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Franklin Templeton

100 Federal Street

Boston, MA 02110

November 7, 2024

    Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549

    Attn: Mindy Rotter

Re:	Comments on public filings with the Securities
and Exchange Commission (the “Commission”) for each of the registered investment companies and series thereof identified on
Exhibit A hereto (each, a “Fund” and collectively, the “Funds”)

Dear Ms. Rotter:

This letter responds to
the comments that you provided by videoconference to Kevin Blatchford, Venice Monagan, and Jeff White of Franklin Templeton, representing
Franklin Advisers, Inc. and Putnam Investment Management, LLC, each an investment manager to certain of the Funds (each, an “Investment
Manager”), and James Forbes of Ropes & Gray LLP, counsel to the Funds, on behalf of the staff of the Commission (the “Staff”)
on October 8, 2024, regarding the annual reports of the Funds on Form N-CSR for their fiscal years ended between August 31, 2023 and April
30, 2024. For convenience of reference, I have summarized each of the Staff’s comments before the Funds’ response.

 1. Comment: For Putnam Focused International Equity Fund, Putnam
Focused Large Cap Growth ETF, Putnam Focused Large Cap Value ETF, Putnam Global Income Trust, Putnam Municipal Opportunities Trust, Putnam
VT Emerging Markets Equity Fund, Putnam VT Focused International Equity Fund, Putnam VT Global Health Care Fund, and Putnam VT Large Cap
Growth Fund only: Please confirm in correspondence that each Fund noted above seeks to operate as a “non-diversified company”
(as defined in Section 5(b)(2) of the Investment Company Act of 1940, as amended (the “1940 Act”)) continues to maintain its
non-diversified status. The Staff notes that, if any Fund has operated as a “diversified company” (as defined in Section 5(b)(1)
of the 1940 Act) for more than three years, the Fund will require shareholder approval prior to changing its status back to non-diversified.

Response: Putnam Focused
Large Cap Value ETF is classified as a non-diversified company but has been operating as diversified since May 2024. Putnam Municipal
Opportunities Trust is classified as a non-diversified company but has been operating as diversified since September 2013. We confirm
that each other Fund noted above continues to maintain its non-diversified status. We note that the Investment Manager’s compliance
team actively monitors each Fund’s non-diversified status.

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 2. Comment: For each Fund with a unitary fee structure, please
confirm in correspondence that the Fund’s Investment Manager is current with all payments to Fund service providers. Additionally,
please describe if agreements filed with the Commission contain provisions as to whether the Fund is contractually obligated to pay such
providers.

Response: We confirm that,
with respect to each Fund with a unitary fee structure, the applicable Investment Manager is current with all payments to Fund service
providers. Each such Fund is subject to contractual obligations to pay service providers under certain agreements filed with the Commission,
which may include, but are not necessarily limited to, a management contract, a master custodian agreement, a credit agreement, a distribution
agreement, and an investor servicing agreement. Subject to limited exceptions provided for by the applicable management contract and disclosed
in a Fund’s registration statement (such as fees payable to the Investment Manager under the management contract management fees
and expenses incurred in connection with a distribution/Rule 12b-1 plan), the Investment Manager is contractually obligated under the
management contract to reimburse each Fund for all expenses incurred by the Fund, including (to the extent not covered by the exceptions)
payments made by the Fund under these agreements. Payments to service providers contemplated by other agreements filed with the Commission
(such as sub-management agreements, sub-advisory agreements, and master sub-accounting services agreements) are the responsibility of
other service providers (e.g., the Investment Manager or the Funds’ administrator) and not the Funds.

 3. Comment: For Putnam Focused Large Cap Growth ETF, Putnam Focused
Large Cap Value ETF, Putnam Sustainable Future ETF, and Putnam Sustainable Leaders ETF only: The Staff notes the inclusion of
an “Other” category of expenses in the statement of operations for each Fund noted above, which appear to have unitary management
fee structures. Please explain in correspondence what these other expenses represent.

Response: The Staff has correctly
noted that each of Putnam Focused Large Cap Value ETF, Putnam Focused Large Cap Growth ETF, Putnam Sustainable Future ETF, and Putnam
Sustainable Leaders ETF has all-inclusive (unitary) management fee. Although Putnam Management, in consideration of the management fee
it receives as Investment Manager to each Fund, generally undertakes in its management contract to pay, or reimburse the Funds, for all
of the Funds’ organizational and other operating expenses, certain categories of expenses are excluded from that undertaking. In
respect of each Fund, these excluded categories of expenses include: (i) interest and taxes (including, but not limited to, income, excise,
transfer and withholding taxes); (ii) expenses of the Fund incurred with respect to the acquisition and disposition of portfolio securities,
commodities or other financial instruments and the execution of portfolio transactions, including brokerage commissions; (iii) expenses
incurred in connection with any distribution plan adopted by the Fund in compliance with Rule 12b-1 under the 1940 Act, including distribution
fees; (iv) expenses of printing and mailing proxy materials to shareholders of the Fund; (v) all other expenses incidental to holding
meetings of the Fund’s shareholders, including proxy solicitations therefor; (vi) litigation expenses (including, but not limited
to, any indemnification obligation, attorneys’ fees, expenses, costs, judgments, amounts paid in settlement, fines, penalties, fees
of expert witnesses, document production fees, and all other liabilities whatsoever incurred or paid by the Fund or a person indemnified
by the

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Fund); (vii) the fee payable to Putnam Management
under the management contract; (viii) any extraordinary expenses (which, for the avoidance of doubt, do not include expenses related to
the organization of any subsidiary for the Fund or the ongoing corporate expenses of maintaining such subsidiary); and (ix) acquired fund
fees and expenses.

During the fiscal year ended August 31, 2023,
each of the Funds incurred expenses in connection with the printing and mailing of proxy materials to Fund shareholders. Pursuant to the
terms of the expense undertaking described above, these expenses were not paid or reimbursed by Putnam Management as part of the unitary
management fee and instead were borne by the Funds. As a result, these expenses are presented as a separate line item in each Fund’s
statement of operations for the fiscal year ended August 31, 2023.

 4. Comment: For Putnam Floating Rate Income Fund, Putnam Global
Income Trust, Putnam Managed Municipal Income Trust, Putnam Master Intermediate Trust, and Putnam Municipal Opportunities Trust only:
According to the Funds’ statements of changes in net assets, each Fund had return of capital distributions. Please confirm
in correspondence that there are no references in the Funds’ marketing materials, financial statement disclosures, and/or website
disclosures to yield or dividends when describing distributions that may contain a return of capital distribution, as those items may
be misinterpreted as income.

Response: We note that,
although recent shareholder reports for each of the Funds noted above include references to the Fund’s “current dividend rate,”
that term is footnoted in each case to clarify that the rate is based on the Fund’s most recent distribution “including
any return of capital and excluding capital gains,” annualized and divided by NAV or market price (in the case of closed-end
Funds) or by share price before or after sales charge (in the case of open-end Funds) at period-end. We confirm that, to the extent that
comparable information is included in future shareholder reports, references will be to the “distribution rate” rather than
the “dividend rate.” We also confirm that the terms “yield” and “dividends” are not used in the Funds’
marketing materials, financial statement disclosures, or website disclosures to describe distributions that may contain a return of capital
distribution.

 5. Comment: For Putnam Global Income Trust, Putnam Managed Municipal
Income Trust, Putnam Master Intermediate Trust, and Putnam Municipal Opportunities Trust only: The Staff notes that each Fund
noted above paid distributions from return of capital during its most recently ended fiscal year but did not check “Yes” (to
indicate that, during the reporting period, the Fund paid any dividend or made any distribution in the nature of a dividend payment required
to be accompanied by a written statement pursuant to section 19(a) of the 1940 Act) on Item B.23 (Rule 19a-1 notice) of the Form N-CEN
filed with respect to that fiscal year. Please explain in correspondence why these distributions were not accompanied by a written statement
pursuant to section 19(a) of the 1940 Act.

Response: We have determined
that, although each of Putnam Managed Municipal Income Trust, Putnam Master Intermediate Income Trust, and Putnam Municipal Opportunities
Trust responded “No” to Item B.23 of the Form N-CEN filed with respect to the referenced fiscal year, each Fund should have
responded “Yes” to that item. Each Fund filed an

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amended Form N-CEN on November 4, 2024
to correct its response to Item B.23. Each Fund’s amended Form N-CEN filing included an explanation of what changes were made.

For Putnam Global Income Trust, the return
of capital presented in the Fund’s Statement of changes in net assets for the referenced fiscal year reflects tax adjustments that
are not taken into account for purposes of section 19(a) of the 1940 Act. We confirm that, on a book (GAAP) basis, the Fund earned more
net income than it paid out in distributions for the fiscal year. Accordingly, we believe that the Fund’s response of “No”
to Item B.23 of its Form N-CEN filing with respect to the fiscal year is appropriate.

 6. Comment: For Putnam Managed Municipal Income Trust,
Putnam Master Intermediate Trust, and Putnam Municipal Opportunities Trust only: The “View Historical Distributions Data”
section of the website for each Fund noted above refers readers to the Fund’s statement of additional information (“SAI”)
for specific information regarding distributions. The Staff was unable to locate this document. Please provide a hyperlink to the SAI
in correspondence. In addition, please explain in correspondence how a Fund shareholder can locate the SAI on the website.

Response: With respect to each
Fund referenced above, we will revise the final sentence appearing under the “View Historical Distributions Data” section
of the Fund’s website as follows to remove the reference to the Fund’s SAI (deletions denoted with strikethrough text):

Refer to the fund’s annual report
or statement of additional information for specific information regarding distributions.

 7. Comment: For Putnam Municipal Opportunities Trust only:
Please explain in correspondence what “Increase from shares repurchased” represents in the Fund’s financial highlights
included with the Fund’s Form N-CSR for the fiscal year ended April 30, 2024. In addition, given the significant impact of the “Increase
from shares repurchased” line item on the Fund’s financial highlights for the fiscal year ended April 30, 2024, going forward,
please include disclosure in the notes to the Fund’s financial statements explaining how the “Decrease from shares repurchased”
noted on the Fund’s statement of changes in net assets for a particular fiscal year relates to the “Increase in shares purchased”
noted in the Fund’s financial highlights for the same fiscal year.

Response: The “Increase
from shares repurchased” line item in the Fund’s financial highlights and “Decrease from shares repurchased” line
item in the Fund’s statement of changes in net assets both relate to the impact of the Fund’s share repurchase program, which
was instituted in 2005. Pursuant to the share repurchase program, during the most recent program year, the Fund was permitted to purchase
up to 10% of its common shares during the 365-day period ended September 30, 2024 (based on the shares outstanding as of September 30,
2023). Because the Fund only engages in share repurchases when its shares are trading at a discount to net asset value, the Fund is able
to retain the difference between the net asset value of the shares repurchased and the market value paid by the Fund to repurchase those
shares, enhancing the Fund’s net asset value per share for remaining Fund shareholders. The “Decrease from shares repurchased”
line item in the Fund’s statement of changes in net assets reflects the market value that the Fund paid over

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a particular period to repurchase its common
shares. The “Increase in shares repurchased” line item in the Fund’s financial highlights reflects the increase in the
Fund’s net asset value (on a per-share basis) resulting from share repurchases over a particular fiscal year.

Going forward, we will update disclosure
in the “Shares repurchased” footnote to the Fund’s financial statements, which describes the Fund’s share repurchase
program, to clarify that share repurchases increase the net asset value of the Fund, as indicated below (additions denoted with underlined/italicized
text). We will also add a reference in the Fund’s financial highlights to the “Shares repurchased” footnote to the Fund’s
financial statements.

Note 5: Shares repurchased

In September 2023, the Trustees approved the
renewal of the repurchase program to allow the fund to repurchase up to 10% of its outstanding common shares over the 365 day period ending
September 30, 2024 (based on shares outstanding as of September 30, 2023). Prior to this renewal, the Trustees had approved a repurchase
program to allow the fund to repurchase up to 10% of its outstanding common shares over the 365 day period ending September 30, 2023 (based
on shares outstanding as of September 30, 2022). Repurchases are made when the fund’s shares are trading at less than net asset
value (and, therefore, increase the net asset value per share of the fund’s remaining shares) and in accordance with
procedures approved by the fund’s Trustees.

 8. Comment: For Putnam Focused International Equity Fund only:
The internal control report included with the Form N-CEN filed on January 1, 2024 for Putnam Focused International Equity Fund
appears to be for Putnam Large Cap Value Fund. Please confirm in correspondence that an amended Form N-CEN will be filed for Putnam Focused
International Equity Fund with the appropriate internal control report as soon as possible.

Response: The Fund filed
an amended Form N-CEN on November 4, 2024 that includes the appropriate internal control report.

 9. Comment: For Putnam Focused International Equity Fund only:
The notes to the Fund’s financial statements indicate that the Fund seeks to operate as a “non-diversified company”
(as defined in Section 5(b)(2) of the 1940 Act). However, the Fund responded “No” to Item C.4 (Diversification) on its Form
N-CEN filed on January 9, 2024, indicating that the Fund does not seek to operate as a “non-diversified company.” Please explain
in correspondence the difference in disclosure and, if appropriate, correct the Fund’s response to Item C.4 in an amended Form N-CEN
filing.

Response: We confirm that
the Fund seeks to operate as a “non-diversifie