PUTNAM INVESTMENTS LLC

This brochure is for clients considering investment management portfolios and strategies that FTPPG and its Subadvisers offer in investment programs sponsored by unaffiliated financial firms ("Sponsor Firms"). It also caters to entity clients who are affiliated managers of FTPPG and want to use these portfolios for their own clients. The brochure details the qualifications, business practices of FTPPG and its Subadvisers, and information about the investment management portfolios and strategies for which the Subadvisers provide investment subadvisory services to FTPPG. Subadvisers may use specific terminology in their disclosures, such as referring to "Sponsor Firms" as "SMA Sponsors" or "Sponsors," Sponsor Firm investment programs as "SMA Programs," the Sponsor Firm for a Non-Discretionary Model Program as a "UMA Sponsor," and model investment portfolios as "Model Portfolios." Employees of the firm are restricted from using non-public information for personal gain, and the firm maintains records of securities transactions. Clients have the right to decline advice, and non-compliance with these rules can lead to disciplinary action. Royce receives asset-based investment advisory fees that are subject to upward or downward adjustment based upon the investment performance of two closed-end U.S. registered management investment companies relative to the investment record of specific equity indexes.

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