<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>3
<FILENAME>legal77e582.txt
<TEXT>
Regulatory matters and litigation

On April 8, 2004, Putnam Management entered into agreements with
the Securities and Exchange Commission and the Massachusetts
Securities Division representing a final settlement of all
charges brought against Putnam Management by those agencies on
October 28, 2003 in connection with excessive short term trading
by Putnam employees and, in the case of the charges brought by
the Massachusetts Securities Division, by participants in some
Putnam administered 401(k) plans.  The settlement with the SEC
requires Putnam Management to pay $5 million in disgorgement plus
a civil monetary penalty of $50 million, and the settlement with
the Massachusetts Securities Division requires Putnam Management
to pay $5 million in restitution and an administrative fine of
$50 million.  The settlements also leave intact the process
established under an earlier partial settlement with the SEC
under which Putnam Management agreed to pay the amount of
restitution determined by an independent consultant, which may
exceed the disgorgement and restitution amounts specified above,
pursuant to a plan to be developed by the independent consultant.

Putnam Management, and not the investors in any Putnam fund, will
bear all costs, including restitution, civil penalties and
associated legal fees stemming from both of these proceedings.
The SECs and Massachusetts Securities Divisions allegations and
related matters also serve as the general basis for numerous
lawsuits, including purported class action lawsuits filed against
Putnam Management and certain related parties, including certain
Putnam funds.  Putnam Management has agreed to bear any costs
incurred by Putnam funds in connection with these lawsuits.
Based on currently available information, Putnam Management
believes that the likelihood that the pending private lawsuits
and purported class action lawsuits will have a material adverse
financial impact on the fund is remote, and the pending actions
are not likely to materially affect its ability to provide
investment management services to its clients, including the
Putnam funds.

Review of these matters by counsel for Putnam Management and by
separate independent counsel for the Putnam funds and their
independent Trustees is continuing.



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