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<FILENAME>legal77e582.txt
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77E

Putnam Management has entered into agreements with the Securities
and Exchange
Commission and the Massachusetts Securities Division settling
charges connected 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. Pursuant to these settlement
agreements, Putnam Management will pay a total of $193.5 million
in penalties and restitution, with $153.5 million being paid to
certain open end funds and their shareholders.
The amount will be allocated to shareholders and funds pursuant
to a plan developed by an independent consultant, and will be
paid following approval of the plan by the SEC and the
Massachusetts Securities Division. The Securities and Exchange
Commissions 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 will bear any costs incurred by
Putnam funds in connection with these lawsuits. 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. Putnam Management and Putnam Retail
Management are named as defendants in a civil suit in which the
plaintiffs allege that the management and distribution fees paid
by certain Putnam funds were excessive and seek recovery under
the Investment Company Act of 1940. Putnam Management and Putnam
Retail Management have contested the plaintiffs claims and the
matter is currently pending in the U.S. District Court for the
District of Massachusetts. Based on currently available
information, Putnam Management believes that this action is
without merit and that it is unlikely to have a material effect
on Putnam Managements and Putnam Retail Managements ability to
provide services to their clients, including the fund.


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