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Putnam Investments

100 Federal Street

Boston, MA 02110

January 26, 2023

    Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549

    Attn: Timothy Worthington, Esq.

 Re: Comments on Post-Effective Amendment No. 55 under the Securities Act of 1933, as amended, and Amendment
No. 56 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 December 9, 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 of Ropes & Gray LLP, counsel to the Funds, on behalf of the staff of the Commission (the “Commission
Staff”) on January 20, 2023 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
9, 2023 (the “485(b) Amendment”). 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.

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.

 2. Comment: The Commission Staff believes that the use of “Sustainable Retirement” in
each Fund’s name might suggest a guarantee of some level of performance. Please consider revising the name of each Fund to avoid
any confusion in this regard.

Response: The Registrant respectfully
notes that the use of “Sustainable” in each Fund’s name is intended to convey each Fund’s strategy of investing
in underlying Putnam Management-sponsored exchange-traded funds (“underlying funds”) that focus on investments with positive
sustainability or environmental, social, and governance (“ESG”) characteristics and believes that the first sentence under
the “Investments” section for each Fund makes this clear. The Registrant also notes that the second and third sentences of
the first paragraph of the “Risks” section for each Fund state that “[l]osses may occur near, at or after the target
date. There is no guarantee that the fund will provide adequate income at and through an investor’s retirement.” The Registrant
believes that, in light of the above-referenced disclosure, as well as the discussion of each Fund’s and underlying fund’s
investment strategies throughout the prospectus, it should be clear to investors that the use of “Sustainable Retirement”
in each Fund’s name is referring to each Fund’s strategy of investing in underlying funds with a focus on positive sustainability
or ESG characteristics and is not intended to suggest a guarantee of a “sustainable” level of performance or income. The Registrant,
therefore, respectfully declines to change the naming convention of the Funds.

Prospectus

Fund summary – Investments, risks,
and performance – Investments

 3. Comment: Please consider removing the disclosure under the heading “Information about each
underlying fund’s investment strategy” with respect to each underlying fund and adding a cross-reference indicating where
in the Funds’ prospectus disclosure regarding the underlying funds’ investment strategies may be found.

Response: The Registrant intends
to retain a brief introductory discussion of each underlying fund’s investment strategy under the heading “Information about
each underlying fund’s investment strategy,” as well as the 80% investment policy adopted pursuant to Rule 35d-1 under the
Investment Company Act for each underlying fund. The Registrant believes that preservation of this disclosure in the summary section of
the Funds’ prospectus will provide Fund investors with insight into their indirect exposure to the types of securities in which
the underlying funds will invest, as well the underlying funds’ investment approach. The Registrant will, however, remove the remainder
of the strategy disclosure under that heading and will include a cross reference stating that, “[f]or a further discussion of [the
underlying fund’s] investment strategy, please turn to the section What are the funds’ and each underlying

    -2-

fund’s main investment strategies
and related risks? beginning on page [ ].” Please see Appendix A to this letter for the above-referenced disclosure
revisions, which will be included in the 485(b) Amendment.

 4. Comment: In the first paragraph in the “Investments” section, please state (if accurate)
that each Fund does not emphasize one ESG factor over another when selecting underlying funds for investment and that each underlying
fund does not emphasize one ESG factor over another when selecting individual securities.

Response: The Registrant notes
that the relative weightings that an underlying fund’s managers ascribe to ESG factors are not constant and may change over time,
and, therefore, declines to add a specific statement that an underlying fund’s managers do not emphasize one ESG factor over another
when selecting individual securities. With respect to the Funds’ managers’ selection of underlying funds for investment, the
Registrant notes that, while the Funds’ predetermined glide path, as disclosed in the prospectus, generally drives allocations to
the underlying funds, the Funds’ managers may also consider the ESG weightings of an underlying fund as part of the overall investment
decision. Because these considerations and weightings will vary over time, the Registrant respectfully declines to add the requested disclosure.

 5. Comment: In the first paragraph in the “Investments” section, please state (if accurate)
that each Fund’s allocations to each underlying fund are based on each Fund’s desired allocation to equity and fixed income
asset classes and are not based on the underlying fund’s weighting or scoring of ESG factors.

Response: The Registrant notes
that, as discussed in the previous response, while the Funds’ predetermined glide path, as disclosed in the prospectus, generally
drives allocations to the underlying funds, the Funds’ managers reserve the right to also consider the ESG weightings of an underlying fund as part
of the overall investment decision. The Registrant, therefore, respectfully declines to add the requested disclosure.

 6. Comment: Referring to the table displaying each Fund’s expected, initial approximate allocations
to each asset class and underlying fund in the “Investments” section, please add “Total” in front of the “Equity”
and “Fixed Income” row headings to more clearly indicate that these two rows represent the total amount of assets allocated
to equity and fixed income for each Fund.

Response: The Registrant confirms
that the requested changes will be included in the 485(b) Amendment.

I believe that this letter
addresses the Commission Staff’s comments. Any questions on the 485(a) Amendment 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.

    -3-

Sincerely yours,

Peter T. Fariel

Putnam Investment Management, LLC

cc: Timothy F. Cormier, Ropes & Gray LLP

James E. Thomas, Ropes & Gray LLP

    -4-

Appendix A

Information about each underlying
fund’s investment strategy

Putnam Sustainable Leaders
ETF (“Sustainable Leaders ETF”)

Sustainable Leaders ETF invests
mainly in common stocks of U.S. companies of any size, with a focus on companies that Putnam Management believes exhibit a commitment
to financially material sustainable business practices. In evaluating investments for Sustainable Leaders ETF, Putnam Management views
“financially material sustainable business practices” as business practices that it believes are reasonably likely to impact
the financial condition or operating performance of a company and that relate to environmental, social, or corporate governance issues.

Putnam
Management identifies relevant environmental, social, or corporate governance issues on a sector-specific basis using an internally developed
materiality map, which is informed by the sustainability issues identified by the Sustainability Accounting Standards Board as material
to companies within a particular industry. A materiality map provides a guide to understanding which ESG criteria are more or less important
for a given sector or subsector; it includes those ESG criteria that may be reasonably likely to influence investment decision-making.
Putnam Management constructs the materiality map by evaluating the significance of specified ESG criteria (i.e., board structure and composition,
diversity, equity and inclusion, or climate change risk, among others) in specific industries (i.e., consumer, healthcare, financials,
etc.), subsectors, or countries. Putnam Management then categorizes the relevance of these ESG criteria for each industry, subsector,
or country. As part of this analysis, Putnam Management may utilize metrics and information such as emissions data, carbon intensity,
sources of energy used for operations, water use and re-use, water generation, waste diversion from landfill, employee safety and diversity
data, supplier audits, product safety, board composition, and incentive compensation structures. Stocks of companies that exhibit a commitment
to financially material sustainable business practices are typically, but not always, considered to be growth stocks. Growth stocks are
stocks of companies whose revenues, earnings, or cash flows are expected to grow faster than those of similar firms, and whose business
growth and other characteristics may lead to an increase in stock price. Sustainable Leaders ETF may consider, among other factors, a
company’s sustainable business practices (as described below), valuation, financial strength, growth potential, competitive position
in its industry, projected future earnings, cash flows and dividends when deciding whether to buy or sell investments.

Under normal circumstances,
Sustainable Leaders ETF invests at least 80% of the value of its net assets in securities that meet Putnam Management’s sustainability
criteria. These criteria are based on the proprietary materiality map described above. In applying these
criteria, Putnam Management will assign each company a proprietary environmental, social and/or corporate governance (ESG) rating ranging
from 1 to 4 (1 indicating the highest (best) ESG rating and 4 indicating the lowest (worst) ESG rating). In order to meet Putnam Management’s
sustainability criteria for purposes of this investment policy, a company must be rated 2 or 1 by Putnam Management. This policy is non-fundamental
and may be changed only after 60 days’ notice to shareholders. While Putnam Management may consider independent third-party data
as a part of its analytical process, the portfolio management team performs its own independent analysis of issuers and does not rely
solely on third-party screens. Putnam Management may not apply sustainability criteria to investments that are not subject to Sustainable
Leaders ETF’s 80% policy, and such investments may not meet Putnam Management’s sustainability criteria.For
a further

    A-1

Appendix A

discussion of Sustainable
Leaders ETF’s investment strategy, please turn to the section What are the funds’ and each underlying fund’s main
investment strategies and related risks? beginning on page [ ].

Putnam Sustainable Future
ETF (“Sustainable Future ETF”)

Sustainable
Future ETF invests mainly in common stocks of U.S. companies of any size, with a focus on companies whose products and services Putnam
Management believes provide solutions that directly contribute to sustainable social, environmental and economic development.

Putnam
Management’s approach to sustainable investing incorporates fundamental research together with consideration of sustainable environmental,
social and economic development impact. Putnam Management believes that companies whose products and services produce positive environmental,
social and economic development impact also often demonstrate potential for strong financial growth. Under normal circumstances,
Sustainable Future ETF invests at least 80% of the value of its net assets in securities
that meet Putnam Management’s sustainability criteria. These criteria are based on a proprietary
sustainability solutions map that links to the United Nations Sustainable Development Goals. In applying these criteria, Putnam Management
will assign each company a proprietary environmental, social and/or corporate governance (ESG) rating ranging from 1 to 4 (1 indicating
the highest (best) ESG rating and 4 indicating the lowest (worst) ESG rating). In order to meet Putnam Management’s sustainability
criteria for purposes of this investment policy, a company must be rated 2 or 1 by Putnam Management. This policy is non-fundamental and
may be changed only after 60 days’ notice to shareholders. In selecting each investment, Putnam Management considers the extent
to which a company’s products or services may provide solutions to forward-looking sustainability needs, creating positive impact
in environmental, social and economic development areas. While Putnam Management may consider independent third-party data as a part of
its analytical process, the portfolio management team performs its own independent analysis of issuers and does not rely solely on third-party
screens. Putnam Management may not apply sustainability criteria to investments that are not subject to Sustainable Future ETF’s
80% policy, and such investments may not meet Putnam Management’s sustainability criteria.For
a further discussion of Sustainable Future ETF’s investment strategy, please turn to the section What are the funds’ and
each underlying fund’s main investment strategies and related risks? beginning on page [ ].

Putnam PanAgora ESG International
Equity ETF (“PanAgora International Equity ETF”)

Putnam
PanAgora ESG Emerging Markets Equity ETF (“PanAgora Emerging Markets Equity ETF”)

PanAgora International Equity ETF invests mainly