0000869392-22-000446.txt : 20220308
0000869392-22-000446.hdr.sgml : 20220308
20220308090948
ACCESSION NUMBER: 0000869392-22-000446
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 22
CONFORMED PERIOD OF REPORT: 20211231
FILED AS OF DATE: 20220308
DATE AS OF CHANGE: 20220308
EFFECTIVENESS DATE: 20220308
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: N-CEN
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-05346
FILM NUMBER: 22720511
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
0000822671
S000003871
Putnam VT Mortgage Securities Fund
C000010837
Class IA Shares
C000010838
Class IB shares
0000822671
S000003873
Putnam VT Growth Opportunities Fund
C000010841
Class IA Shares
C000010842
Class IB Shares
0000822671
S000003874
Putnam VT Global Health Care Fund
C000010843
Class IA Shares
C000010844
Class IB Shares
0000822671
S000003875
Putnam VT High Yield Fund
C000010845
Class IA Shares
C000010846
Class IB Shares
0000822671
S000003876
Putnam VT Income Fund
C000010847
Class IA Shares
C000010848
Class IB Shares
0000822671
S000003877
Putnam VT International Equity Fund
C000010849
Class IA Shares
C000010850
Class IB Shares
0000822671
S000003878
Putnam VT International Value Fund
C000010851
Class IA Shares
C000010852
Class IB Shares
0000822671
S000003879
Putnam VT Emerging Markets Equity Fund
C000010853
Class IA Shares
C000010854
Class IB Shares
0000822671
S000003880
Putnam VT Multi-Cap Core Fund
C000010855
Class IA Shares
C000010856
Class IB Shares
0000822671
S000003881
Putnam VT Sustainable Future Fund
C000010857
Class IA Shares
C000010858
Class IB Shares
0000822671
S000003882
Putnam VT Government Money Market Fund
C000010859
Class IA Shares
C000010860
Class IB Shares
0000822671
S000003883
Putnam VT Small Cap Growth Fund
C000010861
Class IA Shares
C000010862
Class IB Shares
0000822671
S000003884
Putnam VT Sustainable Leaders Fund
C000010863
Class IA Shares
C000010864
Class IB Shares
0000822671
S000003887
Putnam VT Research Fund
C000010869
Class IA Shares
C000010870
Class IB Shares
0000822671
S000003888
Putnam VT Small Cap Value Fund
C000010871
Class IA Shares
C000010872
Class IB Shares
0000822671
S000003893
Putnam VT Diversified Income Fund
C000010881
Class IA Shares
C000010882
Class IB Shares
0000822671
S000003894
Putnam VT Large Cap Value Fund
C000010883
Class IA Shares
C000010884
Class IB Shares
0000822671
S000003895
Putnam VT George Putnam Balanced Fund
C000010885
Class IA Shares
C000010886
Class IB Shares
0000822671
S000003896
Putnam VT Global Asset Allocation Fund
C000010887
Class IA Shares
C000010888
Class IB Shares
0000822671
S000003897
Putnam VT Focused International Equity Fund
C000010889
Class IA Shares
C000010890
Class IB Shares
0000822671
S000032103
Putnam VT Multi-Asset Absolute Return Fund
C000099977
Class IA
C000099978
Class IB
N-CEN
1
primary_doc.xml
X0404
N-CEN
LIVE
0000822671
XXXXXXXX
false
false
N-1A
S000003897
true
S000003875
true
S000003876
true
S000003882
true
S000003896
true
S000003884
true
S000003881
true
S000003883
true
S000003894
true
S000003878
true
S000003877
true
S000003879
true
S000003880
true
S000003895
true
S000003874
true
S000003887
true
S000003888
true
S000003873
true
S000003871
true
S000003893
true
S000032103
true
Putnam Variable Trust
811-05346
0000822671
549300TBVD21LYBGBD46
100 FEDERAL STREET
BOSTON
02110
US-MA
US
1-800-225-1581
Putnam Retail Management Limited Partnership
100 FEDERAL STREET
BOSTON
02110
1-800-225-1581
Records include accounts, books and other documents required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the Rules promulgated thereunder
Putnam Investor Services, Inc.
100 FEDERAL STREET
BOSTON
02110
1-800-225-1581
Records include accounts, books and other documents required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the Rules promulgated thereunder
Putnam Investment Management, LLC
100 FEDERAL STREET
BOSTON
02110
1-800-225-1581
Records include accounts, books and other documents required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the Rules promulgated thereunder
Higgins Michael J.
100 FEDERAL STREET
BOSTON
02110
1-800-225-1581
Records include accounts, books and other documents required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the Rules promulgated thereunder
State Street Bank and Trust Company
2 AVENUE DE LAFAYETTE
BOSTON
02111
1-617-786-3000
Records include accounts, books and other documents required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the Rules promulgated thereunder
State Street Bank and Trust Company
225 FRANKLIN STREET
BOSTON
02110
1-617-786-3000
Records include accounts, books and other documents required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the Rules promulgated thereunder
N
N
N-1A
21
Y
Ahamed Liaquat
N/A
N
Akhoury Ravi
N/A
N
Baumann Barbara M
N/A
N
Domotorffy Katinka
004506390
N
Hill Catharine Bond
N/A
N
Joskow Paul L
N/A
N
Leibler Kenneth R
N/A
N
Putnam, III George
004355835
N
Reynolds Robert L
002009065
Y
Singh Manoj P
N/A
N
Sutphen Mona K
N/A
N
Clark James F
N/A
100 FEDERAL STREET
BOSTON
02110
XXXXXX
N
N
N
N
N
Putnam Retail Management Limited Partnership
8-5088
000007325
N/A
Y
N
PricewaterhouseCoopers LLP
238
5493002GVO7EO8RNNS37
N
N
N
N
N
N
Putnam VT Focused International Equity Fund
S000003897
PK9XS95JYYM8HJ2EFT97
N
2
0
0
Underlying fund
Y
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
1312247.00
1227.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
Y
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters
549300561UZND4C7B569
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
102935.8
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
83962.19
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
74606.89
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
46169.51
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
36972.65
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
32805.11
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
29584.31
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
17074.96
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
9735.38
ODPN - ODDO PINATTON
8-50975
000045104
254900PB6XNTR7C0W579
FR
6622.79
470490.82
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
1014900.15
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
399979.03
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
299991.67
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
299964.4
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
199942.68
WCHV - WELLS FARGO SECURITIES, LLC
8-65876
000126292
VYVVCKR63DVZZN70PB21
99974.8
2314752.73
Y
217981234.26
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT High Yield Fund
S000003875
FZCF32TUQ6MTFH6JWS05
N
2
0
0
Underlying fund
N
N
N
N
N/A
0.00
0.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
Reuters (loan)
549300561UZND4C7B569
N
Reuters
549300561UZND4C7B569
N
Reuters (Corp)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
1178.19
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
584
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
583.76
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
456.6
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
323.75
WCHV - WELLS FARGO SECURITIES, LLC
8-65876
000126292
VYVVCKR63DVZZN70PB21
312
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
292.6
CANA - CANACCORD GENUITY INC
8-3271
000001020
WTX5X269IUOQ9YMI7R44
GB
147.6
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
89.48
3967.98
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
29492107.45
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
19202282.17
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
18667273.05
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
15590622.03
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
13101122.9
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
11389615.56
DBAB - DEUTSCHE BANK SECURITIES INC.
8-17822
000002525
9J6MBOOO7BECTDTUZW19
8094132.39
WCHV - WELLS FARGO SECURITIES, LLC
8-65876
000126292
VYVVCKR63DVZZN70PB21
7672588.25
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
6270317.1
JEFF - JEFFERIES LLC
8-15074
000002347
NY9Q8VBNB6D1L6YV0J84
4089913.35
155164946.08
Y
173618903.56
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Income Fund
S000003876
T240UNT2CVVGMZTWE450
N
2
0
0
Underlying fund
N
N
N
N
N/A
0.00
0.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
PRICESERVE
54930015EWCI4VNCZP82
N
Markit
549300HLPTRASHS0E726
N
Reuters
549300561UZND4C7B569
N
Reuters (Corp)
549300561UZND4C7B569
N
MARKIT
549300HLPTRASHS0E726
GB
N
PDVENDOR
549300WIC0TOJ7N7GD54
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
CITI - CITIBANK, N.A.
8-8177
000007059
E57ODZWZ7FF32TWEFA76
15241.5
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
716
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
691
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
4.5
16653
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
713729290.18
CSAG - CREDIT SUISSE AG, NEW YORK BRANCH
8-422
000000816
ANGGYXNX0JLX3X63JN86
623517799.92
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
395799561.22
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
146263139.68
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
138791131.4
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
131629672.02
CGMI - CITIGROUP GLOBAL MARKETS INC.
8-8177
000007059
MBNUM2BPBDO7JBLYG310
23245381.75
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
14293066.98
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
7528126.4
BMOC - BMO CAPITAL MARKETS CORP.
8-34344
000016686
RUC0QBLBRPRCU4W1NE59
6067951.29
2242545293.75
Y
225853840.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Government Money Market Fund
S000003882
549300EZL9T7TW0BA857
N
2
0
0
Underlying fund
N
N
N
N
N/A
0.00
0.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
Y
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
0
CGMI - CITIGROUP GLOBAL MARKETS INC.
8-8177
000007059
MBNUM2BPBDO7JBLYG310
4709209000
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
4706301352.51
RBCA - ROYAL BANK OF CANADA
8-45411
000031194
ES7IP3U3RHIGC71XBU11
CA
4139200000
SSBS - STATE STREET BANK AND TRUST CO. - BANK ONLY
8-69862
000285852
N/A
426000000
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
148000000
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
9046764.19
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
6121498.25
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
4110664.15
TDSI - TD SECURITIES (USA) LLC
8-36747
000018476
SUVUFHICNZMP2WKHG940
854798.18
BONY - BANK OF NEW YORK
8-35255
000017454
N/A
849875.33
14151391860.66
N
0.00
80871359
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Global Asset Allocation Fund
S000003896
52S5T0ZLZ612Q4T28G76
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
355299.00
1038.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
PRICESERVE
54930015EWCI4VNCZP82
N
Reuters (Corp)
549300561UZND4C7B569
N
Reuters (equities)
549300561UZND4C7B569
N
Reuters
549300561UZND4C7B569
N
MARKIT
549300HLPTRASHS0E726
GB
N
PDVENDOR
549300WIC0TOJ7N7GD54
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
Reuters (loan)
549300561UZND4C7B569
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
22601.56
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
7024.49
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
3802.41
CITI - CITIBANK, N.A.
8-8177
000007059
E57ODZWZ7FF32TWEFA76
3460.5
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
2576.72
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
657.83
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
455.69
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
217.23
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
209.37
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
188.81
41225.67
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
138609041.4
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
63413695.63
CSAG - CREDIT SUISSE AG, NEW YORK BRANCH
8-422
000000816
ANGGYXNX0JLX3X63JN86
53370585.94
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
23621133.08
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
21706546.66
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
16413138.52
CGMI - CITIGROUP GLOBAL MARKETS INC.
8-8177
000007059
MBNUM2BPBDO7JBLYG310
8309145.47
AMHE - AMHERST SECURITIES GROUP L.P.
8-45364
000031141
GR1JCST0OG1YC8O1XP88
2240014.03
WCHV - WELLS FARGO SECURITIES, LLC
8-65876
000126292
VYVVCKR63DVZZN70PB21
1597252.56
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
1457003.79
335332932.14
Y
129451604.72
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Sustainable Leaders Fund
S000003884
B8ZS316QP9AOFBYPRB36
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
17576054.00
51486.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
40238.28
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
31832.8
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
25996.15
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
23535.04
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
22112.33
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
20114.19
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
17021.63
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
9280.32
NITE - VIRTU AMERICAS, LLC
8-68193
000149823
549300RA02N3BNSWBV74
9030.87
WCHV - WELLS FARGO SECURITIES, LLC
8-65876
000126292
VYVVCKR63DVZZN70PB21
8748.6
233518.69
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
3747217
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
599974.09
4347191.09
Y
1005777856.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Sustainable Future Fund
S000003881
JYIPQPR6E8NLCIAKNR15
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
3451545.00
20458.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
NITE - VIRTU AMERICAS, LLC
8-68193
000149823
549300RA02N3BNSWBV74
3072.36
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
2749.84
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
2655.64
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
2608.04
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
2552.28
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
2101.05
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
1659.42
STFL - STIFEL, NICOLAUS & COMPANY INCORPORATED
8-1447
000000793
5WUVMA08EYG4KEUPW589
1425.84
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
1406.67
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
1027.99
25531.91
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
764600.75
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
638003
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
514074.55
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
226292
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
175980
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
24070
2343020.3
Y
46435096.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Small Cap Growth Fund
S000003883
YW6EJ1M3RMPJSDI6CN88
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
2593401.00
3441.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
NITE - VIRTU AMERICAS, LLC
8-68193
000149823
549300RA02N3BNSWBV74
9332.36
STFL - STIFEL, NICOLAUS & COMPANY INCORPORATED
8-1447
000000793
5WUVMA08EYG4KEUPW589
3370.91
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
2513.13
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
2215.72
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
893.8
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
893.35
JEFF - JEFFERIES LLC
8-15074
000002347
NY9Q8VBNB6D1L6YV0J84
603.72
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
562.08
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
550.4
RAJA - RAYMOND JAMES & ASSOCIATES, INC.
8-10999
000000705
U4ONQX15J3RO8XCKE979
489
22867.3
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
955135
NEED - NEEDHAM & COMPANY, L.L.C.
8-33772
000016360
N/A
272085
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
232849.9
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
161619
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
156519
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
153515.8
DBAB - DEUTSCHE BANK SECURITIES INC.
8-17822
000002525
9J6MBOOO7BECTDTUZW19
119465
LEER - LEERINK PARTNERS LLC
8-48535
000039011
549300AAH7U76CEUBI94
36160
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
7032
2094380.7
Y
38574624.40
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Large Cap Value Fund
S000003894
ITNNCTEHDDEMTCLPNT59
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
36263168.00
61482.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
42625.16
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
32441.84
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
26165.26
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
24217.06
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
22830.2
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
22414.58
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
19617.93
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
14454.63
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
13404.74
RAJA - RAYMOND JAMES & ASSOCIATES, INC.
8-10999
000000705
U4ONQX15J3RO8XCKE979
10877.56
277478.53
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
2462596.63
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
1298457.38
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
1199887.28
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
769400.58
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
399860.87
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
199990.49
6330193.23
Y
1606759808.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT International Value Fund
S000003878
TNUK5E0XNNLQBFCQD252
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
206158.00
6713.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
8652.84
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
3745.45
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
3281.45
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
3076.38
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
1803.35
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
1052.45
REDB - REDBURN (USA) LLC
8-67320
000140564
213800TYRTQILMQQLV79
860.74
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
822.51
CSI - CREDIT SUISSE INTERNATIONAL
8-422
000000816
E58DKGMJYYYJLN8C3868
806.3
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
622.72
26435.26
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
499928.54
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
199986.86
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
199976.46
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
99967.9
EXAN - EXANE, INC.
8-49569
000041784
6SDWK6FV8H98XAGSYS75
43055.25
1042915.01
Y
80616446.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT International Equity Fund
S000003877
54930018M6QYQ2Z40165
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
693044.00
31631.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
53283.99
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
31238.52
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
22961.11
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
22450.85
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
12743.58
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
11852.77
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
9945.73
BTIG - BTIG, L.L.C.
8-65473
000122225
549300GTG9PL6WO3EC51
9172.76
DAWA - DAIWA CAPITAL MARKETS AMERICA INC.
8-12242
000001576
M67H5PRC0NQKM73ZAS82
8100.52
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
7461.68
231251.48
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
2058622.63
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
565946.22
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
499953.01
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
399966.73
DBAB - DEUTSCHE BANK SECURITIES INC.
8-17822
000002525
9J6MBOOO7BECTDTUZW19
394840.1
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
299970.04
PARI - BNP PARIBAS SECURITIES CORP
8-32682
000015794
RCNB6OTYUAMMP879YW96
299889.8
EXAN - EXANE, INC.
8-49569
000041784
6SDWK6FV8H98XAGSYS75
134944.34
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
99969.27
4754102.14
Y
247644192.31
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Emerging Markets Equity Fund
S000003879
GOCT55GYSZZ8YF31Q617
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
931477.00
1044.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
Y
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
17032.86
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
15023.27
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
12762.48
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
9241.31
MSUS - MACQUARIE CAPITAL (USA) INC
8-47198
000036368
549300670K07JRB5UQ40
6500.46
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
5732.6
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
5633.61
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
5153.38
CLSA - CLSA LIMITED
8-69166
000165533
213800CF5G9GRZD2RV79
HK
1885.18
HSBCP - HSBC BANK PLC
8-41562
000019585
MP6I5ZYZBEU3UXPYFY54
GB
1754.78
86665.32
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
177933
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
42826
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
20823.21
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
2042.32
243624.53
Y
36304460.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Multi-Cap Core Fund
S000003880
4G7DKLYVENKNDL7R6F33
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
2324670.00
7176.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
Reuters
549300561UZND4C7B569
N
Reuters (equities)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
27843.08
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
27576.53
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
26664.28
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
17346.94
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
15219.18
JONE - JONESTRADING
8-26089
000006888
2138008JJ5PA8H5UIL69
12434.76
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
7485.98
RAJA - RAYMOND JAMES & ASSOCIATES, INC.
8-10999
000000705
U4ONQX15J3RO8XCKE979
6998.68
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
6812
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
5453.67
175629.44
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
11983728.62
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
11182724
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
6228750
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
4812704.68
CANT - CANTOR FITZGERALD & CO.
8-3271
000000134
5493004J7H4GCPG6OB62
1879620
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
1515683.54
STFL - STIFEL, NICOLAUS & COMPANY INCORPORATED
8-1447
000000793
5WUVMA08EYG4KEUPW589
1012317
DBAB - DEUTSCHE BANK SECURITIES INC.
8-17822
000002525
9J6MBOOO7BECTDTUZW19
876950
WCHV - WELLS FARGO SECURITIES, LLC
8-65876
000126292
VYVVCKR63DVZZN70PB21
526180
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
491100
42158675.55
Y
270705680.23
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT George Putnam Balanced Fund
S000003895
MEM8REXDOEBLU02UY840
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
883073.00
7414.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
Reuters
549300561UZND4C7B569
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Muni)
5493000NQ9LYLDBCTL34
N
PRICESERVE
54930015EWCI4VNCZP82
N
Reuters (Corp)
549300561UZND4C7B569
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
8002.46
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
7424.03
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
7161.37
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
6977.49
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
4626.13
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
4206.81
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
4049.31
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
3942.59
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
3518.66
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
3193.77
63468.52
CSAG - CREDIT SUISSE AG, NEW YORK BRANCH
8-422
000000816
ANGGYXNX0JLX3X63JN86
36365117.19
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
31116662.75
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
25213238.25
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
22256277.02
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
20925046.84
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
11048040.4
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
6425644.52
CGMI - CITIGROUP GLOBAL MARKETS INC.
8-8177
000007059
MBNUM2BPBDO7JBLYG310
6036628.79
BOKL - BANK OF OKLAHOMA, NA
8-35381
000017530
N/A
4210753.43
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
2692075.12
181905831.72
Y
240123706.96
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Global Health Care Fund
S000003874
OGC9MX44J30WCPCACY55
N
2
0
0
Underlying fund
Y
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
3326911.00
7767.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
Reuters (equities)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
CANA - CANACCORD GENUITY INC
8-3271
000001020
WTX5X269IUOQ9YMI7R44
GB
24018.96
JONE - JONESTRADING
8-26089
000006888
2138008JJ5PA8H5UIL69
15014.02
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
12780.87
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
11209.8
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
9251.39
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
8789.79
COWN - COWEN & COMPANY, L.L.C.
8-22522
000007616
549300WR155U7DVMIW58
8652.18
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
7850
JEFF - JEFFERIES LLC
8-15074
000002347
NY9Q8VBNB6D1L6YV0J84
6981.08
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
6556.14
150503.65
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
1234592.68
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
997549.04
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
458946
COWN - COWEN & COMPANY, L.L.C.
8-22522
000007616
549300WR155U7DVMIW58
284130
PARI - BNP PARIBAS SECURITIES CORP
8-32682
000015794
RCNB6OTYUAMMP879YW96
99994.48
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
99980.93
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
1227.84
3176420.97
Y
165222130.32
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Research Fund
S000003887
2OWXZ2LGVIYMJOL2HG14
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
320163.00
3235.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
Reuters
549300561UZND4C7B569
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
3160.46
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
3036.78
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
2975.74
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
2897.35
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
1882.98
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
1585.27
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
1558.26
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
1548.8
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
1310.05
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
1039.65
25182.08
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
820135.13
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
707861.92
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
316440.61
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
108643.7
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
99987.48
DBAB - DEUTSCHE BANK SECURITIES INC.
8-17822
000002525
9J6MBOOO7BECTDTUZW19
99980.84
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
79090
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
36930
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
14934.83
FBRR - B. Riley Securities
8-41426
000025027
2549005CLOSQO0MJEA57
12464
2306291.81
Y
63081080.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Small Cap Value Fund
S000003888
PDOQ7DSJON4NJI51RN72
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
7277271.00
7341.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
Reuters (equities)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
65794.75
RAJA - RAYMOND JAMES & ASSOCIATES, INC.
8-10999
000000705
U4ONQX15J3RO8XCKE979
56151.95
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
51416.87
JEFF - JEFFERIES LLC
8-15074
000002347
NY9Q8VBNB6D1L6YV0J84
36678.73
PIJF - PIPER JAFFRAY & CO. (formerly WEEDEN & CO. L.P.)
8-15204
000000665
QUQDBTUSOAKFEVMRMF78
28162.27
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
25805.45
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
24229.19
WBLR - BLAIR (WILLIAM) & COMPANY, L.L.C.
8-2698
000001252
549300J0P7XYE8BMZ775
19957.92
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
15365.42
KBWI - KEEFE, BRUYETTE & WOODS, INC.
8-10888
000000481
549300OM47DQV01G4854
13199.87
404197.28
KBWI - KEEFE, BRUYETTE & WOODS, INC.
8-10888
000000481
549300OM47DQV01G4854
2293266.5
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
1491876
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
1034699.5
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
781974
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
478655.3
RAJA - RAYMOND JAMES & ASSOCIATES, INC.
8-10999
000000705
U4ONQX15J3RO8XCKE979
427289
STFL - STIFEL, NICOLAUS & COMPANY INCORPORATED
8-1447
000000793
5WUVMA08EYG4KEUPW589
300608
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
278413.33
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
219011
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
123112.5
7439981.56
Y
143174048.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Growth Opportunities Fund
S000003873
ZREV7S924QLJLC41VU70
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
19999252.00
17435.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
Reuters (equities)
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
58394.46
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
44660.01
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
25173.98
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
25161.95
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
24699.42
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
23148.54
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
22589.01
JEFF - JEFFERIES LLC
8-15074
000002347
NY9Q8VBNB6D1L6YV0J84
20271.22
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
8958.91
BARD - BAIRD (ROBERT W.) & CO., INCORPORATED
8-497
000008158
549300772UJAHRD6LO53
8938
345540.24
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
301641
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
237270
CITI - CITIBANK, N.A.
8-8177
000007059
E57ODZWZ7FF32TWEFA76
129376.37
668287.37
Y
1167130240.00
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Mortgage Securities Fund
S000003871
BNJ2SUHEY4BD8C3LUN07
N
2
0
0
Underlying fund
N
N
N
N
N/A
0.00
0.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
Y
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
PRICESERVE
54930015EWCI4VNCZP82
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
MARKIT
549300HLPTRASHS0E726
GB
N
Reuters
549300561UZND4C7B569
N
PDVENDOR
549300WIC0TOJ7N7GD54
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
CITI - CITIBANK, N.A.
8-8177
000007059
E57ODZWZ7FF32TWEFA76
6981.75
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
132.75
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
31.5
7146
HSBCP - HSBC BANK PLC
8-41562
000019585
MP6I5ZYZBEU3UXPYFY54
GB
253344000
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
173731324.33
CSAG - CREDIT SUISSE AG, NEW YORK BRANCH
8-422
000000816
ANGGYXNX0JLX3X63JN86
131020468.75
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
80812272.4
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
32418054.12
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
28213385.35
CGMI - CITIGROUP GLOBAL MARKETS INC.
8-8177
000007059
MBNUM2BPBDO7JBLYG310
23280984.8
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
23210968.63
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
5615669.54
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
2058381.77
761021020.79
N
45453262.63
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Diversified Income Fund
S000003893
8JXB19CF5HE2V5XUD764
N
2
0
0
Underlying fund
N
N
N
N
N/A
0.00
0.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
N
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
PRICESERVE
54930015EWCI4VNCZP82
N
ICE Data Services (Convert)
5493000NQ9LYLDBCTL34
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
Reuters (equities)
549300561UZND4C7B569
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
MARKIT
549300HLPTRASHS0E726
GB
N
PDVENDOR
549300WIC0TOJ7N7GD54
N
Reuters (loan)
549300561UZND4C7B569
N
Markit
549300HLPTRASHS0E726
GB
N
Reuters (Corp)
549300561UZND4C7B569
N
Reuters
549300561UZND4C7B569
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
CITI - CITIBANK, N.A.
8-8177
000007059
E57ODZWZ7FF32TWEFA76
10408.5
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
986.75
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
242.86
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
184.84
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
4.53
11827.48
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
855545156.33
CSAG - CREDIT SUISSE AG, NEW YORK BRANCH
8-422
000000816
ANGGYXNX0JLX3X63JN86
646879949.43
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
503868273.89
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
155339303.57
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
142459223.62
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
67514828.26
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
10988933.98
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
7043297.89
JEFF - JEFFERIES LLC
8-15074
000002347
NY9Q8VBNB6D1L6YV0J84
6726662.71
BMOC - BMO CAPITAL MARKETS CORP.
8-34344
000016686
RUC0QBLBRPRCU4W1NE59
6724478.11
2429861598
Y
177508743.16
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
Putnam VT Multi-Asset Absolute Return Fund
S000032103
549300FJ7VYUU81RIO14
N
2
0
0
Underlying fund
N
N
Y
N
N
Goldman Sachs Bank USA
KD3XUN7C6T14HNAYLU02
N
N
Revenue sharing split
716980.00
560.00
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-1 (17 CFR 270.12d1-1)
Rule 17a-6 (17 CFR 270.17a-6)
Rule 17a-7 (17 CFR 270.17a-7)
Y
Y
N
N
Putnam Investment Management, LLC
801-7974
000106629
N/A
N
Putnam Investments Limited
801-61441
000122254
N/A
Y
GB
N
The Putnam Advisory Company, LLC
801-5097
000106631
N/A
Y
N
Putnam Investor Services, Inc.
84-06331
N/A
Y
N
N
PRICESERVE
54930015EWCI4VNCZP82
N
MARKIT
549300HLPTRASHS0E726
GB
N
Reuters (Corp)
549300561UZND4C7B569
N
Markit
549300HLPTRASHS0E726
N
ICE Data Services (Corp)
5493000NQ9LYLDBCTL34
N
Reuters (equities)
549300561UZND4C7B569
N
Reuters
549300561UZND4C7B569
N
PDVENDOR
549300WIC0TOJ7N7GD54
N
JPM Pricing Direct
549300WIC0TOJ7N7GD54
N
N
State Street Bank and Trust Company
N/A
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
N
Putnam Investor Services, Inc.
N/A
Y
N
N
N
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
2798.27
CITI - CITIBANK, N.A.
8-8177
000007059
E57ODZWZ7FF32TWEFA76
2796.75
UBSW - UBS SECURITIES L.L.C.
8-22651
000007654
T6FIZBDPKLYJKFCRVK44
1597.35
RBCD - RBC CAPITAL MARKETS LLC
8-45411
000031194
549300LCO2FLSSVFFR64
881.56
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
792.66
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
745.76
STCM - SUNTRUST ROBINSON HUMPHREY INC
8-17212
000006271
CSVTK36R0PNGXEM7NS14
457.36
CSFB - CREDIT SUISSE SECURITIES (USA), LLC
8-422
000000816
1V8Y6QCX6YMJ2OELII46
456.86
JONE - JONESTRADING
8-26089
000006888
2138008JJ5PA8H5UIL69
454.83
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
401.56
12715.5
CSAG - CREDIT SUISSE AG, NEW YORK BRANCH
8-422
000000816
ANGGYXNX0JLX3X63JN86
39843109.64
JPMS - J.P. MORGAN SECURITIES, LLC.
8-35008
000000079
ZBUT11V806EZRVTWT807
37071593.89
MSCO - MORGAN STANLEY & CO. LLC
8-15869
000008209
9R7GPTSO7KV3UQJZQ078
30450443.21
GSCO - GOLDMAN SACHS & CO LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
16004537.08
BCAP - BARCLAYS CAPITAL, INC.
8-41342
000019714
AC28XWWI3WIBK2824319
11659101.13
MLCO - BofA Securities, Inc.
8-7221
000007691
549300HN4UKV1E2R3U73
11530370.79
CGMI - CITIGROUP GLOBAL MARKETS INC.
8-8177
000007059
MBNUM2BPBDO7JBLYG310
6201179.69
CGML - CITIGROUP GLOBAL MARKETS INC
8-8177
000007059
6SHGI4ZSSLCXXQSBB395
2765817.2
CITG - CITIGROUP GLOBAL MARKETS, INC./SALOMON BROTHERS
8-8177
000007059
MBNUM2BPBDO7JBLYG310
2153500.6
NMRA - NOMURA SECURITIES INTERNATIONAL, INC.
8-15255
000004297
OXTKY6Q8X53C9ILVV871
1349748.88
162604881.28
Y
23297170.70
0.00
Committed
317500000
N
Uncommitted
235500000
N
N
N
N
false
false
true
false
false
false
INTERNAL CONTROL RPT
2
G.1.a.iii016.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Focused International Equity Fund:
In planning and performing our audit of the financial statements
of Putnam VT Focused International Equity Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 10, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
3
G.1.a.iii067.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT High Yield Fund
In planning and performing our audit of the financial statements
of Putnam VT High Yield Fund (one of the funds constituting
Putnam Variable Trust, referred to hereafter as the Fund) as of
and for the year ended December 31, 2021, in accordance with the
standards of the Public Company Accounting Oversight Board
(United States) (PCAOB), we considered the Funds internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
NCEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston,
MA 02210
T (617)530 5000, F (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
4
G.1.a.iii068.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and Shareholders
of Putnam VT Income Fund:
In planning and performing our audit of the financial statements
of Putnam VT Income Fund (one of the funds constituting Putnam
Variable Trust, referred to hereafter as the Fund) as of and for
the year ended December 31, 2021, in accordance with the standards
of the Public Company Accounting Oversight Board (United States)
(PCAOB), we considered the Funds internal control over financial
reporting, including controls over safeguarding securities, as a
basis for designing our auditing procedures for the purpose of
expressing our opinion on the financial statements and to comply
with the requirements of Form NCEN, but not for the purpose of
expressing an opinion on the effectiveness of the Funds internal
control over financial reporting. Accordingly, we do not express
an opinion on the effectiveness of the Funds internal control over
financial reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect
the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles, and that
receipts and expenditures of the company are being made only in
accordance with authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding prevention
or timely detection of unauthorized acquisition, use or
disposition of a companys assets that could have a material effect
on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing their
assigned functions, to prevent or detect misstatements on a timely
basis. A material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such
that there is a reasonable possibility that a material
misstatement of the companys annual or interim financial
statements will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However, we
noted no deficiencies in the Funds internal control over financial
reporting and its operation, including controls over safeguarding
securities, that we consider to be material weaknesses as defined
above as of December 31, 2021.
?
This report is intended solely for the information and use of the
Board of Trustees of Putnam Variable Trust and the Securities and
Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 10, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
5
g.1.a.iii069.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Government Money Market Fund:
In planning and performing our audit of the financial statements
of Putnam VT Government Money Market Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund ) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 10, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
6
G.1.a.iii070.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Global Asset Allocation Fund:
In planning and performing our audit of the financial statements
of Putnam VT Global Asset Allocation Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 11, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
7
G.1.a.iii098.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and Shareholders
of Putnam VT Sustainable Leaders Fund:
In planning and performing our audit of the financial statements
of Putnam VT Sustainable Leaders Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls over
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
NCEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect
the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles, and that
receipts and expenditures of the company are being made only in
accordance with authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding prevention
or timely detection of unauthorized acquisition, use or
disposition of a companys assets that could have a material effect
on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing their
assigned functions, to prevent or detect misstatements on a timely
basis. A material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such
that there is a reasonable possibility that a material
misstatement of the companys annual or interim financial
statements will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However, we
noted no deficiencies in the Funds internal control over financial
reporting and its operation, including controls over safeguarding
securities, that we consider to be material weaknesses as defined
above as of December 31, 2021.
?
This report is intended solely for the information and use of the
Board of Trustees of Putnam Variable Trust and the Securities and
Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
8
g.1.a.iii23h.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Sustainable Future Fund:
In planning and performing our audit of the financial statements
of Putnam VT Sustainable Future Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund ) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
9
G.1.a.iii23k.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Small Cap Growth Fund:
In planning and performing our audit of the financial statements
of Putnam VT Small Cap Growth Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
10
G.1.a.iii23n.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and Shareholders
of Putnam VT Large Cap Value Fund:
In planning and performing our audit of the financial statements
of Putnam VT Large Cap Value Fund (one of the funds constituting
Putnam Variable Trust, referred to hereafter as the Fund) as of
and for the year ended December 31, 2021, in accordance with the
standards of the Public Company Accounting Oversight Board (United
States) (PCAOB), we considered the Funds internal control over
financial reporting, including controls over safeguarding
securities, as a basis for designing our auditing procedures for
the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form NCEN, but not for the
purpose of expressing an opinion on the effectiveness of the Funds
internal control over financial reporting. Accordingly, we do not
express an opinion on the effectiveness of the Funds internal
control over financial reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect
the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles, and that
receipts and expenditures of the company are being made only in
accordance with authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding prevention
or timely detection of unauthorized acquisition, use or
disposition of a companys assets that could have a material effect
on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing their
assigned functions, to prevent or detect misstatements on a timely
basis. A material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such
that there is a reasonable possibility that a material
misstatement of the companys annual or interim financial
statements will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However, we
noted no deficiencies in the Funds internal control over financial
reporting and its operation, including controls over safeguarding
securities, that we consider to be material weaknesses as defined
above as of December 31, 2021.
?
This report is intended solely for the information and use of the
Board of Trustees of Putnam Variable Trust and the Securities and
Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 9, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
11
G.1.a.iii2dn.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT International Value Fund
In planning and performing our audit of the financial statements
of Putnam VT International Value Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However, we
noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T (617)530 5000, F (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
12
G.1.aiii2do.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and Shareholders of
Putnam VT International Equity Fund:
In planning and performing our audit of the financial statements of
Putnam VT International Equity Fund (one of the funds constituting Putnam
Variable Trust, referred to hereafter as the Fund) as of and for the year
ended December 31, 2021, in accordance with the standards of the Public
Company Accounting Oversight Board (United States) (PCAOB), we considered
the Funds internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the financial
statements and to comply with the requirements of Form NCEN, but not for
the purpose of expressing an opinion on the effectiveness of the Funds
internal control over financial reporting. Accordingly, we do not
express an opinion on the effectiveness of the Funds internal control
over financial reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting. In
fulfilling this responsibility, estimates and judgments by management are
required to assess the expected benefits and related costs of controls.
A companys internal control over financial reporting is a process
designed to provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for
external purposes in accordance with generally accepted accounting
principles. A companys internal control over financial reporting
includes those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in accordance
with generally accepted accounting principles, and that receipts and
expenditures of the company are being made only in accordance with
authorizations of management and directors of the company; and (3)
provide reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys assets that
could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in conditions, or
that the degree of compliance with the policies or procedures may
deteriorate.
A deficiency in internal control over financial reporting exists when the
design or operation of a control does not allow management or employees,
in the normal course of performing their assigned functions, to prevent
or detect misstatements on a timely basis. A material weakness is a
deficiency, or a combination of deficiencies, in internal control over
financial reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim financial
statements will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over financial reporting
was for the limited purpose described in the first paragraph and would
not necessarily disclose all deficiencies in internal control over
financial reporting that might be material weaknesses under standards
established by the PCAOB. However, we noted no deficiencies in the Funds
internal control over financial reporting and its operation, including
controls over safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of the Board
of Trustees of Putnam Variable Trust and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone
other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 10, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
13
g.1.a.iii2dp.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Emerging Markets Equity Fund:
In planning and performing our audit of the financial statements
of Putnam VT Emerging Markets Equity Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund ) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 9, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
14
G.1.a.iii2io.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Multi-Cap Core Fund:
In planning and performing our audit of the financial statements
of Putnam VT Multi-Cap Core Fund (one of the funds constituting
Putnam Variable Trust, referred to hereafter as the Fund) as of
and for the year ended December 31, 2021, in accordance with the
standards of the Public Company Accounting Oversight Board
(United States) (PCAOB), we considered the Funds internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
N-CEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 9, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
15
G.1.a.iii2is.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT George Putnam Balanced Fund
In planning and performing our audit of the financial statements
of Putnam VT George Putnam Balanced Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form NCEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 9, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston,
MA 02210
T (617)530 5000, F (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
16
G.1.a.iii2iw.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Global Health Care Fund:
In planning and performing our audit of the financial statements
of Putnam VT Global Health Care Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 10, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
17
g.1.a.iii2la.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Research Fund:
In planning and performing our audit of the financial statements
of Putnam VT Research Fund (one of the funds constituting Putnam
Variable Trust, referred to hereafter as the Fund ) as of and
for the year ended December 31, 2021, in accordance with the
standards of the Public Company Accounting Oversight Board
(United States) (PCAOB), we considered the Funds internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
N-CEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
18
g.1.a.iii2mj.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Small Cap Value Fund:
In planning and performing our audit of the financial statements
of Putnam VT Small Cap Value Fund (one of the funds constituting
Putnam Variable Trust, referred to hereafter as the Fund ) as
of and for the year ended December 31, 2021, in accordance with
the standards of the Public Company Accounting Oversight Board
(United States) (PCAOB), we considered the Funds internal
control over financial reporting, including controls over
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
N-CEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 11, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
19
G.1.a.iii2pu.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and Shareholders
of Putnam VT Growth Opportunities Fund:
In planning and performing our audit of the financial statements
of Putnam VT Growth Opportunities Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls over
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
NCEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect
the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles, and that
receipts and expenditures of the company are being made only in
accordance with authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding prevention
or timely detection of unauthorized acquisition, use or
disposition of a companys assets that could have a material effect
on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing their
assigned functions, to prevent or detect misstatements on a timely
basis. A material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such
that there is a reasonable possibility that a material
misstatement of the companys annual or interim financial
statements will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However, we
noted no deficiencies in the Funds internal control over financial
reporting and its operation, including controls over safeguarding
securities, that we consider to be material weaknesses as defined
above as of December 31, 2021.
?
This report is intended solely for the information and use of the
Board of Trustees of Putnam Variable Trust and the Securities and
Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
20
G.1.aiii2px.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and Shareholders of
Putnam VT Mortgage Securities Fund:
In planning and performing our audit of the financial statements of
Putnam VT Mortgage Securities Fund (one of the funds constituting Putnam
Variable Trust, referred to hereafter as the Fund) as of and for the year
ended December 31, 2021, in accordance with the standards of the Public
Company Accounting Oversight Board (United States) (PCAOB), we considered
the Funds internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the financial
statements and to comply with the requirements of Form NCEN, but not for
the purpose of expressing an opinion on the effectiveness of the Funds
internal control over financial reporting. Accordingly, we do not
express an opinion on the effectiveness of the Funds internal control
over financial reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting. In
fulfilling this responsibility, estimates and judgments by management are
required to assess the expected benefits and related costs of controls.
A companys internal control over financial reporting is a process
designed to provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for
external purposes in accordance with generally accepted accounting
principles. A companys internal control over financial reporting
includes those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in accordance
with generally accepted accounting principles, and that receipts and
expenditures of the company are being made only in accordance with
authorizations of management and directors of the company; and (3)
provide reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys assets that
could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in conditions, or
that the degree of compliance with the policies or procedures may
deteriorate.
A deficiency in internal control over financial reporting exists when the
design or operation of a control does not allow management or employees,
in the normal course of performing their assigned functions, to prevent
or detect misstatements on a timely basis. A material weakness is a
deficiency, or a combination of deficiencies, in internal control over
financial reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim financial
statements will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over financial reporting
was for the limited purpose described in the first paragraph and would
not necessarily disclose all deficiencies in internal control over
financial reporting that might be material weaknesses under standards
established by the PCAOB. However, we noted no deficiencies in the Funds
internal control over financial reporting and its operation, including
controls over safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of the Board
of Trustees of Putnam Variable Trust and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone
other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 8, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
21
G.1.a.iii961.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT Diversified Income Fund:
In planning and performing our audit of the financial statements
of Putnam VT Diversified Income Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
?
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 11, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T: (617)530 5000, F: (617) 530 5001, www.pwc.com/us
INTERNAL CONTROL RPT
22
G.1.a.iiilc3.txt
INFORMATION ABOUT THE REGISTRANT
Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Putnam Variable Trust and
Shareholders of Putnam VT MultiAsset Absolute Return Fund
In planning and performing our audit of the financial statements
of Putnam VT MultiAsset Absolute Return Fund (one of the funds
constituting Putnam Variable Trust, referred to hereafter as the
Fund) as of and for the year ended December 31, 2021, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the Funds
internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our opinion on
the financial statements and to comply with the requirements of
Form NCEN, but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Funds internal control over financial
reporting.
The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls. A companys internal control over
financial reporting is a process designed to provide reasonable
assurance regarding the reliability of financial reporting and
the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles. A
companys internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the
assets of the company (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of
management and directors of the company and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys
assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow
management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on
a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the companys annual or interim
financial statements will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control over financial reporting that might be material
weaknesses under standards established by the PCAOB. However,
we noted no deficiencies in the Funds internal control over
financial reporting and its operation, including controls over
safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2021.
This report is intended solely for the information and use of
the Board of Trustees of Putnam Variable Trust and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
PricewaterhouseCoopers LLP
Boston, Massachusetts
February 11, 2022
1 of 1
1 of 1
PricewaterhouseCoopers LLP, 101 Seaport Boulevard, Suite 500, Boston, MA 02210
T (617)530 5000, F (617) 530 5001, www.pwc.com/us