Correspondence 0000928816-22-001201 from Putnam Target Date Funds (CIK 0001295293)
Putnam Target Date Funds (CIK 0001295293)
Date: Nov. 10, 2022 · CIK: 0001295293 · Accession: 0000928816-22-001201
AI Filing Summary & Sentiment
File numbers found in text: 333-117134, 811-21598
Letter
Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Timothy Worthington, Esq. Re: Comments on Post-Effective Amendment No. 50 under the Securities Act of 1933, as amended, and Amendment No. 51 under the Investment Company Act of 1940, as amended (the “Investment Company Act”), to the Registration Statement on Form N-1A (File Nos. 333-117134 and 811-21598) (the “Registration Statement”) of Putnam Target Date Funds (the “Registrant”), on behalf of Putnam RetirementReady 2025 Fund, Putnam RetirementReady 2030 Fund, Putnam RetirementReady 2035 Fund, Putnam RetirementReady 2040 Fund, Putnam RetirementReady 2045 Fund, Putnam RetirementReady 2050 Fund, Putnam RetirementReady 2055 Fund, Putnam RetirementReady 2060 Fund, Putnam RetirementReady 2065 Fund, and Putnam RetirementReady Maturity Fund (each, a “Fund” and collectively, the “Funds”), filed with the Securities and Exchange Commission (the “Commission”) on July 1, 2022 (the “485(a) Amendment”)
Dear Mr. Worthington:
This letter responds to the comments that you provided to Peter T. Fariel of Putnam Investment Management, LLC (“Putnam Management”), investment adviser to the Funds, and Timothy F. Cormier and Vania Cornelio of Ropes & Gray LLP, counsel to the Funds, on behalf of the Staff of the Commission (the “Commission Staff”) on August 17, 2022 regarding the 485(a) Amendment. For convenience of reference, I have summarized each of the Commission Staff’s comments before the Registrant’s response. These responses, as applicable, will be reflected in the definitive version of the Registrant’s 485(b) filing pertaining to the Funds on Form N-1A expected to be filed with the Commission on or around February 10, 2023 (the “485(b) Amendment”).1 References to specific text in the Commission Staff’s comments and the Registrant’s responses are to the corresponding text of the 485(a) Amendment, as indicated.
1 As discussed with you on August 17, Putnam Management has determined that the repositioning of the Funds as an environmental, social, and governance- (“ESG”) focused target date suite (the “Repositioning”) will not occur until the first quarter of 2023 (currently expected to occur on or around February 10, 2023). Prior to that date, the Funds’ routine annual update will be filed on or around November 28, 2022, with a designated effective date of November 30, 2022. Because of this intervening annual update filing, the Registrant expects to make another Registration Statement amendment filing pursuant to Rule 485(a) to reflect the Repositioning shortly following the annual update, which will contain substantially identical information to that contained in the 485(a) Amendment, and will also include disclosure updates in response to the Commission Staff’s comments addressed in this letter and updated fee, expense, and financial data for the Funds’ most recently completed fiscal year. The Registrant has made two delaying amendment filings with respect to the 485(a) Amendment and intends to make a final delaying amendment filing on or around November 16 so that the 485(a) Amendment will not become effective prior to the annual update filing at the end of November.
General Comment
1. Comment: Please respond to all comments via correspondence on EDGAR no later than five business days before the 485(b) Amendment is scheduled to become automatically effective. Please finalize the Registration Statement filed as the 485(b) Amendment with all brackets removed and all material information provided. If a comment results in a change to the disclosure language, please include the revised disclosure in this letter. The Commission Staff notes that the Registrant is responsible for the adequacy and accuracy of the Registration Statement.
Response: The Registrant confirms that it is responding to all comments via this correspondence on EDGAR. The Registrant also confirms that it will revise the Registration Statement filed as the 485(b) Amendment to remove all brackets and to provide all material information. The Registrant further confirms that if a comment results in a change to the disclosure language, it will include the revised disclosure in this letter (or in Appendix A to this letter). The Registrant acknowledges that it is responsible for the adequacy and accuracy of the Registration Statement.
Prospectus
Fund summary – Fees and expenses
2. Comment: Please bold the following language: “You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.”
Response: The Registrant confirms that the requested change will be made.
Fund summary – Investments, risks, and performance – Investments
3. Comment: The first sentence of the first paragraph of the “Investments” section states that the Funds “invest in exchange-traded funds (“ETFs”) that focus on investments with positive sustainability or environmental, social, and governance (“ESG”) characteristics, referred to as underlying funds.” The first sentence of the second paragraph in that section then states that “[u]nder normal circumstances, the fund will invest in underlying funds such that, in the aggregate, it has indirect exposure to investments that meet Putnam Management’s or PanAgora’s, as applicable, sustainability or ESG criteria and that represent at least 80% of the value of its net assets.” Please describe each underlying fund’s definition of ESG, areas of ESG focus, and related sustainability or ESG criteria.
Response: The Registrant notes that detailed information regarding each underlying fund’s definition of ESG, areas of ESG focus, and related sustainability or ESG criteria is included in the section “What are the funds’ and each underlying fund’s main investment strategies and related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each underlying fund’s ESG investment process in the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy,” which includes a discussion of each underlying fund’s definition of ESG,
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areas of ESG focus, and related sustainability or ESG criteria. Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
4. Comment: Please explain in the “Investments” section how the Funds’ managers consider ESG criteria in making investment decisions.
Response: The Registrant notes that a discussion of how each underlying fund’s managers consider ESG or other sustainability criteria in making investment decisions is included in the section “What are the funds’ and each underlying fund’s main investment strategies and related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each underlying fund’s ESG investment process in the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy,” which includes a discussion of how each underlying fund’s managers consider ESG or other sustainability criteria in making investment decisions. Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
5. Comment: In the “Investments” section, please explain how ESG criteria are weighed against one another.
Response: The Registrant notes that the relative weightings that an underlying fund’s managers ascribe to ESG or other sustainability criteria are not constant and may change over time, and, therefore, declines to add a specific discussion of how ESG or sustainability criteria are weighed against one another. The Registrants confirms, however, that a discussion of how each underlying fund’s managers identify and analyze ESG or other sustainability criteria is included in the section “What are the funds’ and each underlying fund’s main investment strategies and related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each underlying fund’s ESG investment process in the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy,” which includes a discussion of how each underlying fund’s managers identify and analyze ESG or other sustainability criteria. Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
6. Comment: In the second paragraph of the “Investments” section, please consider describing the range of asset classes, capitalization range, and geographic locations in which each underling fund may invest.
Response: The Registrant confirms that the requested disclosure will be added to the “Investments” section of the prospectus for each Fund, under the heading “Information about each underlying fund’s investment strategy.” Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
7. Comment: In the “Investments” section, please describe the criteria each Fund’s managers use in determining what issuers they consider to have ESG characteristics, consistent with each Fund’s chosen ESG definition or focus. In particular, please discuss whether a Fund’s managers select investments with reference to, for example, an ESG index, ESG scores, or data
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from a third-party ratings organization, a proprietary screening (as well as criteria that the screen applies), or a combination of the above methods.
Response: The Registrant notes that a discussion of the criteria each underlying fund’s managers use in determining what issuers they consider to have ESG or other sustainability characteristics is included in the section “What are the funds’ and each underlying fund’s main investment strategies and related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each underlying fund’s ESG investment process in the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy,” which includes a discussion of the criteria each underlying fund’s managers use in determining what issuers they consider to have ESG or other sustainability characteristics. Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
8. Comment: In the “Investments” section, please explain (i) whether a Fund’s ESG criteria are applied to every investment it makes or only to some of its investments and (ii) whether ESG criteria are the exclusive criteria considered by the Funds when making investment decisions or whether additional criteria are considered.
Response: The Registrant confirms that the requested disclosure will be added to the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy.” Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment and which includes the following statement (tailored as appropriate for each underlying fund) with respect to each underlying fund’s ESG process:
Putnam Management or PanAgora, as applicable, may not apply ESG or sustainability criteria to investments that are not subject to the underlying fund’s 80% policy, and such investments may not meet Putnam Management’s or PanAgora’s, as applicable, ESG or sustainability criteria.
9. Comment: The second paragraph of the “Investments” section states that, “[u]nder normal circumstances, the fund will invest in underlying funds such that, in the aggregate, it has indirect exposure to investments that meet Putnam Management’s or PanAgora’s, as applicable, sustainability or ESG criteria and that represent at least 80% of the value of its net assets.” Please supplementally confirm whether the underlying funds also have an 80% investment policy pursuant to Rule 35d-1 under the Investment Company Act with respect to sustainability or ESG criteria.
Response: The Registrant confirms that, as disclosed in the “What are the funds’ and each underlying fund’s main investment strategies and related risks?” section of the Funds’
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prospectus, each underlying fund has adopted an 80% investment policy pursuant to Rule 35d-1 under the Investment Company Act with respect to sustainability or ESG criteria. The Registrant also notes that each underlying fund’s 80% investment policy will be added to the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy.” Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
10. Comment: Please disclose the expected allocation of each Fund after it reaches the target date specified in its name.
Response: The Registrant respectfully declines to add any additional disclosure regarding each Fund’s expected allocation after it reaches the target date specified in its name because the following disclosure regarding each Fund’s target allocation near the end of its target year is already included in the “Investments” section:
It is assumed that investors will begin gradual withdrawals from the fund at around the target date. Near the end of the target date year, the fund’s target allocations will correspond to those of Putnam Sustainable Retirement Maturity Fund (Maturity Fund), a fund that seeks as high a rate of current income as Putnam Management believes is consistent with preservation of capital, and the fund will be merged into Maturity Fund.
Fund summary – Investments, risks, and performance – Risks
11. Comment: Please tailor “Foreign investment risk” and “Geographic focus risk” to reflect any risks that are specific to ESG investing.
Response: The Registrant confirms that “Foreign investment risk” and “Geographic focus risk” will be revised as follows:
Foreign investment risk. The value of international investments traded in foreign currencies may be adversely impacted by fluctuations in exchange rates. International investments, particularly investments in emerging markets, may carry risks associated with potentially less stable economies or governments (such as the risk of seizure by a foreign government, the imposition of currency or other restrictions, or high levels of inflation), and may be or become illiquid. There may be less publicly-available information, or less reliable publicly-available information, about foreign companies (including information related to companies’ ESG practices), particularly with respect to emerging market companies, than publicly-available information regarding U.S. companies. As a result, an underlying fund’s ability to evaluate a foreign company, including with respect to its ESG or sustainability practices, may be more limited than its ability to evaluate a U.S. company.
Geographic focus risk. From time to time, an underlying fund may invest a significant portion of its assets in companies in one or more related geographic regions, industries or sectors, such as European and Asian countries, which would make the fund more vulnerable to adverse developments affecting those geographic regions, industries or sectors, including political, economic, or other developments adversely impacting ESG or sustainable investing.
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12. Comment: Please ensure that the discussion regarding the risks of investing in derivatives that appears under the subheading “Derivatives risk” under the heading “Investment Strategy-Related Risks of the Underlying Funds” is appropriately tailored for each type
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CORRESP
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filename1.htm
a_retirereadycorresp.htm
Putnam Investments
100 Federal Street
Boston, MA 02110
November 10, 2022
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Timothy Worthington, Esq.
Re: Comments on Post-Effective Amendment No. 50 under the Securities Act of 1933, as amended, and Amendment
No. 51 under the Investment Company Act of 1940, as amended (the “Investment Company Act”), to the Registration Statement
on Form N-1A (File Nos. 333-117134 and 811-21598) (the “Registration Statement”) of Putnam Target Date Funds (the “Registrant”),
on behalf of Putnam RetirementReady 2025 Fund, Putnam RetirementReady 2030 Fund, Putnam RetirementReady 2035 Fund, Putnam RetirementReady
2040 Fund, Putnam RetirementReady 2045 Fund, Putnam RetirementReady 2050 Fund, Putnam RetirementReady 2055 Fund, Putnam RetirementReady
2060 Fund, Putnam RetirementReady 2065 Fund, and Putnam RetirementReady Maturity Fund (each, a “Fund” and collectively, the
“Funds”), filed with the Securities and Exchange Commission (the “Commission”) on July 1, 2022 (the “485(a)
Amendment”)
Dear Mr. Worthington:
This letter responds to
the comments that you provided to Peter T. Fariel of Putnam Investment Management, LLC (“Putnam Management”), investment adviser
to the Funds, and Timothy F. Cormier and Vania Cornelio of Ropes & Gray LLP, counsel to the Funds, on behalf of the Staff of the Commission
(the “Commission Staff”) on August 17, 2022 regarding the 485(a) Amendment. For convenience of reference, I have summarized
each of the Commission Staff’s comments before the Registrant’s response. These responses, as applicable, will be reflected
in the definitive version of the Registrant’s 485(b) filing pertaining to the Funds on Form N-1A expected to be filed with the Commission
on or around February 10, 2023 (the “485(b) Amendment”).1
References to specific text in the Commission Staff’s comments and the Registrant’s responses are to the corresponding text
of the 485(a) Amendment, as indicated.
1 As discussed with you on August 17, Putnam Management has determined that the repositioning of the Funds as an environmental, social, and governance- (“ESG”) focused target date suite (the “Repositioning”) will not occur until the first quarter of 2023 (currently expected to occur on or around February 10, 2023). Prior to that date, the Funds’ routine annual update will be filed on or around November 28, 2022, with a designated effective date of November 30, 2022. Because of this intervening annual update filing, the Registrant expects to make another Registration Statement amendment filing pursuant to Rule 485(a) to reflect the Repositioning shortly following the annual update, which will contain substantially identical information to that contained in the 485(a) Amendment, and will also include disclosure updates in response to the Commission Staff’s comments addressed in this letter and updated fee, expense, and financial data for the Funds’ most recently completed fiscal year. The Registrant has made two delaying amendment filings with respect to the 485(a) Amendment and intends to make a final delaying amendment filing on or around November 16 so that the 485(a) Amendment will not become effective prior to the annual update filing at the end of November.
General Comment
1. Comment: Please respond to all comments via correspondence on EDGAR no later than five business
days before the 485(b) Amendment is scheduled to become automatically effective. Please finalize the Registration Statement filed as the
485(b) Amendment with all brackets removed and all material information provided. If a comment results in a change to the disclosure language,
please include the revised disclosure in this letter. The Commission Staff notes that the Registrant is responsible for the adequacy and
accuracy of the Registration Statement.
Response: The Registrant confirms
that it is responding to all comments via this correspondence on EDGAR. The Registrant also confirms that it will revise the Registration
Statement filed as the 485(b) Amendment to remove all brackets and to provide all material information. The Registrant further confirms
that if a comment results in a change to the disclosure language, it will include the revised disclosure in this letter (or in Appendix
A to this letter). The Registrant acknowledges that it is responsible for the adequacy and accuracy of the Registration Statement.
Prospectus
Fund summary – Fees and expenses
2. Comment: Please bold the following language: “You may
pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples
below.”
Response: The Registrant confirms
that the requested change will be made.
Fund summary – Investments, risks,
and performance – Investments
3. Comment: The first sentence of the first paragraph of the “Investments” section states
that the Funds “invest in exchange-traded funds (“ETFs”) that focus on investments with positive sustainability or environmental,
social, and governance (“ESG”) characteristics, referred to as underlying funds.” The first sentence of the second paragraph
in that section then states that “[u]nder normal circumstances, the fund will invest in underlying funds such that, in the aggregate,
it has indirect exposure to investments that meet Putnam Management’s or PanAgora’s, as applicable, sustainability or ESG
criteria and that represent at least 80% of the value of its net assets.” Please describe each underlying fund’s definition
of ESG, areas of ESG focus, and related sustainability or ESG criteria.
Response: The Registrant notes
that detailed information regarding each underlying fund’s definition of ESG, areas of ESG focus, and related sustainability or
ESG criteria is included in the section “What are the funds’ and each underlying fund’s main investment strategies and
related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each underlying fund’s
ESG investment process in the “Investments” section of the prospectus for each Fund under the heading “Information about
each underlying fund’s investment strategy,” which includes a discussion of each underlying fund’s definition of ESG,
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areas of ESG focus, and related sustainability
or ESG criteria. Please see Appendix A to this letter for the above-referenced disclosure, which will be included in the
485(b) Amendment.
4. Comment: Please explain in the “Investments” section how the Funds’ managers
consider ESG criteria in making investment decisions.
Response: The Registrant notes
that a discussion of how each underlying fund’s managers consider ESG or other sustainability criteria in making investment decisions
is included in the section “What are the funds’ and each underlying fund’s main investment strategies and related risks?”
of the Funds’ prospectus. The Registrant has also determined to include a description of each underlying fund’s ESG investment
process in the “Investments” section of the prospectus for each Fund under the heading “Information about each underlying
fund’s investment strategy,” which includes a discussion of how each underlying fund’s managers consider ESG or other
sustainability criteria in making investment decisions. Please see Appendix A to this letter for the above-referenced disclosure,
which will be included in the 485(b) Amendment.
5. Comment: In the “Investments” section, please explain how ESG criteria are weighed
against one another.
Response: The Registrant notes
that the relative weightings that an underlying fund’s managers ascribe to ESG or other sustainability criteria are not constant
and may change over time, and, therefore, declines to add a specific discussion of how ESG or sustainability criteria are weighed against
one another. The Registrants confirms, however, that a discussion of how each underlying fund’s managers identify and analyze ESG
or other sustainability criteria is included in the section “What are the funds’ and each underlying fund’s main investment
strategies and related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each
underlying fund’s ESG investment process in the “Investments” section of the prospectus for each Fund under the heading
“Information about each underlying fund’s investment strategy,” which includes a discussion of how each underlying fund’s
managers identify and analyze ESG or other sustainability criteria. Please see Appendix A to this letter for the above-referenced
disclosure, which will be included in the 485(b) Amendment.
6. Comment: In the second paragraph of the “Investments” section, please consider describing
the range of asset classes, capitalization range, and geographic locations in which each underling fund may invest.
Response: The Registrant confirms
that the requested disclosure will be added to the “Investments” section of the prospectus for each Fund, under the heading
“Information about each underlying fund’s investment strategy.” Please see Appendix A to this letter for
the above-referenced disclosure, which will be included in the 485(b) Amendment.
7. Comment: In the “Investments” section, please describe the criteria each Fund’s
managers use in determining what issuers they consider to have ESG characteristics, consistent with each Fund’s chosen ESG definition
or focus. In particular, please discuss whether a Fund’s managers select investments with reference to, for example, an ESG index,
ESG scores, or data
-3-
from a third-party ratings organization,
a proprietary screening (as well as criteria that the screen applies), or a combination of the above methods.
Response: The Registrant notes
that a discussion of the criteria each underlying fund’s managers use in determining what issuers they consider to have ESG or other
sustainability characteristics is included in the section “What are the funds’ and each underlying fund’s main investment
strategies and related risks?” of the Funds’ prospectus. The Registrant has also determined to include a description of each
underlying fund’s ESG investment process in the “Investments” section of the prospectus for each Fund under the heading
“Information about each underlying fund’s investment strategy,” which includes a discussion of the criteria each underlying
fund’s managers use in determining what issuers they consider to have ESG or other sustainability characteristics. Please see Appendix
A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
8. Comment: In the “Investments” section, please explain (i) whether a Fund’s ESG
criteria are applied to every investment it makes or only to some of its investments and (ii) whether ESG criteria are the exclusive criteria
considered by the Funds when making investment decisions or whether additional criteria are considered.
Response: The Registrant confirms that the requested disclosure will be added to the “Investments” section of the prospectus for each Fund under the heading “Information about
each underlying fund’s investment strategy.” Please see Appendix A
to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment and which includes the following statement
(tailored as appropriate for each underlying fund) with respect to each underlying fund’s ESG process:
Putnam Management or PanAgora, as applicable,
may not apply ESG or sustainability criteria to investments that are not subject to the underlying fund’s 80% policy, and such investments
may not meet Putnam Management’s or PanAgora’s, as applicable, ESG or sustainability criteria.
9. Comment: The second paragraph of the “Investments” section states that, “[u]nder
normal circumstances, the fund will invest in underlying funds such that, in the aggregate, it has indirect exposure to investments that
meet Putnam Management’s or PanAgora’s, as applicable, sustainability or ESG criteria and that represent at least 80% of the
value of its net assets.” Please supplementally confirm whether the underlying funds also have an 80% investment policy pursuant
to Rule 35d-1 under the Investment Company Act with respect to sustainability or ESG criteria.
Response: The Registrant confirms
that, as disclosed in the “What are the funds’ and each underlying fund’s main investment strategies and related risks?”
section of the Funds’
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prospectus, each underlying fund has
adopted an 80% investment policy pursuant to Rule 35d-1 under the Investment Company Act with respect to sustainability or ESG criteria.
The Registrant also notes that each underlying fund’s 80% investment policy will be added to the “Investments” section
of the prospectus for each Fund under the heading “Information about each underlying fund’s investment strategy.” Please
see Appendix A to this letter for the above-referenced disclosure, which will be included in the 485(b) Amendment.
10. Comment: Please disclose the expected allocation of each Fund after it reaches the target date
specified in its name.
Response: The Registrant respectfully
declines to add any additional disclosure regarding each Fund’s expected allocation after it reaches the target date specified in
its name because the following disclosure regarding each Fund’s target allocation near the end of its target year is already included
in the “Investments” section:
It is assumed that investors will begin
gradual withdrawals from the fund at around the target date. Near the end of the target date year, the fund’s target allocations
will correspond to those of Putnam Sustainable Retirement Maturity Fund (Maturity Fund), a fund that seeks as high a rate of current income
as Putnam Management believes is consistent with preservation of capital, and the fund will be merged into Maturity Fund.
Fund summary
– Investments, risks, and performance – Risks
11. Comment: Please tailor “Foreign investment risk” and “Geographic focus
risk” to reflect any risks that are specific to ESG investing.
Response: The Registrant confirms
that “Foreign investment risk” and “Geographic focus risk” will be revised as follows:
Foreign
investment risk. The value of international investments traded in foreign currencies may be adversely impacted by fluctuations in
exchange rates. International investments, particularly investments in emerging markets, may carry risks associated with potentially less
stable economies or governments (such as the risk of seizure by a foreign government, the imposition of currency or other restrictions,
or high levels of inflation), and may be or become illiquid. There may be less publicly-available information, or less reliable
publicly-available information, about foreign companies (including information related to companies’ ESG practices), particularly
with respect to emerging market companies, than publicly-available information regarding U.S. companies. As a result, an underlying fund’s
ability to evaluate a foreign company, including with respect to its ESG or sustainability practices, may be more limited than its ability
to evaluate a U.S. company.
Geographic focus risk. From
time to time, an underlying fund may invest a significant portion of its assets in companies in one or more related geographic regions,
industries or sectors, such as European and Asian countries, which would make the fund more vulnerable to adverse developments affecting
those geographic regions, industries or sectors, including political, economic, or other developments adversely impacting ESG or
sustainable investing.
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12. Comment: Please ensure that the discussion regarding the risks of investing in derivatives that
appears under the subheading “Derivatives risk” under the heading “Investment Strategy-Related Risks of the Underlying
Funds” is appropriately tailored for each type