0000928816-18-000200.txt : 20180409 0000928816-18-000200.hdr.sgml : 20180409 20180131122745 ACCESSION NUMBER: 0000928816-18-000200 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180131 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Putnam RetirementReady Funds CENTRAL INDEX KEY: 0001295293 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 617 760-4623 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 CORRESP 1 filename1.htm



January 31, 2018

By EDGAR

 

U.S. Securities and Exchange Commission

Division of Investment Management

450 Fifth Street, N.W.

Washington, DC 20549

Attention: Jeff Long

 

Re: Annual Report for Putnam RetirementReady Funds (the “Funds”)

 

Dear Mr. Long:

This letter responds to the comments that you provided telephonically to me on behalf of the Staff of the U.S. Securities and Exchange Commission (the “Commission Staff”) on January 2, 2018 regarding the Funds’ annual reports to shareholders.

 

For convenience of reference, I have summarized the Commission Staff’s comment before the response by the applicable Fund(s).

 

1.Comment: The portfolio turnover rate for the fiscal years 2013-2015,for each of the Funds, has been restated as noted by footnote “g” to the financial highlights. Can you please explain why the portfolio turnover rate for each of the Funds has been restated for these time periods.

 

 

Response:  The portfolio turnover rate for each of the Funds was restated for the fiscal years 2013-2015 as a result of an immaterial error related to the overstatement of the Funds’ purchase and sale activity from October 19, 2012 through July 31, 2015.

 

I believe that this letter addresses the Commission Staff’s comments. Please also find attached as Appendix A certain representations by an officer of the Funds. Should you have any further questions, please do not hesitate to call me at (617) 760-5027. Thank you for your assistance.

 

Very truly yours,

/s/Kevin Blatchford

 

Kevin Blatchford

Director of Financial Reporting

 

Cc: James E. Thomas, Esq., Ropes & Gray LLP




Appendix A

 

 

Re: Annual Reports to Shareholders of The Putnam Funds (the “Funds”)

 

 

Reference is made to the Annual Reports to Shareholders and to the attached letter from an officer of Putnam Investments. As requested, we acknowledge the following: (i) the comments of the Commission’s Staff with respect to the filing, and this response, do not foreclose the Commission or its Staff from taking any action with respect to the filing; (ii) should the Commission or its Staff not take any action with respect to the filing, it does not relieve a Fund from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) should the Commission or its Staff not take any action with respect to the filing, the Fund may not assert this as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. As indicated in the Commission’s June 24, 2004 release regarding the public release of comment letters and responses, you are requesting such acknowledgements from all companies whose filings are being reviewed, and this request and these acknowledgements should not be construed as suggesting that there is an inquiry or investigation or other matter involving the Funds.

 

 

Very truly yours,

 

/s/ James Clark

 

James Clark

Vice President and Chief Compliance Officer

The Putnam Funds

 

January 31, 2018