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. 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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