0000928816-16-002956.txt : 20160804 0000928816-16-002956.hdr.sgml : 20160804 20160630130153 ACCESSION NUMBER: 0000928816-16-002956 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20160630 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MONEY MARKET FUND CENTRAL INDEX KEY: 0000081248 IRS NUMBER: 046386436 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A-14 LEGAL DEPARTMENT CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921471 MAIL ADDRESS: STREET 1: MAILSTOP A-14 LEGAL DEPARTMENT STREET 2: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM DAILY DIVIDEND TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL EQUITY FUND CENTRAL INDEX KEY: 0000081251 IRS NUMBER: 046145734 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GLOBAL GROWTH FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL EQUITIES FUND DATE OF NAME CHANGE: 19900722 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL EQUITIES FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INCOME FUND CENTRAL INDEX KEY: 0000081264 STANDARD INDUSTRIAL CLASSIFICATION: OIL ROYALTY TRADERS [6792] IRS NUMBER: 046013712 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921471 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INCOME FUND INC/PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM VOYAGER FUND CENTRAL INDEX KEY: 0000081280 IRS NUMBER: 046187125 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM VOYAGER FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM EQUITY INCOME FUND/NEW/ CENTRAL INDEX KEY: 0000216934 IRS NUMBER: 046407893 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002551581 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM STRATEGIC INCOME TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OPTION INCOME TRUST DATE OF NAME CHANGE: 19910307 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM VARIABLE TRUST CENTRAL INDEX KEY: 0000822671 IRS NUMBER: 046649095 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002551581 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CAPITAL MANAGER TRUST /MA/ DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL UTILITIES FUND CENTRAL INDEX KEY: 0000867824 IRS NUMBER: 046660195 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM UTILITIES GROWTH & INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM ASSET ALLOCATION FUNDS CENTRAL INDEX KEY: 0000914209 IRS NUMBER: 046746612 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM LIFE STAGES ASSET ALLOCATION TRUST DATE OF NAME CHANGE: 19931027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM CALIFORNIA TAX EXEMPT INCOME TRUST CENTRAL INDEX KEY: 0000711402 IRS NUMBER: 042786284 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CALIFORNIA TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM NEW YORK TAX EXEMPT INCOME TRUST CENTRAL INDEX KEY: 0000719712 IRS NUMBER: 042794490 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW YORK TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH YIELD ADVANTAGE FUND CENTRAL INDEX KEY: 0000787836 IRS NUMBER: 066290063 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: NULL FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH YIELD TRUST II DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND/MA CENTRAL INDEX KEY: 0000794612 IRS NUMBER: 046626128 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL INCOME TRUST CENTRAL INDEX KEY: 0000794614 IRS NUMBER: 046549525 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GOVERNMENT INCOME GLOBAL TRUST DATE OF NAME CHANGE: 19870225 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GLOBAL GOVERNMENT INCOME TRUST DATE OF NAME CHANGE: 19870115 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MANAGED MUNICIPAL INCOME TRUST CENTRAL INDEX KEY: 0000844790 IRS NUMBER: 046608976 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM NEW JERSEY TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000857463 IRS NUMBER: 043073948 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INTERNATIONAL EQUITY FUND /MA/ CENTRAL INDEX KEY: 0000868648 IRS NUMBER: 046661045 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921471 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL GROWTH FUND /MA/ DATE OF NAME CHANGE: 19960805 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OVERSEAS GROWTH FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL GROWTH FUND DATE OF NAME CHANGE: 19901107 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INVESTMENT FUNDS CENTRAL INDEX KEY: 0000932101 IRS NUMBER: 043251560 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE STREET 2: MAIL STOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: PUTNAM EQUITY FUNDS STREET 2: ONE POST OFFICE SQUARE MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EQUITY FUNDS DATE OF NAME CHANGE: 19941028 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM FUNDS TRUST CENTRAL INDEX KEY: 0001005942 IRS NUMBER: 043299786 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST STREET 2: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921010 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Putnam Mortgage Recovery Fund CENTRAL INDEX KEY: 0001537610 IRS NUMBER: 453837328 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 18002251581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INVESTORS FUND CENTRAL INDEX KEY: 0000081269 IRS NUMBER: 042713095 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INVESTORS FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FORMER COMPANY: FORMER CONFORMED NAME: INCORPORATED INVESTORS DATE OF NAME CHANGE: 19670327 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000205802 IRS NUMBER: 046396109 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL NATURAL RESOURCES FUND CENTRAL INDEX KEY: 0000317031 IRS NUMBER: 133035507 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NATURAL RESOURCES FUND /MA/ DATE OF NAME CHANGE: 19950629 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM ENERGY RESOURCES TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: EBERSTADT ENERGY RESOURCES FUND INC DATE OF NAME CHANGE: 19850317 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MICHIGAN TAX EXEMPT INCOME FUND / CENTRAL INDEX KEY: 0000794611 IRS NUMBER: 046626130 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 617-292-14 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MICHIGAN TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Putnam RetirementReady Funds CENTRAL INDEX KEY: 0001295293 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 617 760-4623 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM GLOBAL HEALTH CARE FUND CENTRAL INDEX KEY: 0000357295 IRS NUMBER: 046471950 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HEALTH SCIENCES TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM AMERICAN GOVERNMENT INCOME FUND CENTRAL INDEX KEY: 0000759827 IRS NUMBER: 042856297 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: PUTNAM INVESTMENTS INC STREET 2: ONE POST OFFICE SQUARE MAIL STOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH INCOME GOVERNMENT TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM PENNSYLVANIA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000794615 IRS NUMBER: 043057637 STATE OF INCORPORATION: MA FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQU CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM PREMIER INCOME TRUST CENTRAL INDEX KEY: 0000827773 IRS NUMBER: 042995046 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM DIVERSIFIED INCOME TRUST CENTRAL INDEX KEY: 0000836622 IRS NUMBER: 043017475 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND/MA CENTRAL INDEX KEY: 0000794616 IRS NUMBER: 046626129 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 617-292-1000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 021009 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM ARIZONA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000869392 IRS NUMBER: 046665534 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: PUTNAM INVESTMENTS INC STREET 2: ONE POST OFFICE SQUARE MAIL STOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251585 MAIL ADDRESS: STREET 1: 2 LIBERTY SQUARE STREET 2: MAIL STOP L6 CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM FUND FOR GROWTH & INCOME CENTRAL INDEX KEY: 0000081260 IRS NUMBER: 046013678 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAIKLSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GROWTH FUND DATE OF NAME CHANGE: 19841025 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM U S GOVERNMENT INCOME TRUST CENTRAL INDEX KEY: 0000732337 IRS NUMBER: 042811119 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM U S GOVERNMENT GUARANTEED SECURITIES INCOME TRUST DATE OF NAME CHANGE: 19910102 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM UNITED STATES GOVERNMENT SECURITIES INCOME FUND DATE OF NAME CHANGE: 19840806 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM TAX FREE INCOME TRUST /MA/ CENTRAL INDEX KEY: 0000771951 IRS NUMBER: 046483374 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: NULL FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM TAX FREE INCOME TRUST DATE OF NAME CHANGE: 19920101 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MASTER INTERMEDIATE INCOME TRUST CENTRAL INDEX KEY: 0000830622 IRS NUMBER: 046584465 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MUNICIPAL OPPORTUNITIES TRUST CENTRAL INDEX KEY: 0000900422 IRS NUMBER: 043187549 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM CONVERTIBLE SECURITIES FUND CENTRAL INDEX KEY: 0000081247 IRS NUMBER: 042493360 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CONVERTIBLE INCOME GROWTH TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CONVERTIBLE FUND DATE OF NAME CHANGE: 19841212 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CONVERTIBLE FUND INC /PRED/ DATE OF NAME CHANGE: 19821109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM EUROPE EQUITY FUND CENTRAL INDEX KEY: 0000842940 IRS NUMBER: 043083315 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002551581 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EUROPE GROWTH FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EUROPE FUND DATE OF NAME CHANGE: 19900726 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GOVERNMENT INCOME FUND DATE OF NAME CHANGE: 19900412 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MULTI-CAP GROWTH FUND CENTRAL INDEX KEY: 0000865177 IRS NUMBER: 043091455 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW OPPORTUNITIES FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH YIELD TRUST CENTRAL INDEX KEY: 0000225777 IRS NUMBER: 046415410 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A-14 LEGAL DEPARTMENT CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE STREET 2: MAILSTOP A-14 LEGAL DEPARTMENT CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH YIELD TRUST FUND DATE OF NAME CHANGE: 19960328 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH INCOME SECURITIES FUND CENTRAL INDEX KEY: 0000810943 IRS NUMBER: 046562068 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ STREET 2: MAILSTOP A 14 CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002251581 MAIL ADDRESS: STREET 1: PUTNAM LLC STREET 2: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH INCOME BOND FUND DATE OF NAME CHANGE: 20030408 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH BOND FUND DATE OF NAME CHANGE: 20021107 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH INCOME CONVERTIBLE & BOND FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GEORGE PUTNAM BALANCED FUND CENTRAL INDEX KEY: 0000081259 IRS NUMBER: 046013677 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 8002252581 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: GEORGE PUTNAM FUND OF BOSTON DATE OF NAME CHANGE: 19940302 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EQUITY INCOME FUND/NEW DATE OF NAME CHANGE: 19940302 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GEORGE FUND OF BOSTON DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND/MA/ CENTRAL INDEX KEY: 0000792288 IRS NUMBER: 046626127 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: ONE POST OFFICE SQUARE CITY: BOSTON STATE: MA ZIP: 02109 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND /MA/ DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM TAX EXEMPT MONEY MARKET FUND CENTRAL INDEX KEY: 0000806944 IRS NUMBER: 046561110 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE POST OFFICE SQ CITY: BOSTON STATE: MA ZIP: 02109 BUSINESS PHONE: 6172921000 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM TAX EXEMPT MONEY MARKET TRUST DATE OF NAME CHANGE: 19870927 CORRESP 1 filename1.htm



June 30, 2016

By EDGAR

 

U.S. Securities and Exchange Commission

Division of Investment Management

450 Fifth Street, N.W.

Washington, DC 20549

Attention: Jeff Long

 

Re: Annual Reports for the Putnam Funds (the “Funds”)

 

Dear Mr. Long:

This letter responds to the comments that you provided telephonically to me and my colleagues Janet Smith, Venice Monagan and Caitlin Robinson on behalf of the Staff of the U.S. Securities and Exchange Commission (the “Commission Staff”) on June 2, 2016 regarding the Funds’ annual reports to shareholders.

 

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

 

1.Comment: Ticker symbols are missing for a number of the Funds. Please review each fund’s ticker symbols within the EDGAR system and ensure that they are complete.

 

 

Response: Putnam Management has reviewed each fund’s ticker symbols within the EDGAR system and has updated the ticker symbols as necessary.

 

 

2.Comment: Since the N-8F filings for Putnam OTC & Emerging Growth Fund and Putnam Limited Duration Fund have been completed, these funds need to be marked as ‘inactive”.

 

Response: Putnam Management has marked Putnam OTC & Emerging Growth Fund and Putnam Limited Duration Fund as “inactive” in the EDGAR system.

 

 

3.Comment: In reviewing the schedule of investments on the funds, it was noted that the interest rates for each of the securities has an “s” after them. Please explain what that represents and consider adding a tickmark to define.

 

Response: The “s” that is shown after a bond description’s interest rate is another way of stating the percentage. For example, a bond with “7s” would mean that it has an interest rate of 7%. Understanding that this may not be clear to a reader of the shareholder report, we will be replacing the “s” with “%” beginning with reports for funds with fiscal periods ending August 2016.

 

 

4.Comment: For certain funds that disclosed Level 3 securities, there was not a sensitivity analysis presented. Please explain why this is the case. If there is a materiality threshold, include the threshold in the response.

 

Response: Disclosure of the sensitivity analysis is completed for securities that are fair valued by Putnam Management, not for all Level 3 securities. In accordance with 820-10-50-2(bbb) we do not provide a sensitivity analysis for Level 3 securities where Putnam has not developed the inputs. In particular, securities that are priced by a single broker are classified as Level 3 securities. Because fair value was not determined using inputs developed by Putnam Management, a sensitivity analysis is not required under 820-10-50-2. To help clarify this for the reader, we will include a definitive statement noting that securities valued by a broker are not included in the sensitivity analysis disclosure. Level 3 rollforwards, as well as the sensitivity analysis, are included in funds whose value of Level 3 securities are greater than 1 % of a funds’ net asset value.

 

5.Comment: Within the schedule of investments, certain funds only are disclosing the year of the maturity while other funds are disclosing the specific month and year. We would suggest being consistent across the fund complex.

 

Response: We will create a consistent approach across our fund complex and disclose the maturity date using the specific month and year beginning with reports for funds with fiscal periods ending August 2016.

 

6.Comment: Certain funds (i.e., municipal bond funds) contain Putnam ratings for securities. Please explain why these are used and consider explaining how the Putnam ratings correspond with Moody’s and S&P ratings.

 

Response: The municipal bond holdings in the shareholder reports are assigned a rating from one of three rating agencies; Moody’s, S&P and Fitch. If a rating is not available from one of the three agencies, then the security will be rated by Putnam and assigned a “Putnam” rating. The Putnam rating schema is similar to that of the S&P rating system. We will include an additional statement in the footnotes to our municipal bond funds’ schedule of investments clarifying that the Putnam rating system schema is similar to that of the S&P rating system.

 

 

7.Comment: For Putnam International Value Fund and Putnam Global Utilities Fund, the “other expense” line item in the Statement of operations was greater than 5% of net assets. Please ensure that there are not any individual expense items within this line item that are greater than 5%. If there are, they would need to be disclosed separately within the Statement of operations.

 

Response: For Putnam International Value Fund and Putnam Global Utilities Fund, there are not any individual expenses within “Other expenses” on each funds respective statement of operations that is greater than 5% of net assets.

 

8.Comment: Putnam Floating Rate Income Fund had a return of capital during the period. Please confirm that the fund has complied with Rule 19a-1

 

Response: We confirm that the Putnam Floating Rate Income Fund complied with the shareholder notice requirements of Rule 19a-1 under the Investment Company Act of 1940, as amended.

 

 

9.Comment: Please confirm that the expense ratio is gross of brokerage credit and expense offset. The footnote seems to state that they are excluded from the expense ratio. Consider clarifying footnote disclosure.

 

Response: We confirm that the expense ratio presented in each fund’s financial highlights is gross of the brokerage credit and expense offset. Each fund's expense ratio is footnoted to indicate that it includes amounts paid through expense offset and/or brokerage/service arrangements. We believe this footnote states clearly that the expense ratios presented in the shareholder report are gross of the brokerage credit and expense offset amounts.

 

10.Comment: With respect to the fee waivers described in the financial statement footnotes, please confirm in the response if there are any recoupment provisions within these agreements.

 

Response: We confirm that there are not any recoupment provisions as part of any of the fee waivers.

 

11.Comment: Since the funds’ management fee is paid through a tiered structure, consider providing the effective management fee rate that a fund incurred during the period within the notes to the financial statements, similar to the presentation that is made in a funds’ prospectus.

 

Response: We agree that including the effective management fee for the period would be helpful to a reader of the financial statements and will begin including this in Note 2 of a fund’s financial statement footnotes.

.

12.Comment: Please explain why the Putnam Cash Collateral Pool, LLC is not included within the Affiliated Transaction footnote. Consider including it in that note.

Response: The Putnam Cash Collateral Pool, LLC is a limited liability company that is utilized as the investment vehicle for cash collateral received as part of the securities lending program for each of the funds. Due to its purpose, the information regarding this fund, including its affiliation with Putnam Management as well as its current market value has been disclosed in Note 1, within the Securities Lending footnote. We agree, though, that including it with other affiliated activity in the Affiliated Transactions footnote would be a better location for this disclosure. All of the Putnam funds that invest in Putnam Cash Collateral Pool, LLC will disclose this fund, along with the appropriate affiliated transaction information, which includes purchase cost and sales proceeds during the period, in the Affiliated Transaction footnote beginning with reports for funds with fiscal periods ending September 2016.

 

13.Comment: Confirm that the relevant disclosure is included in the financial statement notes for any 17a-7 transactions.

 

Response: Beginning with the reports for the funds with fiscal periods ending December 2015, disclosure regarding 17a-7 related transactions (below) has been included in each of the funds footnotes if these transactions represent less than 5% of each fund’s cost of purchases and/or proceeds from sales. If these transactions are greater than 5%, then disclosure of the total cost of purchases and proceeds from sales will be included in the footnote.

 

“The fund may purchase or sell investments from or to other Putnam funds in the ordinary course of business, which can reduce the fund’s transaction costs, at prices determined in accordance with SEC requirements and policies approved by the Trustees. During the reporting period, purchases or sales from or to other Putnam funds, if any, did not represent more than 5% of the fund’s total cost of purchases and/or total proceeds from sales.”

 

 

14.Comment: For Putnam Investors Fund, the auditor consent was not included in the fund’s July 31, 2015 NSAR-B filing. Please make an amended filing including this consent.

 

Response: On June 2, 2016, Putnam Investor Fund’s July 31, 2015 NSAR-B filing was refiled with the auditor consent.

 

15.Comment: Currently only the fact that a waiver was in effect and the date that the waiver will expire is included within a funds’ prospectus. Consider stating the actual expense limit in basis points in the relevant fee table footnotes

 

Response: Thank you for your comment. Instruction 3.e. to Item 3 of Form N-1A requires that if a fund reflects an expense reimbursement or fee waiver arrangement in its fee table, the fund must disclose the period for which the expense reimbursement or fee waiver arrangement is expected to continue, including the expected termination date, and briefly describe who can terminate the arrangement and under what circumstances. Putnam Management believes that the disclosure in the footnotes to the fee table satisfies the requirements of Instruction 3.e to Item 3, and is not misleading to shareholders. Additionally, the Statement of Additional Information provides further detail about all expense limitation and fee waiver arrangements of the funds.

 

16.Comment: Putnam Global Health Care Fund and Putnam VT Global Health Care Fund each appears to have approximately 80% of its assets in U.S. securities. How do these funds comply with the prospectus disclosure that states the fund will invest at least 40% (or at least 10% less than the benchmark’s foreign holdings) in non-U.S. securities?

 

Response: The prospectuses for Putnam Global Health Care Fund and Putnam VT Global Health Care Fund state that each fund will normally invest "at least 40% of its net assets in securities of foreign companies (or, if less, at least the percentage of net assets that is 10% less than the percentage of the fund's benchmark represented by foreign companies, as determined by the providers of the benchmark)." The prospectus also describes the methodology Putnam uses to determine whether a company is "foreign" for purposes of this test. We note that a company might be considered "foreign" by Putnam for purposes of this compliance test, but be considered a U.S. company for financial statements purposes. We confirm that each fund's investments are in compliance with the test set forth in its prospectus.

 

 

17.Comment: Putnam Small Cap Growth Fund invests 32% of its assets in the health care sector. Should the fund have a policy on concentration and/or should the prospectus include additional risk disclosure as a result?

 

Response: The prospectus for Putnam Small Cap Growth Fund includes the following disclosure: “From time to time, the fund may invest a significant portion of its assets in companies in one or more related industries or sectors which would make the fund more vulnerable to adverse developments affecting those industries or sectors.” The fund does not have a specific investment strategy to invest in companies in the health care sector; however, the health care sector is currently the top sector in the fund’s benchmark, the Russell 2000 Growth Index. The fund currently has a higher allocation of investments in the health care sector than in other sectors as a reflection of a similar allocation in the fund’s benchmark. We note that in recent years, the fund’s level of investment in the health care sector has been significantly lower than its current level. We therefore believe that the current prospectus disclosure regarding periodic industry or sector concentration is adequate and a policy on concentration or additional risk disclosure is not necessary.

 

 

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

 

Very truly yours,

/s/Kevin Blatchford

Kevin Blatchford

Director of Financial Reporting

 

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

 

 

 
 

Appendix A

 

 

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

 

 

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

 

 

Very truly yours,

 

/s/ James Clark

 

James Clark

Vice President and Chief Compliance Officer

The Putnam Funds

 

June 30, 2016