The SEC issued an administrative order pursuant to Section 203(f) of the Investment Advisers Act against Omid Kamshad, a resident of London, England, and former portfolio manager, managing director and chief investment officer of Putnam Investments (Putnam). The Order permanently enjoined him from future violations of Sections 206(1) and 206(2) of the Advisers Act. The SEC's complaint filed in a related court proceeding alleged that Kamshad engaged in inappropriate trading of Putnam mutual funds shares in his Putnam-administered deferred compensation and retirement accounts, including trading of shares of funds over which he exercised investment authority, in violation of Sections 206(1) and (2) of the Advisers Act.

The SEC order provides that Kamshad is liable for disgorgement in the amount of $57,157, plus prejudgment interest thereon in the amount of $13,709, and a civil penalty in the amount of $400,000, for a total monetary obligation of $470,866. The final judgment further provides that Kamshad shall satisfy his monetary obligation by paying $235,433 to the SEC, together with proof of payment of $235,433 to the Secretary of State of the Commonwealth of Massachusetts in connection with a related action, In the Matter of Putnam Investment Management, Inc. et al., Docket No. E-2003-061.

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