One
Franklin Parkway
San Mateo, CA 94403-1906
Tel 800.632.2350
www.franklintempleton.com
December 29, 2025
VIA EDGAR
David Manion
U.S. Securities
and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549-8626
Subject: Franklin Templeton Funds (the “Funds”) (as listed on the attached Appendix)
Dear Mr. Manion:
On behalf of the Funds, the following are the responses to the U.S. Securities and Exchange Commission (“SEC”) Staff’s comments conveyed telephonically on April 17, 2025, regarding filings made by the Funds with the SEC on Form N-CSR. References made to the Funds’ shareholder reports on Form N-CSR refer to the corresponding reporting periods reviewed by the Staff as listed on the Appendix. Each comment is summarized below, followed by the applicable Fund’s response to the comment.
1. Comment: With respect to Franklin Universal Trust’s annual shareholder report on Form N-CSR (the “FUT Report”), the Staff notes that certain marketplace loans listed on the Schedule of Investments have no value or are valued at a significantly small fraction of the principal amount (i.e., the par value). Please discuss whether such loans are in default and indicate in future financial statements when a loan held by the Fund is in default.
Response: Certain of such marketplace loans were delinquent on payment. With respect to the reporting cycle ended August 31, 2025, the Fund has identified on the Schedule of Investments any marketplace loans that are considered in default for purposes of U.S. Generally Accepted Accounting Principles (“U.S. GAAP”).
2. Comment: In the Schedule of Investments of the FUT Report, the Staff notes that certain marketplace loans appear to be impaired based on their disclosed valuation (i.e., 10% or less of their par value). The cost to collect such loans may be greater than their fair value. (For example, certain marketplace loans listed on the Schedule of Investments have a modest principal amount and are valued at less than 10% of that amount.) Please explain whether the costs to collect have been considered in the valuation of such marketplace loans. In addition, please indicate who would bear the costs of collecting these loans (e.g., the Fund or the servicing agent).
Response: The valuation of such marketplace loans (i.e., charged-off loans) reflected the recovery amount expected to be received by the Fund, which is net of the applicable collection cost. The recovery of unsecured charged-off loans are realized mainly through debt sales and collections made by the servicer. Given that the disclosed valuation of such loans is net of collection cost, the Fund is effectively bearing the cost of the collection.
3. Comment: With respect to the annual shareholder report of the Franklin California High Yield Municipal Fund series of Franklin Municipal Securities Trust, the Staff notes that such Fund is holding escrow certificates (i.e., securities representing interests in securities placed in an escrow account) with no disclosed cost. Please explain how these certificates were acquired by the Fund, the accounting treatment of such certificates, and how value was assigned. In connection with such discussion, please include specific references to U.S. GAAP.
Response: The escrow securities referenced in the annual shareholder report were acquired by the Fund pursuant to a restructuring plan and related agreements associated with the Fund’s participation as a bondholder in the court-supervised restructuring of the Puerto Rico Electric Power Authority (“PREPA”). These securities were not acquired via open-market purchases or direct investment. Instead, they represented the Fund’s right to reimbursement of documented legal and professional fees, subject to court approval and other specified conditions. The fair value of the escrow securities position was immaterial to the Fund.

Mr.
Manion
December 29, 2025
Page 2
Upon further review and analysis, the Fund has determined that the potential reimbursement associated with the escrow securities constituted a contingent claim rather than an investment security subject to valuation. In accordance with ASC Topic 450 (Contingencies), such a claim should not be recognized as an asset (i.e., a gain) until the contingency has been resolved and the realization has occurred or is virtually assured. Accordingly, the Fund has concluded that the escrow securities should not have been recorded as assets of the Fund and no fair value should have been assigned. As a result, the Fund has removed these positions from its accounting records (effective as of October 1, 2025) and has updated its internal procedures to ensure that similar items are evaluated and assessed under ASC Topic 450 in future reporting periods, as applicable.
We believe that we have responded fully to each of the Staff’s comments as set forth above. However, should you have any further questions or require any further information, please do not hesitate to contact the undersigned at 916-463-1966, or, in his absence, Jeffrey White at 916-463-4396.
Very truly yours,
/s/CHRISTOPHER KINGS
Christopher
Kings
Senior Vice President,
Global Fund Administration & Oversight
Franklin
Templeton
On behalf of the Funds listed in the attached Appendix
Appendix
Funds and Fiscal Year Ends Reviewed by SEC Staff
Fund # | File # | Registrant Name | Series ID | Series Name | FYE Reviewed |
1 | 811-22641 | Franklin Alternative Strategies Funds | S000042023 | K2 Alternative Strategies Fund | 5/31/2024 |
2 | 811-02605 | Franklin U.S. Government Money Fund | S000006859 | Franklin U.S. Government Money Fund | 6/30/2024 |
3 | 811-04267 | Institutional Fiduciary Trust | S000007358 | Money Market Portfolio | 6/30/2024 |
4 | 811-04356 | Franklin California Tax Free Trust | S000006719 | Franklin California Intermediate-Term Tax-Free Income Fund | 6/30/2024 |
5 | 811-07038 | Money Market Portfolios | S000007450 | The U.S. Government Money Market Portfolio | 6/30/2024 |
6 | 811-01700 | Franklin Gold & Precious Metals Fund | S000006839 | Franklin Gold & Precious Metals Fund | 7/31/2024 |
7 | 811-10157 | Franklin Global Trust | S000012347 | Franklin Emerging Market Debt Opportunities Fund | 7/31/2024 |
8 | 811-10157 | Franklin Global Trust | S000022425 | Franklin International Growth Fund | 7/31/2024 |
9 | 811-02781 | Templeton Funds | S000008745 | Templeton World Fund | 8/31/2024 |
10 | 811-02781 | Templeton Funds | S000008746 | Templeton Foreign Fund | 8/31/2024 |
11 | 811-03143 | Templeton Global Smaller Companies Fund | S000008758 | Templeton Global Smaller Companies Fund | 8/31/2024 |
12 | 811-04892 | Templeton Growth Fund Inc | S000008759 | Templeton Growth Fund, Inc. | 8/31/2024 |
13 | 811-04985 | Templeton Emerging Markets Fund | CEF0014434 | Templeton Emerging Markets Fund | 8/31/2024 |
14 | 811-05569 | Franklin Universal Trust | CEF0014022 | Franklin Universal Trust | 8/31/2024 |
15 | 811-06243 | Franklin Strategic Series | S000065648 | Franklin Templeton SMACS: Series CH | 8/31/2024 |
16 | 811-06243 | Franklin Strategic Series | S000065649 | Franklin Templeton SMACS: Series E | 8/31/2024 |
17 | 811-06243 | Franklin Strategic Series | S000065650 | Franklin Templeton SMACS: Series H | 8/31/2024 |
18 | 811-06243 | Franklin Strategic Series | S000065651 | Franklin Templeton SMACS: Series I | 8/31/2024 |
19 | 811-08226 | Templeton Global Investment Trust | S000068644 | Franklin Templeton SMACS: Series EM | 8/31/2024 |
20 | 811-00537 | Franklin Custodian Funds | S000006754 | FRANKLIN DYNATECH FUND | 9/30/2024 |
21 | 811-00537 | Franklin Custodian Funds | S000006755 | Franklin Growth Fund | 9/30/2024 |
22 | 811-00537 | Franklin Custodian Funds | S000006756 | Franklin Income Fund | 9/30/2024 |
23 | 811-00537 | Franklin Custodian Funds | S000006757 | Franklin U.S. Government Securities Fund | 9/30/2024 |
24 | 811-00537 | Franklin Custodian Funds | S000006758 | Franklin Utilities Fund | 9/30/2024 |
25 | 811-04787 | Franklin New York Tax Free Trust | S000006871 | Franklin New York Intermediate-Term Tax-Free Income Fund | 9/30/2024 |
26 | 811-04894 | Franklin Managed Trust | S000006858 | Franklin Rising Dividends Fund | 9/30/2024 |
27 | 811-07288 | Franklin Strategic Mortgage Portfolio | S000006875 | Franklin Strategic Mortgage Portfolio | 9/30/2024 |
28 | 811-06481 | Franklin Municipal Securities Trust | S000006860 | Franklin California High Yield Municipal Fund | 2/29/2024 |