0000928816-13-001937.txt : 20140408 0000928816-13-001937.hdr.sgml : 20140408 20131220175737 ACCESSION NUMBER: 0000928816-13-001937 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20131220 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM FUND FOR GROWTH & INCOME CENTRAL INDEX KEY: 0000081260 IRS NUMBER: 046013678 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAIKLSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GROWTH FUND DATE OF NAME CHANGE: 19841025 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INCOME FUND CENTRAL INDEX KEY: 0000081264 STANDARD INDUSTRIAL CLASSIFICATION: OIL ROYALTY TRADERS [6792] IRS NUMBER: 046013712 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921471 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INCOME FUND INC/PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM VOYAGER FUND CENTRAL INDEX KEY: 0000081280 IRS NUMBER: 046187125 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM VOYAGER FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH YIELD TRUST CENTRAL INDEX KEY: 0000225777 IRS NUMBER: 046415410 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A-14 LEGAL DEPARTMENT CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE STREET 2: MAILSTOP A-14 LEGAL DEPARTMENT CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH YIELD TRUST FUND DATE OF NAME CHANGE: 19960328 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM U S GOVERNMENT INCOME TRUST CENTRAL INDEX KEY: 0000732337 IRS NUMBER: 042811119 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM U S GOVERNMENT GUARANTEED SECURITIES INCOME TRUST DATE OF NAME CHANGE: 19910102 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM UNITED STATES GOVERNMENT SECURITIES INCOME FUND DATE OF NAME CHANGE: 19840806 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL INCOME TRUST CENTRAL INDEX KEY: 0000794614 IRS NUMBER: 046549525 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GOVERNMENT INCOME GLOBAL TRUST DATE OF NAME CHANGE: 19870225 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GLOBAL GOVERNMENT INCOME TRUST DATE OF NAME CHANGE: 19870115 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MUNICIPAL OPPORTUNITIES TRUST CENTRAL INDEX KEY: 0000900422 IRS NUMBER: 043187549 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM FUNDS TRUST CENTRAL INDEX KEY: 0001005942 IRS NUMBER: 043299786 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST STREET 2: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921010 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM NEW YORK TAX EXEMPT INCOME TRUST CENTRAL INDEX KEY: 0000719712 IRS NUMBER: 042794490 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW YORK TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND/MA/ CENTRAL INDEX KEY: 0000792288 IRS NUMBER: 046626127 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND /MA/ DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND/MA CENTRAL INDEX KEY: 0000794612 IRS NUMBER: 046626128 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM TAX EXEMPT MONEY MARKET FUND CENTRAL INDEX KEY: 0000806944 IRS NUMBER: 046561110 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM TAX EXEMPT MONEY MARKET TRUST DATE OF NAME CHANGE: 19870927 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM VARIABLE TRUST CENTRAL INDEX KEY: 0000822671 IRS NUMBER: 046649095 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002551581 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CAPITAL MANAGER TRUST /MA/ DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MASTER INTERMEDIATE INCOME TRUST CENTRAL INDEX KEY: 0000830622 IRS NUMBER: 046584465 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM NEW JERSEY TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000857463 IRS NUMBER: 043073948 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INTERNATIONAL EQUITY FUND /MA/ CENTRAL INDEX KEY: 0000868648 IRS NUMBER: 046661045 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921471 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL GROWTH FUND /MA/ DATE OF NAME CHANGE: 19960805 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OVERSEAS GROWTH FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL GROWTH FUND DATE OF NAME CHANGE: 19901107 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM ARIZONA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000869392 IRS NUMBER: 046665534 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: PUTNAM INVESTMENTS INC STREET 2: ONE POST OFFICE SQUARE MAIL STOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251585 MAIL ADDRESS: STREET 1: 2 LIBERTY SQUARE STREET 2: MAIL STOP L6 CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM ASSET ALLOCATION FUNDS CENTRAL INDEX KEY: 0000914209 IRS NUMBER: 046746612 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM LIFE STAGES ASSET ALLOCATION TRUST DATE OF NAME CHANGE: 19931027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM CONVERTIBLE SECURITIES FUND CENTRAL INDEX KEY: 0000081247 IRS NUMBER: 042493360 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CONVERTIBLE INCOME GROWTH TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CONVERTIBLE FUND DATE OF NAME CHANGE: 19841212 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CONVERTIBLE FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEORGE PUTNAM FUND OF BOSTON CENTRAL INDEX KEY: 0000081259 IRS NUMBER: 046013677 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002252581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EQUITY INCOME FUND/NEW DATE OF NAME CHANGE: 19940302 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GEORGE FUND OF BOSTON DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INVESTORS FUND CENTRAL INDEX KEY: 0000081269 IRS NUMBER: 042713095 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INVESTORS FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FORMER COMPANY: FORMER CONFORMED NAME: INCORPORATED INVESTORS DATE OF NAME CHANGE: 19670327 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM DIVERSIFIED INCOME TRUST CENTRAL INDEX KEY: 0000836622 IRS NUMBER: 043017475 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL HEALTH CARE FUND CENTRAL INDEX KEY: 0000357295 IRS NUMBER: 046471950 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HEALTH SCIENCES TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM AMERICAN GOVERNMENT INCOME FUND CENTRAL INDEX KEY: 0000759827 IRS NUMBER: 042856297 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: PUTNAM INVESTMENTS INC STREET 2: ONE POST OFFICE SQUARE MAIL STOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH INCOME GOVERNMENT TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND/MA CENTRAL INDEX KEY: 0000794616 IRS NUMBER: 046626129 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 617-292-1000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 021009 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM PREMIER INCOME TRUST CENTRAL INDEX KEY: 0000827773 IRS NUMBER: 042995046 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM EUROPE EQUITY FUND CENTRAL INDEX KEY: 0000842940 IRS NUMBER: 043083315 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002551581 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EUROPE GROWTH FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EUROPE FUND DATE OF NAME CHANGE: 19900726 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GOVERNMENT INCOME FUND DATE OF NAME CHANGE: 19900412 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL UTILITIES FUND CENTRAL INDEX KEY: 0000867824 IRS NUMBER: 046660195 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM UTILITIES GROWTH & INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL EQUITY FUND CENTRAL INDEX KEY: 0000081251 IRS NUMBER: 046145734 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GLOBAL GROWTH FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL EQUITIES FUND DATE OF NAME CHANGE: 19900722 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL EQUITIES FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM PENNSYLVANIA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000794615 IRS NUMBER: 043057637 STATE OF INCORPORATION: MA FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQU CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000205802 IRS NUMBER: 046396109 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MONEY MARKET FUND CENTRAL INDEX KEY: 0000081248 IRS NUMBER: 046386436 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A-14 LEGAL DEPARTMENT CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921471 MAIL ADDRESS: STREET 1: MAILSTOP A-14 LEGAL DEPARTMENT STREET 2: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM DAILY DIVIDEND TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM EQUITY INCOME FUND/NEW/ CENTRAL INDEX KEY: 0000216934 IRS NUMBER: 046407893 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002551581 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM STRATEGIC INCOME TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OPTION INCOME TRUST DATE OF NAME CHANGE: 19910307 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MULTI-CAP GROWTH FUND CENTRAL INDEX KEY: 0000865177 IRS NUMBER: 043091455 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW OPPORTUNITIES FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MANAGED MUNICIPAL INCOME TRUST CENTRAL INDEX KEY: 0000844790 IRS NUMBER: 046608976 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INVESTMENT FUNDS CENTRAL INDEX KEY: 0000932101 IRS NUMBER: 043251560 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE STREET 2: MAIL STOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: PUTNAM EQUITY FUNDS STREET 2: ONE POST OFFICE SQUARE MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EQUITY FUNDS DATE OF NAME CHANGE: 19941028 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH YIELD ADVANTAGE FUND CENTRAL INDEX KEY: 0000787836 IRS NUMBER: 066290063 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: NULL FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH YIELD TRUST II DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH INCOME SECURITIES FUND CENTRAL INDEX KEY: 0000810943 IRS NUMBER: 046562068 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: PUTNAM LLC STREET 2: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH INCOME BOND FUND DATE OF NAME CHANGE: 20030408 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH BOND FUND DATE OF NAME CHANGE: 20021107 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH INCOME CONVERTIBLE & BOND FUND DATE OF NAME CHANGE: 19920703 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 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM CALIFORNIA TAX EXEMPT INCOME TRUST CENTRAL INDEX KEY: 0000711402 IRS NUMBER: 042786284 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CALIFORNIA TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL NATURAL RESOURCES FUND CENTRAL INDEX KEY: 0000317031 IRS NUMBER: 133035507 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NATURAL RESOURCES FUND /MA/ DATE OF NAME CHANGE: 19950629 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM ENERGY RESOURCES TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: EBERSTADT ENERGY RESOURCES FUND INC DATE OF NAME CHANGE: 19850317 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MICHIGAN TAX EXEMPT INCOME FUND / CENTRAL INDEX KEY: 0000794611 IRS NUMBER: 046626130 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 617-292-14 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MICHIGAN TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM TAX FREE INCOME TRUST /MA/ CENTRAL INDEX KEY: 0000771951 IRS NUMBER: 046483374 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: NULL FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM TAX FREE INCOME TRUST DATE OF NAME CHANGE: 19920101 CORRESP 1 filename1.htm a_cwcorresp.htm
Putnam Investments 
One Post Office Square 
Boston, MA 02109 
December 20, 2013 

 

BY EDGAR CORRESPONDENCE

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Monique Botkin

Re:  Preliminary Proxy Statement on Schedule 14A filed by The Putnam Funds (each a 
  “Fund” and collectively the “Funds”) 

 

Dear Ms. Botkin:

This letter responds to the comments that you and Laura Hatch provided telephonically to me and my colleague, Carlo Forcione, on behalf of the Staff of the Securities and Exchange Commission (the “Commission Staff”) on December 4, 2013 regarding the preliminary proxy statement on Schedule 14A, as filed by the Funds with the Securities and Exchange Commission on November 27, 2013 (the “Proxy Statement”). For convenience of reference, I have summarized the Commission Staff’s comments before the responses by the Funds.

1. Comment: We note the statement in Proposal 1 of the Proxy Statement that “there are no current plans to make changes with respect to existing management fees, expense limitations, distribution arrangements, or the quality of any services provided to the funds or their shareholders as a result of the Transfer.” Please confirm that for a one-year period from October 8, 2013 there will be no changes to the advisory fees reflected in the proposed new management contracts that would be required to be disclosed pursuant to Item 22(c)(9) of Schedule 14A.

Response: Item 22(c)(9) of Schedule 14A requires certain disclosures “[i]f a change in the investment advisory fee is sought.” We confirm that no change in any fund’s investment advisory fee is sought and that there are no proposed or intended changes to the advisory fees reflected in the proposed new management contracts. We do not believe that Item 22(c)(9) requires a firm commitment that there will be no changes to advisory fees for any other reason (that is, for reasons unrelated to the Transfer) for a one year period.


2. Comment: Please confirm supplementally that no disclosure about Putnam Management’s financial condition is required to be provided pursuant to Item 22(c)(7) of Schedule 14A.

Response: We confirm that no disclosure pursuant to Item 22(c)(7) is required.

3. Comment: Please confirm supplementally that the provisions of the proposed new management contract described in the sub-paragraph of Proposal 1 in the Proxy Statement “The Proposed New Management Contract; Comparison with your Fund’s Prior Management Contract—Expenses” relating to the payment by the Funds of Trustee fees and reimbursement of Putnam Management by the Funds of certain expenses do not differ from the relevant provisions of each Fund’s previous management contract. If there is no difference, please consider revising the Proxy Statement disclosure to clarify.

Response: We confirm that there is no change to these provisions in each Fund’s proposed management contract. We have revised the disclosure in this sub-paragraph to clarify this point.

4. Comment: Please confirm supplementally that George Putnam, III is not an interested person of the Funds or of Putnam Management.

Response: We confirm that Mr. Putnam is not an interested person of the Funds or of Putnam Management, and has not been an interested person since the 2007 acquisition of Putnam Investments by Great-West Lifeco Inc. Before the 2007 acquisition, Mr. Putnam had been considered an interested person primarily due to his family’s direct and indirect stock ownership of Marsh & McLennan, the former ultimate parent company of Putnam Investments. Before the 2007 acquisition, Mr. Putnam also served as President of the Funds, in which capacity he presided at the Funds’ shareholder meetings. Mr. Putnam’s role as President terminated in 2007.

5. Comment: Please consider revising the Proxy Statement disclosure to provide additional information about how shareholders of the Funds may access the Funds’ Declarations of Trust that have been filed with the Secretary of The Commonwealth of Massachusetts.

Response: We have revised the Proxy Statement disclosure to indicate that the Declarations of Trust are available on the website of the Secretary of The Commonwealth of Massachusetts.

6. Comment: We note that, as disclosed in paragraph 4 of Proposal 3 of the Proxy Statement, the Revised Declaration “permits a fund to make involuntary redemptions in certain additional circumstances, including . . . (iv) if the Trustees determine for any other reason, in their sole discretion, that the ownership of fund shares by a shareholder is not in the best interests of the remaining shareholders of the Trust or of the applicable series


or class.” Please revise the Proxy Statement disclosure to provide additional information about the circumstances in which this plenary authority might be exercised.

Response: We have revised the Proxy Statement to provide some illustrative examples of the circumstances in which the Trustees may authorize an involuntary redemption under clause (iv). These circumstances may include situations in which (i) a shareholder repeatedly violates a Fund’s short-term trading restrictions or otherwise abuses shareholder privileges, (ii) a shareholder’s residence in a particular foreign jurisdiction may impose regulatory restrictions on a Fund, or (iii) a shareholder is added to the Specially Designated Nationals List maintained by the Office of Foreign Assets Control within the U.S. Department of the Treasury (or a similar list of persons subject to sanctions).

7. Comment: Please confirm that no redemption fees will be introduced or modified for any Fund upon the adoption by the relevant Funds of the Revised Declaration or, if any such changes are to be made, revise the disclosure in the Proxy Statement to provide the disclosure required by Item 22(c) of Schedule 14A with respect to such changes.

Response: As indicated in paragraph 8 of Proposal 3 in the Proxy Statement disclosure, the Revised Declaration, if adopted by the Affected Funds, would merely clarify the authority of the Trustees to assess redemption fees. The adoption of the Revised Declaration, by itself, would not result in any changes to a fund’s fee structure (including with respect to redemption fees), and no such changes are planned in connection with the adoption of the Revised Declaration by the Affected Funds. The introduction or modification of any redemption fee would be considered separately by the Trustees, in accordance with Rule 22c-2 under the Investment Company Act of 1940, and would be accompanied by appropriate disclosure in an Affected Fund’s prospectus. Currently, none of the Funds assesses redemption fees.

8. Comment: In addition to referring shareholders to Putnam Dynamic Asset Allocation Conservative Fund’s prospectus, please revise the disclosure in Proposal 4 of the Proxy Statement to provide additional information about the risks associated with investments in commodities by Putnam Dynamic Asset Allocation Conservative Fund.

Response: We have revised the Proxy Statement disclosure accordingly.

9. Comment: Please indicate supplementally which Proposals in the Proxy Statement will be subject to “echo voting” by Putnam Fiduciary Trust Company and Putnam Investor Services, Inc., acting as trustee of retirement plan accounts and shareholder of record for Fund shares held in such accounts.


Response: Putnam Fiduciary Trust Company and Putnam Investor Services, Inc. will “echo vote” shares for which they are the shareholder of record, in the manner set forth in the Proxy Statement, for all Proposals.

10. Comment: Please indicate supplementally whether the proportional voting mechanic outlined in the section of the Proxy Statement “Special Rule for Proportional Voting for Putnam Managed Municipal Income Trust and Putnam Municipal Opportunities Trust” will be utilized for all Proposals.

Response: The proportional voting mechanic will be utilized for all Proposals, in accordance with Section 402.08(C) of the New York Stock Exchange Listed Company Manual.

11. Comment: We note that the disclosure in Appendix F of the Proxy Statement describing the Trustees’ approval of the Funds’ previous management contracts states that “the Trustees noted that a portion of available soft dollars continues to be used to pay fund expenses.” Please describe supplementally this practice and its relation to the safe harbor set forth in Section 28(e) of the Securities Exchange Act of 1934.

Response: As indicated in the cited Proxy Statement disclosure, Putnam Management, in placing portfolio transactions for the Funds with broker-dealers, has entered into arrangements with certain broker-dealers whereby a negotiated portion of the trading commissions payable by the Funds in respect of certain portfolio transactions is allocated by the broker-dealer for use in paying certain Fund expenses, such as custody fees. This practice results in lower expenses for the Funds and, in the view of Putnam Management, is consistent with Putnam Management’s fiduciary duty to seek best execution in placing portfolio transactions on behalf of the Funds. Putnam Management and its affiliates do not receive any benefit from these arrangements.

The practice of using brokerage commissions to pay fund expenses is separate from the common practice by investment advisers of using “soft dollars,” in accordance with the Section 28(e) safe harbor, to obtain “research” and “brokerage services” that may benefit the adviser even where the brokerage commission paid exceeds the commission that might have been payable if the broker-dealer were not providing research or brokerage services to the adviser. As indicated in the Proxy Statement disclosure in Proposal 1, Putnam Management is authorized under both the previous management contracts and the proposed new management contracts to use soft dollars to obtain research and brokerage services in accordance with policies adopted from time to time by the Trustees, which include usage consistent with the Section 28(e) safe harbor and applicable guidance issued by the Securities and Exchange Commission and the Commission Staff. As indicated in Appendix F to the Proxy Statement, the Trustees regularly review Putnam Management’s use of soft dollars, including the benefits received by Putnam


Management in the form of research and brokerage services, both in connection with their consideration of management contract approvals and as part of their oversight of Putnam Management’s portfolio trading processes.

Putnam Management and the Trustees believe that the use of brokerage commissions to pay fund expenses is analytically different from the use of soft dollars to obtain research and brokerage services, as the former practice does not inure to the benefit of Putnam Management and instead benefits solely the Funds. We note that, since no benefit inures to Putnam Management from the use of brokerage commissions to pay fund expenses, there is no need for reliance on the Section 28(e) safe harbor. We have revised the cited statement in the Proxy Statement disclosure to substitute “brokerage commissions” for “soft dollars” to reduce potential confusion caused by the use of the latter term in describing this practice.

12. Comment: Please provide supplementally an update on the matters described in the section of Appendix G entitled “A note for funds audited by PricewaterhouseCoopers LLP.”

Response: As of the date of this letter, we have been advised by PricewaterhouseCoopers LLP that it expects the asset transfers described in the Proxy Statement disclosure to be complete on or before December 31, 2013.

13. Comment: Please revise the disclosure in the Proxy Statement accompanying paragraph 10 of Proposal 3 to make more prominent the statement “The proposed changes would expand, to a certain extent, the Trustees’ authority to amend a declaration of trust without obtaining a shareholder vote.”

Response: We have revised the Proxy Statement disclosure accordingly.

I believe this letter addresses the Commission Staff’s comments. Should you have any further questions, please do not hesitate to call me at (617) 760-8939. Thank you for your assistance.

Very truly yours,

/s/ James F. Clark

James F. Clark

Associate General Counsel


Putnam Investments

cc: Carlo N. Forcione, Esq., Putnam Investments

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