to the references to our firm under the captions “Service Providers,” “Representations and Warranties” in Appendix A – Form of Agreement and Plan of Reorganization, and “Appendix C - Financial Highlights” in the combined Information Statement and Prospectus of Guggenheim Mid Cap Value Fund and Guggenheim Mid Cap Value Institutiona

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com _________________________

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.

Guggenheim Funds Trust DEFA14A - - DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ¨ Defin

Guggenheim Funds Trust DEFR14A - - DEFR14A

DEFR14A 1 gfttvt82019proxy.htm DEFR14A UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (as

Guggenheim Funds Trust DEF 14A - - DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a party other than the Registrant ¨ Check the appropriate box: ¨ Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) x Defin

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

NPORT-EX 1 fp0043169nportexjwjwrce3.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.8% Consumer, Non-cyclical - 34.7% McKesson Corp. 8,365 $ 1,124,172 Medtronic plc1 11,211 1,091,839 Archer-Daniels-Midland Co.1 26,551 1,083,281 Amgen, Inc. 5,830 1,074,352 Merck & Company, Inc.1 12,446 1,043,597 Pfizer, Inc.1 23

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

NPORT-EX 1 fp0043169nportexjkhvqmi2.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.8% Consumer, Non-cyclical - 34.7% McKesson Corp. 8,365 $ 1,124,172 Medtronic plc1 11,211 1,091,839 Archer-Daniels-Midland Co.1 26,551 1,083,281 Amgen, Inc. 5,830 1,074,352 Merck & Company, Inc.1 12,446 1,043,597 Pfizer, Inc.1 23

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

NPORT-EX 1 fp0043169nportexcay05q5z.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.8% Consumer, Non-cyclical - 34.7% McKesson Corp. 8,365 $ 1,124,172 Medtronic plc1 11,211 1,091,839 Archer-Daniels-Midland Co.1 26,551 1,083,281 Amgen, Inc. 5,830 1,074,352 Merck & Company, Inc.1 12,446 1,043,597 Pfizer, Inc.1 23

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

NPORT-EX 1 fp0043169nportexo433gf3s.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.8% Consumer, Non-cyclical - 34.7% McKesson Corp. 8,365 $ 1,124,172 Medtronic plc1 11,211 1,091,839 Archer-Daniels-Midland Co.1 26,551 1,083,281 Amgen, Inc. 5,830 1,074,352 Merck & Company, Inc.1 12,446 1,043,597 Pfizer, Inc.1 23

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

NPORT-EX 1 fp0043169nportex04rxligh.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.8% Consumer, Non-cyclical - 34.7% McKesson Corp. 8,365 $ 1,124,172 Medtronic plc1 11,211 1,091,839 Archer-Daniels-Midland Co.1 26,551 1,083,281 Amgen, Inc. 5,830 1,074,352 Merck & Company, Inc.1 12,446 1,043,597 Pfizer, Inc.1 23

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

NPORT-EX 1 fp0043169nportexky4sf0gn.htm GUGGENHEIM FUNDS TRUST NQ Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.8% Consumer, Non-cyclical - 34.7% McKesson Corp. 8,365 $ 1,124,172 Medtronic plc1 11,211 1,091,839 Archer-Daniels-Midland Co.1 26,551 1,083,281 Amgen, Inc. 5,830 1,074,352 Merck & Company, Inc.1 12,446 1,043,597 Pfizer, Inc.1 23

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust NPORT-EX - - GUGGENHEIM FUNDS TRUST NQ

Alpha Opportunity Fund SCHEDULE OF INVESTMENTS (Unaudited) June 30, 2019 Shares Value COMMON STOCKS† - 99.

Guggenheim Funds Trust AW - - AW

June 11, 2019 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Registrant”) Ladies and Gentlemen: Pursuant to Rule 477 under the Securities Act of 1933, as amended (the “1933 Act”), the Registrant, on behalf of its series Guggenheim Multi-Asset Fund (the “Fu

CERTIFICATIONS

EX.-3(i) CERTIFICATIONS I, Brian E. Binder, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Funds Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the p

Guggenheim Funds Trust (Quarterly Schedule of Portfolio Holdings)

N-Q 1 fp0038246nq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of registrant as specified in charter) 702 King Farm Boulevard, Suite 200 Rockville, Maryland 20850 (Address of principal executive of

GIBRX / Guggenheim Total Return Bond Fund CORRESP - -

December 13, 2018 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Jaea Hahn Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Registrant”) Dear Ms. Hahn: On behalf of the Registrant, we wish to respond by this letter to comments of the U.S. Securities and Exchange Commission (the “SEC” or “Commis

GIBRX / Guggenheim Total Return Bond Fund CORRESP - -

December 4, 2018 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Jaea Hahn Re: Guggenheim Funds Trust (File Nos. 002-19458 and 811-01136) (the “Registrant”) Dear Ms. Hahn: On behalf of the Registrant, we wish to respond by this letter to one of the comments of the U.S. Securities and Exchange Commission (the “SEC”

CERTIFICATIONS

EX.-3(i) CERTIFICATIONS I, Brian E. Binder, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Funds Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the p

Guggenheim Funds Trust N-Q (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of registrant as specified in charter) 702 King Farm Boulevard, Suite 200 Rockville, Maryland 20850 (Address of principal executive offices) (Zip code) Amy J.

* * *

August 24, 2018 VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Guggenheim Funds Trust (File Nos. 811-01136 and 002-19458) (the “Trust”) Ladies and Gentlemen: On behalf of the Trust, attached for filing via the EDGAR system pursuant to Rule 485(a) under the Securities Act of 1933, as amended, is Post-Effective Amendment

EX-99.77.Q.3

A C Institutional P R6 72. DD) Total income distributions Alpha Opportunity Fund n/a n/a n/a n/a n/a Large Cap Value Fund 648 13 23 2 n/a Market Neutral Real Estate Fund n/a n/a n/a n/a n/a Risk Managed Real Estate Fund 119 5 1,323 36 n/a Small Cap Value Fund 109 n/a 65 n/a n/a StylePlus—Large Core Fund 1,948 6 75 5 n/a StylePlus—Mid Growth Fund 394 n/a 16 1 n/a World Equity Income Fund 506 17 34

GUGGENHEIM FUNDS RULE 10F-3 REPORT (Refer to the Rule 10f-3 Procedures for definitions of the defined terms used herein.) REPORTING PERIOD: Q1-2018

Procedure Number: IC03.4 GUGGENHEIM FUNDS RULE 10F-3 REPORT (Refer to the Rule 10f-3 Procedures for definitions of the defined terms used herein.) REPORTING PERIOD: Q1-2018 1. Name of the purchasing Fund(s): Guggenheim Total Return Bond Fund, Guggenheim Limited Duration, Guggenheim Investment Grade Bond Fund 2. Name of Issuer: CVS Health Corp. 3. Security Description (Ticker, Cusip/ISIN/Sedol, cou

Guggenheim Funds Trust (Quarterly Schedule of Portfolio Holdings)

N-Q 1 fp0029549nq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of registrant as specified in charter) 702 King Farm Boulevard, Suite 200 Rockville, Maryland 20850 (Address of principal executive of

CERTIFICATIONS

EX.-3(i) CERTIFICATIONS I, Amy J. Lee, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Funds Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

Guggenheim Funds Trust CORRESP

February 26, 2018 VIA EDGAR Ms. Megan Miller U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Claymore Exchange-Traded Fund Trust (File Nos. 333-134551 & 811-21906) Claymore Exchange-Traded Fund Trust 2 (File Nos. 333-135105 & 811-21910) Guggenheim Funds Trust (File Nos. 002-19458 & 811-01136) (collectively, the “Registrants”) De

EX-99.77Q3

EX-99.77Q3 3 fp0029430ex9977q3.htm A C Institutional P R6 72. DD) Total income distributions Alpha Opportunity Fund n/a n/a n/a n/a n/a Large Cap Value Fund 784 26 2 2 n/a Market Neutral Real Estate Fund n/a n/a n/a n/a n/a Risk Managed Real Estate Fund 19 8 2,442 16 n/a Small Cap Value Fund 88 n/a 4 1 n/a StylePlus—Large Core Fund 1,415 n/a 47 3 n/a StylePlus—Mid Growth Fund 439 n/a 1 1 n/a World

Report of Independent Registered Public Accounting Firm

Report of Independent Registered Public Accounting Firm To the Shareholders and Board of Trustees of Guggenheim Funds Trust In planning and performing our audits of the financial statements of Guggenheim Funds Trust (the ?Trust?) as of and for the year ended September 30, 2017, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Trus

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of reg

N-Q 1 fp0026307nq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of registrant as specified in charter) 805 King Farm Boulevard, Suite 600 Rockville, Maryland 20850 (Address of principal executive of

CERTIFICATIONS

EX.-3(i) CERTIFICATIONS I, Amy J. Lee, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Funds Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

EX-99

A C Institutional P R6 72. DD) Total income distributions Alpha Opportunity Fund n/a n/a n/a n/a n/a Large Cap Value Fund 784 26 2 2 n/a Market Neutral Real Estate Fund n/a n/a n/a n/a n/a Risk Managed Real Estate Fund 6 5 1,329 1 n/a Small Cap Value Fund 88 n/a 4 0 n/a StylePlus?Large Core Fund 1,415 n/a 47 3 n/a StylePlus?Mid Growth Fund 439 n/a 1 1 n/a World Equity Income Fund 817 47 31 1 n/a M

GUGGENHEIM FUNDS RULE 10F-3 REPORT (Refer to the Rule 10f-3 Procedures for definitions of the defined terms used herein.) REPORTING PERIOD: Q1-2017

EX-99.77O RULE 10F-3 2 fp0026040ex9977o.htm 10F-3 TRANSACTIONS GUGGENHEIM FUNDS RULE 10F-3 REPORT (Refer to the Rule 10f-3 Procedures for definitions of the defined terms used herein.) REPORTING PERIOD: Q1-2017 1. Name of the purchasing Fund(s): Guggenheim Alpha Opportunity Fund 2. Name of Issuer: Kite Pharma Inc. 3. Security Description (Ticker, Cusip/ISIN/Sedol, coupon, etc.): Ticker: KITE CUSIP

CERTIFICATIONS

EX.-3(i) CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Funds Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect t

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of reg

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of registrant as specified in charter) 805 King Farm Boulevard, Suite 600 Rockville, Maryland 20850 (Address of principal executive offices) (Zip code) Donald C.

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com _____________________ Corey F. Rose [email protected] +1 202 261 3314 Direct +1 202 261 3158 Fax

1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.

Report of Independent Registered Public Accounting Firm

Report of Independent Registered Public Accounting Firm To the Shareholders and Board of Trustees of Guggenheim Funds Trust In planning and performing our audits of the financial statements of Guggenheim Funds Trust (the ?Trust?) as of and for the year ended September 30, 2016, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Trus

GPIM AFFILIATED UNDERWRITER TRANSACTION FORM

GPIM AFFILIATED UNDERWRITER TRANSACTION FORM 1. Name of Issuer: Albertsons Companies 2. Security Description (Ticker, Cusip/ISIN/Sedol, coupon, etc.): Senior Notes 2024 3. Underwriting Syndicate: Bank of America Merrill Lynch, Credit Suisse, Citigroup, Morgan Stanley, Goldman, Sachs & Co., Deutsche Bank Securities, Barclays, Guggenheim Securities, RBC Capital Markets, Wells Fargo Securities, Drexe

GPIM AFFILIATED UNDERWRITER TRANSACTION FORM

GPIM AFFILIATED UNDERWRITER TRANSACTION FORM Completed Affiliated Underwriter Transaction Forms should be submitted by the applicable GPIM invest team to the GPIM Compliance Conflicts team at GPIMComplianceNewTransactionReporting@guggenheimpartners.

Guggenheim Funds Trust

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-01136 Guggenheim Funds Trust (Exact name of registrant as specified in charter) 805 King Farm Boulevard, Suite 600 Rockville, Maryland 20850 (Address of principal executive offices) (Zip code) Donald C.

CERTIFICATIONS

EX.-3(i) CERTIFICATIONS I, Donald C. Cacciapaglia, certify that: 1. I have reviewed this report on Form N-Q of Guggenheim Funds Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect t

APP ORDR

UNITED STATES OF AMERICA BEFORE THE SECURITIES AND EXCHANGE COMMISSION INVESTMENT COMPANY ACT OF 1940 Release No.

APP NTC

SECURITIES AND EXCHANGE COMMISSION Investment Company Act Release No. 32140; File No. 812-14525 Guggenheim Funds Trust, et al.; Notice of Application June 6, 2016 Agency: Securities and Exchange Commission (“Commission”). Action: Notice of an application for an order under section 12(d)(1)(J) of the Investment Company Act of 1940 (the “Act”) for an exemption from sections 12(d)(1)(A), (B), and (C)

EX-99

Because the electronic format for filing Form N-SAR does not provide adequate space for responding to Items 72DD 73 74U and 74V correctly the correct answers are as follows A C Institutional P 72.

AMENDED AND RESTATED DECLARATION OF TRUST Guggenheim Funds Trust (a Delaware Statutory Trust) Dated as of February 24, 2016 TABLE OF CONTENTS AMENDED AND RESTATED DECLARATION OF TRUST

AMENDED AND RESTATED DECLARATION OF TRUST Of Guggenheim Funds Trust (a Delaware Statutory Trust) Dated as of February 24, 2016 TABLE OF CONTENTS AMENDED AND RESTATED DECLARATION OF TRUST Page ARTICLE I Name and Definitions 1 Section 1.

As filed with the Securities and Exchange Commission on May 12, 2016

As filed with the Securities and Exchange Commission on May 12, 2016 Registration No.

AMENDED AND RESTATED DECLARATION OF TRUST Guggenheim Funds Trust (a Delaware Statutory Trust) Dated as of February 24, 2016 TABLE OF CONTENTS AMENDED AND RESTATED DECLARATION OF TRUST Page ARTICLE I Name and Definitions 1 Section 1.1. Name 1 Section

AMENDED AND RESTATED DECLARATION OF TRUST of Guggenheim Funds Trust (a Delaware Statutory Trust) Dated as of February 24, 2016 TABLE OF CONTENTS AMENDED AND RESTATED DECLARATION OF TRUST Page ARTICLE I Name and Definitions 1 Section 1.