Putnam Municipal Opportunities Trust (PMO)
Filed: 18 Mar 19, 12:00am
March 18, 2019
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Jill Ehrlich
| Re: | Comments on Application for an Order Granting Exemptions from Section 19(b) of the |
| Investment Company Act of 1940, as amended (the “1940 Act”), and Rule 19b-1 thereunder | |
| with respect to Putnam Managed Municipal Income Trust, et al. (File No. 812-14970) (the | |
| “Application”), filed with the Securities and Exchange Commission (the “Commission”) on | |
| November 6, 2018. |
Dear Ms. Ehrlich:
This letter responds to the comments regarding the Application that you provided to Venice Monagan of Putnam Investment Management, LLC and Bryan Chegwidden of Ropes & Gray LLP, counsel to Putnam Managed Municipal Income Trust, Putnam Master Intermediate Income Trust, Putnam Municipal Opportunities Trust, and Putnam Premier Income Trust (the “Funds”), on behalf of the Staff of the Commission (the “Commission Staff”) via a letter dated February 26, 2019. For convenience of reference, the Commission Staff’s comments have been replicated below before the Funds’ responses. These responses will be reflected in an amendment to the Application filed electronically on EDGAR on or around the date hereof.
1. Comment: In the carryover sentence on pages 1-2:
a. Please replace “providing the Funds” with “providing PMM, PIM, PMO, PPT.”
b. Please insert “, Putnam Investments” after “in the future by Putnam Management.” Please also insert “or Putnam Investments” after “with Putnam Management.” (Alternatively, please explain supplementally why such references to Putnam Investments have not been included.)
Response: The above-referenced sentence has been revised as follows (additions are underlined and deletions are struck - through ):
Putnam Managed Municipal Income Trust (“PMM”), Putnam Master Intermediate Income Trust (“PIM”), Putnam Municipal Opportunities Trust (“PMO”), Putnam Premier Income Trust (“PPT”), Putnam Investment Management, LLC (“Putnam Management”) and
| - 2 - | March 18, 2019 |
Putnam Investments Limited (“Putnam Investments” and together with PMM, PIM, PMO, PPT and Putnam Management, the “Applicants”) hereby submit this amended application for an order (the “Order”) of the Securities and Exchange Commission (the “Commission”) pursuant to Section 6(c) of the Investment Company Act of 1940, as amended (the “1940 Act”), providing the Funds PMM, PIM, PMO, PPT, and each other closed-end management investment company registered under the 1940 Act advised or to be advised in the future by Putnam Management, Putnam Investments, or by an entity controlling, controlled by or under common control (within the meaning of Section 2(a)(9) of the 1940 Act) with Putnam Management or Putnam Investments (including any successor in interest 1 ) (each such entity, including Putnam Management and Putnam Investments, an “Adviser”) that in the future seeks to rely on the Order (such investment companies, together with PMM, PIM, PMO, and PPT, are collectively referred to herein as the “Funds” and each separately as a “Fund”), an exemption from the provisions of Section 19(b) of the 1940 Act and Rule 19b-1 thereunder, as more fully set forth below (the “ Application”). 2
2. Comment: In the section entitled “The Applicants” beginning on page 2:
a. Please clarify that each of PMM, PIM, PMO, and PPT are registered under the 1940 Act.
b. Please delete the phrase “, a national securities exchange as defined in Section 2(a)(26) of the 1940 Act,” the last three times it appears.
Response: The requested changes have been made.
3. Comment: In the first sentence of the second full paragraph on page 2, please state whether PIM is diversified or non-diversified.
Response: The above-referenced sentence has been revised to indicate that Putnam Master Intermediate Income Trust is a diversified closed-end management investment company.
I believe this letter addresses the Commission Staff’s comments. Should you have any further questions, please do not hesitate to call me at (617) 760-2577. Thank you for your assistance.
| Sincerely, |
| /s/ Venice Monagan |
| Putnam Investment Management, LLC |
| cc: | James Thomas, Esq., Ropes & Gray LLP |
| Bryan Chegwidden, Esq., Ropes & Gray LLP | |
| Timothy Cormier, Esq., Ropes & Gray LLP |
