0000928816-23-001112.txt : 20231208 0000928816-23-001112.hdr.sgml : 20231208 20230731165459 ACCESSION NUMBER: 0000928816-23-001112 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20230731 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM LIFE STAGES ASSET ALLOCATION TRUST DATE OF NAME CHANGE: 19931027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Putnam ETF Trust CENTRAL INDEX KEY: 0001845809 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02111 BUSINESS PHONE: 6177601060 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02111 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM FOCUSED INTERNATIONAL 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM GLOBAL EQUITY FUND DATE OF NAME CHANGE: 20030707 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 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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 INCOME FUND CENTRAL INDEX KEY: 0000081264 IRS NUMBER: 046013712 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INCOME FUND INC/PRED/ DATE OF NAME CHANGE: 19821109 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM LARGE CAP VALUE FUND CENTRAL INDEX KEY: 0000216934 IRS NUMBER: 046407893 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EQUITY INCOME FUND DATE OF NAME CHANGE: 20190212 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM EQUITY INCOME FUND/NEW/ DATE OF NAME CHANGE: 19940302 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM STRATEGIC INCOME TRUST DATE OF NAME CHANGE: 19920703 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HEALTH SCIENCES TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM CALIFORNIA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000711402 IRS NUMBER: 042786284 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921562 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CALIFORNIA TAX EXEMPT INCOME TRUST DATE OF NAME CHANGE: 19941214 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 FUND CENTRAL INDEX KEY: 0000719712 IRS NUMBER: 042794490 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW YORK TAX EXEMPT INCOME TRUST DATE OF NAME CHANGE: 19940603 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW YORK TAX EXEMPT INCOME FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MORTGAGE SECURITIES FUND CENTRAL INDEX KEY: 0000732337 IRS NUMBER: 042811119 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM U S GOVERNMENT INCOME TRUST DATE OF NAME CHANGE: 19920703 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 CENTRAL INDEX KEY: 0000771951 IRS NUMBER: 046483374 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM TAX FREE INCOME TRUST /MA/ DATE OF NAME CHANGE: 19920902 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM TAX FREE INCOME TRUST DATE OF NAME CHANGE: 19920101 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM HIGH YIELD 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH YIELD ADVANTAGE FUND DATE OF NAME CHANGE: 19920716 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM HIGH YIELD TRUST II 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND II DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND /MA/ DATE OF NAME CHANGE: 19920609 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000794612 IRS NUMBER: 046626128 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MINNESOTA TAX EXEMPT INCOME FUND/MA DATE OF NAME CHANGE: 20080729 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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 PENNSYLVANIA TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000794615 IRS NUMBER: 043057637 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND CENTRAL INDEX KEY: 0000794616 IRS NUMBER: 046626129 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 617-292-1000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM OHIO TAX EXEMPT INCOME FUND/MA DATE OF NAME CHANGE: 20080729 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 VARIABLE TRUST CENTRAL INDEX KEY: 0000822671 IRS NUMBER: 046649095 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM CAPITAL MANAGER TRUST /MA/ DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM PREMIER INCOME TRUST CENTRAL INDEX KEY: 0000827773 IRS NUMBER: 042995046 STATE OF INCORPORATION: MA FISCAL YEAR END: 1117 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MASTER INTERMEDIATE INCOME TRUST CENTRAL INDEX KEY: 0000830622 IRS NUMBER: 046584465 STATE OF INCORPORATION: MA FISCAL YEAR END: 1117 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM SUSTAINABLE LEADERS 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM MULTI-CAP GROWTH FUND DATE OF NAME CHANGE: 20101004 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM NEW OPPORTUNITIES FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM INTERNATIONAL EQUITY FUND CENTRAL INDEX KEY: 0000868648 IRS NUMBER: 046661045 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM INTERNATIONAL EQUITY FUND /MA/ DATE OF NAME CHANGE: 20030430 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 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PUTNAM MUNICIPAL OPPORTUNITIES TRUST CENTRAL INDEX KEY: 0000900422 IRS NUMBER: 043187549 STATE OF INCORPORATION: MA FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Putnam Target Date Funds CENTRAL INDEX KEY: 0001295293 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: Putnam RetirementReady Funds DATE OF NAME CHANGE: 20040624 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6177601000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 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 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: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 6172921000 MAIL ADDRESS: STREET 1: 100 FEDERAL STREET CITY: BOSTON STATE: MA ZIP: 02110 FORMER COMPANY: FORMER CONFORMED NAME: PUTNAM DAILY DIVIDEND TRUST DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm

Putnam Investments

100 Federal Street

Boston, MA 02110

July 31, 2023

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attn: Asen Parachkevov, Esq. and Alberto Zapata, Esq.

    

 

 

Re:Comments on Preliminary Proxy Statement on Schedule 14A under the Securities Exchange Act of 1934, as amended, filed with the Securities and Exchange Commission (the “Commission”) on July 7, 2023 (the “Preliminary Proxy Statement”), of Putnam Asset Allocation Funds (Investment Company Act File No. 811-07121), on behalf of its Putnam Dynamic Asset Allocation Balanced Fund, Putnam Dynamic Asset Allocation Conservative Fund, Putnam Dynamic Asset Allocation Growth Fund, and Putnam Multi-Asset Income Fund series; Putnam California Tax Exempt Income Fund (Investment Company Act File No. 811-03630); Putnam Convertible Securities Fund (Investment Company Act File No. 811-02280); Putnam Diversified Income Trust (Investment Company Act File No. 811-05635); Putnam ETF Trust (Investment Company Act File No. 811-23643), on behalf of its Putnam BDC Income ETF, Putnam BioRevolutionTM ETF, Putnam Emerging Markets ex-China ETF, Putnam ESG Core Bond ETF, Putnam ESG High Yield ETF, Putnam ESG Ultra Short ETF, Putnam Focused Large Cap Growth ETF, Putnam Focused Large Cap Value ETF, Putnam PanAgora ESG Emerging Markets Equity ETF, Putnam PanAgora ESG International Equity ETF, Putnam Sustainable Future ETF, and Putnam Sustainable Leaders ETF series; Putnam Focused International Equity Fund (Investment Company Act File No. 811-01403); Putnam Funds Trust (Investment Company Act File No. 811-07513), on behalf of its Putnam Core Bond Fund, Putnam Core Equity Fund, Putnam Dynamic Asset Allocation Equity Fund, Putnam Emerging Markets Equity Fund, Putnam Floating Rate Income Fund, Putnam Focused Equity Fund, Putnam Global Technology Fund, Putnam Intermediate-Term Municipal Income Fund, Putnam International Value Fund, Putnam Mortgage Opportunities Fund, Putnam Short Duration Bond Fund, Putnam Short Term Investment Fund, Putnam Short-Term Municipal Income Fund, Putnam Small Cap Growth Fund, Putnam Ultra Short Duration Income Fund, and Putnam Ultra Short MAC Series series; George Putnam Balanced Fund (Investment Company Act File No. 811-00058); Putnam Global Health Care Fund (Investment Company Act File No. 811-03386); Putnam Global Income Trust (Investment Company Act File No. 811-04524); Putnam High Yield Fund (Investment Company Act File No. 811-04616); Putnam Income Fund (Investment Company Act File No. 811-00653); Putnam International Equity Fund (Investment Company Act File No. 811-06190); Putnam Investment Funds (Investment Company Act File No. 811-07237), on behalf of its Putnam Government Money Market Fund, Putnam International Capital Opportunities Fund, Putnam Large Cap Growth Fund, Putnam Research Fund, Putnam Small Cap Value Fund, and Putnam Sustainable Future Fund series; Putnam Large Cap Value Fund (Investment Company Act File No. 811-02742); Putnam Massachusetts Tax Exempt Income Fund (Investment Company Act File No. 811-04518); Putnam Minnesota Tax Exempt Income
 
 

Fund (Investment Company Act File No. 811-04527); Putnam Money Market Fund (Investment Company Act File No. 811-02608); Putnam Mortgage Securities Fund (Investment Company Act File No. 811-03897); Putnam New Jersey Tax Exempt Income Fund (Investment Company Act File No. 811-05977); Putnam New York Tax Exempt Income Fund (Investment Company Act File No. 811-03741); Putnam Ohio Tax Exempt Income Fund (Investment Company Act File No. 811-04528); Putnam Pennsylvania Tax Exempt Income Fund (Investment Company Act File No. 811-05802); Putnam Sustainable Leaders Fund (Investment Company Act File No. 811-06128); Putnam Target Date Funds (Investment Company Act File No. 811-21598), on behalf of its Putnam Retirement Advantage 2025 Fund, Putnam Retirement Advantage 2030 Fund, Putnam Retirement Advantage 2035 Fund, Putnam Retirement Advantage 2040 Fund, Putnam Retirement Advantage 2045 Fund, Putnam Retirement Advantage 2050 Fund, Putnam Retirement Advantage 2055 Fund, Putnam Retirement Advantage 2060 Fund, Putnam Retirement Advantage 2065 Fund series, and Putnam Retirement Advantage Maturity Fund, Putnam Sustainable Retirement 2025 Fund, Putnam Sustainable Retirement 2030 Fund, Putnam Sustainable Retirement 2035 Fund, Putnam Sustainable Retirement 2040 Fund, Putnam Sustainable Retirement 2045 Fund, Putnam Sustainable Retirement 2050 Fund, Putnam Sustainable Retirement 2055 Fund, Putnam Sustainable Retirement 2060 Fund, Putnam Sustainable Retirement 2065 Fund series, and Putnam Sustainable Retirement Maturity Fund series; Putnam Tax Exempt Income Fund (Investment Company Act File No. 811-02675); Putnam Tax-Free Income Trust (Investment Company Act File No. 811-04345), on behalf of its Putnam Strategic Intermediate Municipal Fund and Putnam Tax-Free High Yield Fund series; and Putnam Variable Trust (Investment Company Act File No. 811-05346), on behalf of its Putnam VT Core Equity Fund, Putnam VT Diversified Income Fund, Putnam VT Emerging Markets Equity Fund, Putnam VT Focused International Equity Fund, Putnam VT George Putnam Balanced Fund, Putnam VT Global Asset Allocation Fund, Putnam VT Global Health Care Fund, Putnam VT Government Money Market Fund, Putnam VT High Yield Fund, Putnam VT Income Fund, Putnam VT International Equity Fund, Putnam VT International Value Fund, Putnam VT Large Cap Growth Fund, Putnam VT Large Cap Value Fund, Putnam VT Mortgage Securities Fund, Putnam VT Research Fund, Putnam VT Small Cap Growth Fund, Putnam VT Small Cap Value Fund, Putnam VT Sustainable Future Fund, and Putnam VT Sustainable Leaders Fund series; Putnam Managed Municipal Income Trust (Investment Company Act File No. 811-05740); Putnam Municipal Opportunities Trust (Investment Company Act File No. 811-07626); Putnam Master Intermediate Income Trust (Investment Company Act File No. 811- 05498); Putnam Premier Income Trust (Investment Company Act File No. 811- 05452) (collectively, the “Registrants” or the “Funds”) regarding the Preliminary Proxy Statement.

 

 

Dear Messrs. Parachkevov and Zapata:

This letter responds to the comments that you provided on July 18, 2023 to Peter T. Fariel, Venice Monagan, and Elissa O’Bryant of Putnam Investment Management, LLC (“Putnam Management”), investment adviser to the Funds, and Timothy F. Cormier and Samuel Herling Moore of Ropes & Gray LLP, counsel to the Funds and their Independent Trustees, on behalf of

-2- 
 

the staff of the Commission (the “Commission Staff”) regarding the Preliminary Proxy Statement. For convenience of reference, I have summarized each of the Commission Staff’s comments before the Registrants’ response. To the extent noted below, these responses will be reflected in the definitive version of the proxy statement on Schedule 14A for the Putnam Closed-End Funds expected to be filed with the Commission on or about July 31, 2023 and the definitive version of the proxy statement on Schedule 14A for the Putnam Open-End Funds and ETFs expected to be filed with the Commission on or about August 3, 2023 (each, a “Definitive Proxy Statement”), as applicable. References to page numbers or specific text in the Commission Staff’s comments and the Registrants’ responses are to the corresponding page numbers and text of the Preliminary Proxy Statement, as indicated. Each capitalized term used and not otherwise defined herein shall have the meaning ascribed to it in the Preliminary Proxy Statement.

1.    Comment: Please consider preparing a separate proxy statement for (i) the Putnam Closed-End Funds (which excludes information specific to the Putnam Open-End Fund and ETFs) and (ii) the Putnam Open-End Funds and ETFs (which excludes information specific to the Putnam Closed-End Funds), in light of the fact that the special meetings of shareholders for the Putnam Closed-End Funds will be held on a different date than the special meetings of shareholders for the Putnam Open-End Funds and ETFs and the fact that the proposals for two of the Putnam Closed-End Funds are expected to be contested.

Response: As communicated to the Commission Staff, the Registrants will use a separate Definitive Proxy Statement for (i) the Putnam Closed-End Funds (which excludes information specific to the Putnam Open-End Funds and ETFs) and (ii) the Putnam Open-End Funds and ETFs (which excludes information specific to the Putnam Closed-End Funds), as requested by the Commission Staff.

2.    Comment: Please provide information in the Definitive Proxy Statement regarding the order in which proposals will be voted on during the shareholder meetings.

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Response: The Registrants expect the vast majority of votes on the proposals listed in the Definitive Proxy Statements will be provided in advance of the special shareholder meetings by proxy. In the event that shareholders attend a special shareholder meeting in person, instructions for voting at the meeting, including the process by which proposals will be presented, will be provided to them. To clarify this, the Registrants will add the following sentence to each Definitive Proxy Statement as a new subsection under “Further Information About Voting and the Special Meeting” titled “Voting in Person”: “Instructions on how to vote and the process for voting will be provided at the special shareholder meetings to any shareholders who choose to attend the special shareholder meetings to vote in person.”

3.Comment: Please supplementally explain why shareholder approval may not be required for the PIL and PAC sub-advisory contracts. See, e.g., p. 24 (“Consistent with current law and interpretations of the Securities and Exchange Commission and its staff, it may not be necessary for shareholders to approve the New PIL Sub-Advisory Contract”) and p. 28 (“Consistent with current law and interpretations of the Securities and Exchange Commission and its staff, it may not be necessary for shareholders to approve the New PAC Sub-Advisory Contract.”).

Response: The statements that shareholder approval may not be required for the New PIL Sub-Advisory Contract or the New PAC Sub-Advisory Contract are based primarily on no action relief provided to Wells Fargo Bank by the Commission Staff (the “Wells Fargo NAL”). See Wells Fargo Bank, N.A. SEC No-Action Letter, 1998 SEC No-Act. LEXIS 458 (Mar. 31, 1998). In the Wells Fargo NAL, the Commission Staff noted that it would not recommend enforcement action under Section 15(a) of the Investment Company Act of 1940, as amended, where an investment adviser to a series of mutual funds appointed a wholly-owned subsidiary to act as a sub-adviser to the mutual funds without shareholder approval under certain conditions. In the case of the Transaction, the organizational structure of PIL and PAC following the consummation of the Transaction could be subject to change, so it is unclear whether the conditions of the Wells Fargo NAL would be satisfied. If shareholder approval of the New PIL Sub-Advisory Contract and/or the New PAC Sub-Advisory Contract is not obtained, the applicable Funds may enter into the New PIL Sub-Advisory Contract and the New PAC Sub-Advisory Contract based on the Wells Fargo NAL or other applicable guidance, if they determine that the conditions are satisfied.

4.Comment: Please include on the first page of the Definitive Proxy Statement the approximate date on which the proxy statement and form of proxy will be first sent or given to security holders, as required by Item 1(b) of Schedule 14A.

Response: The Registrants confirm that the requested update will be made in each Definitive Proxy Statement.

5.Comment: Please confirm that all required disclosure elements from Item 1 of Schedule 14A will be included in the Definitive Proxy Statement.

Response: The Registrants so confirm.

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6.Comment: Please supplementally explain the legal basis for shares to be voted in accordance with the Board of Trustees’ recommendations if a shareholder signs and returns a proxy card but does not fill in a vote. See p. 11.

Response: Rule 14a-4(b)(1) under the Securities Exchange Act of 1934, as amended, provides the legal basis for shares to be voted in the discretion of the shareholder’s proxy if the shareholder does not specify a choice between approval or disapproval of (or abstention with respect to) any proposal to be voted upon, so long as the form of proxy indicates how such discretionary votes will be cast in bold-face type. Specifically, the Rule provides that “[a] proxy may confer discretionary authority with respect to matters as to which a choice is not specified by the security holder provided that the form of proxy states in bold-face type how it is intended to vote the shares represented by the proxy in each such case.” The proxy cards that will be delivered to shareholders in connection with each Definitive Proxy Statement will include the following language, in bold-face type: “If you simply sign this proxy card, and do not indicate a vote on a specific proposal, your shares will be automatically voted as the Trustees recommend.” This comports with the requirements of Rule 14a-4(b)(1) and, therefore, shares may be voted in accordance with the Board of Trustees’ recommendations if a shareholder signs and returns a proxy card but does not fill in a vote pursuant the proxies’ discretionary authority.

7.Comment: Please include in the Definitive Proxy Statement the approximate value of the material interest that Robert Reynolds has in the Transaction, per Item 22(c)(6) of Schedule 14A. See p. 13.

Response: The Registrants confirm that the requested update will be made in each Definitive Proxy Statement.

8.Comment: Please include in the Definitive Proxy Statement the date on which the Board of Trustees approved the Interim Management Contracts and the Interim Sub-Advisory Contracts.

Response: The Registrants confirm that the requested update will be made in each Definitive Proxy Statement.

9.Comment: Please consider updating the body of the Definitive Proxy Statement so that a shareholder can ascertain which Funds are covered by sections not applicable to all Funds without having to refer to the cited appendices.

Response: The Registrants confirm that the requested update will be made in each Definitive Proxy Statement.

10.Comment: Please supplementally explain why a “No Third-Party Beneficiaries” provision has been added to the New Management Contracts for the Putnam Open-End Funds and the ETFs, while the same provision was not added to the New Management Contracts for the Putnam Closed-End Funds.

Response: Putnam Management informed the Registrants of its view that it may be preferable to minimize the number of changes to the Putnam Closed-End Funds’ Current

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Management Contracts in order to potentially simplify the shareholder solicitation process for those Funds.

11.Comment: Please consider clarifying in the Definitive Proxy Statement how the arrangements described under the heading “Potential Conflict of Interest Relating to One of the Independent Trustees” could result in a conflict of interest with respect to the proposals. Please also consider including in the Definitive Proxy Statement any measures taken to mitigate this potential conflict of interest. See p. 36.

Response: The Registrants have revised the relevant disclosure as follows (additions marked with underline; deletions marked with strikethrough):

The In light of this potential conflict of interest, Ms. Murphy withdrew from a portion of two meetings of the Independent Trustees met on two occasions, at their regular meetings, on January 27, 2023 and June 23, 2023, in the absence of Ms. Murphy, to provide to facilitate an opportunity for further discussion of the Transaction and related matters without her present.

The Registrants believe that the relevant paragraph’s heading, which refers to a “potential conflict of interest,” and the subsequent revised text, which describes Ms. Murphy’s current connections to Franklin Templeton and its affiliates, provide shareholders with sufficient information to determine whether a conflict of interest exists and, if so, whether it impacts how they will vote on the proposals (understanding that Ms. Murphy is one of ten Independent Trustees and, as noted in the Preliminary Proxy Statement and will be noted in each Definitive Proxy Statement, steps to mitigate any potential conflict of interest were taken by her withdrawing from a portion of two meetings of the Independent Trustees to facilitate an opportunity for further discussion of the Transaction and related matters without her present).

12.Comment: The Commission Staff notes that, because none of the proposals to be considered at the special shareholder meetings are “routine” proposals pursuant to NYSE Rule 452, brokers will not be able to vote on any proposal without instructions. The Commission Staff, therefore, notes that there should not be any “broker non-votes” in connection with the meetings. Please update the disclosure in the Definitive Proxy Statement regarding “broker non-votes” accordingly. See p. 36.

Response: The requested change has been made, as follows (additions marked with underline; deletions marked with strikethrough):

Shares represented by proxies that reflect abstentions and “broker non-votes” (i.e., shares held by brokers or nominees as to which (i) instructions have not been received from the beneficial owners or the persons entitled to vote and (ii) the broker or nominee does not have the discretionary voting power on a particular matter) will be counted as shares that are present and entitled to vote on the proposals matter for purposes of determining the presence of a quorum. Abstentions and broker non-votes have the effect of votes against the proposals. Broker non-votes may result in the proposals not being approved, even though the votes cast in

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favor would have been sufficient to approve the proposal if some or all of the broker non-votes had been withheld. Because broker-dealers (in the absence of specific authorization from their customers) are not expected to have discretionary authority to vote on the proposals any shares owned beneficially by their customers, there are unlikely to be any “broker non-votes” (i.e., shares held by brokers or nominees as to which (i) instructions have not been received from the beneficial owners or the persons entitled to vote and (ii) the broker or nominee does not have discretionary voting power on a particular matter) at the special shareholder meetings. Broker non-votes would otherwise have the same effect as abstentions (that is, they would be treated as being present and entitled to vote on the proposals for purposes of determining the presence of a quorum, and as if they were votes against the proposals).

13.Comment: Please update the following sentence in the Definitive Proxy Statement to reflect that it applies to all proposals: “Abstentions and broker non-votes have the effect of votes against the proposal. Broker non-votes may result in the proposals not being approved, even though the votes cast in favor would have been sufficient to approve the proposal if some or all of the broker non-votes had been withheld.” See p. 36.

Response: The Registrants confirm that the requested update will be made in each Definitive Proxy Statement. See response to Comment #12 for updated language to be included in each Definitive Proxy Statement.

14.Comment: Please confirm that the Registrants expect that the following disclosure regarding “Control Share Provisions” in the Preliminary Proxy Statement will remain true with respect to the proposals applicable to the Putnam Closed-End Funds, particularly in light of the above-referenced contested solicitation: “On February 23, 2023, the Trustees of each fund determined to exempt all prior, and, until further notice, new purchases of the funds’ shares that might otherwise be deemed Control Share Acquisitions under the Control Share Provision. Thus, the Control Share Provision currently has no effect, and will not affect voting at the special meeting in any way.” See p. 37-38.

Response: The Registrants so confirm.

15.Comment: Please update in the Definitive Proxy Statement the section titled “Simultaneous Meetings” to make clear that there are two separate meeting dates—one for the Putnam Closed-End Funds and one for the Putnam Open-End Funds and ETFs. See p. 38.

Response: As noted in response to Comment #1, the Registrants will use a separate Definitive Proxy Statement for (i) the Putnam Closed-End Funds (which excludes information specific to the Putnam Open-End Funds and ETFs) and (ii) the Putnam Open-End Funds and ETFs (which excludes information specific to the Putnam Closed-End Funds). The Definitive Proxy Statement for the Putnam Closed-End Funds will only disclose details on the simultaneous meetings for the Putnam Closed-End Funds to be held on October 6, 2023, and the Definitive Proxy Statement for the Putnam Open-End Funds and ETFs will only disclose details on the simultaneous meetings for the Putnam Open-End Funds and ETFs to be held on October 20, 2023.

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16.Comment: Please make clear in the Definitive Proxy Statement that the information in the “Fund Information” section, including the officer table included on p. 48, applies to all Funds included in the Definitive Proxy Statement.

Response: The Registrants confirm that the requested update will be made in each Definitive Proxy Statement, as follows (addition marked with underline):

Fund Information (applicable to all funds, unless otherwise noted below)

 

17.Comment: In the Definitive Proxy Statement, please add a header to the last column of Appendix B.

Response: The Registrants confirm that all columns of Appendix B in each Definitive Proxy Statement will include appropriate headers.

18.Comment: Please supplementally confirm that the proxy cards attached to the PRE14A filing are form-of proxy cards and that the actual proxy cards provided to shareholders will include only those proposals relevant to their applicable Fund(s).

Response: The Registrants so confirm.

19.Comment: Please include a form of proxy card in the DEF14A filing for the Putnam Closed-End Funds.

Response: The Registrants confirm that a form of proxy card will be included in the DEF14A filing for the Putnam Closed-End Funds.

 

I believe that this letter addresses the Commission Staff’s comments. Any questions on the Preliminary Proxy Statements or with respect to this comment response letter may be directed to the undersigned by phone at (617) 760-0023 or by email at Peter_Fariel@putnam.com. Thank you for your assistance.

Sincerely yours,

Peter T. Fariel

Putnam Investment Management, LLC

 

cc: Venice Monagan, Putnam Investment Management, LLC

Elissa O’Bryant, Putnam Investment Management, LLC

James E. Thomas, Ropes & Gray LLP

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Timothy F. Cormier, Ropes & Gray LLP

 

 

 

 

 

 

 

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