Form 485BPOS PUTNAM INVESTMENT FUNDS
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
We hereby consent to the use in this Registration Statement on Form N-1A of Putnam Investment Funds of our report dated October 8, 2021, relating to the financial statements and financial highlights of Putnam International Capital Opportunities Fund, which appears in such Registration Statement. We also consent to the references to us under the headings "Financial highlights" and "Independent Registered Public Accounting Firm and Financial Statements" in such Registration Statement.
/s/ PricewaterhouseCoopers LLP
Boston, Massachusetts
December 23, 2021
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
We hereby consent to the use in this Registration Statement on Form N-1A of Putnam Investment Funds of our report dated October 12, 2021, relating to the financial statements and financial highlights of Putnam PanAgora Risk Parity Fund, which appears in such Registration Statement. We also consent to the references to us under the headings "Financial highlights" and "Independent Registered Public Accounting Firm and Financial Statements" in such Registration Statement.
/s/ PricewaterhouseCoopers LLP
Boston, Massachusetts
December 23, 2021
AMENDMENT TO MASTER CUSTODIAN AGREEMENT
This Amendment to Master Custodian Agreement (“Amendment”) is made as of June 25, 2021, by and between each management investment company party thereto (each, a “Fund” and collectively, the “Funds,” and each series of a Fund, a “Portfolio”), each severally and not jointly, and State Street Bank and Trust Company (the “Custodian”).
WHEREAS, each Fund and the Custodian entered into that certain Master Custodian Agreement dated as of January 1, 2007 (as amended, modified and supplemented from time to time, the “Agreement”); and
WHEREAS, each Fund and the Custodian desire to amend the Agreement as set forth herein.
NOW THEREFORE, in consideration of the foregoing, each Fund, acting on its own behalf separately from all of the other investment companies and not jointly or jointly and severally with any of the other investment companies, and the Custodian hereby agree to amend the Agreement, pursuant to the terms thereof, as follows:
1. Section 16(a) of the Agreement is hereby deleted in its entirety and replaced with the following:
“(a) This Agreement shall continue in full force and effect until December 31, 2021, unless the Funds provide written notice to Custodian of the Funds’ intent either to renew this Agreement for an additional term or to terminate this Agreement, which notice shall be provided by the Funds to the Custodian no later than December 31, 2021 (“Fund Notice”). If the Funds provide a Fund Notice pursuant to which the Funds elect to terminate this Agreement, this Agreement shall then terminate one hundred eighty (180) days after the last day of the month during which the Fund Notice is provided (the effective date of such termination being referred to as the “Termination Date”), subject to any Extension Period (as defined below) and any additional extension as the parties may agree to separately in writing. Upon termination of this Agreement pursuant to this paragraph, upon receipt of a final bill from the Custodian, the Funds shall pay all accrued and unpaid fees under this Agreement. If the Funds provide a Fund Notice pursuant to which the Funds elect to renew the Agreement, the parties will engage in good faith negotiations to enter into an extension or an amendment and restatement of this Agreement on mutually acceptable terms (“Extension”), and this Agreement shall continue in full force and effect until such time as the parties execute the Extension, subject to either party’s right to give one hundred eighty (180) days’ prior written notice of its intention to terminate the Agreement (subject to any Extension Period and any additional extension as the parties may agree to separately in writing) in the event that, in its reasonable judgement, substantial good faith progress toward agreement of an Extension is not being made. If this Agreement is terminated, the Custodian shall, at the reasonable request of the Funds, and subject to the consent of the Custodian (which consent shall not be unreasonably withheld or delayed), continue to provide services hereunder for a period (the "Extension Period") not to exceed ninety (90) days from the Termination Date, and the compensation payable to the Custodian for its services and expenses during such Extension Period shall not exceed one hundred and five percent (105%) (per annum) of the compensation last agreed upon by each Fund and the Custodian and in effect immediately prior to the Termination Date.
Termination of this Agreement with respect to any one particular Fund or Portfolio shall in no way affect the rights and duties under this Agreement with respect to any other Fund or Portfolio. The provisions of Section 14 and 15 of this Agreement shall survive termination of this Agreement for any reason.
This Agreement may be modified or amended from time to time by mutual written agreement of the parties hereto.”
2. Except as expressly amended by this Amendment, the provisions of the Agreement shall remain in full force and effect.
3. A copy of the Amended and Restated Agreement and Declaration of Trust of each Fund is on file with the Secretary of The Commonwealth of The Commonwealth of Massachusetts. Notice is hereby given, and it is expressly agreed, that the obligations under this Amendment and the Agreement of any such Fund shall not be binding upon any of the trustees, shareholders, nominees, officers, agents or employees of such Fund personally, but bind only the trust property of such Fund. Furthermore, notice is given that the assets and liabilities of each series of each Fund that is a series company are separate and distinct and that the obligations of or arising out of this Amendment and the Agreement are several and not joint and are binding only on the assets or property of each series with respect to its obligations. In the case of each Fund, the execution and delivery of this Amendment on its behalf has been authorized by its trustees, and signed by an authorized officer, in each case acting in such capacity and not individually, and neither such authorization by the trustees nor such execution and delivery shall be deemed to have been made by any of them individually, but shall only bind the trust property of each Fund.
4. Attached as Appendix A hereto is a replacement of “Appendix A” to the Agreement, effective as of the date set forth below.
Information Classification: Limited Access |
Information Classification: Limited Access |
| 2 |
IN WITNESS WHEREOF, each of the parties hereto has caused this Amendment to be executed in its name and behalf by its duly authorized representative as of the date first written above.
| EACH MANAGEMENT INVESTMENT COMPANY | ||
| PARTY TO THE MASTER CUSTODIAN | ||
| AGREEMENT, OTHER THAN PUTNAM ETF TRUST | ||
| By: | /s/ Jonathan S. Horwitz | |
| Name: | Jonathan S. Horwitz | |
| Title: | Executive Vice President, Principal Executive Officer, | |
| and Compliance Liaison | ||
| PUTNAM ETF TRUST, ON BEHALF OF EACH OF ITS | ||
| SERIES | ||
| By: | /s/ Susan Malloy | |
| Name: | Susan Malloy | |
| Title: | Head of Accounting and Middle Office Services | |
| STATE STREET BANK AND TRUST COMPANY | ||
| By: | /s/ Michael T. Goonan | |
| Name: | Michael T. Goonan | |
| Title: | Executive Vice President | |
APPENDIX A
to
Master Custodian Agreement
| FUND/PORTFOLIO | Putnam Fund # | State Street Fund # | |||
| PUTNAM ASSET ALLOCATION FUNDS | |||||
| on behalf of: | |||||
| Putnam Dynamic Asset Allocation Balanced Fund | 259 | 38MY | |||
| Putnam Dynamic Asset Allocation Conservative Fund | 264 | 38MZ | |||
| Putnam Dynamic Asset Allocation Growth Fund | 250 | 38MX | |||
| Putnam Income Strategies Portfolio | VC9 | 38AK | |||
| PUTNAM CALIFORNIA TAX EXEMPT INCOME FUND | 027 | 38Q5 | |||
| PUTNAM CONVERTIBLE SECURITIES FUND | 008 | 38QG | |||
| PUTNAM DIVERSIFIED INCOME TRUST | 075 | 38MS | |||
| PUTNAM LARGE CAP VALUE FUND (f/k/a PUTNAM EQUITY INCOME FUND) | 012 | 38QH | |||
| PUTNAM FUNDS TRUST | |||||
| on behalf of: | |||||
| Putnam Short Duration Bond Fund | EB3 | 38V5 | |||
| Putnam Fixed Income Absolute Return Fund | EC3 | 38V6 | |||
| Putnam Multi-Asset Absolute Return Fund | ED8 | 38V8 | |||
| Putnam Capital Spectrum Fund | GA6 | 38VW | |||
| Putnam Dynamic Asset Allocation Equity Fund | FL7 | 38ZA | |||
| Putnam Dynamic Risk Allocation Fund | EC2 | 38BG | |||
| Putnam Emerging Markets Equity Fund | CT2 | 38P4 | |||
| Putnam Equity Spectrum Fund | GA7 | 38VX | |||
| Putnam Floating Rate Income Fund | 29X | 38PJ | |||
| Putnam Focused Equity Fund | EL8 | 38VE | |||
| Putnam Global Technology Fund | EM7 | 38VF | |||
| Putnam Intermediate-Term Municipal Income Fund | ND5 | 38AM | |||
| Putnam International Value Fund | 2CE | 38ND | |||
| Putnam Multi-Cap Core Fund | HF8 | 38WG | |||
| Putnam Ultra Short Duration Income Fund | LU7 | 38BE | |||
| Putnam Short Term Investment Fund | NB2 | 38AJ | |||
| Putnam Short-Term Municipal Income Fund | NC7 | 38AL | |||
| Putnam Small Cap Growth Fund | 2HF | 38NI | |||
| Putnam Mortgage Opportunities Fund | PZ4 | 38PO | |||
| Putnam Focused International Equity Fund (f/k/a PUTNAM GLOBAL EQUITY FUND) | 005 | 38QE | |||
| PUTNAM GLOBAL HEALTH CARE FUND | 021 | 38QJ | |||
| PUTNAM GLOBAL INCOME TRUST | 041 | 38QL | |||
Information Classification: Limited Access |
Information Classification: Limited Access |
| 4 |
| PUTNAM HIGH YIELD FUND | 060 | 38MI |
| PUTNAM INCOME FUND | 004 | 38QD |
| PUTNAM INTERNATIONAL EQUITY FUND | 841 | 38NX |
| PUTNAM INVESTMENT FUNDS | ||
| on behalf of: | ||
| Putnam Growth Opportunities Fund | 2AP | 38QR |
| Putnam International Capital Opportunities Fund | 2AZ | 38PG |
| Putnam Sustainable Future Fund | 2OV | 38NO |
| Putnam Research Fund | 2AQ | 38NB |
| Putnam Small Cap Value Fund | 2MF | 38NL |
| Putnam Government Money Market Fund | QW2 | 38GM |
| PUTNAM MANAGED MUNICIPAL INCOME TRUST | 052 | 38R1 |
| PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND | 845 | 38RD |
| PUTNAM MASTER INTERMEDIATE INCOME TRUST | 074 | 38MR |
| PUTNAM MINNESOTA TAX EXEMPT INCOME FUND | 847 | 38RF |
| PUTNAM MONEY MARKET FUND | 010 | 38Q2 |
| Putnam Sustainable Leaders Fund | 852 | 38NY |
| PUTNAM MUNICIPAL OPPORTUNITIES TRUST | 582 | 38RB |
| PUTNAM NEW JERSEY TAX EXEMPT INCOME FUND | 019 | 38Q4 |
| PUTNAM NEW YORK TAX EXEMPT INCOME FUND | 030 | 38Q6 |
| PUTNAM OHIO TAX EXEMPT INCOME FUND | 848 | 38RG |
| PUTNAM PENNSYLVANIA TAX EXEMPT INCOME FUND | 047 | 38R0 |
| PUTNAM PREMIER INCOME TRUST | 073 | 38MQ |
| PUTNAM TARGET DATE FUNDS | ||
| on behalf of: | ||
| Putnam RetirementReady 2065 Fund | WJ7 | 38B2 |
| Putnam RetirementReady 2060 Fund | QN8 | 38KH |
| Putnam RetirementReady 2055 Fund | KT2 | 38KB |
| Putnam RetirementReady 2050 Fund | 7CR | FFAM |
| Putnam RetirementReady 2045 Fund | 40M | FFAD |
| Putnam RetirementReady 2040 Fund | 40F | FFAB |
| Putnam RetirementReady 2035 Fund | 49Y | FFAL |
| Putnam RetirementReady 2030 Fund | 49R | FFAJ |
| Putnam RetirementReady 2025 Fund | 49K | FFAI |
| Putnam RetirementReady Maturity Fund | 48P | FFAF |
| Putnam Retirement Advantage 2025 Fund | UU4 | 38BL |
| Putnam Retirement Advantage 2030 Fund | UU5 | 38BN |
| Putnam Retirement Advantage 2035 Fund | UU6 | 38BP |
| Putnam Retirement Advantage 2040 Fund | UU7 | 38BQ |
| Putnam Retirement Advantage 2045 Fund | UU8 | 38BR |
| Putnam Retirement Advantage 2050 Fund | UU9 | 38BS |
| Putnam Retirement Advantage 2055 Fund | UV2 | 38BU |
| Putnam Retirement Advantage 2060 Fund | UV3 | 38BV |
| Putnam Retirement Advantage 2065 Fund | WJ8 | 38B1 |
| Putnam Retirement Advantage Maturity Fund | UV4 | 38BM |
| PUTNAM TAX EXEMPT INCOME FUND | 011 | 38Q3 |
| PUTNAM TAX-FREE INCOME TRUST | ||
| on behalf of: | ||
| Putnam Strategic Intermediate Municipal Fund (f/k/a Putnam AMT-Free Municipal Fund) | 035 | 38Q7 |
| Putnam Tax-Free High Yield Fund | 036 | 38Q8 |
| PUTNAM MORTGAGE SECURITIES FUND | 032 | 38MF |
| PUTNAM VARIABLE TRUST | ||
| on behalf of: | ||
| Putnam VT Multi-Asset Absolute Return Fund | LC3 | 38AD |
| Putnam VT Mortgage Securities Fund | 2PX | 38NP |
| Putnam VT Small Cap Growth Fund | 23K | 38QO |
| Putnam VT Diversified Income Fund | 961 | 38PA |
| Putnam VT Equity Income Fund | 23N | 38QP |
| Putnam VT George Putnam Balanced Fund | 2IS | 38QV |
| Putnam VT Global Asset Allocation Fund | 070 | 38MO |
| Putnam VT Global Equity Fund | 016 | 38QI |
| Putnam VT Global Health Care Fund | 2IW | 38QW |
| Putnam VT Growth Opportunities Fund | 2PU | 38QY |
| Putnam VT High Yield Fund | 067 | 38MN |
| Putnam VT Income Fund | 068 | 38QM |
| Putnam VT International Equity Fund | 2DO | 38NF |
| Putnam VT Emerging Markets Equity Fund | 2DP | 38NG |
| Putnam VT International Value Fund | 2DN | 38NE |
| Putnam VT Multi-Cap Core Fund | 2IO | 38QU |
| Putnam VT Government Money Market Fund | 069 | 38R5 |
| Putnam VT Sustainable Leaders Fund | 098 | 38PF |
| Putnam VT Sustainable Future Fund | 23H | 38MV |
| Putnam VT Research Fund | 2LA | 38PH |
| Putnam VT Small Cap Value Fund | 2MJ | 38NM |
| GEORGE PUTNAM BALANCED FUND | 001 | 38QA |
| PUTNAM INVESTMENT FUNDS | ||
| on behalf of: | ||
| Putnam PanAgora Risk Parity Fund | SP2 | 38PU |
| Putnam ETF Trust | ||
| Putnam Focused Large Cap Growth ETF | ||
| Putnam Focused Large Cap Value ETF | ||
| Putnam Sustainable Future ETF | ||
| Putnam Sustainable Leaders ETF |
Information Classification: Limited Access |
Information Classification: Limited Access |
| 6 |
AMENDMENT TO MASTER SUB-ACCOUNTING SERVICES AGREEMENT
(Registered Funds)
This Amendment to Master Sub-Accounting Services Agreement (“Amendment”) is made as of June 25, 2021, by and between the Putnam entity identified on Appendix A (the “Administrator”) and State Street Bank and Trust Company (the “Sub-Accounting Agent”).
WHEREAS, the Administrator and the Sub-Accounting Agent entered into that certain Sub-Accounting Services Agreement dated as of January 1, 2007 (as amended, modified and supplemented from time to time, the “Agreement”); and
WHEREAS, the Administrator and Sub-Accounting Agent desire to amend the Agreement as set forth herein.
NOW THEREFORE, in consideration of the foregoing, the Administrator and the Sub-Accounting Agent hereby agree to amend the Agreement, pursuant to the terms thereof, as follows:
| 1. | Section 6(a) of the Agreement is hereby deleted in its entirety and replaced with the following: |
This Agreement shall continue in full force and effect until December 31, 2021, unless the Administrator provides written notice to Sub-Accounting Agent of the Administrators’ intent either to renew this Agreement for an additional term or to terminate this Agreement, which notice shall be provided by the Administrator to the Sub-Accounting Agent no later than December 31, 2021 (“Administrator Notice”). If the Administrator provides an Administrator Notice pursuant to which the Administrator elects to terminate this Agreement, this Agreement shall then terminate one hundred eighty (180) days after the last day of the month during which the Administrator Notice is provided (the effective date of such termination being referred to as the “Termination Date”), subject to any Extension Period (as defined below) and any additional extension as the parties may agree to separately in writing. Upon termination of this Agreement pursuant to this paragraph, upon receipt of a final bill from the Sub-Accounting Agent, the Administrator shall pay all accrued and unpaid fees under this Agreement. If the Administrator provides a Administrator Notice pursuant to which the Administrator elects to renew the Agreement, the parties will engage in good faith negotiations to enter into an extension or an amendment and restatement of this Agreement on mutually acceptable terms (“Extension”), and this Agreement shall continue in full force and effect until such time as the parties execute the Extension, subject to either party’s right to give one hundred eighty (180) days’ prior written notice of its intention to terminate the Agreement (subject to any Extension Period and any additional extension as the parties may agree to separately in writing) in the event that, in its reasonable judgement, substantial good faith progress toward agreement of an Extension is not being made. If this Agreement is terminated, the Sub-Accounting Agent shall, at the reasonable request of the Administrator, and subject to the consent of the Sub-Accounting Agent (which consent shall not be unreasonably withheld or delayed), continue to provide services hereunder for a period (the "Extension Period") not to exceed ninety (90) days from the Termination Date, and the compensation payable to the Sub-Accounting Agent for its services and expenses during such Extension Period shall not exceed one hundred and five percent (105%) (per annum) of the compensation last agreed upon by each Administrator and the Sub-Accounting Agent and in effect immediately prior to the Termination Date.”
2. Except as expressly amended by this Amendment, the provisions of the Agreement shall remain in full force and effect.
3. Attached as Appendix A hereto is a replacement of “Appendix A” to the Agreement, effective as of the date set forth above.
[Signature page follows.]
IN WITNESS WHEREOF, each of the parties hereto has caused this Amendment to be executed in its name and behalf by its duly authorized representative as of the date first written above.
| PUTNAM INVESTMENT MANAGEMENT, LLC | ||
| By: | /s/ Michael J. Woodall | |
| Name: | Michael J. Woodall | |
| Title: | Chief of Operations | |
| STATE STREET BANK AND TRUST COMPANY | ||
| By: | /s/ Michael T. Goonan | |
| Name: | Michael T. Goonan | |
| Title: | Executive Vice President | |
Information Classification: Limited Access |
| 2 |
APPENDIX A
to
Master Sub-Accounting Services Agreement
| FUND/PORTFOLIO | Putnam Fund # | State Street Fund # |
| PUTNAM ASSET ALLOCATION FUNDS | ||
| on behalf of: | ||
| Putnam Dynamic Asset Allocation Balanced Fund | 259 | 38MY |
| Putnam Dynamic Asset Allocation Conservative Fund | 264 | 38MZ |
| Putnam Dynamic Asset Allocation Growth Fund | 250 | 38MX |
| Putnam Income Strategies Portfolio | VC9 | 38AK |
| PUTNAM CALIFORNIA TAX EXEMPT INCOME FUND | 027 | 38Q5 |
| PUTNAM CONVERTIBLE SECURITIES FUND | 008 | 38QG |
| PUTNAM DIVERSIFIED INCOME TRUST | 075 | 38MS |
| PUTNAM LARGE CAP VALUE FUND (f/k/a PUTNAM EQUITY INCOME FUND) | 012 | 38QH |
| PUTNAM FUNDS TRUST | ||
| on behalf of: | ||
| Putnam Short Duration Bond Fund | EB3 | 38V5 |
| Putnam Fixed Income Absolute Return Fund | EC3 | 38V6 |
| Putnam Multi-Asset Absolute Return Fund | ED8 | 38V8 |
| Putnam Capital Spectrum Fund | GA6 | 38VW |
| Putnam Dynamic Asset Allocation Equity Fund | FL7 | 38ZA |
| Putnam Dynamic Risk Allocation Fund | EC2 | 38BG |
| Putnam Emerging Markets Equity Fund | CT2 | 38P4 |
| Putnam Equity Spectrum Fund | GA7 | 38VX |
| Putnam Floating Rate Income Fund | 29X | 38PJ |
| Putnam Focused Equity Fund | EL8 | 38VE |
| Putnam Global Technology Fund | EM7 | 38VF |
| Putnam Intermediate-Term Municipal Income Fund | ND5 | 38AM |
| Putnam International Value Fund | 2CE | 38ND |
| Putnam Multi-Cap Core Fund | HF8 | 38WG |
| Putnam Ultra Short Duration Income Fund | LU7 | 38BE |
| Putnam Short Term Investment Fund | NB2 | 38AJ |
| Putnam Short-Term Municipal Income Fund | NC7 | 38AL |
| Putnam Small Cap Growth Fund | 2HF | 38NI |
| Putnam Mortgage Opportunities Fund | PZ4 | 38PO |
| Putnam Focused International Equity Fund (f/k/a PUTNAM GLOBAL EQUITY FUND) | 005 | 38QE |
Information Classification: Limited Access |
| 3 |
| PUT EMERG MKTS SM CAP EQ LLP | UG8 | 38BF |
| PUTNAM GLOBAL HEALTH CARE FUND | 021 | 38QJ |
| PUTNAM GLOBAL INCOME TRUST | 041 | 38QL |
| Putnam High Yield Fund | 060 | 38MI |
| PUTNAM INCOME FUND | 004 | 38QD |
| PUTNAM INTERNATIONAL EQUITY FUND | 841 | 38NX |
| PUTNAM INVESTMENT FUNDS | ||
| on behalf of: | ||
| Putnam Growth Opportunities Fund | 2AP | 38QR |
| Putnam International Capital Opportunities Fund | 2AZ | 38PG |
| Putnam Sustainable Future Fund | 2OV | 38NO |
| Putnam Research Fund | 2AQ | 38NB |
| Putnam Small Cap Value Fund | 2MF | 38NL |
| Putnam Government Money Market Fund | QW2 | 38GM |
| PUTNAM MANAGED MUNICIPAL INCOME TRUST | 052 | 38R1 |
| PUTNAM MASSACHUSETTS TAX EXEMPT INCOME FUND | 845 | 38RD |
| PUTNAM MASTER INTERMEDIATE INCOME TRUST | 074 | 38MR |
| PUTNAM MINNESOTA TAX EXEMPT INCOME FUND | 847 | 38RF |
| PUTNAM MONEY MARKET FUND | 010 | 38Q2 |
| Putnam Sustainable Leaders Fund | 852 | 38NY |
| PUTNAM MUNICIPAL OPPORTUNITIES TRUST | 582 | 38RB |
| PUTNAM NEW JERSEY TAX EXEMPT INCOME FUND | 019 | 38Q4 |
| PUTNAM NEW YORK TAX EXEMPT INCOME FUND | 030 | 38Q6 |
| PUTNAM OHIO TAX EXEMPT INCOME FUND | 848 | 38RG |
| PUTNAM PENNSYLVANIA TAX EXEMPT INCOME FUND | 047 | 38R0 |
| PUTNAM PREMIER INCOME TRUST | 073 | 38MQ |
| PUTNAM TARGET DATE FUNDS | ||
| on behalf of: | ||
| Putnam RetirementReady 2065 Fund | WJ7 | 38B2 |
| Putnam RetirementReady 2060 Fund | QN8 | 38KH |
| Putnam RetirementReady 2055 Fund | KT2 | 38KB |
| Putnam RetirementReady 2050 Fund | 7CR | FFAM |
| Putnam RetirementReady 2045 Fund | 40M | FFAD |
| Putnam RetirementReady 2040 Fund | 40F | FFAB |
| Putnam RetirementReady 2035 Fund | 49Y | FFAL |
| Putnam RetirementReady 2030 Fund | 49R | FFAJ |
| Putnam RetirementReady 2025 Fund | 49K | FFAI |
| Putnam RetirementReady Maturity Fund | 48P | FFAF |
| Putnam Retirement Advantage 2025 Fund | UU4 | 38BL |
| Putnam Retirement Advantage 2030 Fund | UU5 | 38BN |
Information Classification: Limited Access |
| 4 |
| Putnam Retirement Advantage 2035 Fund | UU6 | 38BP |
| Putnam Retirement Advantage 2040 Fund | UU7 | 38BQ |
| Putnam Retirement Advantage 2045 Fund | UU8 | 38BR |
| Putnam Retirement Advantage 2050 Fund | UU9 | 38BS |
| Putnam Retirement Advantage 2055 Fund | UV2 | 38BU |
| Putnam Retirement Advantage 2060 Fund | UV3 | 38BV |
| Putnam Retirement Advantage 2065 Fund | WJ8 | 38B1 |
| PUTNAM RET ADVANTAGE 2065 TRUST | WN3 | 38B8 |
| Putnam Retirement Advantage Maturity Fund | UV4 | 38BM |
| Putnam 529 Age-Based 2021 Fund | WK2 | 38B3 |
| PUTNAM TAX EXEMPT INCOME FUND | 011 | 38Q3 |
| PUTNAM TAX-FREE INCOME TRUST | ||
| on behalf of: | ||
| Putnam Strategic Intermediate Municipal Fund (f/k/a Putnam AMT-Free Municipal Fund) | 035 | 38Q7 |
| Putnam Tax-Free High Yield Fund | 036 | 38Q8 |
| Putnam Mortgage Securities Fund | 032 | 38MF |
| PUTNAM VARIABLE TRUST | ||
| on behalf of: | ||
| Putnam VT Multi-Asset Absolute Return Fund | LC3 | 38AD |
| Putnam VT Mortgage Securities Fund | 2PX | 38NP |
| Putnam VT Small Cap Growth Fund | 23K | 38QO |
| Putnam VT Diversified Income Fund | 961 | 38PA |
| Putnam VT Equity Income Fund | 23N | 38QP |
| Putnam VT George Putnam Balanced Fund | 2IS | 38QV |
| Putnam VT Global Asset Allocation Fund | 070 | 38MO |
| Putnam VT Global Equity Fund | 016 | 38QI |
| Putnam VT Global Health Care Fund | 2IW | 38QW |
| Putnam VT Growth Opportunities Fund | 2PU | 38QY |
| Putnam VT High Yield Fund | 067 | 38MN |
| Putnam VT Income Fund | 068 | 38QM |
| Putnam VT International Equity Fund | 2DO | 38NF |
| Putnam VT Emerging Markets Equity Fund | 2DP | 38NG |
| Putnam VT International Value Fund | 2DN | 38NE |
| Putnam VT Multi-Cap Core Fund | 2IO | 38QU |
| Putnam VT Government Money Market Fund | 069 | 38R5 |
| Putnam VT Sustainable Leaders Fund | 098 | 38PF |
| Putnam VT Sustainable Future Fund | 23H | 38MV |
| Putnam VT Research Fund | 2LA | 38PH |
| Putnam VT Small Cap Value Fund | 2MJ | 38NM |
Information Classification: Limited Access |
| 5 |
| George Putnam Balanced Fund | 001 | 38QA |
| PUTNAM INVESTMENT FUNDS | ||
| on behalf of: | ||
| Putnam PanAgora Risk Parity Fund | SP2 | 38PU |
| Putnam PanAgora Market Neutral Fund | SL6 | 38PW |
| Putnam PanAgora Managed Futures Strategy Ltd. | SN8 | 38PY |
| Putnam ETF Trust | ||
| Putnam Focused Large Cap Growth ETF | ||
| Putnam Focused Large Cap Value ETF | ||
| Putnam Sustainable Future ETF | ||
| Putnam Sustainable Leaders ETF |
Information Classification: Limited Access |
| 6 |
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