Defendant Name: Putnam Investment Management, LLC

Defendant Type: Subsidiary of Public Company
Public Company Parent: Marsh & McLennan Companies, Inc.
SIC Code: 6411
CUSIP: 57174810

Initial Case Details

Legal Case Name In the Matter of Putnam Investment Management, LLC
First Document Date 28-Oct-2003
Initial Filing Format Administrative Action
File Number 3-11317
Allegation Type Investment Advisers/Investment Companies

Violations Alleged

Other
Sections 203(e)(6), 204A, 206(1), 206(2) Investment Advisers Act; Section 17(j) Investment Company Act; Rule 17j-1(c) Investment Company Act

Resolutions

First Resolution Date 13-Nov-2003

Related Documents:

IA-2185 28-Oct-2003 Administrative Proceeding
SEC Institutes Administrative Proceeding Against Putnam Investment Management LLC In Connection With Self-Dealing in Putnam Mutual Funds By Two Managing Directors and Other Putnam Investment Professionals
On October 28, 2003, the SEC instituted administrative proceedings against Putnam Investment Management LLC. According to the SEC: "the Division of Enforcement (the Division) alleges that Putnam engaged in securities fraud by failing to disclose to the funds or to the fund boards the potentially self-dealing transactions in fund shares by [Justin M. Scott], [Omid Kamshad] and other employees."
IA-2192 13-Nov-2003 Administrative Proceeding
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 Section 9(b) and 9(f) of the Investment Company Act of 1940
On November 13, 2003, the SEC issued an order imposing partial relief against Putnam Investment Management, LLC, including final censure, remedial undertakings and a cease-and-desist order. According to the SEC: "Beginning in at least 1998, at least six Putnam employees who worked as investment management professionals engaged in excessive short-term trading of Putnam mutual funds in their personal accounts."
IA-2226 08-Apr-2004 Administrative Proceeding
Order Making Findings and Imposing Supplemental Remedial Sanctions Pursuant to Sections 203(e) of the Investment Advisers Act of 1940 and Section 9(b) of the Investment Company Act of 1940
On April 8, 2004, the SEC issued an order imposing supplemental remedial sanctions against Putnam Investment Management, LLC.
34-59041 02-Dec-2008 Administrative Proceeding
Order Directing Disbursement of Fair Fund
The Commission stated: " it is ORDERED that the Commission staff shall arrange for the transfer of $33,514,769.84 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such monies, along with $13,000,532.54 in additional Fair Fund monies currently being held at Northern Trust Company, to investors over a period of approximately two business days beginning within one business day after the transfer, for a total second distribution of $46,515,302.38, as provided in the Plan."
34-59447 25-Feb-2009 Administrative Proceeding
Order Directing Disbursement of Fair Fund
The Commission ordered that: "the Commission staff shall arrange for the transfer of $28,128,811.12 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such monies to investors over a period of approximately two business days beginning within one business day after the transfer, as provided in the Plan."
34-59994 28-May-2009 Administrative Proceeding
Order Directing Disbursement of Fair Fund
The Commission stated: "[I]t is ORDERED that the Commission staff shall arrange for the transfer of $4,199,306.98 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such amount, plus an additional $46,622.46 from Fair Fund monies already being held at Northern Trust Company, to the payees identified in the Payment File for the fourth distribution beginning within one business day after such transfer, for a total fourth distribution of $4,245,929.44, as provided in the Plan".
34-60412 31-Jul-2009 Administrative Proceeding
Order Directing Disbursement of Fair Fund
The SEC stated: "[I]t is ORDERED that the Commission staff shall arrange for the transfer of $19,354,093.35 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such amount to the payees identified in the Payment File for the fifth distribution, over a period of approximately eight to ten (8-10) business days, beginning within one business day after such transfer."
34-61098 02-Dec-2009 Administrative Proceeding
Order Directing Disbursement of Fair Fund
On December 2, 2009, the SEC ordered that "the Commission staff shall arrange for the transfer of $4,356,590.74 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such amount to the payees identified in the Payment File for the sixth distribution beginning within one business day after such transfer."
34-61463 02-Feb-2010 Administrative Proceeding
Order Directing Disbursement of Fair Fund
On February 2, 2010, the SEC ordered that "the Commission staff shall arrange for the transfer of $4,214,238.67 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such amount to the payees identified in the Payment File for the seventh distribution over a period of approximately three (3) business days, beginning within one (1) business day after such transfer."
34-63221 01-Nov-2010 Administrative Proceeding
Order Directing Disbursement of Fair Fund
On November 1, 2010, the SEC ordered that "the Commission staff shall arrange for the transfer of $2,641,841.14 of the Fair Fund to Northern Trust Company, and the Plan Administrator shall distribute such amount to the payees identified in the Payment File for the eighth distribution beginning within one (1) business day after such transfer."
34-64034 04-Mar-2011 Administrative Proceeding
Order Directing Disbursement of Fair Fund
On March 4, 2011, the SEC ordered that "the Plan Administrator shall, beginning within one (1) business day after the issuance of this Order, distribute $1,045,492.65 to the payees identified in the Payment File for the ninth distribution. The ninth distribution will be made using monies currently being held in escrow at Northern Trust Company."
34-65243 01-Sep-2011 Administrative Proceeding
Order Directing Disbursement of Fair Fund Residual
On September 1, 2011, the SEC ordered that "the Commission staff shall arrange for the transfer of $10,052,040.97 of the Fair Fund to Northern Trust Company, and, beginning within one business day after such transfer, the Plan Administrator shall distribute such amount, plus the additional $36,059,018.56 of Fair Fund monies being held at Northern Trust Company, to the Putnam mutual funds identified in the payment file that Putnam has submitted to the Commission staff, for a total Residual distribution of $46,111,059.53. According to the SEC: "The Plan further provides that any monies remaining in the Fair Fund that are not able to be distributed directly to injured investors ('Residual') shall be distributed to the Putnam mutual funds harmed by the market timing activity.
34-65243A 12-Dec-2011 Administrative Proceeding
Amended Order Directing Disbursement of Fair Fund Residual
On December 12, 2011, the SEC ordered that "the Commission staff shall arrange for the transfer of $10,018,437.29 of the Fair Fund to Northern Trust Company, and, beginning within one business day after such transfer, the Plan Administrator shall distribute such amount, plus the additional $36,059,008.56 of Fair Fund monies being held at Northern Trust Company, to the Putnam mutual funds identified in the payment file that Putnam has submitted to the Commission staff, for a total Residual distribution of $46,007,445.85. According to the SEC: "The Plan further provides that any monies remaining in the Fair Fund that are not able to be distributed directly to injured investors ('Residual') shall be distributed to the Putnam mutual funds harmed by the market timing activity. This Order amends the SEC's prior September 1, 2011 Order.
34-67591 02-Aug-2012 Administrative Proceeding
Order Authorizing the Transfer of Residual Funds and Any Future Funds Received by the Fair Fund to the U.S. Treasury, Discharging the Fund Administrator, and Terminating the Fair Fund
On August 2, 2012, the SEC ordered that the "$1,380.84 balance in the Fair Fund and any future funds received by the Fair Fund shall be transferred to the U.S. Treasury". The SEC also ordered the discharge of the Fund Administrator and the termination of the Fair Fund.
IA-3600 03-May-2013 Administrative Proceeding
Order Modifying 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
According to the SEC: "Putnam has submitted an Amended Offer of Settlement ('Offer') proposed to relieve it of the obligations" imposed under the previous October 28, 2003 Order. On May 3, 2013, the SEC modified its previous October 28, 2003 Order against Putnam Investment Management, LLC as agreed to in the Offer.

Related Actions:

In the Matter of Federated Investment Management Company, Federated Securities Corp. and Federated Shareholder Services Company
SEC v. Justin M. Scott and Omid Kamshad
In the Matter of Justin Scott
In the Matter of Omid Kamshad