0001109441-20-000023.txt : 20220103 0001109441-20-000023.hdr.sgml : 20220103 20201006100704 ACCESSION NUMBER: 0001109441-20-000023 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 2 FILED AS OF DATE: 20201006 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FRANKLIN FLOATING RATE MASTER TRUST CENTRAL INDEX KEY: 0001109441 IRS NUMBER: 943356217 STATE OF INCORPORATION: DE FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 BUSINESS PHONE: 650-312-2000 MAIL ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 FORMER COMPANY: FORMER CONFORMED NAME: FRANKLIN FLOATING RATE MASTER TRUST DATE OF NAME CHANGE: 20000316 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FRANKLIN MUTUAL SERIES FUNDS CENTRAL INDEX KEY: 0000825063 IRS NUMBER: 222894171 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 101 JOHN F KENNEDY PARKWAY CITY: SHORT HILLS STATE: NJ ZIP: 07078 BUSINESS PHONE: 973-912-2000 MAIL ADDRESS: STREET 1: 101 JOHN F KENNEDY PARKWAY CITY: SHORT HILLS STATE: NJ ZIP: 07078 FORMER COMPANY: FORMER CONFORMED NAME: FRANKLIN MUTUAL SERIES FUND INC DATE OF NAME CHANGE: 19970227 FORMER COMPANY: FORMER CONFORMED NAME: MUTUAL SERIES FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST CENTRAL INDEX KEY: 0000837274 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 BUSINESS PHONE: 650-312-2000 MAIL ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 FORMER COMPANY: FORMER CONFORMED NAME: FRANKLIN VALUEMARK FUNDS DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: FRANKLIN VALUEMARK ANNUITY FUNDS DATE OF NAME CHANGE: 19881129 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TEMPLETON INSTITUTIONAL FUNDS CENTRAL INDEX KEY: 0000865722 IRS NUMBER: 593020895 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 300 S.E. 2ND STREET CITY: FORT LAUDERDALE STATE: FL ZIP: 33301-1923 BUSINESS PHONE: 9545277500 MAIL ADDRESS: STREET 1: 300 S.E. 2ND STREET CITY: FORT LAUDERDALE STATE: FL ZIP: 33301-1923 FORMER COMPANY: FORMER CONFORMED NAME: TEMPLETON INSTITUTIONAL FUNDS INC DATE OF NAME CHANGE: 19940602 FORMER COMPANY: FORMER CONFORMED NAME: TEMPLETON INSTITUTIONAL TRUST INC DATE OF NAME CHANGE: 19930326 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TEMPLETON DEVELOPING MARKETS TRUST CENTRAL INDEX KEY: 0000878087 IRS NUMBER: 593078238 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 300 S.E. 300 2ND STREET CITY: FORT LAUDERDALE STATE: FL ZIP: 33301-1923 BUSINESS PHONE: 9545277500 MAIL ADDRESS: STREET 1: 300 S.E. 300 2ND STREET CITY: FORT LAUDERDALE STATE: FL ZIP: 33301-1923 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TEMPLETON DRAGON FUND INC CENTRAL INDEX KEY: 0000919893 IRS NUMBER: 650473580 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 300 S.E. 2ND STREET CITY: FORT LAUDERDALE STATE: FL ZIP: 33301-1923 BUSINESS PHONE: 9545277500 MAIL ADDRESS: STREET 1: 300 S.E. 2ND STREET CITY: FORT LAUDERDALE STATE: FL ZIP: 33301-1923 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FRANKLIN INVESTORS SECURITIES TRUST CENTRAL INDEX KEY: 0000809707 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 BUSINESS PHONE: 650-312-2200 MAIL ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 FORMER COMPANY: FORMER CONFORMED NAME: FRANKLIN INVESTORS SECURITIES TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FRANKLIN VALUE INVESTORS TRUST CENTRAL INDEX KEY: 0000856119 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 BUSINESS PHONE: 650-312-2000 MAIL ADDRESS: STREET 1: ONE FRANKLIN PARKWAY CITY: SAN MATEO STATE: CA ZIP: 94403-1906 FORMER COMPANY: FORMER CONFORMED NAME: FRANKLIN BALANCE SHEET INVESTMENT FUND DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm ftsecsoxltr2020.htm - Generated by SEC Publisher for SEC Filing

 One Franklin Parkway

San Mateo, CA 94403-1906

tel 800.632.2350

franklintempleton.com

 

October 5, 2020

 

VIA EDGAR

Mr. David Manion

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549-8626

Subject:  Franklin Templeton Funds (the “Funds”) (as listed on the attached Appendix)

 

Dear Mr. Manion:

On behalf of the Funds, the following are the responses to the U.S. Securities and Exchange Commission (“SEC”) Staff’s comments conveyed telephonically on September 3, 2020 with regard to the various filings made by the Funds with the SEC on Forms N-CEN and N-CSR, as well as corresponding disclosures made in their prospectuses filed as part of their registration statements.  References made to a Fund number, or a Fund’s shareholder report, refer to the Funds and shareholder reports reviewed by the Staff, as listed on the Appendix.  Each comment is summarized below, followed by the Funds’ response to the comment. 

Comments to Form N-CEN:

1.         Comment:  In response to Item B.13 of Form N-CEN, certain of Funds 13 – 36 reported that claims were filed under the directors and officers/errors and omissions liability insurance policy maintained by the Funds during the reporting period. Please discuss the nature of the claim(s) and whether there was any impact on the shareholders of the Funds. 

             Response:  Funds 13, 14, 16, 17, 25 and 26 were named in an Advisory complaint filed by The Special Claims Committee of the Financial Oversight and Management Board for Puerto Rico, acting by and through its Members; the Official Committee of Unsecured Creditors of the Commonwealth of Puerto Rico; and the Commonwealth of Puerto Rico (“Commonwealth”), et al.  The defendants, which included a number of Franklin Templeton (“FT”) funds, received payments from the Commonwealth on account of purported principal and interest obligations relating to certain purported general obligation bonds.  This matter has had no impact on the shareholders of the aforementioned Funds, as it is in the process of being dismissed without repayment of principal or interest from former bondholders, including the applicable FT funds.

2.         Comment:  In response to Item C.12 of Form N-CEN, it was reported that Franklin Templeton Investor Services, LLC provided custodial services to Fund 1 and/or 2 during the reporting period pursuant to Rule 17f-2 under the Investment Company Act of 1940, as amended (the “1940 Act”). The Staff notes that such Funds have not made Form N-17f-2 filings with the SEC during the reporting period. Please discuss if Fund 1 and/or 2 are subject to the reporting requirements of Rule 17f-2 and, if subject to the reporting requirements, discuss the reasons why such reports have not been filed. If Fund 1 and/or 2 are subject to the reporting requirements of Rule 17f-2, bring the required filings up to date.

 
 

Mr. David Manion

October 5, 2020

Page 2

 

Franklin Templeton

 

             Response:  Funds 1 and 2 have conducted a review and determined that they are subject to the reporting requirements of Rule 17f-2.  Fund 1 had a small investment in Fund 2 during the period ended July 31, 2019 and was thus subject to the review and reporting requirements of Rule 17f-2, which were inadvertently missed.  Fund 2 invests in the Money Market Portfolio series of Institutional Fiduciary Trust and was included as part of the security counts performed during the reporting period but for which the Form N-17f-2 filing has not yet occurred.  Funds 1 and 2 will ensure that their required Rule 17f-2 filings are brought up to date.

3.         Comment:  In response to Item G.1a of Form N-CEN, Funds 1 and 2 filed the independent public accountant’s report on internal control with the SEC as an attachment without including the independent public accountant’s name or signature. Please file an amendment to such Form to include the properly signed report on internal control as an attachment.

             Response:  Funds 1 and 2 will file an amendment to Form N-CEN to include the properly signed report on internal control as an attachment.

Comments to Form N-CSR:

4.         Comment:  Please consider, for Funds that engage in mortgage dollar rolls (e.g., Funds 7 and 8), disclosing in future shareholder reports the total value of the receivables and/or payables on open mortgage dollar rolls when the amounts are significant.

            Response:  The applicable Funds will consider adding additional disclosure related to the value of mortgage dollars rolls in future shareholder reports.

5.         Comment:  With respect to certain Funds, the Significant Accounting Policies in the Notes to Financial Statements state that income received from equity-linked securities is recorded as realized gains in the Statements of Operations. The Staff notes that no coupon information appears to be presented in the applicable Statements of Investments for such securities. Please explain the accounting for income received from equity-linked securities. Include appropriate GAAP references or other important authoritative guidance. 

            Response:  The Funds note that equity-linked notes (“ELNs”) are considered hybrid instruments that are packaged and issued by major financial institutions.  They combine two or more different financial instruments and generally contain both debt and equity characteristics.  They are heavily influenced by price movements of the underlying stock.  The investment strategy, generally, is to gain exposure to equity securities that the applicable Fund believes are desirable, but which do not pay a dividend. There is a purchase option component to ELNs which incorporates an agreed upon upfront premium.  This premium is spread and paid to the Fund in the form of fixed periodic payments.  For U.S. GAAP purposes, the applicable Fund records all such payments as realized gain.  The Funds relied in part upon FASB ASC 320-10-55 to conclude on this accounting treatment.

 
 

Mr. David Manion

October 5, 2020

Page 3

 

 

6.         Comment:  In future shareholder reports, please disclose the maturity date of equity-linked securities held by the Funds.

            Response:  The applicable Funds will disclose the maturity date of equity-linked securities in future shareholder reports.

7.         Comment:  Please discuss how Fund 11 views liquidity, especially where the size of the Fund’s position in a security may be significant in relation to the daily trading activity of that security. Include general market data and other factors that are used to assess the liquidity of such securities.

            Response:  The Funds note that each open-end Fund has adopted and implemented a written Liquidity Risk Management Program (the “LRMP”) as required by Rule 22e-4 under the 1940 Act (the “Liquidity Rule”). The LRMP is designed to assess and manage each open-end Fund’s liquidity risk, which is defined as the risk that the Fund could not meet requests to redeem shares issued by the Fund without significant dilution of remaining investors’ interests in the Fund.

 

In assessing and managing each open-end Fund’s liquidity risk, the Investment Liquidity Committee considers, as relevant, a variety of factors, including the Fund’s investment strategy and the liquidity of its portfolio investments during both normal and reasonably foreseeable stressed conditions; its short and long-term cash flow projections; and its cash holdings and access to other funding sources including the Fund’s interfund lending facility and line of credit. 

 

Fund 11 primarily holds liquid assets that are defined under the Liquidity Rule as "Highly Liquid Investments" (“HLI”), and therefore is not required to establish a highly liquid investment minimum under the Liquidity Rule and the LRMP.  Highly Liquid Investments are defined as cash and any investment reasonably expected to be convertible to cash in current market conditions in three business days or less without the conversion to cash significantly changing the market value of the investment.

 

For equity securities, the days to liquidate (“DtL”) is determined using 20% of the three-month Average Daily Volume. Per the Liquidity Rule, the Reasonably Anticipated Trade Size (“RATS”) percentage is multiplied by the DtL and settlement days are added to determine days to cash.

 

As of October 31, 2019, the liquidity profile of Fund 11 per the Liquidity Rule is shown below:

 

 
 

Mr. David Manion

October 5, 2020

Page 4

 

 

As of Date

FT Portfolio Number

Portfolio Name

RATS Value

HLI

MLI

LLI

II

10/31/19

4189

FVIT-Franklin Microcap Value Fund

0.020

90%

5%

0%

5%

 

As of October 31, 2019, using a full liquidation cumulative scenario without RATS, the liquidity profile of Fund 11 is shown below. The DtL noted exclude settlement days.

 

As of Date

FT Portfolio Number

Portfolio Name

1 day

7 days

15 days

30 days

>30 days

10/31/19

4189

FVIT-Franklin Microcap Value Fund

20%

53%

66%

80%

20%

 

8.         Comment:  At period end, Fund 40 reported that its investments in a Cayman Islands exempted company that is a wholly-owned subsidiary of the Fund constituted 26.9% of the Fund’s consolidated net assets. Please discuss how the Fund is in compliance with regulations under the U.S. Internal Revenue Code of 1986, as amended (the “Code”), that limit regulated investment company investments in controlled foreign corporations to 25% of the investment company’s total assets.

            Response:  Fund 40 invests in certain China A-shares through its investment in Templeton China Opportunities Fund, Ltd (the “China Fund”). The China Fund is: (a) a Cayman Islands exempted company; (b) wholly-owned by the Fund; and (c) able to invest directly in China A-shares consistent with the investment objective of the Fund.  For U.S. federal income tax purposes: (a) since the China Fund is wholly-owned by the Fund, it is disregarded as an entity separate from the Fund (see Section 7701 of the Code and the regulations thereunder); and (b) as a result of (a), the Fund is treated as the direct owner of the China Fund’s assets.  The fact that the China Fund constituted 26.9% of the Fund’s consolidated net assets is irrelevant for purposes of the Fund’s compliance with Section 851(b)(3)(B) of the Code, which prohibits a regulated investment company (“RIC”) from having more than 25% of the value of its total assets invested in the securities of any one issuer (measured at the close of each quarter of the RIC’s taxable year).  The Fund, for purposes of complying with the RIC qualifying asset rules, must test its ownership of the China Fund’s assets as if the Fund held such assets directly (because of the China Fund’s status as a disregarded entity for U.S. federal income tax purposes) and any other assets the Fund owns directly.  It is inappropriate, based on the foregoing, to test the Fund’s ownership of the China Fund for purposes of determining its compliance with the rules relating to the Fund’s status as a RIC.

9.         Comment:  Fund 32 reported on the Statement of Operations a reimbursement of legal fees from an unaffiliated party in the amount of $226,875, which were incurred in connection with certain Fund holdings. Please discuss what such reimbursement relates to and when the initial expenses were incurred by the Fund.

            Response:  Fund 32 notes that it incurred legal fees from 2016 to 2018 pertaining to the litigation and bankruptcy of secured debt issued by iHeartCommunications, Inc. f/k/a Clear Channel Communications, Inc. Per the restructuring support agreement, upon court approval of the bankruptcy plan, all legal fees and expenses incurred by the Fund pertaining to this matter would be reimbursed. The Fund received reimbursement during the fiscal year end under review.

 
 

Mr. David Manion

October 5, 2020

Page 5

 

 

10.       Comment:  The Staff notes that Fund 19 appears to be operating as a non-diversified fund for purposes of classification under the 1940 Act. Please discuss the diversification status of the Fund and how the Fund ensures compliance with its diversification status.

            Response:  Fund 19 notes that its current diversification concentration is 26.058% (above the 25% maximum limit) due to passive market movements. FT Investment Compliance communicates with the Fund’s portfolio managers and FT Legal regarding the Fund’s diversification status, including discussion at the Fund’s annual registration statement update meeting. FT Investment Compliance monitors portfolio compliance with diversification requirements on a pre-trade basis (prior to trade execution) and on a post-trade basis (nightly comparison of the portfolio against pre-defined limitations).

11.       Comment:  The Staff notes that the prospectus for Fund 33 states that the Fund invests at least 80% of its net assets in investments of large-capitalization companies and may invest up to 20% of its net assets in investments of small to mid-capitalization companies. Please explain the rationale for including small and mid-capitalization companies as a principal risk of the Fund, while not including a principal risk specific to large-capitalization companies.            

            Response: Fund 33 believes that large capitalization risks are appropriately disclosed under “Market” risk.

12.       Comment:  The Staff notes that Fund 24 has classified the following securities as U.S. Government and Agency Securities on the Statement of Investments: DY9 Leasing LLC (“DY9”), Israel Government Agency for International Development (“Israel”), Reliance Industries Ltd. (“Reliance”), and Petroleos Mexicanos (“Petroleos”). Please discuss the rationale for classifying such private companies and companies and agencies of foreign governments, as applicable, as U.S. Government and Agency Securities.

            Response:  Fund 24 notes that DY9, Reliance, and Petroleos should have been classified as Corporate Bonds, and Israel classified as Foreign Government and Agency Securities. These classifications will be reflected in future shareholder reports, as applicable.

We believe that we have responded fully to each of the SEC’s Staff comments as set forth above.  However, should you have any further questions or require any further information, please do not hesitate to contact the undersigned at 916-463-1135, or, in his absence, Lindsey Hicks at 916-463-1169. 

 

 

Very truly yours,

 

 

 
 

Mr. David Manion

October 5, 2020

Page 6

 

 

 

 

/s/MATTHEW T. HINKLE             

Matthew T. Hinkle

Senior Vice President,

Global Fund Administration and Reporting & Global Fund Tax

Franklin Templeton

On behalf of the Funds listed in the attached Appendix

 
 

APPENDIX

FUNDS AND FINANCIAL STATEMENTS REVIEWED BY SEC STAFF

Fund #

File #

Registrant Name

Series ID

Series Name

FYE Reviewed

1        

811-09869

Franklin Floating Rate Master Trust

S000007441

Franklin Floating Rate Master Series

7/31/2019

2        

 

Franklin Floating Rate Master Trust

S000052547

Franklin Floating Rate Income Fund

7/31/2019

3        

811-04986

Franklin Investors Securities Trust

S000006850

Franklin Adjustable U.S. Government Securities Fund

10/31/2019

4        

 

Franklin Investors Securities Trust

S000006851

Franklin Convertible Securities Fund

10/31/2019

5        

 

Franklin Investors Securities Trust

S000006852

Franklin Equity Income Fund

10/31/2019

6        

 

Franklin Investors Securities Trust

S000006853

Franklin Floating Rate Daily Access Fund

10/31/2019

7        

 

Franklin Investors Securities Trust

S000006855

Franklin Low Duration Total Return Fund

10/31/2019

8        

 

Franklin Investors Securities Trust

S000006857

Franklin Total Return Fund

10/31/2019

9        

 

Franklin Investors Securities Trust

S000012705

Franklin Managed Income Fund

10/31/2019

10     

811-05878

Franklin Value Investors Trust

S000007352

Franklin Mutual U.S. Value Fund

10/31/2019

11     

 

Franklin Value Investors Trust

S000007354

Franklin Microcap Value Fund

10/31/2019

12     

 

Franklin Value Investors Trust

S000007356

Franklin Small Cap Value Fund

10/31/2019

13     

811-05387

Franklin Mutual Series Funds

S000007860

Franklin Mutual Beacon Fund

12/31/2019

14     

 

Franklin Mutual Series Funds

S000007861

Franklin Mutual Global Discovery Fund

12/31/2019

15     

 

Franklin Mutual Series Funds

S000007862

Franklin Mutual European Fund

12/31/2019

16     

 

Franklin Mutual Series Funds

S000007863

Franklin Mutual Quest Fund

12/31/2019

17     

 

Franklin Mutual Series Funds

S000007864

Franklin Mutual Shares Fund

12/31/2019

18     

 

Franklin Mutual Series Funds

S000007865

Franklin Mutual Financial Services Fund

12/31/2019

19     

811-05583

Franklin Templeton Variable Insurance Products Trust

S000007312

Franklin Flex Cap Growth VIP Fund

12/31/2019

20     

 

Franklin Templeton Variable Insurance Products Trust

S000007313

Franklin Rising Dividends VIP Fund

12/31/2019

21     

 

Franklin Templeton Variable Insurance Products Trust

S000007314

Franklin Small-Mid Cap Growth VIP Fund

12/31/2019

22     

 

Franklin Templeton Variable Insurance Products Trust

S000007315

Franklin Small Cap Value VIP Fund

12/31/2019

23     

 

Franklin Templeton Variable Insurance Products Trust

S000007316

Franklin Strategic Income VIP Fund

12/31/2019

24     

 

Franklin Templeton Variable Insurance Products Trust

S000007317

Franklin U.S. Government Securities VIP Fund

12/31/2019

25     

 

Franklin Templeton Variable Insurance Products Trust

S000007319

Franklin Mutual Global Discovery VIP Fund

12/31/2019

26     

 

Franklin Templeton Variable Insurance Products Trust

S000007320

Franklin Mutual Shares VIP Fund

12/31/2019

27     

 

Franklin Templeton Variable Insurance Products Trust

S000007321

Templeton Developing Markets VIP Fund

12/31/2019

28     

 

Franklin Templeton Variable Insurance Products Trust

S000007322

Templeton Foreign VIP Fund

12/31/2019

29     

 

Franklin Templeton Variable Insurance Products Trust

S000007325

Templeton Global Bond VIP Fund

12/31/2019

30     

 

Franklin Templeton Variable Insurance Products Trust

S000007326

Templeton Growth VIP Fund

12/31/2019

31     

 

Franklin Templeton Variable Insurance Products Trust

S000007327

Franklin Growth and Income VIP Fund

12/31/2019

32     

 

Franklin Templeton Variable Insurance Products Trust

S000007329

Franklin Income VIP Fund

12/31/2019

33     

 

Franklin Templeton Variable Insurance Products Trust

S000007330

Franklin Large Cap Growth VIP Fund

12/31/2019

34     

 

Franklin Templeton Variable Insurance Products Trust

S000007333

Franklin Global Real Estate VIP Fund

12/31/2019

35     

 

Franklin Templeton Variable Insurance Products Trust

S000017299

Franklin Allocation VIP Fund

12/31/2019

36     

 

Franklin Templeton Variable Insurance Products Trust

S000040299

Franklin Volsmart Allocation VIP Fund

12/31/2019

37     

811-06135

Templeton Institutional Funds

S000008751

International Equity Series

12/31/2019

38     

 

Templeton Institutional Funds

S000008752

Foreign Smaller Companies Series

12/31/2019

39     

811-06378

Templeton Developing Markets Trust

S000008756

Templeton Developing Markets Trust

12/31/2019

40     

811-08394

Templeton Dragon Fund, Inc.

 

 

12/31/2019

Appendix 1-3

 1

 

 
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