SEC
Whistleblower
Attorneys

September 27, 2018

Zachary Harrison, Putnam Investment Management, LLC

Trading and Pricing

SANCTION AMOUNT: $2145000

Defendants: Putnam Investment Management, LLC
Zachary Harrison

The Commission found that Respondents, an investment adviser and one of its former portfolio managers, facilitated dozens of prearranged, illegal cross-trades of RMBS between client advisory accounts in a manner that disadvantaged the selling clients. Trades were executed at the bid price instead of the midpoint between the bid and the ask as required.

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