Putnam Investor Services TA-1/A Registration as a transfer agent (amended)

Form TA-1 Filer Information	UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM TA-1/A	OMB APPROVAL
FORM TA-1/A		OMB Number:   3235-0084 Estimated average burden hours per response: 1.5

TA-1/A : Filer Information

Form Version X0405

1(a). Filer CIK:	0001448300
1(b). Filer CCC:	********
1(c). Is this a LIVE or TEST submission?	Live   Test
1(d). Would you like a Return Copy?	Yes

Submission Contact Information

The registrant may provide a single e-mail address for contact purposes.

1(f)(i). Contact Name:

1(f)(ii). Contact Phone Number:

1(f)(iii). Contact E-Mail Address:

Notification Information

The registrant may provide additional e-mail addresses for those persons the filer would like to receive notification e-mails regarding the filing.

1(g). Notification E-mail Address:

TA-1/A : Registrant Information

2. Appropriate regulatory agency (check one):   Securities and Exchange Commission     Federal Deposit Insurance Corporation     Comptroller of the Currency  

3(a). Full Name of Registrant:	Putnam Investor Services, Inc.
3(a)(i). Previous name, if being amended:	Putnam Investor Services Inc
3(b). Financial Industry Number (FINS) number:	338483

3(c). Address of principal office where transfer agent activities are, or will be, performed:

3(c)(i). Address 1	100 Federal Street
3(c)(ii). Address 2
3(c)(iii). City	Boston
3(c)(iv). State or Country	MASSACHUSETTS
3(c)(v). Postal Code	02110
3(d). Is Mailing address different from response to Question 3c? If "yes" provide address(es):	Yes   No
3(e). Telephone Number (Include Area Code)	617-292-1000
4. Does Registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Questions 3(c) above? If "Yes" provide address (es):	Yes   No
5. Does registrant act, or will it act, as a transfer agent solely for its own securities, and/or securities of an affiliate(s)?	Yes   No
6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions?	Yes   No

7. Has registrant been engaged, or will it be engaged as a service company by a named transfer agent to perform transfer agent functions?  Yes   No

TA-1/A : Independent, Non-Issuer Registrant Information

Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select "Not Applicable".

8. Is registrant a: Corporation

Section for Initial Registration and for Amendments Reporting Additional Persons.

corporation or partner information Related to item 8 Record: 1

8(a)(i). Full Name	Putnam U.S. Holdings I, LLC
8(a)(ii). Relationship Start Date	12/30/2008
8(a)(iii). Title or Status	Parent of Registrant
8(a)(iv). Ownership Code	E
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 2

8(a)(i). Full Name	Robert L. Reynolds
8(a)(ii). Relationship Start Date	10/16/2008
8(a)(iii). Title or Status	Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	01/02/2024

corporation or partner information Related to item 8 Record: 3

8(a)(i). Full Name	Steven D. Krichmar
8(a)(ii). Relationship Start Date	10/16/2008
8(a)(iii). Title or Status	Senior Managing Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	11/19/2016

corporation or partner information Related to item 8 Record: 4

8(a)(i). Full Name	Michael J. Woodall
8(a)(ii). Relationship Start Date	12/16/2016
8(a)(iii). Title or Status	President, Putnam Investor Services, Inc
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	01/04/2024

corporation or partner information Related to item 8 Record: 5

8(a)(i). Full Name	Clare Richer
8(a)(ii). Relationship Start Date	12/01/2008
8(a)(iii). Title or Status	Chief Financial Officer
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	06/01/2017

corporation or partner information Related to item 8 Record: 6

8(a)(i). Full Name	Andra S. Bolotin
8(a)(ii). Relationship Start Date	06/01/2017
8(a)(iii). Title or Status	Chief Financial Officer and Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	01/02/2024

corporation or partner information Related to item 8 Record: 7

8(a)(i). Full Name	Robert T. Burns
8(a)(ii). Relationship Start Date	05/13/2011
8(a)(iii). Title or Status	Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	06/30/2021

corporation or partner information Related to item 8 Record: 8

8(a)(i). Full Name	Aaron M. Cooper
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	EVP and Chief Operating Officer
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 9

8(a)(i). Full Name	Stephen J. Tate
8(a)(ii). Relationship Start Date	07/01/2021
8(a)(iii). Title or Status	Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 10

8(a)(i). Full Name	Heidi Croel
8(a)(ii). Relationship Start Date	01/04/2024
8(a)(iii). Title or Status	Director and President
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 11

8(a)(i). Full Name	Gwen Shaneyfelt
8(a)(ii). Relationship Start Date	01/04/2024
8(a)(iii). Title or Status	Director and CFO
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

9. Does any person or entity not named in the answer to Question 8:

9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant, or;….  Yes   No

Entity information Related to item 9(a) Record: 1

9(a)(i). Exact name of each person or entity:	Templeton Worldwide, Inc., Legg Mason, Inc., Franklin Resources, Inc.
9(a)(ii). Description of the Agreement or other basis:	Putnam Investor Services, Inc., is a wholly-owned subsidiary of Putnam U.S. Holdings I, LLC, which is a wholly-owned subsidiary of Templeton Worldwide, Inc., which is a wholly-owned subsidiary of Legg Mason, Inc., which is a wholly-owned subsidiary of Franklin Resources, Inc.

9(b). wholly or partially finance the business of the applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others?…..  Yes   No

TA-1/A : 10. Applicant and Control Affiliate Disciplinary History

The following definitions apply for purposes of answering this Question 10

Control Affiliate	- An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority.
Investment or investment related	- Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association).
Involved	- Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act.

10(a). In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contendere ("no contest") to:

10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting, or extortion?  Yes   No

10(a)(2). any other felony?  Yes   No

10(b). Has any court in the past ten years:
10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity?	Yes   No

10(b)(2). found that the applicant or control affiliate was involved in a violation of investment-related statutes or regulations?  Yes   No

10 (c). Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:
10(c)(1). found the applicant or control affiliate to have made a false statement or omission?	Yes   No

Entity information Related to item 10(c)(1) Record: 1

10(c)(1)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(1)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(c)(1)(iii). Date of Action	11/13/2003
10(c)(1)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(1)(v). Description of the Action	On November 13, 2003, the SEC entered an order making findings and imposing partial relief, including a final censure, remedial undertakings and a cease and desist order pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940 and Sections 9(b) and 9(f) of the Investment Company Act of 1940 and rule 17J-1(c) under the Investment Company Act of 1940 in connection with the personal trading of employees who allegedly engaged in excessive short-term trading (market timing) of Putnam Mutual Funds, and Putnam's failure to reasonably supervise such employees or to properly disclose such actions. Four of the individuals traded in mutual funds over which they had investment authority. In connection with this order, Putnam has agreed to undertake corporate governance, compliance and ethics reforms.
10(c)(1)(vi). The disposition of the proceeding	On April 8, 2004, Putnam entered into a settlement agreement with the SEC pursant to which it agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders of the funds.

Entity information Related to item 10(c)(1) Record: 2

10(c)(1)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(1)(ii). Title of Action	In the Matter of Putnam Investments Management, LLC
10(c)(1)(iii). Date of Action	03/23/2005
10(c)(1)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(1)(v). Description of the Action	On March 23, 2005 Putnam entered into a settlement agreement with the SEC with respect to the SEC's inquiry concerning Putnam's alleged failure to adequately disclose certain brokerage practices. These practices involved the allocation of brokerage to broker-dealers who sold shares of Putnam mutual funds. The settlement order states that Putnam failed to fully and effectively disclose to the Boards of Trustees and to shareholders of the Putnam funds the specifics of its preferred marketing agreements with certain brokerage firms selling Putnam fund shares. Putnam ceased directing brokerage to broker-dealers in connection with the sale of the fund shares as of January 1, 2004.
10(c)(1)(vi). The disposition of the proceeding	Under the settlement, Putnam paid a civil penalty in the amount of $40 million and disgorgement in the amount of $1. The total amount of the payment was paid to certain Putnam Funds.

Entity information Related to item 10(c)(1) Record: 3

10(c)(1)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(1)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(c)(1)(iii). Date of Action	09/28/2007
10(c)(1)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(1)(v). Description of the Action	On September 28, 2007 the SEC entered an order making findings and imposing remedial sanctions and a cease and desist order pursuant to Section 203(e) of the Investment Advisers Act of 1940 and Sections 9(b) and (f) of the Investment Company Act of 1940. The SEC found that Putnam violated Section 19(a) of the Investment Company Act of 1940 and Rule 19A-1 there under in connection with certain notices for shareholder distributions for four closed end investment companies: The Putnam Master Intermediate Trust, Putnam Premier Income Trust, Putnam Master Income Trust, and Putnam Managed High Yield Trust. The settlement order states that during the period from August 1, 2000 through May 31, 2002 these funds made distributions to shareholders partly funded from shareholder capital and that although Putnam, as administrator to the funds, sent written notices with these distributions, the notices did not contain the information required by Rule 19A-1 under The Investment Company Act of 1940.
10(c)(1)(vi). The disposition of the proceeding	Under the settlement, Putnam paid a civil penalty in the amount of $350,000.

10(c)(2). found the applicant or control affiliate to have been involved in a violation of its regulation or statutes?  Yes   No

Entity information Related to item 10(c)(2) Record: 1

10(c)(2)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(2)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(c)(2)(iii). Date of Action	11/13/2003
10(c)(2)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(2)(v). Description of the Action	On November 13, 2003, the SEC entered an order making findings and imposing partial relief, including a final censure, remedial undertakings and a cease and desist order pursuant to Sections 203(e) and 203(k) of The Investment Advisers Act of 1940 and Sections 9(b) and 9(f) of The Investment Company Act of 1940. The SEC found that Putnam violated Sections 203(e)(6), 206(1), 206(2) and 204A of The Investment Advisers Act of 1940 and Rule 17J-1(c) under the Investment Company Act of 1940 in connection with the personal trading of employees who allegedly engaged in excessive short-term trading (market timing) of Putnam Mutual Funds, and Putnam's failure to reasonably supervise such employees or to properly disclose such actions. Four of the individuals traded in mutual funds over which they had investment authority. In connection with this order, Putnam has agreed to undertake corporate governance, compliance and ethics reforms.
10(c)(2)(vi). The disposition of the proceeding	On April 8, 2004 Putnam entered into a settlement agreement with SEC pursuant to which it agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders of the funds.

Entity information Related to item 10(c)(2) Record: 2

10(c)(2)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(2)(ii). Title of Action	In the Matter of Putnam Investment Management LLC
10(c)(2)(iii). Date of Action	03/23/2005
10(c)(2)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(2)(v). Description of the Action	On March 23, 2005 Putnam entered into a settlement agreement with the SEC with respect to the SEC's inquiry concerning Putnam's alleged failure to adequately disclose certain brokerage practices. These practices involved the allocation of brokerage to broker-dealers who sold shares of Putnam mutual funds. The settlement order states that Putnam failed to fully and effectively disclose to the Boards of Trustees and to shareholders of the Putnam funds the specifics of its preferred marketing agreements with certain brokerage firms selling Putnam fund shares. Putnam ceased directing brokerage to broker-dealers in connection with the sale of the fund shares as of January 1, 2004.
10(c)(2)(vi). The disposition of the proceeding	Under the settlement, Putnam paid a civil penalty in the amount of $40 million and disgorgement in the amount of $1. The total amount of the payment was paid to certain Putnam Funds.

Entity information Related to item 10(c)(2) Record: 3

10(c)(2)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(2)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(c)(2)(iii). Date of Action	09/07/2006
10(c)(2)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(2)(v). Description of the Action	On September 7, 2006 the SEC entered into an order making findings and imposing relief including censure, remedial sanctions and a cease and desist order pursuant to Sections 203(e) and 203(k) of The Investments Advisers Act of 1940. The SEC found that Putnam violated Section 205(a) of The Investment Advisers Act in connection with the entering into or performing an advisory contract with the Putnam Research Fund (The Fund), a registered investment company, which provided for performance-based compensation to be computed based on the fund's daily net asset value over the quarter rather than based on the average net asset value for the 36 month performance period used for calculating the fee, as required by Rule 205 under The Advisers Act.
10(c)(2)(vi). The disposition of the proceeding	Putnam discontinued the method used for calculating the performance fee and reimbursed the fund for excess fees and interest totaling $1,650,601.

Entity information Related to item 10(c)(2) Record: 4

10(c)(2)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(c)(2)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(c)(2)(iii). Date of Action	09/28/2007
10(c)(2)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission
10(c)(2)(v). Description of the Action	On September 28, 2007 the SEC entered an order making findings and imposing remedial sanctions and a cease and desist order pursuant to Section 203(e) of the Investment Advisers Act of 1940 and Sections 9(b) and (f) of the Investment Company Act of 1940. The SEC found that Putnam violated Section 19(a) of the Investment Company Act of 1940 and Rule 19A-1 there under in connection with certain notices for shareholder distributions for four closed end investment companies: The Putnam Master Intermediate Trust, Putnam Premier Income Trust, Putnam Master Income Trust, and Putnam Managed High Yield Trust. The settlement order states that during the period from August 1, 2000 through May 31, 2002 these funds made distributions to shareholders partly funded from shareholder capital and that although Putnam, as administrator to the funds, sent written notices with these distributions, the notices did not contain the information required by Rule 19A-1 under The Investment Company Act of 1940.
10(c)(2)(vi). The disposition of the proceeding	Under the settlement, Putnam paid a civil penalty in the amount of $350,000.

Entity information Related to item 10(c)(2) Record: 5

10(c)(2)(i). The individuals named in the Action	GWFS Equities, Inc.
10(c)(2)(ii). Title of Action	In the Matter of GWFS Equities, Inc.
10(c)(2)(iii). Date of Action	05/07/2021
10(c)(2)(iv). The Court or body taking the Action and its location	Securities and Exchange Commission, Washington, DC
10(c)(2)(v). Description of the Action	On May 7, 2021, GWFS Equities, Inc. ("GWFS") entered into a settlement agreement with the SEC relating to past deficiencies in its filing of suspicious activity reports ("SARs"). The SEC found that GWFS filed certain reports without adequately describing the relevant incidents, and that it did not file SARs on other incidents, but did not conclude that any of the identified SAR deficiencies were intentional.
10(c)(2)(vi). The disposition of the proceeding	Refer to response D in the supplemental correspondence.

10(c)(3). found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?  Yes   No

10(c)(4). entered an order denying, suspending or revoking the applicant’s or control affiliate’s registration or otherwise disciplined it by restricting its activities?  Yes   No

10(d). Has any other Federal regulatory agency or any state regulatory agency :
10(d)(1). ever found the applicant or control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical?	Yes   No

Entity information Related to item 10(d)(1) Record: 1

10(d)(1)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(d)(1)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(d)(1)(iii). Date of Action	04/08/2004
10(d)(1)(iv). The Court or body taking the Action and its location	Massachusetts Securities Division
10(d)(1)(v). Description of the Action	On April 8, 2004, the Commonwealth of Massachusetts entered into a consent order with Putnam pursuant to an offer of settlement. The consent order found that Putnam violated Sections 101 and 102 of the Massachusetts Uniform Securities Act in connection with the personal trading of employees and certain DC/401K plans who allegedly engaged in excessive short-term trading. In connection with the consent order, Putnam admitted certain facts solely for the purpose of resolving the administrative proceeding.
10(d)(1)(vi). The disposition of the proceeding	Pursuant to the consent order, Putnam agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders of the funds.

10(d)(2). ever found the applicant or control affiliate to have been involved in a violation of investment-related regulations or statutes?  Yes   No

Entity information Related to item 10(d)(2) Record: 1

10(d)(2)(i). The individuals named in the Action	Putnam U.S. Holdings I, LLC
10(d)(2)(ii). Title of Action	Class A Share Issue
10(d)(2)(iii). Date of Action	07/29/2008
10(d)(2)(iv). The Court or body taking the Action and its location	United States Department of Labor
10(d)(2)(v). Description of the Action	On July 29, 2008, the Department of Labor entered into a settlement agreement with Putnam U.S. Holdings I, LLC concerning allegations that Putnam inappropriately offered, as investment options under the Putnam Investment Profit Sharing Retirement Plan, Class A shares in certain Putnam mutual funds which carried 12b-1 fees which were paid to Putnam Retail Management Limited Partnership, an affiliate of Putnam, in violation of sections 404(a)(1)(A), 406(a)(1)(D), 406(b)(1) and 406(b)(2) of ERISA.
10(d)(2)(vi). The disposition of the proceeding	Under the settlement, Putnam paid $270,000 in restitution to the Putnam Investments Profit Sharing Retirement Plan and a civil penalty of $27,000.

Entity information Related to item 10(d)(2) Record: 2

10(d)(2)(i). The individuals named in the Action	GWFS Equities, Inc.
10(d)(2)(ii). Title of Action	In re: GWFS Equities, Inc.
10(d)(2)(iii). Date of Action	03/05/2001
10(d)(2)(iv). The Court or body taking the Action and its location	State of Florida Division of Securities and Investor Protection
10(d)(2)(v). Description of the Action	Matter related to GWFS's failure to renew the Florida branch office location within prescribed time while continuing to conduct business.
10(d)(2)(vi). The disposition of the proceeding	Final Order - Stipulation and Consent Agreement to cease and desist and payment of administrative fine of $5,000.00; state agreed to approve branch office application upon receipt of fine.

Entity information Related to item 10(d)(2) Record: 3

10(d)(2)(i). The individuals named in the Action	GWFS Equities, Inc.
10(d)(2)(ii). Title of Action	In re: GWFS Equities, Inc.
10(d)(2)(iii). Date of Action	06/22/1993
10(d)(2)(iv). The Court or body taking the Action and its location	Michigan Securities Department
10(d)(2)(v). Description of the Action	GWFS, formerly known as Benefitscorp Equities, Inc., failed to respond to an inquiry from the Michigan Securities Department regarding the activities of an agent.
10(d)(2)(vi). The disposition of the proceeding	Benefitscorp Equities filed a consent order and paid a fine of $2,000.

Entity information Related to item 10(d)(2) Record: 4

10(d)(2)(i). The individuals named in the Action	Putnam Investment Management, LLC
10(d)(2)(ii). Title of Action	In the Matter of Putnam Investment Management, LLC
10(d)(2)(iii). Date of Action	04/08/2004
10(d)(2)(iv). The Court or body taking the Action and its location	Massachusetts Securities Divison
10(d)(2)(v). Description of the Action	On April 8, 2004, the Commonwealth of Massachusetts entered into a consent order with Putnam pursuant to an offer of settlement, the consent order found that Putnam violated Sections (101 and 102 of Massachusetts Uniform Securities Act in connection with the personal trading of employees and certain DC/401K plans who allegedly engaged in excessive short-term trading. In connection with the consent order, Putnam admitted certain facts solely for the purpose of resolving the administrative proceeding.
10(d)(2)(vi). The disposition of the proceeding	Pursuant to the consent order, Putnam agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders of the funds.

Entity information Related to item 10(d)(2) Record: 5

10(d)(2)(i). The individuals named in the Action	I.G. Investment Management, LTD (IGM)
10(d)(2)(ii). Title of Action	In re: I.G. Investment Management, LTD (IGM)
10(d)(2)(iii). Date of Action	12/22/2004
10(d)(2)(iv). The Court or body taking the Action and its location	Manitoba Securities Commission and Ontario Securities Commission
10(d)(2)(v). Description of the Action	Matter related to market timing trading conducted by one institutional investor (whose relationship was terminated by IGM in 2001) in certain investor group funds under management by IGM. The manager implemented measures to reduce harm to other investors in the funds from market timing activity, but these measures did not recognize all the costs of the client's trading activity.
10(d)(2)(vi). The disposition of the proceeding	Under the terms of a settlement agreement with the Manitoba Securities Commission and the Ontario Securities Commission, IGM paid restitution of $19.2 million to investors of the funds in which the market timing had occurred.

Entity information Related to item 10(d)(2) Record: 6

10(d)(2)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(d)(2)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(d)(2)(iii). Date of Action	10/18/2006
10(d)(2)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(d)(2)(v). Description of the Action	Action related to failure of Investors Group Financial Services, Inc. and its then affiliate, LES Services Investors LTD, which amalgamated with Investors Group Financial Services, Inc., on January 1, 2006 to file termination notices within prescribed time periods and failing to reinstate a salesperson's registration before conducting registerable activity. Also related failure by LES Services Investors LTD to be registered in Nova Scotia when trading with clients.
10(d)(2)(vi). The disposition of the proceeding	Settlement with payment of $25,000 fine and costs of $2,500 approved by staff of Nova Scotia Securities Commission.

Entity information Related to item 10(d)(2) Record: 7

10(d)(2)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(d)(2)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(d)(2)(iii). Date of Action	01/09/2006
10(d)(2)(iv). The Court or body taking the Action and its location	New Brunswick Securities Commission
10(d)(2)(v). Description of the Action	New Brunswick Securities Commission (NBSC) alleged that Investors Group Financial Services, Inc. had violated Section 45 of the Securities Act (New Brunswick) - Trading in Securities without Registration. The unregistered activity was conducted by salespersons of LES Services Investors, LTD, an affiliate that amalgamated with IGFS on January 1, 2006.
10(d)(2)(vi). The disposition of the proceeding	NBSC issued an order on January 19, 2006 approving a settlement agreement where IGFS paid a penalty and costs of $68,200.

Entity information Related to item 10(d)(2) Record: 8

10(d)(2)(i). The individuals named in the Action	IPC Securities Corporation
10(d)(2)(ii). Title of Action	In re: IPC Securities Corporation
10(d)(2)(iii). Date of Action	01/01/2006
10(d)(2)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(d)(2)(v). Description of the Action	Nova Scotia Securities Commission (NSSC) found that IPC Securities Corporation was in violation of Sections 22, 134, 135 and 135A of the Securities Act (Nova Scotia) in connection with allowing approved person to operate out of the Wolfville office prior to receiving an exemption request from the NSSC.
10(d)(2)(vi). The disposition of the proceeding	Pursuant to a settlement agreement with NSSC, IPC Securities Corporation paid an administrative penalty of $10,000 and costs of $2,500.

Entity information Related to item 10(d)(2) Record: 9

10(d)(2)(i). The individuals named in the Action	IPC Securities Corporation (IPC)
10(d)(2)(ii). Title of Action	In re: IPC Securities Corporation (IPC)
10(d)(2)(iii). Date of Action	03/18/2004
10(d)(2)(iv). The Court or body taking the Action and its location	Investment Dealers Association of Canada (IDA)
10(d)(2)(v). Description of the Action	Pursuant to settlement agreement, IPC admitted that they (a) failed to maintain adequate records of supervisor activity in accordance with IDA requirements concerning head office account supervision and thereby contravened IDA by-law 29.27 principal trading done on its behalf, contrary to IDA by law 29.27(A)(1) and (VI) and (b) failed to maintain its risk adjusted capital at a level greater than zero calculated in accordance with IDA Form 1, contrary to IDA by-law 17.1
10(d)(2)(vi). The disposition of the proceeding	IPC paid a monetary fine of $100,000.

Entity information Related to item 10(d)(2) Record: 10

10(d)(2)(i). The individuals named in the Action	IPC Investment Corporation (IPC)
10(d)(2)(ii). Title of Action	In re: IPC Investment Corporation
10(d)(2)(iii). Date of Action	12/06/2001
10(d)(2)(iv). The Court or body taking the Action and its location	New Brunswick Securities Commission (NBSC)
10(d)(2)(v). Description of the Action	Matter related to unregistered trading activity conducted by a salesperson of an affiliate, Henry Hicks and Associates, LTD, which amalgamated with IPC effective May 16, 2001.
10(d)(2)(vi). The disposition of the proceeding	IPC paid a monetary penalty of $14,400, including administrative costs.

Entity information Related to item 10(d)(2) Record: 11

10(d)(2)(i). The individuals named in the Action	IPC Investment Corporation (IPC)
10(d)(2)(ii). Title of Action	In re: IPC Investment Corporation
10(d)(2)(iii). Date of Action	11/30/2009
10(d)(2)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(d)(2)(v). Description of the Action	Matter related to contraventions of Sections 31(1) and 61 of the Nova Scotia Securities Regulations for failure to ensure securities purchased by 3 clients were suitable, for failing to address the complaint made by one of these 3 clients in a manner that was fair, honest, or in good faith.
10(d)(2)(vi). The disposition of the proceeding	Nova Scotia Securities Commission issued an order approving a settlement agreement with IPC, under which IPC agreed to pay an administrative penalty in the amount of $40,000 and costs of the Nova Scotia Securities Commission in the amount of $3,000.

Entity information Related to item 10(d)(2) Record: 12

10(d)(2)(i). The individuals named in the Action	IPC Securities Corporation (IPC)
10(d)(2)(ii). Title of Action	In re: IPC Securities Corporation
10(d)(2)(iii). Date of Action	06/01/2010
10(d)(2)(iv). The Court or body taking the Action and its location	Investment Industry Regulatory Organization Of Canada
10(d)(2)(v). Description of the Action	Action related to failure to establish and maintain adequate policies and procedures to ensure that clients qualified as accredited investors in accordance with provisions of Ontario Securities Act.
10(d)(2)(vi). The disposition of the proceeding	Investment Industry Regulatory Organization Of Canada approved a settlement agreement with IPC under which IPC agreed to pay a fine in the amount of $65,000 and costs of $10,000.

Entity information Related to item 10(d)(2) Record: 13

10(d)(2)(i). The individuals named in the Action	Quadrus Investment Services Ltd
10(d)(2)(ii). Title of Action	In re: Quadrus Investment Services Ltd
10(d)(2)(iii). Date of Action	07/30/2015
10(d)(2)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(d)(2)(v). Description of the Action	Matter related to violation of Section 31(1) of the Securities Regulations, as Rep. by Rule 31801 for failure to supervise the activities of a Mutual Fund Salesperson.
10(d)(2)(vi). The disposition of the proceeding	Quadrus Investment Services Ltd. agreed to pay a fine in the amount of $40,000 and costs in the amount of $1,000.

Entity information Related to item 10(d)(2) Record: 14

10(d)(2)(i). The individuals named in the Action	I.G. Investment Management, Ltd. (IGIM)
10(d)(2)(ii). Title of Action	In re: I.G. Investment Management, Ltd
10(d)(2)(iii). Date of Action	08/12/2015
10(d)(2)(iv). The Court or body taking the Action and its location	Financial Services Commission Of Ontario
10(d)(2)(v). Description of the Action	In connection with IGIMs license as a Mortgage Broker under the Mortgage Brokers, Lenders and Administrators Act (Ontario) (the "Act"), the Superintendent of Financial Services Ontario issued an Administrative Mandatory Penalty Order (the Order) against IGIM for failing to meet certain administrative requirements under the Act and/or its regulations. IGIM has addressed or is addressing the deficiencies identified in the order.
10(d)(2)(vi). The disposition of the proceeding	Administrative Mandatory Penalty Order against IGIM in the total amount of $4,500.

Entity information Related to item 10(d)(2) Record: 15

10(d)(2)(i). The individuals named in the Action	IPC Securities Corporation (IPC)
10(d)(2)(ii). Title of Action	In re: IPC Securities Corporation
10(d)(2)(iii). Date of Action	08/29/2016
10(d)(2)(iv). The Court or body taking the Action and its location	Investment Industry Regulatory Organization Of Canada
10(d)(2)(v). Description of the Action	Matter related related to IPCs failure between January and June 2014, to conduct strict supervision of a registered representative pursuant to acknowledge and consent provided to the Investment Industry Regulatory Organization Of Canada (IIROC)contrary to IIROC Dealer Member Rules 29.1 and 2500.
10(d)(2)(vi). The disposition of the proceeding	Investment Industry Regulatory Organization Of Canada approved a settlement agreement with IPC under which IPC agreed to pay a fine in the amount of $65,000 and costs of $5,000. Payments totaled $70,000.

Entity information Related to item 10(d)(2) Record: 16

10(d)(2)(i). The individuals named in the Action	Quadrus Investment Services Ltd.
10(d)(2)(ii). Title of Action	In re: Quadrus Investment Services Ltd.
10(d)(2)(iii). Date of Action	11/17/2016
10(d)(2)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association Of Canada (MFDA)
10(d)(2)(v). Description of the Action	Matter related to Quadrus's failure to appropriately supervise the activities of a Dealing Representative during the period from March, 2009 to July, 2015 and provide certain notices to the MFDA with respect to same, pursuant to MFDA Rules 2.1.1, 2.1.4, 2.3.1 and 2.5.1, and MFDA Policy No. 6.
10(d)(2)(vi). The disposition of the proceeding	MFDA approved a settlement agreement with Quadrus under which Quadrus agreed to pay a fine in the amount of $70,000 and costs of $20,000. Payments totaled $95,000.

Entity information Related to item 10(d)(2) Record: 17

10(d)(2)(i). The individuals named in the Action	Quadrus Investment Services Ltd.
10(d)(2)(ii). Title of Action	In re: Quadrus Investment Services Ltd.
10(d)(2)(iii). Date of Action	11/10/2015
10(d)(2)(iv). The Court or body taking the Action and its location	Ontario Securities Commission (OSC)
10(d)(2)(v). Description of the Action	Quadrus Investment Services Ltd. (Quadrus) entered a settlement agreement with the Ontario Securities Commission (OSC) relating to allegations that Quadrus had, as a result of certain control and supervision inadequacies, charged certain mutual fund clients an excess fee. OSC staff were satisfied that Quadrus discovered and self-reported the issue.
10(d)(2)(vi). The disposition of the proceeding	Settlement included appropriate compensation to affected clients, voluntary reimbursement to OSC for costs incurred of $20,000, and voluntary payment to OSC of $250,000 to be allocated to third parties or investor education. Payments totaled $270,000.

10(d)(3). ever found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business Denied, suspended, revoked or restricted?  Yes   No

10(d)(4). in the past ten years entered an order against the applicant or control affiliate in connection with investment-related activity?  Yes   No

Entity information Related to item 10(d)(4) Record: 1

10(d)(4)(i). The individuals named in the Action	Putnam U.S. Holdings I, LLC
10(d)(4)(ii). Title of Action	Class A Share Issue
10(d)(4)(iii). Date of Action	07/29/2008
10(d)(4)(iv). The Court or body taking the Action and its location	United States Department of Labor
10(d)(4)(v). Description of the Action	On July 29, 2008, the Department of Labor entered into a settlement agreement with Putnam U.S. Holdings I, LLC concerning allegations that Putnam inappropriately offered, as investment options under the Putnam Investment Profit Sharing Retirement Plan, Class A shares in certain Putnam mutual funds which carried 12b-1 fees which were paid to Putnam Retail Management Limited Partnership, an affiliate of Putnam, in violation of sections 404(a)(1)(A), 406(a)(1)(D), 406(b)(1) and 406(b)(2) of ERISA.
10(d)(4)(vi). The disposition of the proceeding	Under the settlement, Putnam paid $270,000 in restitution to the Putnam Investments Profit Sharing Retirement Plan and a civil penalty of $27,000.

Entity information Related to item 10(d)(4) Record: 2

10(d)(4)(i). The individuals named in the Action	IPC Investment Corporation (IPC)
10(d)(4)(ii). Title of Action	In re: IPC Investment Corporation
10(d)(4)(iii). Date of Action	11/30/2009
10(d)(4)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(d)(4)(v). Description of the Action	Matter related to contraventions of Sections 31(1) and 61 of the Nova Scotia Securities Regulations for failure to ensure securities purchased by 3 clients were suitable, for failing to address the complaint made by one of these 3 clients in a manner that was fair, honest, or in good faith.
10(d)(4)(vi). The disposition of the proceeding	Nova Scotia Securities Commission issued an order approving a settlement agreement with IPC, under which IPC agreed to pay an administrative penalty in the amount of $40,000 and costs of the Nova Scotia Securities Commission in the amount of $3,000.

Entity information Related to item 10(d)(4) Record: 3

10(d)(4)(i). The individuals named in the Action	Partners In Planning Financial Services Ltd.
10(d)(4)(ii). Title of Action	In re: Partners In Planning Financial Services Ltd.
10(d)(4)(iii). Date of Action	11/25/2010
10(d)(4)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association Of Canada (MFDA)
10(d)(4)(v). Description of the Action	Partners In Planning Financial Services Ltd (PIP), a foreign control affiliate, was found to have inadequate policies and procedures for head office supervision of leveraged trades and inadequate supervision of leveraged trades at the branches, contrary to MFDA Rules 2.2.1, 2.5.1, 2.10, 2.5.2(b), 2.5.3(b) and 2.5.4 and MFDA Policy No. 2.
10(d)(4)(vi). The disposition of the proceeding	MFDA ordered a monetary penalty in the amount of $20,000 and costs of $2,500. PIP also agreed to appoint an independent consultant at PIPs expense to assist in resolving the leveraged trading issues.

Entity information Related to item 10(d)(4) Record: 4

10(d)(4)(i). The individuals named in the Action	The Putnam Advisory Company LLC
10(d)(4)(ii). Title of Action	In re: The Putnam Advisory Company LLC
10(d)(4)(iii). Date of Action	05/05/2014
10(d)(4)(iv). The Court or body taking the Action and its location	Secretary, Commonwealth Of Massachusetts, Securities Division
10(d)(4)(v). Description of the Action	On October 17, 2012, the Massachusetts Securities Division (MSD) filed an administrative action containing allegations against The Putnam Advisory Company, LLC (PAC) as collateral manager of two collateralized debt obligations (CDOs).
10(d)(4)(vi). The disposition of the proceeding	The matter was settled by payment to the Commonwealth of $950,000 and an agreement to cease and desist from any violation of the Massachusetts Uniform Securities Act and its related regulations.

Entity information Related to item 10(d)(4) Record: 5

10(d)(4)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(d)(4)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(d)(4)(iii). Date of Action	12/15/2017
10(d)(4)(iv). The Court or body taking the Action and its location	The Manitoba Securities Commission (MSC)
10(d)(4)(v). Description of the Action	Action relates to the fact that Investors Group Financial Services, Inc. and Investors Group Securities Inc. (collectively "Investors Group") did not establish, maintain and apply policies and procedures to establish a system of controls and supervision that consistently ensured that the holders of Investors Group funds who were eligible for a lower MER series of the same fund were so advised in a timely manner.
10(d)(4)(vi). The disposition of the proceeding	The MSC approved a settlement agreement with Investors Group under which Investors Group agreed to make a voluntary one-time payment to the Treasury of the Province of Manitoba in the amount of$750,000 and costs payable to the MSC in the amount of$30,000.

Entity information Related to item 10(d)(4) Record: 6

10(d)(4)(i). The individuals named in the Action	Investors Group Securities, Inc.
10(d)(4)(ii). Title of Action	In re: Investors Group Securities, Inc.
10(d)(4)(iii). Date of Action	12/15/2017
10(d)(4)(iv). The Court or body taking the Action and its location	The Manitoba Securities Commission (MSC)
10(d)(4)(v). Description of the Action	Action relates to the fact that Investors Group Financial Services, Inc. and Investors Group Securities Inc. (collectively "Investors Group") did not establish, maintain and apply policies and procedures to establish a system of controls and supervision that consistently ensured that the holders of Investors Group funds who were eligible for a lower MER series of the same fund were so advised in a timely manner.
10(d)(4)(vi). The disposition of the proceeding	The MSC approved a settlement agreement with Investors Group under which Investors Group agreed to make a voluntary one-time payment to the Treasury of the Province of Manitoba in the amount of$750,000 and costs payable to the MSC in the amount of$30,000.

10(d)(5). ever denied, suspended, or revoked applicant’s or control affiliate’s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities?  Yes   No

10(d)(6). ever revoked or suspended the applicant’s or a control affiliate’s license as an attorney or accountant?  Yes   No

10(e). Has any self-regulatory organization or commodities exchange ever:

10(e)(1). found the applicant or a control affiliate to have made a false statement or omission?  Yes   No

10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules?  Yes   No

Entity information Related to item 10(e)(2) Record: 1

10(e)(2)(i). The individuals named in the Action	Putnam Retail Management Limited Partnership
10(e)(2)(ii). Title of Action	Putnam Retail Management Limited Partnership CRD No. 7325
10(e)(2)(iii). Date of Action	10/03/2006
10(e)(2)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers
10(e)(2)(v). Description of the Action	Putnam Retail Management Limited Partnership entered into an Acceptance, Waiver and Consent (AWC) with the NASD regarding allegations that Putnam violated NASD Conduct Rules 2830(I)5, 2820(g)4 and 2110 by paying for or reimbursing guest meals and ground transportation expenses during the period of 2001 to 2004 and providing and paying for entertainment at two training and educational meetings. In addition, the AWC resolved allegations that Putnam violated Rules 3010 and 2110 by failing to properly supervise its non-cash compensation spending and failing to enforce its policies and procedures to ensure compliance with the NASD's non-cash compensation rules.
10(e)(2)(vi). The disposition of the proceeding	Under the AWC, Putnam received a censure and paid a fine of $175,000.

Entity information Related to item 10(e)(2) Record: 2

10(e)(2)(i). The individuals named in the Action	GWFS Equities, Inc.
10(e)(2)(ii). Title of Action	In re: GWFS Equities, Inc.
10(e)(2)(iii). Date of Action	05/29/1985
10(e)(2)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers
10(e)(2)(v). Description of the Action	A routine exam of American Capital Planning, Inc., discovered that the firm was in violation of SEC Rule 15c3-1 (net capital rule). The violation was incurred due to the improper treatment of concessions receivable and related concessions payable.
10(e)(2)(vi). The disposition of the proceeding	Monetary fine of $1,000.

Entity information Related to item 10(e)(2) Record: 3

10(e)(2)(i). The individuals named in the Action	Putnam Retail Management Limited Partnership
10(e)(2)(ii). Title of Action	In re: Putnam Retail Management Limited Partnership
10(e)(2)(iii). Date of Action	05/05/1972
10(e)(2)(iv). The Court or body taking the Action and its location	NASD - District Business Conduct Committee of District 13
10(e)(2)(v). Description of the Action	The Committee found reason to believe that Putnam Retail Management had violated Section 1 of Article III of the Rules of Fair Practice during the period of 12/1968 - 2/1971 through its failure to comply with one or more provisions of Regulation T of the Board of Governors of the Federal Reserve System.
10(e)(2)(vi). The disposition of the proceeding	The matter was settled upon the imposition of a censure and fine of $500.

Entity information Related to item 10(e)(2) Record: 4

10(e)(2)(i). The individuals named in the Action	GRS Securities Inc. (GRSSI)
10(e)(2)(ii). Title of Action	In re: GRS Securities Inc.
10(e)(2)(iii). Date of Action	03/28/2006
10(e)(2)(iv). The Court or body taking the Action and its location	Investment Dealers Association Of Canada (IDA)
10(e)(2)(v). Description of the Action	GRSSI held the assets of client investment plans with a trust company that, unknown to it, did not meet certain requirements of an acceptable securities location. As such, the assets were not allowable assets for the purposes of regulatory capital requirements and, for a short period of time until the matter was rectified, GRSSI did not meet the IDA capital adequacy requirements.
10(e)(2)(vi). The disposition of the proceeding	The matter was disposed of by way of settlement agreement approved by IDA district council. $40,000 plus costs of $7000, fully paid by GRSSI, none waived.

Entity information Related to item 10(e)(2) Record: 5

10(e)(2)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(e)(2)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(e)(2)(iii). Date of Action	12/16/2004
10(e)(2)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association Of Canada (MFDA)
10(e)(2)(v). Description of the Action	This matter related to market timing trading by one institutional client of Investors Group in certain Investors Group funds. Investors Group Financial Services Inc. entered into a Settlement Agreement with MFDA which was approved on December 16, 2004. and under which Investors Group Financial Services Inc. agreed to pay $2.65 million in compensation in investors of mutual funds where market timing occurred, a fine of $2.65 million payable to MFDA, and $50,000 in costs.
10(e)(2)(vi). The disposition of the proceeding	Under the settlement agreement, Investors Group Financial Services Inc. agreed to pay $2.65 million in compensation in investors of mutual funds where market timing occurred, a fine of $2.65 million payable to MFDA, and $50,000 in costs.

Entity information Related to item 10(e)(2) Record: 6

10(e)(2)(i). The individuals named in the Action	Excel Private Wealth Inc. (Excel)
10(e)(2)(ii). Title of Action	In re: Excel Private Wealth Inc.
10(e)(2)(iii). Date of Action	09/06/2018
10(e)(2)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association of Canada (MFDA).
10(e)(2)(v). Description of the Action	Matter related to Excel's violation of MFDA Rule 2.5.1 and MFDA Policy No.2 for failure to: (a) conduct adequate due diligence on an Approved Person (as defined under MFDA By-Law No.1) between August 20, 2014 and September 16, 2014; (b) maintain a tier two supervision structure for its Approved Persons from April 2016 to December 2016; and (c) conduct supervisory reviews of quarterly trend analysis reports.
10(e)(2)(vi). The disposition of the proceeding	Excel entered into a settlement agreement with the MFDA, under which Excel agreed to pay a fine in the amount of $40,000 and costs in the amount of $7,500.

Entity information Related to item 10(e)(2) Record: 7

10(e)(2)(i). The individuals named in the Action	Investors Group Financial Services Inc. (IGFS)
10(e)(2)(ii). Title of Action	In re: Investors Group Financial Services Inc.
10(e)(2)(iii). Date of Action	05/17/2019
10(e)(2)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association of Canada (MFDA)
10(e)(2)(v). Description of the Action	IGFS entered into a settlement agreement with the MFDA in which IGFS admitted that it failed to adequately query the suitability of the recommendation and sale of mutual funds subject to deferred sales charges ("DSC") to two elderly clients, which occurred between May 2013 and July 2014, contrary to MFDA Rule 2.2.1 and 2.5.1 and MFDA Policy No. 2. The settlement agreement notes that IGFS fully cooperated with the MFDA's investigation of the issues making up the subject matter of the agreement and that the DSC fees incurred in these cases were reimbursed. It also notes that since the events at issue, IGFS made significant changes to its policies concerning the sale of DSC mutual funds, including, without limitation, that IGFS discontinued purchases of is propriety mutual funds that would trigger DSCs on redemption for all clients as of January 1,2017. Other enhancements to IGFS's compliance oversight regime were also implemented and are outlined in the settlement agreement.
10(e)(2)(vi). The disposition of the proceeding	IGFS agreed to pay a fine in the amount of $150,000 and costs in the amount of $15,000.

Entity information Related to item 10(e)(2) Record: 8

10(e)(2)(i). The individuals named in the Action	Quadrus Investment Services Ltd. (Quadrus)
10(e)(2)(ii). Title of Action	In Re: Quadrus Investment Services Ltd.
10(e)(2)(iii). Date of Action	11/23/2021
10(e)(2)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association of Canada (MFDA), Toronto, ON
10(e)(2)(v). Description of the Action	Matter related to Quadrus's failure from 2002 to 2018 to establish and maintain an adequate system of controls and supervision to ensure that it complied with securities legislation including relating to internal dealer incentive and sales practices, contrary to MFDA Rules 2.5.1 and 2.1.1.
10(e)(2)(vi). The disposition of the proceeding	Quadrus entered into a settlement agreement with the MFDA, under which it agreed to pay a fine in the amount of $600,000 and costs in the amount of $25,000.

10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business?  Yes   No

10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities?  Yes   No

10(f). Has any foreign government, court, regulatory agency or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud?  Yes   No

Entity information Related to item 10(f) Record: 1

10(f)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(f)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(f)(iii). Date of Action	10/18/2006
10(f)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(f)(v). Description of the Action	Action related to failure of Investors Group Financial Services, Inc., and its then affiliate, LES Services Investors LTD, which amalgamated with Investors Group Financial Services, Inc., on January 1, 2006 to file termination notices within prescribed time periods and failing to reinstate a salesperson's registration before conducting registerable activity. Also related failure by LES Services Investors LTD to be registered in Nova Scotia when trading with clients.
10(f)(vi). The disposition of the proceeding	Settlement with payment of $25,000 fine and costs of $2,500 approved by staff of Nova Scotia Securities Commission.

Entity information Related to item 10(f) Record: 2

10(f)(i). The individuals named in the Action	IPC Securities Corporation
10(f)(ii). Title of Action	In re: IPC Securities Corporation
10(f)(iii). Date of Action	01/01/2006
10(f)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(f)(v). Description of the Action	Nova Scotia Securities Commission (NSSC) found that IPC Securities Corporation was in violation of Sections 22, 134, 135 and 135A of the Securities Act (Nova Scotia) in connection with allowing approved person to operate out of the Wolfville office prior to receiving an exemption request from the NSSC.
10(f)(vi). The disposition of the proceeding	Pursuant to a settlement agreement with NSSC, IPC Securities Corporation paid an administrative penalty of $10,000 and costs of $2,500.

Entity information Related to item 10(f) Record: 3

10(f)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(f)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(f)(iii). Date of Action	01/09/2006
10(f)(iv). The Court or body taking the Action and its location	New Brunswick Securities Commission
10(f)(v). Description of the Action	New Brunswick Securities Commission (NBSC) alleged that Investors Group Financial Services, Inc. had violated Section 45 of the Securities Act (New Brunswick) - Trading in Securities without Registration. The unregistered activity was conducted by salespersons of LES Services Investors, LTD, an affiliate that amalgamated with IGFS on January 1, 2006.
10(f)(vi). The disposition of the proceeding	NBSC issued an order on January 19, 2006 approving a settlement agreement where IGFS paid a penalty and costs of $68,200.

Entity information Related to item 10(f) Record: 4

10(f)(i). The individuals named in the Action	I.G. Investment Management, LTD (IGM)
10(f)(ii). Title of Action	In re: I.G. Investment Management, LTD (IGM)
10(f)(iii). Date of Action	12/22/2004
10(f)(iv). The Court or body taking the Action and its location	Manitoba Securities Commission and Ontario Securities Commission
10(f)(v). Description of the Action	Matter related to market timing trading conducted by one institutional investor (whose relationship was terminated by IGM in 2001) in certain Investor Group funds under management by IGM. The manager implemented measures to reduce harm to other investors in the funds from market timing activity, but these measures did not recognize all the costs of the client's trading activity.
10(f)(vi). The disposition of the proceeding	Under the terms of a settlement agreement with the Manitoba Securities Commission and the Ontario Securities Commission, IGM paid restitution of $19.2 million to investors of the funds in which the market timing had occurred.

Entity information Related to item 10(f) Record: 5

10(f)(i). The individuals named in the Action	IPC Securities Corporation (IPC)
10(f)(ii). Title of Action	In re: IPC Securities Corporation (IPC)
10(f)(iii). Date of Action	03/18/2004
10(f)(iv). The Court or body taking the Action and its location	Investment Dealers Association of Canada (IDA)
10(f)(v). Description of the Action	Pursuant to settlement agreement, IPC admitted that they (a) failed to maintain adequate records of supervisor activity in accordance with IDA requirements concerning head office account supervision and thereby contravened IDA by-law 29.27 principal trading done on its behalf, contrary to IDA by-law 29.27(A)(1) and (VI) and (b) failed to maintain its risk adjusted capital at a level greater than zero calculated in accordance with IDA Form 1, contrary to IDA by-law 17.1
10(f)(vi). The disposition of the proceeding	IPC paid a monetary fine of $100,000.

Entity information Related to item 10(f) Record: 6

10(f)(i). The individuals named in the Action	M.R.S. Trust Company (MRST)
10(f)(ii). Title of Action	In re: M.R.S. Trust Company
10(f)(iii). Date of Action	02/24/2004
10(f)(iv). The Court or body taking the Action and its location	Manitoba Securities Commission
10(f)(v). Description of the Action	Pursuant to a settlement agreement with the Manitoba Securities Commission, MRST confirmed that other than acting as trustee of the Locked-in funds, the company did not participate in and was not aware of a pension and RSP scheme that facilitated the improper withdrawal of locked-in funds from various Manitoba-resident plan holders' pension and registered plans.
10(f)(vi). The disposition of the proceeding	Upon approval of the settlement agreement, MRST made a voluntary payment of $35,000 to the Treasury of the Province of Manitoba.

Entity information Related to item 10(f) Record: 7

10(f)(i). The individuals named in the Action	IPC Investment Corporation (IPC)
10(f)(ii). Title of Action	In re: IPC Investment Corporation
10(f)(iii). Date of Action	12/06/2001
10(f)(iv). The Court or body taking the Action and its location	New Brunswick Securities Commission (NBSC)
10(f)(v). Description of the Action	Matter related to unregistered trading activity conducted by a salesperson of an affiliate, Henry Hicks and Associates, LTD, which amalgamated with IPC effective May 16, 2001.
10(f)(vi). The disposition of the proceeding	IPC paid a monetary penalty of $14,400, including administrative costs.

Entity information Related to item 10(f) Record: 8

10(f)(i). The individuals named in the Action	GRS Securities Inc. (GRSSI)
10(f)(ii). Title of Action	In re: GRS Securities Inc.
10(f)(iii). Date of Action	03/28/2006
10(f)(iv). The Court or body taking the Action and its location	Investment Dealers Association Of Canada (IDA)
10(f)(v). Description of the Action	GRSSI held the assets of client investment plans with a trust company that, unknown to it, did not meet certain requirements of an acceptable securities location. As such, the assets were not allowable assets for the purposes of regulatory capital requirements and, for a short period of time until the matter was rectified, GRSSI did not meet the IDA capital adequacy requirements.
10(f)(vi). The disposition of the proceeding	The matter was disposed of by way of settlement agreement approved by IDA district council. $40,000 plus costs of $7000, fully paid by GRSSI, none waived.

Entity information Related to item 10(f) Record: 9

10(f)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(f)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(f)(iii). Date of Action	12/16/2004
10(f)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association Of Canada (MFDA)
10(f)(v). Description of the Action	This matter related to market timing trading by one institutional client of Investors Group in certain Investors Group funds. Investors Group Financial Services Inc. entered into a Settlement Agreement with MFDA which was approved on December 16, 2004. and under which Investors Group Financial Services Inc. agreed to pay $2.65 million in compensation in investors of mutual funds where market timing occurred, a fine of $2.65 million payable to MFDA, and $50,000 in costs.
10(f)(vi). The disposition of the proceeding	Under the settlement agreement, Investors Group Financial Services Inc. agreed to pay $2.65 million in compensation in investors of mutual funds where market timing occurred, a fine of $2.65 million payable to MFDA, and $50,000 in costs.

Entity information Related to item 10(f) Record: 10

10(f)(i). The individuals named in the Action	IPC Investment Corporation (IPC)
10(f)(ii). Title of Action	In re: IPC Investment Corporation
10(f)(iii). Date of Action	11/30/2009
10(f)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(f)(v). Description of the Action	Matter related to contraventions of Sections 31(1) and 61 of the Nova Scotia Securities Regulations for failure to ensure securities purchased by 3 clients were suitable, for failing to address the complaint made by one of these 3 clients in a manner that was fair, honest, or in good faith.
10(f)(vi). The disposition of the proceeding	Nova Scotia Securities Commission issued an order approving a settlement agreement with IPC, under which IPC agreed to pay an administrative penalty in the amount of $40,000 and costs of the Nova Scotia Securities Commission in the amount of $3,000.

Entity information Related to item 10(f) Record: 11

10(f)(i). The individuals named in the Action	IPC Securities Corporation (IPC)
10(f)(ii). Title of Action	In re: IPC Securities Corporation
10(f)(iii). Date of Action	06/01/2010
10(f)(iv). The Court or body taking the Action and its location	Investment Industry Regulatory Organization Of Canada
10(f)(v). Description of the Action	Action related to failure to establish and maintain adequate policies and procedures to ensure that clients qualified as accredited investors in accordance with provisions of Ontario Securities Act.
10(f)(vi). The disposition of the proceeding	Investment Industry Regulatory Organization Of Canada approved a settlement agreement with IPC under which IPC agreed to pay a fine in the amount of $65,000 and costs of $10,000.

Entity information Related to item 10(f) Record: 12

10(f)(i). The individuals named in the Action	Partners In Planning Financial Services Ltd.
10(f)(ii). Title of Action	In re: Partners In Planning Financial Services Ltd.
10(f)(iii). Date of Action	11/25/2010
10(f)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association Of Canada (MFDA)
10(f)(v). Description of the Action	Partners In Planning Financial Services Ltd (PIP), a foreign control affiliate, was found to have inadequate policies and procedures for head office supervision of leveraged trades and inadequate supervision of leveraged trades at the branches, contrary to MFDA Rules 2.2.1, 2.5.1, 2.10, 2.5.2(b), 2.5.3(b) and 2.5.4 and MFDA Policy No. 2.
10(f)(vi). The disposition of the proceeding	MFDA ordered a monetary penalty in the amount of $20,000 and costs of $2,500. PIP also agreed to appoint an independent consultant at PIPs expense to assist in resolving the leveraged trading issues.

Entity information Related to item 10(f) Record: 13

10(f)(i). The individuals named in the Action	Quadrus Investment Services Ltd.
10(f)(ii). Title of Action	In re: Quadrus Investment Services Ltd.
10(f)(iii). Date of Action	07/30/2015
10(f)(iv). The Court or body taking the Action and its location	Nova Scotia Securities Commission
10(f)(v). Description of the Action	Matter related to violation of Section 31(1) of the Securities Regulations, as Rep. by Rule 31801 for failure to supervise the activities of a Mutual Fund Salesperson.
10(f)(vi). The disposition of the proceeding	Quadrus Investment Services Ltd. agreed to pay a fine in the amount of $40,000 and costs in the amount of $1,000.

Entity information Related to item 10(f) Record: 14

10(f)(i). The individuals named in the Action	Quadrus Investment Services Ltd.
10(f)(ii). Title of Action	In re: Quadrus Investment Services Ltd.
10(f)(iii). Date of Action	11/17/2016
10(f)(iv). The Court or body taking the Action and its location	Mutual Fund Dealers Association Of Canada (MFDA)
10(f)(v). Description of the Action	Matter related to Quadrus's failure to appropriately supervise the activities of a Dealing Representative during the period from March, 2009 to July, 2015 and provide certain notices to the MFDA with respect to same, pursuant to MFDA Rules 2.1.1, 2.1.4, 2.3.1 and 2.5.1, and MFDA Policy No. 6.
10(f)(vi). The disposition of the proceeding	MFDA approved a settlement agreement with Quadrus under which Quadrus agreed to pay a fine in the amount of $70,000 and costs of $20,000. Payments totaled $95,000.

Entity information Related to item 10(f) Record: 15

10(f)(i). The individuals named in the Action	I.G. Investment Management, Ltd. (IGIM)
10(f)(ii). Title of Action	In re: I.G. Investment Management, Ltd.
10(f)(iii). Date of Action	08/12/2015
10(f)(iv). The Court or body taking the Action and its location	Financial Services Commission Of Ontario
10(f)(v). Description of the Action	In connection with IGIMs license as a Mortgage Broker under the Mortgage Brokers, Lenders and Administrators Act (Ontario) (the "Act"), the Superintendent of Financial Services Ontario issued an Administrative Mandatory Penalty Order (the "Order") against IGIM for failing to meet certain administrative requirements under the Act and/or its regulations. IGIM has addressed or is addressing the deficiencies identified in the order.
10(f)(vi). The disposition of the proceeding	Administrative Mandatory Penalty Order against IGIM in the total amount of $4,500.

Entity information Related to item 10(f) Record: 16

10(f)(i). The individuals named in the Action	IPC Securities Corporation (IPC)
10(f)(ii). Title of Action	In re: IPC Securities Corporation
10(f)(iii). Date of Action	08/29/2016
10(f)(iv). The Court or body taking the Action and its location	Investment Industry Regulatory Organization Of Canada
10(f)(v). Description of the Action	Matter related related to IPCs failure between January and June 2014, to conduct strict supervision of a registered representative pursuant to acknowledge and consent provided to the Investment Industry Regulatory Organization Of Canada (IIROC)contrary to IIROC Dealer Member Rules 29.1 and 2500.
10(f)(vi). The disposition of the proceeding	Investment Industry Regulatory Organization Of Canada approved a settlement agreement with IPC under which IPC agreed to pay a fine in the amount of $65,000 and costs of $5,000. Payments totaled $70,000.

Entity information Related to item 10(f) Record: 17

10(f)(i). The individuals named in the Action	Quadrus Investment Services Ltd.
10(f)(ii). Title of Action	In re: Quadrus Investment Services Ltd.
10(f)(iii). Date of Action	11/10/2015
10(f)(iv). The Court or body taking the Action and its location	Ontario Securities Commission (OSC)
10(f)(v). Description of the Action	Quadrus Investment Services Ltd. (Quadrus) entered a settlement agreement with the Ontario Securities Commission (OSC) relating to allegations that Quadrus had, as a result of certain control and supervision inadequacies, charged certain mutual fund clients an excess fee. OSC staff were satisfied that Quadrus discovered and self-reported the issue.
10(f)(vi). The disposition of the proceeding	Settlement included appropriate compensation to affected clients, voluntary reimbursement to OSC for costs incurred of $20,000, and voluntary payment to OSC of $250,000 to be allocated to third parties or investor education. Payments totaled $270,000.

Entity information Related to item 10(f) Record: 18

10(f)(i). The individuals named in the Action	IPC Investment Corporation
10(f)(ii). Title of Action	Druiven,et al.
10(f)(iii). Date of Action	07/02/1996
10(f)(iv). The Court or body taking the Action and its location	Ontario Court of Justice, Ontario Canada
10(f)(v). Description of the Action	Plantiffs commenced an action against Associated Financial Planners, LTD (AFP), a predecessor company of AFP Wealth Management, Inc., which amalgamated into IPC Investment Corporation (IPC) on June 1, 2001 and against Bruce Warrington and Moneysem Financial Consultants, Inc., with respect to losses alleged to have been sustained in making ill-obtained judgement against Warrington in July 1996, continuing to advance other claims against him and claims for accounting, damages for restitution, and quantum merit against AFP. The civil court found AFP negligent in its duties to adequately supervise Warrington's outside business activities.
10(f)(vi). The disposition of the proceeding	Judgement entered against AFP in the amount of $469,000, including interest.

Entity information Related to item 10(f) Record: 19

10(f)(i). The individuals named in the Action	Investors Group Financial Services, Inc.
10(f)(ii). Title of Action	In re: Investors Group Financial Services, Inc.
10(f)(iii). Date of Action	12/15/2017
10(f)(iv). The Court or body taking the Action and its location	The Manitoba Securities Commission (MSC)
10(f)(v). Description of the Action	Action relates to the fact that Investors Group Financial Services, Inc. and Investors Group Securities Inc. (collectivley "Investors Group") did not establish, maintain and apply policies and procedures to establish a system of controls and supervision that consistently ensured that the holders of Investors Group funds who were eligible for a lower MER series of the same fund were so advised in a timely manner.
10(f)(vi). The disposition of the proceeding	The MSC approved a settlement agreement with Investors Group under which Investors Group agreed to make a voluntary one-time payment to the Treasury of the Province of Manitoba in the amount of$750,000 and costs payable to the MSC in the amount of$30,000,

Entity information Related to item 10(f) Record: 20

10(f)(i). The individuals named in the Action	Investors Group Securities, Inc.
10(f)(ii). Title of Action	In re: Investors Group Securities, Inc.
10(f)(iii). Date of Action	12/15/2017
10(f)(iv). The Court or body taking the Action and its location	The Manitoba Securities Commission (MSC)
10(f)(v). Description of the Action	Action relates to the fact that Investors Group Financial Services, Inc. and Investors Group Securities Inc. (collectively "Investors Group") did not establish, maintain and apply policies and procedures to establish a system of controls and supervision that consistently ensured that the holders of Investors Group funds who were eligible for a lower MER series of the same fund were so advised in a timely manner.
10(f)(vi). The disposition of the proceeding	The MSC approved a settlement agreement with Investors Group under which Investors Group agreed to make a voluntary one-time payment to the Treasury of the Province of Manitoba in the amount of$750,000 and costs payable to the MSC in the amount of$30,000.

Entity information Related to item 10(f) Record: 21

10(f)(i). The individuals named in the Action	Mackenzie Financial Corporation (Mackenzie)
10(f)(ii). Title of Action	In The Matter Of Mackenzie Financial Corporation
10(f)(iii). Date of Action	04/06/2018
10(f)(iv). The Court or body taking the Action and its location	Ontario Securities Commission ("OSC"), Toronto, Ontario
10(f)(v). Description of the Action	Mackenzie entered into a Settlement Agreement with the OSC on April 6, 2018. The Settlement Agreement states that Mackenzie failed to (i) comply with National Instrument 81-105 Mutual Fund Sales Practices ("NI 81-105") by not meeting the minimum standards of conduct expected of industry participants in relation to certain sales practices between May 2014 and December 2017; (ii) have systems of controls and supervision over its sales practices that were sufficient to provide reasonable assurances that it was complying with its obligations under NI 81-105; and (iii) maintain adequate books, records and other documents to demonstrate its compliance with NI 81-105. In the Settlement Agreement, the OSC noted that in response to the OSC investigation Mackenzie: (i) has dedicated significant financial and human resources to enhance its systems of its controls and supervision for sales practices; (ii) retained an independent consultant in September 2017 to assess the quality of Mackenzie's controls around its sales practices and the consultant noted that overall Mackenzie had demonstrated a continuously improving compliance culture and since 2014 had seen increased investment in resources, both people and systems, focused on sales practices compliance; and (iii) had no disciplinary history with the Commission and cooperated with the OSC staff in connection with staff's investigation.
10(f)(vi). The disposition of the proceeding	Refer to response B in the supplemental correspondence.

Entity information Related to item 10(f) Record: 22

10(f)(i). The individuals named in the Action	IPC Securities Corporation and IPC Investment Corporation
10(f)(ii). Title of Action	In the Matter of IPC Securities Corporation and IPC Investment Corporation
10(f)(iii). Date of Action	06/07/2018
10(f)(iv). The Court or body taking the Action and its location	Ontario Securities Commission ("OSC"), Toronto, Ontario
10(f)(v). Description of the Action	IPC Securities Corporation and IPC Investment Corporation (the "IPC Dealers") entered into a Settlement Agreement with the OSC in relation to allegations by the OSC that there were inadequacies in the IPC Dealers' systems of controls and supervision, which resulted in certain clients paying, directly or indirectly, excess fees. There were no allegations or evidence of dishonest conduct by the IPC Dealers. Prior to entering into the settlement agreement, the IPC Dealers self-reported the matter to their respective self-regulatory organizations (the Investment Industry Regulatory Organization of Canada and the Mutual Fund Dealers Association of Canada).
10(f)(vi). The disposition of the proceeding	Refer to response C in the supplemental correspondence.

Entity information Related to item 10(f) Record: 23

10(f)(i). The individuals named in the Action	The Putnam Advisory Company, LLC. (PAC)
10(f)(ii). Title of Action	In re: The Putnam Advisory Company, LLC.
10(f)(iii). Date of Action	09/01/2022
10(f)(iv). The Court or body taking the Action and its location	The Korean Financial Supervisory Service
10(f)(v). Description of the Action	The Korean Financial Supervisory Service initiated an action against The Putnam Advisory Company, LLC (PAC) relating to an alleged violation of short sale restrictions. Due to an operational error in restricting dividend-awarded shares that had yet to be received, PAC inadvertently sold shares of a Korean-domiciled company that it did not possess.
10(f)(vi). The disposition of the proceeding	The Korean Financial Supervisory Service concluded an action relating to the above violation and on September 4, 2023 PAC was assessed and paid a fine of approximately $3,500.

10(g). Is the applicant or a control affiliate now the subject of a proceeding that could result in a yes answer for questions 10(a) – 10(f) ?  Yes   No

10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate?  Yes   No

Entity information Related to item 10(h) Record: 1

10(h)(i). The individuals named in the Action	Putnam Fiduciary Trust Company
10(h)(ii). Title of Action	In re: Tyco/Marine Harvest, et al.
10(h)(iii). Date of Action	05/21/2002
10(h)(iv). The Court or body taking the Action and its location	N/A
10(h)(v). Description of the Action	In early 2002, Putnam Fiduciary Trust Company (PFTC) the transfer agent for the Putnam funds, received applications to establish accounts in the names of several corporate entities, such as Tyco, Inc. and Marine Harvest, Inc., along with checks issued payable to the corporate entities. The checks were used to fund investments in the new accounts. The accounts were substantially depleted through the use of check writing drafts. Subsequently, PFTC became aware that the investment checks had been intercepted, the endorsements of the corporate payees had been forged, and the accounts had been established without the knowledge or authorization of the corporate payees. The corporate payees pursued forgery claims through the banks off of which the checks were drawn.
10(h)(vi). The disposition of the proceeding	PFTC filed a claim under its Fidelity Bond and recovered $697,120.28.

10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it?  Yes   No

TA-1/A : Signature

ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a) SIGNATURE: The registrant submitting this form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.

11(a). Signature of Official responsible for Form:	Karen Walsh
11(b). Telephone Number:	617-760-4467
11(c). Title of Signing Officer:	Senior Vice President
11(d). Date Signed (Month/Day/Year):	02/28/2024