Firm profile

Franklin Templeton Investments Corp.

TORONTO (ONTARIO), CanadaCRD 111364Registration Status: ApprovedEffective since December 6, 2000SEC # 801-58185Latest ADV September 16, 2026

Franklin Templeton Investments Corp. is an SEC registered investment adviser organized as a corporation with a primary office location in Toronto (Ontario), Canada. Its latest Form ADV filing, dated September 16, 2026, reports $12.8B in regulatory assets under management, 193 employees, 3 offices, and 101 accounts.

Assets Under Management
$12.8B
Employees
193
Offices
3 offices
Total Clients
138

Associated firm names

9 names listed
  • CLEARBRIDGE INVESTMENTS
  • FRANKLIN TEMPLETON INVESTMENTS CORP.
  • FRANKLIN TEMPLETON INVESTMENTS
  • FRANKLIN TEMPLETON INVESTMENT SOLUTIONS

Leadership

2 roles identified
CCOKathy Lisa Johnson
CFODavid Paterson

Advisory services offered

3 types reported
Other advisory services
Portfolio management for businesses
Portfolio management for investment companies

Fee models offered

2 types reported
Asset based fees
Performance-based fees

Offices & Contact

Primary office

TORONTO (ONTARIO), Canada

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Canada

TORONTO (ONTARIO)Primary office · CALGARY · MONTREAL, QUEBEC

3 office records listed · 3 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$12.8Bas of September 16, 2026
Discretionary99.9%
$12.8B
100% of total RAUM99.9%
Non-discretionary0.1%
$8M
0% of total RAUM0.1%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentPooled Investment Vehicles represent 34.8% of total clients.
Top client categories% of clientsClients
1
Pooled Investment Vehicles
34.8%
48
2
HNWI
34.1%
47
3
Charitable
16.7%
23
4
Pension Plans
12.3%
17
5
Investment Cos.
2.2%
3
Categories with <5 clients
Insurance companies<5 clients
Other investment advisers<5 clients
Other categories<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$12.8B
Total Accounts101
10Y AUM Change$-18.0B (-58.4%)

Private Funds

Private funds reported by Franklin Templeton Investments Corp.

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees193
Clients per Employee1:1
10Y Employee Change-169 (-46.7%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
TEMPLETON INTERNATIONAL, INC.Direct owner · Schedule AInterest in FRANKLIN TEMPLETON INVESTMENTS CORP.
75%+
FRANKLIN TEMPLETON, INC.Indirect owner · Schedule BInterest in LEGG MASON, INC.
75%+
TEMPLETON WORLDWIDE, INC.Indirect owner · Schedule BInterest in TEMPLETON INTERNATIONAL, INC.
75%+
LEGG MASON, INC.Indirect owner · Schedule BInterest in TEMPLETON WORLDWIDE, INC.
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Franklin Templeton Investments Corp..

Reported ownership and control details

Form ADV · Filing date 2026-09-16 · Schedules A and B

12 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1GAREY JAMES AITKENMANAGING DIRECTOR, HEAD OF CANADIAN EQUITIESIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesMANAGING DIRECTOR, HEAD OF CANADIAN EQUITIES08/2017Schedule APDF page 98
2TINA MARIE SADLEREXEC. VICE PRESIDENT/PORTFOLIO MANAGER/RESEARCH ANALYSTIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesEXEC. VICE PRESIDENT/PORTFOLIO MANAGER/RESEARCH ANALYST12/2014Schedule APDF page 98
3ANDREW JAMES ASHTONDIRECTOR AND CHAIRMANIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesDIRECTOR AND CHAIRMAN01/2017Schedule APDF page 98
4TEMPLETON INTERNATIONAL, INC.SHAREHOLDERDomestic entityFRANKLIN TEMPLETON INVESTMENTS CORP.75% or moreCode EYesSHAREHOLDER04/2018Schedule APDF page 98
5David PatersonCHIEF FINANCIAL OFFICER AND DIRECTORIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesCHIEF FINANCIAL OFFICER AND DIRECTOR08/2019Schedule APDF page 98
6Kathy Lisa JohnsonCHIEF COMPLIANCE OFFICERIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NANoCHIEF COMPLIANCE OFFICER09/2024Schedule APDF page 98
7DENNIS CHARLES TEWHEAD OF SALES, DIRECTORIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesHEAD OF SALES, DIRECTOR02/2022Schedule APDF page 98
8THOMAS MICHAEL OGORMANSENIOR VICE-PRESIDENT/ DIRECTOR LAM AMERICAS FIXED INCOMEIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesSENIOR VICE-PRESIDENT/ DIRECTOR LAM AMERICAS FIXED INCOME06/2010Schedule APDF page 98
9BRADLEY GORDON BEUTTENMILLERSENIOR ASSOCIATE GENERAL COUNSELIndividualFRANKLIN TEMPLETON INVESTMENTS CORP.Less than 5%Code NAYesSENIOR ASSOCIATE GENERAL COUNSEL08/2004Schedule APDF page 98
10FRANKLIN TEMPLETON, INC.SHAREHOLDERDomestic entityLEGG MASON, INC.75% or moreCode EYesSHAREHOLDER07/2020Schedule BPDF page 99
11TEMPLETON WORLDWIDE, INC.SHAREHOLDERDomestic entityTEMPLETON INTERNATIONAL, INC.75% or moreCode EYesSHAREHOLDER04/2018Schedule BPDF page 99
12LEGG MASON, INC.SHAREHOLDERDomestic entityTEMPLETON WORLDWIDE, INC.75% or moreCode EYesSHAREHOLDER06/2021Schedule BPDF page 99

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 9/16/2026 6:54:12 AM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions1 Yes4 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 3 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PDF pages 99–101
Regulator name — filed text
FINANSINSPEKTIONEN, SWEDEN'S FINANCIAL SUPERVISORY AUTHORITY
How was matter resolved — filed text
Decision

Action status / disposition — filed text

PLEASE SEE RESPONSE TO QUESTION 12.B. ABOVE.
Other filed details

Description of allegations — filed text

ON APRIL 15, 2015, FINANSINSPEKTIONEN, SWEDEN'S FINANCIAL SUPERVISORY AUTHORITY, IMPOSED A PENALTY OF SEK 300,000 (APPROXIMATELY USD 35,659 AT DATE OF PAYMENT) AGAINST FRANKLIN TEMPLETON INVESTMENTS CORP. ("FTIC") IN CONNECTION WITH FTIC'S INADVERTENT FAILURE TO TIMELY REPORT CHANGES IN MAJOR SHAREHOLDINGS OF A CANADIAN ISSUER HELD BY FUNDS AND ACCOUNTS ADVISED BY FTIC. THE CHANGE WAS REPORTED ON A TIMELY BASIS TO CANADIAN SECURITIES REGULATORS, BUT AFTER THE REPORTING DEADLINE IN SWEDEN, WHERE THE CANADIAN ISSUER HAS A DUAL LISTING. FTIC APPEALED THE PENALTY UNSUCCESSFULLY AND THE PENALTY BECAME FINAL ON MARCH 8, 2016.

Sanction detail — filed text

FINANSINSPEKTIONEN IMPOSED A PENALTY OF SEK 300,000 (APPROXIMATELY USD 35,659 AT DATE OF PAYMENT)
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:

11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4),
and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in
Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANSINSPEKTIONEN, SWEDEN'S FINANCIAL SUPERVISORY AUTHORITY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/15/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
11712-15
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INVESTMENT IN CANADIAN ISSUER DUAL LISTED IN SWEDEN

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 15, 2015, FINANSINSPEKTIONEN, SWEDEN'S FINANCIAL SUPERVISORY AUTHORITY, IMPOSED A PENALTY OF SEK 300,000 (APPROXIMATELY USD
35,659 AT DATE OF PAYMENT) AGAINST FRANKLIN TEMPLETON INVESTMENTS CORP. ("FTIC") IN CONNECTION WITH FTIC'S INADVERTENT FAILURE TO
TIMELY REPORT CHANGES IN MAJOR SHAREHOLDINGS OF A CANADIAN ISSUER HELD BY FUNDS AND ACCOUNTS ADVISED BY FTIC. THE CHANGE WAS
REPORTED ON A TIMELY BASIS TO CANADIAN SECURITIES REGULATORS, BUT AFTER THE REPORTING DEADLINE IN SWEDEN, WHERE THE CANADIAN ISSUER
HAS A DUAL LISTING. FTIC APPEALED THE PENALTY UNSUCCESSFULLY AND THE PENALTY BECAME FINAL ON MARCH 8, 2016.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
03/08/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PAYMENT OF PENALTY IN SWEDISH CURRENCY
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
FINANSINSPEKTIONEN IMPOSED A PENALTY OF SEK 300,000 (APPROXIMATELY USD 35,659 AT DATE OF PAYMENT)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must
fit within the space provided).
PLEASE SEE RESPONSE TO QUESTION 12.B. ABOVE.
regulatory · block 2PDF pages 101–103
Regulator name — filed text
SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 75,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, REGISTRANT CONSENTED TO ITS ENTRY. ON JULY 2, 2020, THE SEC ENTERED THE ORDER.
Other filed details

Description of allegations — filed text

ON JULY 2, 2020, THE SEC ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940 (THE "INVESTMENT COMPANY ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER AGAINST REGISTRANT (THE "ORDER"). IN THE ORDER, THE SEC FOUND THAT AT VARIOUS POINTS BETWEEN OCTOBER 2013 AND SEPTEMBER 2016, REGISTRANT CAUSED CERTAIN FRANKLIN TEMPLETON FUNDS IT MANAGES TO INVEST IN SHARES OF TWO UNAFFILIATED EXCHANGED-TRADED FUNDS IN EXCESS OF THE 3% INVESTMENT LIMIT UNDER SECTION 12(D)(1) (A)(I) OF THE INVESTMENT COMPANY ACT. REGISTRANT NEITHER ADMITTED NOR DENIED THE SEC'S FINDINGS.

Sanction detail — filed text

MONETARY/FINE (AMOUNT $75,000); CEASE AND DESIST
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4),
and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in
Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
REGISTRANT CONSENTED TO ENTRY OF A CEASE-AND-DESIST ORDER, AND AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000.
3.
Date Initiated (MM/DD/YYYY): 
07/02/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19854
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JULY 2, 2020, THE SEC ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 9(F) OF THE
INVESTMENT COMPANY ACT OF 1940 (THE "INVESTMENT COMPANY ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940,
MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER AGAINST REGISTRANT (THE "ORDER"). IN THE ORDER, THE SEC
FOUND THAT AT VARIOUS POINTS BETWEEN OCTOBER 2013 AND SEPTEMBER 2016, REGISTRANT CAUSED CERTAIN FRANKLIN TEMPLETON FUNDS IT
MANAGES TO INVEST IN SHARES OF TWO UNAFFILIATED EXCHANGED-TRADED FUNDS IN EXCESS OF THE 3% INVESTMENT LIMIT UNDER SECTION 12(D)(1)
(A)(I) OF THE INVESTMENT COMPANY ACT. REGISTRANT NEITHER ADMITTED NOR DENIED THE SEC'S FINDINGS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
07/02/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 75,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
MONETARY/FINE (AMOUNT $75,000); CEASE AND DESIST
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must
fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, REGISTRANT CONSENTED TO ITS ENTRY. ON JULY 2, 2020, THE SEC ENTERED THE ORDER.
regulatory · block 3LEGG MASON, INC.PDF pages 103–105
Advisory affiliate name — filed text
LEGG MASON, INC.
Regulator name — filed text
U.S. SECURITIES AND EXCHANGE COMMISSION
How was matter resolved — filed text
Order

Action status / disposition — filed text

ON AUGUST 27, 2018, THE SEC ISSUED AN ORDER THAT CONTAINED FINDINGS THAT LEGG MASON HAD VIOLATED SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT BY FAILING TO DEVISE AND MAINTAIN APPROPRIATE INTERNAL ACCOUNTING CONTROLS WITH RESPECT TO THE USE OF INTRODUCING BROKERS AND OTHER INTERMEDIARIES IN EMERGING MARKETS, INCLUDING LIBYA, AND THAT IMPOSED A CEASE-AND-DESIST ORDER ON LEGG MASON WITH RESPECT TO ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 13(B)(2)(B). PREVIOUSLY, LEGG MASON HAD SUBMITTED AN OFFER OF SETTLEMENT WHICH THE SEC DETERMINED TO ACCEPT. THE ORDER RESOLVED A FCPA INVESTIGATION CONCERNING THE ACTIVITIES OF LEGG MASON'S FORMER PERMAL BUSINESS IN CONNECTION WITH MANAGING ASSETS OF LIBYAN GOVERNMENTAL ENTITIES IN STRUCTURES ESTABLISHED BY A THIRD- PARTY FINANCIAL INSTITUTION. PURSUANT TO THE ORDER, THE SEC ORDERED LEGG MASON TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND FUTURE VIOLATIONS OF SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND TO PAY DISGORGEMENT OF $27,594,729 AND PREJUDGMENT INTEREST OF $6,907,765 FOR A TOTAL PAYMENT OF $34,502,944. SEPARATELY, ON JUNE 4, 2018 LEGG MASON AGREED TO PAY A PENALTY AND DISGORGEMENT TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS DESCRIBED IN THE RESPONSE TO ITEM 2 ABOVE.
Other filed details

Description of allegations — filed text

ON AUGUST 27, 2018, THE SEC ISSUED AN ORDER THAT FOUND THAT LEGG MASON HAD VIOLATED SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 BY FAILING TO DEVISE AND MAINTAIN A SYSTEM OF APPROPRIATE INTERNAL ACCOUNTING CONTROLS WITH RESPECT TO THE USE OF INTRODUCING BROKERS AND OTHER INTERMEDIARIES IN EMERGING MARKETS, INCLUDING LIBYA, AND THAT IMPOSED A CEASE-AND-DESIST ORDER ON LEGG MASON WITH RESPECT TO ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 13(B)(2)(B). PREVIOUSLY, LEGG MASON HAD SUBMITTED AN OFFER OF SETTLEMENT IN CONNECTION WITH THE MATTER WHICH THE SEC DETERMINED TO ACCEPT. THE ORDER RESOLVED A FCPA INVESTIGATION CONCERNING THE ACTIVITIES OF LEGG MASON'S FORMER PERMAL BUSINESS IN CONNECTION WITH MANAGING ASSETS OF LIBYAN GOVERNMENTAL ENTITIES IN STRUCTURES ESTABLISHED BY A THIRD-PARTY FINANCIAL INSTITUTION. THOSE INVESTMENTS WERE MADE IN CALENDAR YEARS 2005-2007 AND ALL WERE TERMINATED BY 2012. THE MATTER DOES NOT RELATE TO ANY CURRENT BUSINESS ACTIVITIES OR CLIENT RELATIONSHIPS OF LEGG MASON OR ANY AFFILIATE, AND WAS FOCUSED ON THE ACTIONS OF FORMER PERMAL EMPLOYEES WHO LEFT THAT FIRM IN 2013. LEGG MASON BECAME AN ADVISORY AFFILIATE OF REGISTRANT IN JUNE 2021.

Sanction detail — filed text

THE ORDER REQUIRED LEGG MASON TO PAY DISGORGEMENT OF $27,594,729 AND PREJUDGMENT INTEREST OF $6,907,765 TO THE SEC. THE SEC DID NOT IMPOSE ITS OWN PENALTY BASED UPON THE PENALTY PAID TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS DESCRIBED IN THE RESPONSE TO ITEM 2 ABOVE.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
LEGG MASON, INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4),
and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in
Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
DISGORGEMENT OF $27,594,729 AND PREJUDGMENT INTEREST OF $6,907,765. SEPARATELY, ON JUNE 4, 2018 LEGG MASON, INC. ("LEGG MASON")
AGREED TO PAY A PENALTY OF $32,625,000 AND DISGORGEMENT OF $31,617,000 TO RESOLVE A U.S. DEPARTMENT OF JUSTICE ("DOJ") INVESTIGATION
INTO VIOLATIONS OF THE FOREIGN CORRUPT PRACTICES ACT (FCPA) ARISING OUT OF THE SAME MATTER. THE DISGORGEMENT AMOUNT PAID TO THE SEC
WAS TO BE CREDITED AGAINST THE DOJ DISGORGEMENT AMOUNT ASSESSED BY THE DOJ.
3.
Date Initiated (MM/DD/YYYY): 
08/27/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
EXCHANGE ACT RELEASE NO. 83948; ACCOUNTING AND AUDITING RELEASE NO. 3961; AMINISTRATIVE PROCEEDING FILE NO. 3-18684
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON AUGUST 27, 2018, THE SEC ISSUED AN ORDER THAT FOUND THAT LEGG MASON HAD VIOLATED SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE
ACT OF 1934 BY FAILING TO DEVISE AND MAINTAIN A SYSTEM OF APPROPRIATE INTERNAL ACCOUNTING CONTROLS WITH RESPECT TO THE USE OF
INTRODUCING BROKERS AND OTHER INTERMEDIARIES IN EMERGING MARKETS, INCLUDING LIBYA, AND THAT IMPOSED A CEASE-AND-DESIST ORDER ON
LEGG MASON WITH RESPECT TO ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 13(B)(2)(B). PREVIOUSLY, LEGG MASON HAD SUBMITTED AN OFFER
OF SETTLEMENT IN CONNECTION WITH THE MATTER WHICH THE SEC DETERMINED TO ACCEPT. THE ORDER RESOLVED A FCPA INVESTIGATION
CONCERNING THE ACTIVITIES OF LEGG MASON'S FORMER PERMAL BUSINESS IN CONNECTION WITH MANAGING ASSETS OF LIBYAN GOVERNMENTAL
ENTITIES IN STRUCTURES ESTABLISHED BY A THIRD-PARTY FINANCIAL INSTITUTION. THOSE INVESTMENTS WERE MADE IN CALENDAR YEARS 2005-2007
AND ALL WERE TERMINATED BY 2012. THE MATTER DOES NOT RELATE TO ANY CURRENT BUSINESS ACTIVITIES OR CLIENT RELATIONSHIPS OF LEGG MASON
OR ANY AFFILIATE, AND WAS FOCUSED ON THE ACTIONS OF FORMER PERMAL EMPLOYEES WHO LEFT THAT FIRM IN 2013. LEGG MASON BECAME AN
ADVISORY AFFILIATE OF REGISTRANT IN JUNE 2021.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):
08/27/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PREJUDGMENT INTEREST OF $6,907,765 RELATING TO DISGORGEMENT AMOUNT OF $27,594,729. SEPARATELY, ON JUNE 4, 2018 LEGG MASON
AGREED TO PAY A PENALTY AND DISGORGEMENT TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS DESCRIBED IN THE
RESPONSE TO ITEM 2 ABOVE.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE ORDER REQUIRED LEGG MASON TO PAY DISGORGEMENT OF $27,594,729 AND PREJUDGMENT INTEREST OF $6,907,765 TO THE SEC. THE SEC
DID NOT IMPOSE ITS OWN PENALTY BASED UPON THE PENALTY PAID TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS
DESCRIBED IN THE RESPONSE TO ITEM 2 ABOVE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must
fit within the space provided).
ON AUGUST 27, 2018, THE SEC ISSUED AN ORDER THAT CONTAINED FINDINGS THAT LEGG MASON HAD VIOLATED SECTION 13(B)(2)(B) OF THE SECURITIES
EXCHANGE ACT BY FAILING TO DEVISE AND MAINTAIN APPROPRIATE INTERNAL ACCOUNTING CONTROLS WITH RESPECT TO THE USE OF INTRODUCING
BROKERS AND OTHER INTERMEDIARIES IN EMERGING MARKETS, INCLUDING LIBYA, AND THAT IMPOSED A CEASE-AND-DESIST ORDER ON LEGG MASON
WITH RESPECT TO ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 13(B)(2)(B). PREVIOUSLY, LEGG MASON HAD SUBMITTED AN OFFER OF
SETTLEMENT WHICH THE SEC DETERMINED TO ACCEPT. THE ORDER RESOLVED A FCPA INVESTIGATION CONCERNING THE ACTIVITIES OF LEGG MASON'S
FORMER PERMAL BUSINESS IN CONNECTION WITH MANAGING ASSETS OF LIBYAN GOVERNMENTAL ENTITIES IN STRUCTURES ESTABLISHED BY A THIRD-
PARTY FINANCIAL INSTITUTION. PURSUANT TO THE ORDER, THE SEC ORDERED LEGG MASON TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY
VIOLATIONS AND FUTURE VIOLATIONS OF SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND TO PAY DISGORGEMENT OF $27,594,729
AND PREJUDGMENT INTEREST OF $6,907,765 FOR A TOTAL PAYMENT OF $34,502,944. SEPARATELY, ON JUNE 4, 2018 LEGG MASON AGREED TO PAY A
PENALTY AND DISGORGEMENT TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS DESCRIBED IN THE RESPONSE TO ITEM 2
ABOVE.

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