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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

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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