Putnam Investments 

One Post Office Square 

Boston, MA 02109 

March 7, 2017

BY EDGAR

Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Jaea Hahn

Re:	Putnam Variable Trust (the “Trust”) with respect to its series, Putnam VT Equity Income
	Fund (the “Fund”)
	Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14
	File Number: 333-215836

Dear Ms. Hahn:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, the Trust respectfully requests that the effectiveness of the above-referenced pre-effective amendment to its registration statement (the “Registration Statement”) on Form N-14 be accelerated to March 7, 2017, or as soon thereafter as practicable.

Please call Venice Monagan at (617) 760-2577 as soon as the Registration Statement has been declared effective.

Very truly yours, 

By: /s/ Venice Monagan 

Name: Venice Monagan 

Title: Counsel 

cc:	Peter T. Fariel, Esq., Putnam Investments
	Bryan Chegwidden, Esq., Ropes & Gray LLP
	James E. Thomas, Esq., Ropes & Gray LLP

Putnam Retail Management 

One Post Office Square 

Boston, MA 02109 

March 7, 2017

BY EDGAR

Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Jaea Hahn

Re:	Putnam Variable Trust (the “Trust”) with respect to its series, Putnam VT Equity Income
	Fund (the “Fund”)
	Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14
	File Number: 333-215836

Dear Ms. Hahn:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Putnam Retail Management, as principal underwriter of shares of the Fund, hereby joins in the request of the Trust for acceleration of the effective date of the above-referenced pre-effective amendment to the Trust’s registration statement on Form N-14 so that it becomes effective on March 7, 2017, or as soon thereafter as practicable.

Very truly yours, 

By: /s/ Venice Monagan 

Name: Venice Monagan 

Title: Counsel 

cc:	Peter T. Fariel, Esq., Putnam Investments
	Bryan Chegwidden, Esq., Ropes & Gray LLP
	James E. Thomas, Esq., Ropes & Gray LLP