-----BEGIN PRIVACY-ENHANCED MESSAGE-----
Proc-Type: 2001,MIC-CLEAR
Originator-Name: webmaster@www.sec.gov
Originator-Key-Asymmetric:
 MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen
 TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB
MIC-Info: RSA-MD5,RSA,
 S4JUfXOz666mT45kCGVAHKoLsqBCfbXYZTGjQKk7dNLOBFpxKGPxmxYxk6tmUthU
 yYyEk37P0bkxjAzo4UE1uA==

<SEC-DOCUMENT>0000928816-03-000854.txt : 20031223
<SEC-HEADER>0000928816-03-000854.hdr.sgml : 20031223
<ACCEPTANCE-DATETIME>20031223164718
ACCESSION NUMBER:		0000928816-03-000854
CONFORMED SUBMISSION TYPE:	N-CSR
PUBLIC DOCUMENT COUNT:		4
CONFORMED PERIOD OF REPORT:	20031031
FILED AS OF DATE:		20031223
EFFECTIVENESS DATE:		20031223

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PUTNAM MANAGED MUNICIPAL INCOME TRUST
		CENTRAL INDEX KEY:			0000844790
		IRS NUMBER:				046608976
		STATE OF INCORPORATION:			MA
		FISCAL YEAR END:			1031

	FILING VALUES:
		FORM TYPE:		N-CSR
		SEC ACT:		1940 Act
		SEC FILE NUMBER:	811-05740
		FILM NUMBER:		031071593

	BUSINESS ADDRESS:	
		STREET 1:		ONE POST OFFICE SQ
		STREET 2:		MAILSTOP A14
		CITY:			BOSTON
		STATE:			MA
		ZIP:			02109
		BUSINESS PHONE:		6172921000
</SEC-HEADER>
<DOCUMENT>
<TYPE>N-CSR
<SEQUENCE>1
<FILENAME>mmi1.txt
<DESCRIPTION>PUTNAM MANAGED MUNICIPAL INCOME TRUST
<TEXT>
Putnam
Managed
Municipal
Income Trust

Item 1. Report to Stockholders:
- -------------------------------
The following is a copy of the report transmitted to stockholders pursuant
to Rule 30e-1 under the Investment Company Act of 1940:


ANNUAL REPORT ON PERFORMANCE AND OUTLOOK

10-31-03

[GRAPHIC OMITTED: WATCH]

[SCALE LOGO OMITTED]


From the Trustees

[GRAPHIC OMITTED: PHOTO OF JOHN A. HILL AND GEORGE PUTNAM, III]

John A. Hill and
George Putnam, III

Dear Fellow Shareholder:

You may have read recent press coverage regarding  investigations
involving Putnam Investments. Last month all Putnam shareholders were
sent a letter detailing the steps being taken by Putnam to address the
issues raised by federal and state regulators. Since then, a number of
remedial actions, some of which were discussed in last month's letter,
are being instituted under the terms of an order from the Securities and
Exchange Commission (SEC). These include stringent employee trading
restrictions, enhanced compliance standards and systems, new redemption
fees for certain fund shares held less than three months, and a process
for making full monetary restitution for any losses to fund
shareholders. This process will be directed by an independent third
party approved by the SEC and by Putnam's Board of Trustees.

The Board is also continuing its own independent investigation of these
issues and when complete a report will be issued detailing the
additional steps being taken to make sure that nothing like this happens
at Putnam again. We believe that the new senior management team at
Putnam is fully committed to re-establishing the firm as a model for the
highest ethical standards in the mutual fund industry. Our Board is
committed to working with Putnam's management to ensure that everything
possible is done to restore your full confidence in the Putnam
organization.

We are pleased to report strong performance of Putnam Managed Municipal
Income Trust during the fiscal year ended October 31, 2003. Your fund's
results at net asset value significantly outperformed both the fund's
primary benchmark and its Lipper peer group average. The details are
shown on the facing page. In their report, your fund's managers cite the
recovery in airline-related industrial development bond holdings as the
primary source of these positive results. They also offer their views on
prospects for the fiscal year that just began.

Respectfully yours,

/S/ JOHN A. HILL              /S/ GEORGE PUTNAM, III

John A. Hill                  George Putnam, III
Chairman of the Trustees      President of the Funds

December 17, 2003


Report from Fund Management

Fund highlights

 * Putnam Managed Municipal Income Trust's total return for the fiscal
   year ended October 31, 2003, was 9.67% at net asset value (NAV) and
   6.44% at market price.

 * The fund's return at net asset value was significantly better than the
   Lehman Municipal Bond Index, which returned 5.12% for the same period,
   largely because of strongly positive performance by airline-related
   industrial development bond holdings (IDBs), as well as the fund's use
   of leverage.

 * Performance of these holdings, as well as adjustments in the fund's
   portfolio duration, also helped it outperform, at NAV, the average for
   Lipper's Closed-End High Yield Municipal Debt Funds category, which was
   7.48% for the 12-month period.

 * See the Performance Summary beginning on page 8 for complete fund
   performance, comparative performance, and Lipper data.

Performance commentary

The financial markets experienced a major shift in the middle of fiscal
2003, but the fund's investment mix and the adjustments we made to its
duration -- a measure of interest-rate sensitivity -- helped it
outperform, at NAV, its benchmark and Lipper group in both environments.
In the first half, we maintained a relatively long duration that allowed
the fund to participate in the bond price rally. Although the fund's
lower-rated holdings lagged, its high-quality bonds were a positive, as
investors focused on  relatively secure investments. By the spring,
however, interest rates had declined to the point where we considered
them unsustainably low. To protect the portfolio against the negative
effects of a potential rate increase, we shortened the duration. This
proved beneficial when rates spiked upward in late June and July. Prices
of the lower-quality, higher-yielding bonds subsequently proved more
resilient than the investment-grade holdings, and some positions,
particularly the airline-related IDBs, appreciated, boosting the fund's
returns. Market price performance reflects investor demand as well as
investment results, and we believe the recovery in the equity market
over the year's second half reduced investor demand for fixed-income
investments, accounting for the lower return at market price.

FUND PROFILE

Putnam Managed Municipal Income Trust seeks to provide as high a level
of current income free from federal in come tax as is consistent with
preser vation of capital through investments in investment- grade and
higher-yielding, lower-rated mu nicipal bonds. The fund is designed for
investors seeking tax-exempt income and willing to accept the risks
associated with below-investment-grade bonds.


Market overview

The municipal bond market was highly volatile during the fund's fiscal
year ended October 31, 2003. In the first few months, falling tax
revenues led to a decline in municipal credit quality. This, in
combination with a burgeoning supply of bonds, pushed yields higher and
bond prices lower. During the winter and spring, fears of an economic
slowdown and deflation led to lower yields and higher prices. Through
summer and early fall, mixed economic reports caused bond yields to
trace a very jagged path. Overall, yields ended the fiscal year higher.
The spread, or difference between yields of 10-year municipal bonds and
10-year Treasuries, widened, with municipals yielding close to their
long-term average of 85% of comparable Treasury yields at the end of
October, after yielding nearly 100% of Treasury yields earlier in the
year. Investor demand for higher-yielding municipals increased,
resulting in higher bond prices and lower yields. As the economy
improved, airline-related industrial development bonds outperformed.
California general obligation bonds were downgraded and underperformed
as the state's budget crisis worsened. Tobacco settlement bonds
initially underperformed following unfavorable rulings in some of the
industry's ongoing litigations, although they began to rally in the
second half following the Illinois Supreme Court's favorable ruling on
one of the industry's ongoing litigation matters.

- -------------------------------------------------------------------------------
MARKET SECTOR PERFORMANCE 12 MONTHS ENDED 10/31/03
- -------------------------------------------------------------------------------
Fixed-income securities
- -------------------------------------------------------------------------------
Lehman Municipal Bond Index (tax-exempt bonds)                          5.12%
- -------------------------------------------------------------------------------
Lehman Aggregate Bond Index (broad bond market)                         4.90%
- -------------------------------------------------------------------------------
Lehman Government Bond Index (U.S. Treasury and agency
securities)                                                             2.90%
- -------------------------------------------------------------------------------
Lehman Intermediate Treasury Bond Index
(intermediate-maturity U.S. Treasury bonds)                             2.29%
- -------------------------------------------------------------------------------
Stocks
- -------------------------------------------------------------------------------
S&P 500 Index (broad stock market)                                     20.80%
- -------------------------------------------------------------------------------
S&P Utilities Index (utilities stocks)                                 26.25%
- -------------------------------------------------------------------------------
Russell 2000 Growth Index (growth stocks of small and
midsize companies)                                                     46.56%
- -------------------------------------------------------------------------------
These indexes provide an overview of performance in different market
sectors for the 12 months ended 10/31/03.
- -------------------------------------------------------------------------------

Strategy overview

We shortened the fund's duration (a measure of sensitivity to changes in
interest rates) in May because interest rates were at historically low
levels and were more likely, in our opinion, to rise than to fall. This
defensive strategy helped protect portfolio assets when rates rose
sharply between mid June and the end of July. We resumed a neutral
duration in August and September, as we believed rates were unlikely to
rise further. In September, rates fell again, so we shortened duration
somewhat. This was beneficial when rates rose in October. At the end of
the period, the portfolio's duration remained slightly defensive.

In late July, we closed out the fund's cross-market arbitrage position,
a strategy we had established earlier in the fiscal year. You may recall
that we sought to take advantage of a market anomaly in which municipal
bond yields, which are generally tax exempt, were nearly as high as
comparable taxable Treasury yields. We bought intermediate-term
municipal bonds and sold 10-year Treasury futures contracts,
anticipating that the muni/Treasury yield ratio would revert to its
long-term average and create an opportunity for gain. In fact, the yield
ratio did fall; however, we bought back the Treasury futures too soon
and the trade was not profitable for the fund.

We took the opportunity afforded by strong demand for higher-yielding
municipal bonds to reduce positions in some of the fund's lower-quality
holdings, particularly airline-related industrial development bonds.
This enabled us to expand the fund's diversification into other areas
where we saw stronger potential, such as utilities and real estate
development.


[GRAPHIC OMITTED: horizontal bar chart TOP SECTOR WEIGHTINGS COMPARED]

TOP SECTOR WEIGHTINGS COMPARED

                          as of 4/30/03          as of 10/31/03

Health care                   26.7%                  26.5%

Utilities                     16.0%                  20.2%

Transportation                19.5%                  14.0%

Water and sewer                3.0%                   3.8%

Housing                        3.2%                   3.6%

Footnote reads:
Weightings are shown as a percentage of portfolio market value. Holdings
will vary over time.


How fund holdings affected performance

While the fund's relatively long duration proved beneficial during the
first half of the year, the second half was dominated by the strong
price recovery from its airline-related industrial development bonds
(IDBs), which had detracted significantly from performance during fiscal
2002 and the first half of 2003. IDBs are usually issued to finance
local expansion by various businesses and are backed by revenues from
the companies benefiting from the financing. As a result, IDB prices are
affected by investor perceptions of the health of the backing company or
of the industry group. Especially since the terrorist attacks of
September 11, 2001, airline-related IDBs (generally issued to finance
airport facility expansion) have been negatively affected by declining
air traffic, high fixed costs, and high-profile bankruptcies. As the
prospects for economic recovery improved during the fiscal year, the
airline market strengthened and concerns about bankruptcies diminished.
We capitalized on the strong price recovery to trim the fund's airline
IDBs, including airport facility improvement bonds in Illinois,
Kentucky, Michigan, North Carolina, Pennsylvania, Texas, and Washington
state for American Airlines, United Airlines, Delta Airlines, US
Airways, and Northwest Airlines. Since all of these bonds have been in
the portfolio for some time, none of the sales resulted in a profit
based on their acquisition cost, but the fund was able to sell on
strength rather than in distress.

The airline business is one of many industries that have been recovering
with the economy. One of the fund's larger holdings, Pocahontas Parkway
Association Toll Road Revenue Bonds, also rose in value as traffic (and
tolls) picked up. We purchased $3.9 million of these bonds in 1998. They
have a coupon of 5.5%, mature in 2028, and are rated Baa3 by Moody's and
BB by Standard & Poor's. The Pocahontas Parkway, which opened in October
of 2002, is a major connector to the Richmond International Airport, and
includes the only bridge crossing the James River for 15 miles. During
construction, the price of the bonds fell as the sluggish economy caused
traffic projections to fall off and investors to become concerned about
the issuer's ability to service debt. However, road traffic has picked
up with the economy in the past six months and tolls are approaching
previous projections. The bonds are still trading at a discount, and
traffic will need to increase further in order to support the bond's
interest payments, but we are cautiously optimistic.


[GRAPHIC OMITTED: pie chart CREDIT QUALITY OVERVIEW]

CREDIT QUALITY OVERVIEW

Aaa/AAA (37.6%)

Aa/AA (2.2%)

A (10.6%)

Baa/BBB (26.0%)

Ba/BB (11.2%)

B (5.4%)

CCC and
below (1.8%)

VMIG1/A-1+ (5.2%)

Footnote reads:
As a percentage of market value as of 10/31/03. A bond rated Baa or
higher is considered investment grade. The chart reflects Moody's and
Standard & Poor's ratings; percentages may include unrated bonds
considered by Putnam Management to be of comparable quality. Ratings
will vary over time.

Although the past several months have been positive for the bond market
as a whole, not every bond has gone up in value. For example, in 1998 we
bought Michigan State Strategic Fund Resource Recovery Revenue Bonds
issued for Central Wayne Energy Resources. These bonds were issued to
finance a trash-to-energy project in Detroit, but it experienced
numerous technical problems and the plant never met production
expectations. It was shut down in August of 2003 and we sold the
position at a loss. In another situation, we are in discussions with the
managers of Hoover Group, Inc., a Nebraska company that makes large
industrial containers for shipping products and raw materials. We own
IDBs issued for Hoover Group by Gage County, Nebraska in 1987 with a
coupon of 8.5%. The poor economy and competitive pricing have eroded
revenues and the company is seeking concessions from debt holders. As of
the end of October 2003, the fund's counsel was studying the situation.

All our purchase and sale decisions involve careful judgments, balancing
yield and credit quality as well as diversification by industry and
issuer. In March of this year, when several court cases threatened to go
against tobacco companies, we became concerned about possible weakness
in their revenues and began reducing the fund's exposure to some
high-yielding tobacco settlement bonds. (These bonds are issued by
municipalities and secured by settlements from class-action lawsuits
against the tobacco industry.) However, this fall, a series of rulings
has been more favorable for the tobacco companies. Since the bonds have
attractive coupons and give the fund exposure to a unique type of bond,
we have been rebuilding the position. For example, we recently added $3
million in Badger Tobacco Asset Securitization bonds issued in
Wisconsin. The series we purchased has a coupon of 7%, matures in 2028,
and is rated Baa2 by Moody's.

Another facet of our diversification strategy includes municipal bonds
issued to finance real estate developments. These deals are relatively
hard to come by, and our analysts' experience in this market is
especially valuable here. Two recent acquisitions are in California --
one in Sacramento for North Natomas Community Facilities District and
the other in Chula Vista for Otay Ranch Village. Both bonds have a
coupon of 6% and mature in 2033. Neither is rated by Moody's or S&P. In
both cases, the  developers purchased a large tract of land and are
using the bond proceeds for such municipal improvements as roads, sewer
systems, and street lighting. Currently, taxes paid by each developer
are funding the bonds. The developers plan to sell large tracts of land
to home-building contractors who create developments that include
commercial properties as well as single- and multi-family homes. As
builders acquire tracts, the taxpayer base for each issue diversifies.
As people buy the new homes, their taxes pay interest on the bonds,
spreading out bondholders' risks still further. Since these issues are
not rated, we are careful about which developments we choose, and often
deal with developers we know from past experience.

Please note that all holdings discussed in this report are subject to
review in accordance with the fund's investment strategy and may vary in
the future.

The fund's management team

The fund is managed by the Putnam Tax Exempt Fixed-Income Team. The
members of the team are David Hamlin (Portfolio Leader), Paul Drury
(Portfolio Member), Susan McCormack (Portfolio Member), James St. John
(Portfolio Member), Richard Wyke (Portfolio Member), and Kevin Cronin.


The outlook for your fund

The following commentary reflects anticipated developments that could
affect your fund over the next six months, as well as your management
team's plans for responding to them.

We anticipate continued market volatility in the coming six months, and
we believe the Federal Reserve Board will hold the federal funds rate
steady at 1%. Our 12- to 18-month outlook is less certain. If economic
policy succeeds, we may experience a classic bear market for bonds that
may push yields higher. However, it is also possible that the economy
may not respond satisfactorily to fiscal and monetary policy, and the
yield on 10-year Treasuries could fall. Given this degree of
uncertainty, we have, at this time, positioned the fund's duration
somewhat defensively, and we believe rates may rise in the short term.
Currently, we no longer see much opportunity to capitalize on yield
spreads between municipal bonds and Treasuries, as the relationship
between them is now near the long-term average. We expect that the
credit quality of general obligation municipal bonds will remain under
pressure because tax revenues cannot be expected to grow significantly
until taxpayers begin to report improved earnings. Although yield
spreads between high- and low-quality municipal bonds have narrowed
somewhat, we believe they could narrow further. As a result, we may see
more opportunity for potential gain in this area. In keeping with the
fund's objective, we will continue to monitor market conditions as we
pursue a high level of tax-free income and manage the fund's risk
exposures.

The views expressed in this report are exclusively those of Putnam
Management. They are not meant as investment advice. Lower-rated bonds
may offer higher yields in return for more risk. Mutual funds that
invest in government securities are not guaranteed. Mortgage-backed
securities are subject to prepayment risk.


Performance summary

This section provides information about your fund's performance during
its fiscal year, which ended October 31, 2003. In accordance with
regulatory requirements, we also include performance for the most
current calendar quarter-end. Performance should always be considered in
light of a fund's investment strategy. Past performance does not
indicate future results. More recent returns may be less or more than
those shown. Investment return, net asset value, and market price will
fluctuate and you may have a gain or a loss when you sell your shares. A
profile of your fund's strategy appears on the first page of this
report. See page 9 for definitions of some terms used in this section.

<TABLE>
<CAPTION>
- ----------------------------------------------------------------------------------
TOTAL RETURN FOR PERIODS ENDED 10/31/03
- ----------------------------------------------------------------------------------
                                                                   Lipper Closed-
                                                                   End High Yield
                                                       Lehman        Municipal
                                                      Municipal     Debt Funds
                           NAV       Market price    Bond Index  category average*
- ----------------------------------------------------------------------------------
<S>                      <C>           <C>           <C>            <C>
1 year                     9.67%         6.44%         5.12%          7.48%
- ----------------------------------------------------------------------------------
5 years                   17.70         -7.05         31.08          19.28
Annual average             3.31         -1.45          5.56           3.55
- ----------------------------------------------------------------------------------
10 years                  55.18         36.52         78.34          66.54
Annual average             4.49          3.16          5.96           5.20
- ----------------------------------------------------------------------------------
Annual average
Life of fund
(since 2/24/89)            6.84          5.71          7.39           5.86
- ----------------------------------------------------------------------------------

  Performance does not reflect taxes on reinvested distributions.

  Index and Lipper results should be compared to fund performance at net
  asset value.

* Over the 1-, 5-, and 10-year periods ended 10/31/03, there were 12,
  12, and 12 funds, respectively, in this Lipper category.

</TABLE>


- -------------------------------------------------------------------------
TOTAL RETURN FOR PERIODS ENDED 9/30/03 (MOST RECENT CALENDAR QUARTER)
- -------------------------------------------------------------------------
                            NAV       Market price
- -------------------------------------------------------------------------
1 year                     6.15%         -0.03%
- -------------------------------------------------------------------------
5 years                   17.83          -2.20
Annual average             3.34          -0.44
- -------------------------------------------------------------------------
10 years                  56.60          41.28
Annual average             4.59           3.52
- -------------------------------------------------------------------------
Annual average
Life of fund
(since 2/24/89)            6.90           5.95
- -------------------------------------------------------------------------


- ------------------------------------------------------------------------------
PRICE AND DISTRIBUTION INFORMATION 12 MONTHS ENDED 10/31/03
- ------------------------------------------------------------------------------
Putnam Managed Municipal Income Trust
- ------------------------------------------------------------------------------
Distributions from common shares
Number                                               12
- ------------------------------------------------------------------------------
Income 1                                             $0.570
- ------------------------------------------------------------------------------
Capital gains 1                                      --
- ------------------------------------------------------------------------------
Total                                                $0.570
- ------------------------------------------------------------------------------
Distributions from                   Series A         Series B       Series C
preferred shares                   (550 shares)     (550 shares)   (650 shares)
- ------------------------------------------------------------------------------
Income 1                            $1,091.89        $1,090.74      $1,093.77
- ------------------------------------------------------------------------------
Capital gains 1                     --               --             --
- ------------------------------------------------------------------------------
Total                               $1,091.89        $1,090.74      $1,093.77
- ------------------------------------------------------------------------------
Share value (common shares)                           NAV       Market price
- ------------------------------------------------------------------------------
10/31/02                                             $7.84          $7.43
- ------------------------------------------------------------------------------
10/31/03                                              7.98           7.34
- ------------------------------------------------------------------------------
Current return (common shares, end of period)
- ------------------------------------------------------------------------------
Current dividend rate 2                              7.14%          7.77%
- ------------------------------------------------------------------------------
Taxable equivalent 3                                10.98          11.95
- ------------------------------------------------------------------------------

1 Capital gains, if any, are taxable for federal and, in most cases,
  state purposes. For some investors, investment income may be subject to
  the federal alternative minimum tax. Income from federally exempt funds
  may be subject to state and local taxes.

2 Most recent distribution, excluding capital gains, annualized and
  divided by NAV or market price at end of period.

3 Assumes maximum 35% federal tax rate for 2003. Results for investors
  subject to lower tax rates would not be as advantageous.


Terms and definitions

Total return shows how the value of the fund's shares changed over time,
assuming you held the shares through the entire period and reinvested
all distributions in the fund.

Net asset value (NAV) is the value of all your fund's assets, minus any
liabilities and the net assets allocated to remarketed preferred shares
divided by the number of outstanding common shares.

Market price is the current trading price of one share of the fund.
Market prices are set by transactions between buyers and sellers on
public exchanges such as the New York Stock Exchange or the American
Stock Exchange.


Comparative indexes

Lehman Aggregate Bond Index is an unmanaged index used as a general
measure of U.S. fixed-income securities.

Lehman Government Bond Index is an unmanaged index of U.S. Treasury and
agency securities.

Lehman Intermediate Treasury Bond Index is an unmanaged index of
Treasury bonds with maturities between 1 and 10 years.

Lehman Municipal Bond Index is an unmanaged index of long-term
fixed-rate investment-grade tax-exempt bonds.

Russell 2000 Growth Index is an unmanaged index of those companies in
the Russell 2000 Index chosen for their growth orientation.

S&P 500 Index is an unmanaged index of common stock performance.

S&P Utilities Index is an unmanaged index of common stock issued by
utilities companies.

Indexes assume reinvestment of all distributions and do not account for
fees. Securities and performance of a fund and an index will differ. You
cannot invest directly in an index.

Lipper Inc. is a third-party industry ranking entity that ranks funds
(without sales charges) with similar current investment styles or
objectives as determined by Lipper. Lipper category averages reflect
performance trends for funds within a category and are based on results
at net asset value.


Putnam's policy on confidentiality

In order to conduct business with our shareholders, we must obtain
certain personal information such as account holders' addresses,
telephone numbers, Social Security numbers, and the names of their
financial advisors. We use this information to assign an account number
and to help us maintain accurate records of transactions and account
balances.

It is our policy to protect the confidentiality of your information,
whether or not you currently own shares of our funds, and in particular,
not to sell information about you or your accounts to outside marketing
firms. We have safeguards in place designed to prevent unauthorized
access to our computer systems and procedures to protect personal
information from unauthorized use.

Under certain circumstances, we share this information with outside
vendors who provide services to us, such as mailing and proxy
solicitation. In those cases, the service providers enter into
confidentiality agreements with us, and we provide only the information
necessary to process transactions and perform other services related to
your account. We may also share this information with our Putnam
affiliates to service your account or provide you with information about
other Putnam products or services. It is also our policy to share
account information with your financial advisor, if you've listed one on
your Putnam account.

If you would like clarification about our confidentiality policies or
have any questions or concerns, please don't hesitate to contact us at
1-800-225-1581, Monday through Friday, 8:30 a.m. to 7:00 p.m., or
Saturdays from 9:00 a.m. to 5:00 p.m. Eastern Time.

Putnam is committed to managing our mutual funds in the best interests
of our shareholders. Our proxy voting guidelines and policies are
available on the Putnam Individual Investor Web site,
www.putnaminvestments.com, by calling Putnam's Shareholder Services at
1-800-225-1581, or on the SEC's Web site, www.sec.gov.


A guide to the financial statements

These sections of the report, as well as the accompanying Notes,
preceded by the Independent Auditors' Report, constitute the fund's
financial statements.

The fund's portfolio lists all the fund's investments and their values
as of the last day of the reporting period. Holdings are organized by
asset type and industry sector, country, or state to show areas of
concentration and diversification.

Statement of assets and liabilities shows how the fund's net assets and
share price are determined. All investment and noninvestment assets are
added together.  Any unpaid expenses and other liabilities are
subtracted from this total. The result is divided by the number of
shares to determine the net asset value per share, which is calculated
separately for each class of shares. (For funds with preferred shares,
the amount subtracted from total assets includes the net assets
allocated to remarketed preferred shares.)

Statement of operations shows the fund's net investment gain or loss.
This is done by first adding up all the fund's earnings -- from
dividends and interest income -- and subtracting its operating expenses
to determine net investment income (or loss).  Then, any net gain or
loss the fund realized on the sales of its holdings -- as well as any
unrealized gains or losses over the period -- is added to or subtracted
from the net investment result to determine the fund's net gain or loss
for the fiscal year.

Statement of changes in net assets shows how the fund's net assets were
affected by distributions to shareholders and by changes in the number
of the fund's shares. It lists distributions and their sources (net
investment income or realized capital gains) over the current reporting
period and the most recent fiscal year-end. The distributions listed
here may not match the sources listed in the Statement of operations
because the distributions are determined on a tax basis and may be paid
in a different period from the one in which they were earned.

Financial highlights provide an overview of the fund's investment
results,   per-share distributions, expense ratios, net investment
income ratios, and portfolio turnover in one summary table, reflecting
the five most recent reporting periods. In a semiannual report, the
highlight table also includes the current reporting period. For open-end
funds, a separate table is provided for each share class.


Independent auditors' report

The Board of Trustees and Shareholders
Putnam Managed Municipal Income Trust

We have audited the accompanying statement of assets and liabilities of
Putnam Managed Municipal Income Trust, including the fund's portfolio,
as of October 31, 2003, and the related statement of operations for the
year then ended, the statements of changes in net assets for each of the
two years in the period then ended and the financial highlights for each
of the five years in the period then ended. These financial statements
and financial highlights are the responsibility of the Fund's
management. Our responsibility is to express an opinion on these
financial statements and financial highlights based on our audits.

We conducted our audits in accordance with auditing standards generally
accepted in the United States of America. Those standards require that
we plan and perform our audit to obtain reasonable assurance about
whether the financial statements and financial highlights are free of
material misstatement. An audit includes examining, on a test basis,
evidence supporting the amounts and disclosures in the financial
statements. Our procedures included confirmation of securities owned as
of October 31, 2003 by correspondence with the custodian and brokers or
by other appropriate auditing procedures. An audit also includes
assessing the accounting principles used and significant estimates made
by management, as well as evaluating the overall financial statement
presentation. We believe that our audits provide a reasonable basis for
our opinion.

In our opinion, the financial statements and financial highlights
referred to above present fairly, in all material respects, the
financial position of Putnam Managed Municipal Income Trust as of
October 31, 2003, the results of its operations for the year then ended,
the changes in its net assets for each of the two years in the period
then ended, and the financial highlights for each of the five years in
the period then ended in conformity with accounting principles generally
accepted in the United States of America.


KPMG  LLP
Boston, Massachusetts
December 9, 2003


The fund's portfolio
October 31, 2003

Key to Abbreviations
- -------------------------------------------------------------------------------
AMBAC                 AMBAC Indemnity Corporation
COP                   Certificate of Participation
FGIC                  Financial Guaranty Insurance Company
FNMA Coll.            Federal National Mortgage Association Collateralized
FRB                   Floating Rate Bonds
FSA                   Financial Security Assurance
GNMA Coll.            Government National Mortgage Association Collateralized
G.O. Bonds            General Obligation Bonds
IFB                   Inverse Floating Rate Bonds
MBIA                  MBIA Insurance Company
PSFG                  Permanent School Fund Guaranteed
U.S. Govt. Coll.      U.S. Government Collateralized
VRDN                  Variable Rate Demand Notes

Municipal bonds and notes (98.8%) (a)
Principal amount                                     Rating (RAT)         Value

Arizona (1.5%)
- -------------------------------------------------------------------------------
    $1,000,000 Apache Cnty., Indl. Dev. Auth. Poll.
               Control Rev. Bonds (Tucson Elec.
               Pwr. Co.), Ser. B, 5 7/8s, 3/1/33     Ba3               $928,750
     1,000,000 AZ Hlth. Fac. Auth. Hosp. Syst.
               Rev. Bonds  (John C. Lincoln Hlth.
               Network), 6 3/8s, 12/1/37             BBB              1,022,500
     1,800,000 Casa Grande, Indl. Dev. Auth.
               Rev. Bonds  (Casa Grande Regl. Med.
               Ctr.), Ser. A, 7 5/8s, 12/1/29        B-/P             1,854,000
     3,000,000 Coconino Cnty., Poll. Control
               Rev. Bonds (Tuscon/Navajo Elec.
               Pwr.), Ser. A, 7 1/8s, 10/1/32        Ba3              3,045,000
       560,000 Scottsdale, Indl. Dev. Auth.
               Rev. Bonds (Westminster Village),
               7 7/8s, 6/1/09                        BB-/P              586,600
     1,000,000 Scottsdale, Indl. Dev. Hosp. Auth.
               Rev. Bonds (Scottsdale Hlth. Care),
               5.8s, 12/1/31                         A3               1,028,750
                                                                 --------------
                                                                      8,465,600

Arkansas (1.5%)
- -------------------------------------------------------------------------------
     4,600,000 AR State Hosp. Dev. Fin. Auth.
               Rev. Bonds  (WA Regl. Med. Ctr.),
               7 3/8s, 2/1/29                        Baa3             4,979,500
     2,750,000 Northwest Regl. Arpt. Auth.
               Rev. Bonds,  7 5/8s, 2/1/27           BB/P             2,990,625
                                                                 --------------
                                                                      7,970,125

California (13.6%)
- -------------------------------------------------------------------------------
       250,000 ABAG Fin. Auth. for Nonprofit Corps.
               Rev. Bonds (San Diego Hosp. Assn.),
               Ser. C, 5 3/8s, 3/1/21                Baa1               242,500
     1,235,000 Brentwood, Infrastructure Auth.
               Rev. Bonds, Ser. 94-1, 5 5/8s,
               9/2/29                                BB-/P            1,204,125
     7,000,000 CA Hlth. Fac. Auth. IFB (Catholic
               Hlth. Care West), AMBAC, 9.506s,
               7/1/17                                Aaa              7,535,150
     2,000,000 CA State G.O. Bonds, FGIC, 6.6s,
               2/1/11                                Aaa              2,397,500
               CA State Dept. of Wtr. Resources
               Rev. Bonds, Ser. A
     1,000,000 6s, 5/1/15                            A3               1,117,500
    20,000,000 AMBAC, 5 1/2s, 5/1/13                 Aaa             22,450,000
     3,000,000 5 1/2s, 5/1/11                        A3               3,318,750
     3,000,000 CA Statewide Cmnty. Dev. Auth. COP
               (The Internext Group), 5 3/8s,
               4/1/30                                BBB-             2,760,000
     1,250,000 Chula Vista, Cmnty. Fac. Dist.
               Special Tax  (No. 08-1 Otay Ranch
               Village Six), 6s, 9/1/33              BB/P             1,223,438
               Corona, COP
     2,775,000 (Vista Hosp. Syst.), Ser. B, 9 1/2s,
               7/1/20 (In default) (NON)             D/P              1,110,000
     5,000,000 (Hosp. Syst., Inc.), Ser. C, 8 3/8s,
               7/1/11 (In default) (NON)             D/P              2,000,000
       750,000 Folsom, Special Tax (Cmnty. Facs.
               Dist. No. 10), 5 7/8s, 9/1/28         BB/P               743,438
     1,970,000 Gilroy, Rev. Bonds (Bonfante Gardens
               Park),  8s, 11/1/25                   B/P              1,615,400
     2,500,000 Golden State Tobacco Securitization
               Corp.  Rev. Bonds, Ser. B, 5 5/8s,
               6/1/38                                Baa1             2,425,000
     1,755,000 Lancaster, Redev. Agcy. Tax Alloc.
               (Redev. Project Areas), MBIA, 5s,
               8/1/16                                Aaa              1,926,112
       650,000 Orange Cnty., Cmnty. Fac. Dist.
               Special Tax Bonds (Ladera Ranch -
               No. 02-1), Ser. A, 5.55s, 8/15/33     BB+/P              632,938
     1,250,000 Sacramento, Special Tax (North
               Natomas Cmnty. Fac.), Ser. 4-C, 6s,
               9/1/33                                BB+/P            1,246,875
     7,000,000 San Bernardino Cnty.,
               Certificates of Participation (Med.
               Ctr. Fin.), Ser. A, MBIA, 6 1/2s,
               8/1/28                                Aaa              7,778,750
     3,000,000 San Luis Obispo, COP (Vista Hosp.
               Syst., Inc.), 8 3/8s, 7/1/29 (In
               default) (NON)                        D/P              1,200,000
     8,750,000 Santa Clara Cnty., Fin. Auth. Lease
               Rev. Bonds (VMC Fac. Replacement
               Project), Ser. A, AMBAC, 6 3/4s,
               11/15/20                              Aaa              9,433,463
     3,400,000 Valley Hlth. Syst. Hosp. Rev. Bonds
               (Refunding & Impt.),  Ser. A,
               6 1/2s, 5/15/25                       B+               2,282,250
                                                                 --------------
                                                                     74,643,189

Colorado (1.9%)
- -------------------------------------------------------------------------------
     3,015,000 CO Hlth. Fac. Auth.
               Rev. Bonds (Evangelical Lutheran),
               3.05s, 10/1/05                        A3               3,094,144
               CO Hwy. Auth. Rev. Bonds (E-470 Pub.
               Hwy.), Ser. B
    15,500,000 zero %, 9/1/35                        Baa3             1,472,500
    16,500,000 zero %, 9/1/34                        Baa3             1,691,250
               Denver, City & Cnty. Arpt.
               Rev. Bonds
     1,050,000 Ser. D, AMBAC, 7 3/4s, 11/15/13       AAA              1,294,125
     2,500,000 MBIA, 5 1/2s, 11/15/25                Aaa              2,618,750
                                                                 --------------
                                                                     10,170,769

District of Columbia (0.6%)
- -------------------------------------------------------------------------------
     4,000,000 DC Tobacco Settlement Fin. Corp.
               Rev. Bonds, 6 1/2s, 5/15/33           Baa2             3,525,000

Florida (3.7%)
- -------------------------------------------------------------------------------
     2,000,000 Cap. Trust Agcy. Rev. Bonds
               (Seminole Tribe Convention), Ser. A,
               10s, 10/1/33                          B/P              2,377,500
     3,210,000 Escambia Cnty., Poll. Control
               Rev. Bonds (Champion Intl. Corp.),
               6.9s, 8/1/22                          Baa2             3,345,687
     1,000,000 Fishhawk, Cmnty. Dev. Dist. II
               Rev. Bonds, Ser. B, 5s, 11/1/07       BB-/P            1,006,250
     1,000,000 Gateway Svcs. Cmnty. Dev. Dist.
               Special Assmt. (Stoneybrook),
               5 1/2s, 7/1/08                        BB-/P            1,013,750
       500,000 Heritage Harbor, South Cmnty. Dev.
               Distr. Rev. Bonds (Cap. Impt.),
               Ser. A, 6 1/2s, 5/1/34                BB-/P              507,500
     5,000,000 Hernando Cnty., Indl. Dev.
               Rev. Bonds (FL Crushed Stone Co.),
               8 1/2s, 12/1/14                       A-/P             5,113,900
     1,000,000 Lee Cnty., Indl. Dev. Auth.
               Rev. Bonds (Alliance Cmnty.
               Project), Ser. C, 5 1/2s, 11/15/29    BBB-               928,750
     1,335,000 Miami Beach, Hlth. Fac. Auth. Hosp.
               Rev. Bonds (Mount Sinai Med. Ctr.),
               Ser. A, 6.7s, 11/15/19                BB               1,309,969
     1,500,000 South Miami, Hlth. Fac. Auth.
               Rev. Bonds (Baptist Hlth.), 5 1/4s,
               11/15/33                              Aa3              1,501,875
     2,000,000 St. Johns Cnty., Hlth. Care Indl.
               Dev. Auth. Rev. Bonds  (Glenmoor St.
               Johns Project), Ser. A, 8s, 1/1/30    B-/P             1,905,000
     1,000,000 Sterling Hill, Cmnty. Dev. Dist.
               Rev. Bonds, Ser. B, 5 1/2s, 11/1/10   BB-/P              993,750
                                                                 --------------
                                                                     20,003,931

Georgia (0.9%)
- -------------------------------------------------------------------------------
     4,000,000 Burke Cnty., Poll. Control Dev.
               Auth. Mandatory Put Bonds (GA Power
               Co.), 4.45s, 1/1/32                   A2               4,205,000
       700,000 GA Med. Ctr. Hosp. Auth. IFB, MBIA,
               11.568s, 8/1/10                       Aaa                718,879
                                                                 --------------
                                                                      4,923,879

Hawaii (0.3%)
- -------------------------------------------------------------------------------
     1,760,000 HI Dept. of Trans. Special Fac.
               Rev. Bonds (Continental Airlines,
               Inc.), 7s, 6/1/20                     B                1,665,400

Illinois (2.4%)
- -------------------------------------------------------------------------------
               Chicago, G.O. Bonds
     4,850,000 Ser. A, AMBAC, 5 5/8s, 1/1/39         Aaa              5,110,678
     3,500,000 Ser. C, FGIC, 5 1/2s, 1/1/40          Aaa              3,640,000
     1,495,000 Chicago, O'Hare Intl. Arpt. Special
               Fac. Rev. Bonds (American Airlines,
               Inc.), 8.2s, 12/1/24                  Caa2             1,044,631
     3,250,000 IL Dev. Fin. Auth. Hosp. Rev. Bonds
               (Adventist Hlth. Syst./Sunbelt
               Obligation), 5.65s, 11/15/24          A                3,270,313
                                                                 --------------
                                                                     13,065,622

Indiana (2.0%)
- -------------------------------------------------------------------------------
     2,500,000 IN State Dev. Fin. Auth. Env. Impt.
               Rev. Bonds (USX Corp.), 5.6s,
               12/1/32                               Baa1             2,440,625
     6,500,000 IN Trans. Fin. Auth. Arpt. Facs.
               Lease Rev. Bonds, Ser. A, AMBAC, 5s,
               11/1/16                               Aaa              6,857,500
     1,750,000 Rockport, Poll. Control Mandatory
               Put Bonds (Indiana Michigan Pwr.
               Co.), Ser. C, 2 5/8s, 4/1/25          Baa2             1,739,063
                                                                 --------------
                                                                     11,037,188

Iowa (1.0%)
- -------------------------------------------------------------------------------
               IA Fin. Auth. Hlth. Care Fac.
               Rev. Bonds (Care Initiatives)
    $2,970,000 9 1/4s, 7/1/25                        BBB-/P          $3,526,875
     1,555,000 9.15s, 7/1/09                         BBB-/P           1,799,913
                                                                 --------------
                                                                      5,326,788

Kentucky (0.8%)
- -------------------------------------------------------------------------------
     2,035,000 Kenton Cnty., Arpt. Board Rev. Bonds
               (Special Fac. -  Delta Airlines,
               Inc.), Ser. A, 7 1/2s, 2/1/20         B                2,034,349
     1,700,000 KY Econ. Dev. Fin. Auth. Rev. Bonds
               (Norton Healthcare, Inc.), Ser. A,
               6 1/2s, 10/1/20                       BBB/P            1,772,250
     1,000,000 Scott Cnty., Indl. Dev. Rev. Bonds
               (Hoover Group, Inc.), 8 1/2s,
               11/1/14                               Ba3                500,000
                                                                 --------------
                                                                      4,306,599

Louisiana (0.9%)
- -------------------------------------------------------------------------------
     2,000,000 LA Pub. Fac. Auth. Hosp. Rev. Bonds
               (Lake Charles Memorial Hosp.
               Project), 8 5/8s, 12/1/30             CCC/P            1,642,500
       500,000 Tangipahoa Parish Hosp. Svcs.
               Rev. Bonds (North Oaks Med. Ctr.
               Project), Ser. A, 5s, 2/1/25          A                  480,625
     2,750,000 W. Feliciana Parish, Poll. Control
               Rev. Bonds (Gulf States Util. Co.),
               Ser. C, 7s, 11/1/15                   Ba1              2,859,918
                                                                 --------------
                                                                      4,983,043

Maine (0.4%)
- -------------------------------------------------------------------------------
     2,000,000 Rumford, Solid Waste Disp.
               Rev. Bonds (Boise Cascade Corp.),
               6 7/8s, 10/1/26                       Ba2              2,000,000

Massachusetts (5.0%)
- -------------------------------------------------------------------------------
               MA State Hlth. & Edl. Fac. Auth.
               Rev. Bonds
     2,000,000 (Civic Investments), Ser. A, 9s,
               12/15/15                              BB/P             2,272,500
     3,240,000 (Rehab. Hosp. Cape & Islands),
               Ser. A,  (U.S. Govt. Coll.) 7 7/8s,
               8/15/24                               AAA/P            3,471,563
     1,185,000 (Norwood Hosp.), Ser. C, 7s, 7/1/14   Ba2              1,494,581
     1,200,000 (Jordan Hosp.), Ser. E, 6 3/4s,
               10/1/33                               BBB-             1,194,000
     2,500,000 (UMass Memorial), Ser. C, 6 5/8s,
               7/1/32                                Baa2             2,578,125
     1,875,000 (UMass Memorial), Ser. C, 6 1/2s,
               7/1/21                                Baa2             1,928,906
     1,500,000 (Caritas Christi Oblig. Group),
               Ser. A, 5 1/4s, 7/1/08                BBB              1,509,375
     7,645,000 MA State Hsg. Fin. Agcy. IFB, AMBAC,
               9.493s, 7/1/40 (acquired 6/3/98,
               cost $7,739,951) (RES)                AAA/P            7,950,800
     2,000,000 MA State Hsg. Fin. Agcy. Rev. Bonds
               (Rental Mtge.), Ser. C, AMBAC,
               5 5/8s, 7/1/40                        Aaa              2,035,000
     1,000,000 MA State Indl. Fin. Agcy. Rev. Bonds
               (1st Mtge. Brookhaven), Ser. A, 7s,
               1/1/15                                BBB/P            1,030,000
     1,900,000 MA State Wtr. Resource Auth. VRDN
               (Multi-Modal), Ser. C, 1.15s, 8/1/20  VMIG1            1,900,000
                                                                 --------------
                                                                     27,364,850

Michigan (3.5%)
- -------------------------------------------------------------------------------
     3,500,000 Detroit, Swr. Disp. VRDN, Ser. B,
               FSA, 1.15s, 7/1/33                    VMIG1            3,500,000
       500,000 Flint, Hosp. Bldg. Auth. Rev. Bonds
               (Hurley Med. Ctr.), 6s, 7/1/20        Baa3               468,750
     2,200,000 Macomb Cnty., Hosp. Fin. Auth.
               Rev. Bonds  (Mt. Clemens Gen.
               Hosp.), Ser. B, 5 7/8s, 11/15/34      BBB-             2,101,000
     1,500,000 MI State Hosp. Fin. Auth. Rev. Bonds
               (Oakwood Hosp.), Ser. A, 6s, 4/1/22   A2               1,599,375
     2,700,000 Pontiac, Hosp. Fin. Auth. Rev. Bonds
               (NOMC Obligation Group), Ser. B, 6s,
               8/1/18                                Ba1              2,227,500
     2,975,000 Warren Cons. School Dist. G.O.
               Bonds, FSA,  5 3/8s, 5/1/18           Aaa              3,227,875
     6,780,000 Waterford, Econ. Dev. Corp.
               Rev. Bonds (Canterbury Hlth.), 6s,
               1/1/39                                B-/P             4,618,875
     2,000,000 Wayne Charter Cnty., Special Arpt.
               Fac. Rev. Bonds (Northwest Airlines,
               Inc.), 6s, 12/1/29                    B+/P             1,587,500
                                                                 --------------
                                                                     19,330,875

Minnesota (1.1%)
- -------------------------------------------------------------------------------
     2,525,000 Chaska, Indl. Dev. Rev. Bonds
               (Lifecore Biomedical, Inc. Project),
               10 1/4s, 9/1/20                       BB/P             2,641,125
     3,200,000 St. Paul, Hsg. & Hosp. Redev. Auth.
               Rev. Bonds (Healtheast), Ser. B,
               6 5/8s, 11/1/17                       Ba2              3,204,000
                                                                 --------------
                                                                      5,845,125

Mississippi (0.4%)
- -------------------------------------------------------------------------------
     2,250,000 Mississippi Bus. Fin. Corp. Poll.
               Control Rev. Bonds (Syst. Energy
               Resources, Inc.), 5.9s, 5/1/22        BBB-             2,250,000

Missouri (0.9%)
- -------------------------------------------------------------------------------
     1,500,000 Cape Girardeau Cnty., Indl. Dev.
               Auth. Hlth. Care Fac. Rev. Bonds
               (St. Francis Med. Ctr.),
               Ser. A, 5 1/2s, 6/1/32                A                1,503,750
     2,000,000 MO Hsg. Dev. Comm. Rev. Bonds (Home
               Ownership), GNMA/FNMA Coll., 5.55s,
               9/1/34                                AAA              2,190,000
     1,450,000 MO State Hlth. & Edl. Fac. Auth.
               Rev. Bonds  (BJC Hlth. Syst.),
               5 1/4s, 5/15/32                       Aa2              1,473,563
                                                                 --------------
                                                                      5,167,313

Montana (1.8%)
- -------------------------------------------------------------------------------
     1,775,000 Forsyth, Poll. Control Mandatory Put
               Bonds (Avista Corp.), AMBAC, 5s,
               10/1/32                               Aaa              1,932,531
     8,130,000 Forsyth, VRDN (Pacific Corp.
               Project), 1.20s, 1/1/18               VMIG1            8,130,000
                                                                 --------------
                                                                     10,062,531

Nebraska (0.2%)
- -------------------------------------------------------------------------------
     2,000,000 Gage Cnty., Indl. Dev. Rev. Bonds
               (Hoover Group, Inc.), 8 1/2s,
               12/1/07                               Ba3              1,000,000
     2,410,239 Kearney, Indl. Dev. Rev. Bonds
               (Great Platte River Road), 6 3/4s,
               1/1/28 (In default) (NON)             D/P                     24
                                                                 --------------
                                                                      1,000,024

Nevada (1.3%)
- -------------------------------------------------------------------------------
     5,000,000 Clark Cnty., Indl. Dev. Rev. Bonds
               (Southwest Gas Corp.), Ser. C,
               AMBAC, 5.95s, 12/1/38                 Aaa              5,425,000
     1,595,000 Henderson, Local Impt. Dist. Special
               Assmt.  (No. T-14), 3.2s, 3/1/06      BB-/P            1,587,025
                                                                 --------------
                                                                      7,012,025

New Hampshire (1.1%)
- -------------------------------------------------------------------------------
               NH Muni. Bond Bank Rev. Bonds
     1,000,000 Ser. A, 5s, 2/15/11                   Aa2              1,102,500
     1,600,000 Ser. B, ST GTD, 5s, 2/15/08           AA+              1,770,000
       625,000 Ser. B, ST GTD, 5s, 8/15/07           AA+                689,063
     2,565,000 NH State Bus. Fin. Auth. Rev. Bonds
               (Alice Peck Day Hlth. Syst.),
               Ser. A, 7s, 10/1/29                   BB+/P            2,606,681
                                                                 --------------
                                                                      6,168,244

New Jersey (3.1%)
- -------------------------------------------------------------------------------
               NJ Econ. Dev. Auth. Rev. Bonds
     1,000,000 (1st Mtge.-Cranes Mill), Ser. A,
               7 1/2s, 2/1/27                        BB-/P            1,040,000
     1,250,000 (Cedar Crest Village, Inc. Fac.),
               Ser. A, 7 1/4s, 11/15/31              BB-/P            1,278,125
               NJ Hlth. Care Fac. Fin. Auth.
               Rev. Bonds
     3,000,000 (Trinitas Hosp. Oblig. Group),
               7 1/2s, 7/1/30                        Baa3             3,288,750
     2,000,000 (Columbus Hosp.), Ser. A, 5 3/4s,
               7/1/29                                BB+              1,872,500
     1,250,000 (Atlantic City Med. Ctr.), 5 3/4s,
               7/1/25                                A3               1,289,063
     1,000,000 (Somerset Med. Ctr.), 5 1/2s, 7/1/33  Baa2               955,000
     6,500,000 NJ State Trans. Trust Fund Auth.
               Rev. Bonds (Trans. Syst.), Ser. A,
               FSA, 5 1/2s, 6/15/12                  Aaa              7,369,375
                                                                 --------------
                                                                     17,092,813

New Mexico (1.4%)
- -------------------------------------------------------------------------------
     7,500,000 Farmington, Poll. Control VRDN (AZ
               Pub. Svc. Co.), Ser. A, 1.20s,
               5/1/24                                VMIG1            7,500,000

New York (14.7%)
- -------------------------------------------------------------------------------
     3,000,000 Long Island, Pwr. Auth. VRDN, Ser.
               2, 1.1s, 5/1/33                       VMIG1            3,000,000
     1,800,000 Long Island, Pwr. Auth. NY Elec.
               Syst. IFB, 9.264s,  12/1/24
               (acquired 10/20/03, cost $1,981,188)
               (RES)                                 BBB+/P           2,009,250
     2,000,000 Metro. Trans. Auth. Rev. Bonds,
               Ser. F, MBIA,  5s, 11/15/10           Aaa              2,232,500
    13,000,000 Nassau Cnty., Interim Fin. Auth.
               Rev. Bonds, Ser. B, MBIA, 5s,
               11/15/10                              Aaa             14,511,250
    10,000,000 NY City, G.O. Bonds, Ser. B, 5 1/4s,
               12/1/09                               A2              11,062,500
     1,500,000 NY City, Indl. Dev. Agcy. Rev. Bonds
                (Visy Paper, Inc.), 7.95s, 1/1/28    B+/P             1,548,750
     6,025,000 NY City, Indl. Dev. Agcy. Special
               Fac. Rev. Bonds (British Airways),
               5 1/4s, 12/1/32                       Ba2              4,255,156
     1,495,000 NY City, Indl. Dev. Agency
               Rev. Bonds (Staten Island U. Hosp.
               Project), 6.45s, 7/1/32               Baa3             1,569,750
     4,200,000 NY City, Muni. Wtr. & Swr. Fin.
               Auth. VRDN, Ser. G, FGIC, 1.5s,
               6/15/24                               VMIG1            4,200,000
    10,000,000 NY City, Muni. Wtr. Fin. Auth.
               Rev. Bonds, Ser. C, MBIA, 5 1/2s,
               6/15/17                               Aaa             10,937,500
       900,000 NY State Dorm. Auth. Rev. Bonds
               (Winthrop-U. Hosp. Assn.), Ser. A,
               5 1/2s, 7/1/32                        Baa1               916,875
     2,000,000 Onondaga Cnty., Indl. Dev. Agcy.
               Rev. Bonds (Solvay Paperboard, LLC),
               7s, 11/1/30                           BB-/P            2,105,000
     5,000,000 Port Auth. NY & NJ Rev. Bonds, Ser.
               96, FGIC, 6.6s, 10/1/23               Aaa              5,228,850
     5,000,000 Port Auth. NY & NJ Special
               Obligation IFB, Ser. N18, MBIA,
               8.64s, 12/1/17 (acquired
               7/19/00, cost $5,234,450) (RES)       Aaa              6,631,250
    10,000,000 Port Auth. NY & NJ Special
               Obligation FRB, Ser. N18, MBIA,
               1.15s, 12/1/17                        Aaa             10,000,000
                                                                 --------------
                                                                     80,208,631

North Carolina (1.3%)
- -------------------------------------------------------------------------------
               NC Eastern Muni. Pwr. Agcy. Syst.
               Rev. Bonds
     1,500,000 Ser. D, 6 3/4s, 1/1/26                BBB              1,642,500
     3,000,000 Ser. A, 5 3/4s, 1/1/26                BBB              3,056,250
               NC State Muni. Pwr. Agcy. Rev. Bonds
     1,000,000 (No. 1, Catawba Elec.), Ser. B,
               6 1/2s, 1/1/20                        Baa1             1,091,250
     1,300,000 Ser. A, 5 1/2s, 1/1/13                Baa1             1,404,000
                                                                 --------------
                                                                      7,194,000

Ohio (2.0%)
- -------------------------------------------------------------------------------
               Cuyahoga Cnty., Rev. Bonds, Ser. A
     1,280,000 6s, 1/1/16                            A1               1,400,000
     2,000,000 6s, 1/1/15                            A1               2,205,000
     1,000,000 Dayton, Fac. Rev. Bonds (Emery Air
               Freight), Ser. A, 5 5/8s, 2/1/18      BB+                801,250
     1,000,000 Erie Cnty., Ohio Hosp. Fac.
               Rev. Bonds (Firelands Regl. Med.
               Ctr.), 5 5/8s, 8/15/32                A2               1,012,500
     3,000,000 OH State Air Quality Dev. Auth.
               Rev. Bonds (Toledo Poll. Control),
               Ser. A, 6.1s, 8/1/27                  Baa2             3,075,000
     2,100,000 OH State Solid Waste Rev. Bonds
               (General Motors Corp. Project),
               6.3s, 12/1/32                         Baa1             2,189,250
                                                                 --------------
                                                                     10,683,000

Oklahoma (2.3%)
- -------------------------------------------------------------------------------
     3,150,000 OK City Arpt. Trust Rev. Bonds (Jr.
               Lien 27th Ser.),  Ser. A, FSA, 5s,
               7/1/18                                Aaa              3,252,375
     2,400,000 OK Dev. Fin. Auth. Rev. Bonds
               (Hillcrest Hlth. Care),  Ser. A,
               5 5/8s, 8/15/29                       B1               1,647,000
     7,000,000 OK State Indl. Dev. Auth. Rev. Bonds
               (Hlth. Syst.- Oblig. Group), Ser. A,
               MBIA, 5 3/4s, 8/15/29                 Aaa              7,446,250
                                                                 --------------
                                                                     12,345,625

Oregon (0.4%)
- -------------------------------------------------------------------------------
     2,000,000 Multnomah Cnty., Hosp. Fac. Auth.
               Rev. Bonds (Terwilliger Plaza
               Project), 6 1/2s, 12/1/29             BB-/P            1,902,500

Pennsylvania (7.6%)
- -------------------------------------------------------------------------------
       750,000 Allentown, Hosp. Auth. Rev. Bonds
               (Sacred Heart Hosp.), Ser. A,
               6 3/4s, 11/15/14                      Baa3               748,125
     2,165,000 Carbon Cnty., Indl. Dev. Auth.
               Rev. Bonds  (Panther Creek
               Partners), 6.65s, 5/1/10              BBB-             2,327,375
     3,500,000 Dauphin Cnty., Gen. Auth. Rev. Bonds
               (Office & Pkg.), Ser. A, 6s,
               1/15/25                               CCC/P            1,505,000
       350,000 Lebanon Cnty., Hlth. Fac. Auth.
               Rev. Bonds  (Good Samaritan Hosp.
               Project), 6s, 11/15/35                Baa1               350,438
     1,000,000 Lehigh Cnty., Gen. Purpose Auth.
               Rev. Bonds (Lehigh Valley Hosp.
               Hlth. Network), Ser. A, 5 1/4s,
               7/1/32                                A2                 962,500
       500,000 Monroe Cnty., Hosp. Auth. (Pocono
               Med. Ctr.),  6s, 1/1/43               BBB+               495,625
               PA Convention Ctr. Auth. Rev. Bonds
       750,000 Ser. A, 6 3/4s, 9/1/19                Baa2               785,753
     7,250,000 MBIA, 6.7s, 9/1/14                    Aaa              7,706,823
               PA Econ. Dev. Fin. Auth. Rev. Bonds
     7,750,000 (MacMillan Ltd. Partnership), 7.6s,
               12/1/20                               Baa2             8,844,688
     1,000,000 (Amtrak Project), Ser. A, 6 3/8s,
               11/1/41                               A3                 985,000
     1,000,000 PA Econ. Dev. Fin. Auth. Resource
               Recvy. Rev. Bonds (Colver Project),
               Ser. D, 7 1/8s, 12/1/15               BBB-             1,033,810
     4,200,000 PA State Econ. Dev. Fin. Auth.
               Resource Recvy. Rev. Bonds
               (Northampton Generating), Ser. A,
               6.6s, 1/1/19                          BBB-             4,236,750
               PA State Higher Edl. Fac. Auth.
               Rev. Bonds
     1,000,000 (Widener U.), 5.4s, 7/15/36           BBB+               996,250
       995,000 (Philadelphia College of Osteopathic
               Medicine), 5s, 12/1/07                A                1,092,013
     5,715,000 Philadelphia, Gas Wks. Rev. Bonds
               (1975 Gen. Ordinance 17th), FSA, 5s,
               7/1/07                                Aaa              6,279,356
     2,739,243 Philadelphia, Hosp. & Higher Ed.
               Fac. Auth. Rev. Bonds  (Graduate
               Hlth. Syst.), 7 1/4s, 7/1/10 (In
               default) (NON)                        D/P                  3,424
     2,000,000 Philadelphia, Indl. Dev. Auth. Arpt.
               Rev. Bonds (Aero Philadelphia, LLC),
               5 1/2s, 1/1/24                        BB/P             1,565,000
     1,800,000 Sayre, Hlth. Care Fac. Auth.
               Rev. Bonds  (Guthrie Hlth.), Ser. A,
               5 7/8s, 12/1/31                       A-               1,842,750
                                                                 --------------
                                                                     41,760,680

South Carolina (2.1%)
- -------------------------------------------------------------------------------
     4,750,000 Connector 2000 Assn., Inc. SC Toll
               Road Rev. Bonds (SR-Southern
               Connector), Ser. A, 5 3/8s, 1/1/38    B-               2,030,625
       775,000 Lexington Cnty. Rev. Bonds, 5 1/2s,
               11/1/32                               A2                 784,688
     5,000,000 Richland Cnty. Rev. Bonds (Intl.
               Paper Co. Project),  Ser. A, 4 1/4s,
               10/1/07                               Baa2             5,243,750
     1,250,000 SC Hosp. Auth. Rev. Bonds (Med. U.),
               Ser. A,  6 1/2s, 8/15/32              BBB+             1,289,063
     1,000,000 SC Jobs Econ. Dev. Auth. Hosp. Fac.
               Rev. Bonds (Palmetto Hlth.
               Alliance), Ser. A, 7 3/8s, 12/15/21   Baa2             1,271,250
     1,300,000 SC Tobacco Settlement Rev. Mgt.
               Rev. Bonds, Ser. B, 6 3/8s, 5/15/30   Baa2             1,126,125
                                                                 --------------
                                                                     11,745,501

South Dakota (0.3%)
- -------------------------------------------------------------------------------
     2,000,000 SD Edl. Enhancement Funding Corp.
               Rev. Bonds, Ser. B, 6 1/2s, 6/1/32    Baa2             1,765,000

Tennessee (2.6%)
- -------------------------------------------------------------------------------
     6,000,000 Johnson City, Hlth. & Edl. Fac.
               Board Hosp. IFB, Ser. A2, MBIA,
               10.915s, 7/1/21 (acquired
               2/8/00, cost $5,651,400) (RES)        Aaa              7,575,000
     4,200,000 Johnson City, Hlth. & Edl. Fac.
               Board Hosp. Rev. Bonds (Mountain
               States Hlth.), Ser. A, 7 1/2s,
               7/1/33                                Baa2             4,562,250
     2,000,000 Shelby Cnty. Hlth. Edl. & Hsg. Fac.
               Board Rev. Bonds (Methodist
               Healthcare), 6 1/2s, 9/1/26           A-               2,165,000
                                                                 --------------
                                                                     14,302,250

Texas (6.9%)
- -------------------------------------------------------------------------------
     7,800,000 Alliance, Arpt. Auth. Rev. Bonds
               (Federal Express Corp.), 6 3/8s,
               4/1/21                                Baa2             8,160,750
     4,655,000 Carrollton, Farmers Branch Indpt.
               School Dist. G.O. Bonds, PSFG, 5s,
               2/15/17                               Aaa              4,899,388
     1,000,000 Comal Cnty. Hlth. Fac. Dev. Corp.
               Rev. Bonds (Hlth. Care Syst. -
               McKenna Memorial Project), Ser. A,
               6 1/4s, 2/1/32                        Baa2             1,002,500
     2,360,000 Dallas-Fort Worth, Intl. Arpt. Fac.
               Impt. Corp. Rev. Bonds (American
               Airlines, Inc.), 6 3/8s, 5/1/35       Caa2             1,492,700
     4,790,000 Garland, Indpt. School Dist. G.O.
               Bonds, PSFG,  5s, 2/15/11             Aaa              5,274,964
     3,000,000 Harris Cnty., Hlth. Fac. Rev. Bonds
               (Memorial Hermann Hlth. Care),
               Ser. A, 6 3/8s, 6/1/29                A2               3,206,250
     3,880,000 Houston, Arpt. Syst. Rev. Bonds
               (Continental Airlines, Inc.),
               Ser. C, 5.7s, 7/15/29                 B-               2,861,500
     2,000,000 Lower Neches Valley Indl. Dev. Swr.
               Auth. Rev. Bonds (Mobil Oil Refining
               Corp.), 6.4s, 3/1/30                  Aaa              2,082,500
     1,400,000 Matagorda Cnty., Navigation Dist.
               Mandatory Put Bonds, 2.15s, 5/1/30    Baa2             1,400,000
     2,500,000 Sam Rayburn Muni. Pwr. Agcy.
               Rev. Bonds, 6s, 10/1/21               Baa2             2,584,375
               Tomball, Hosp. Auth. Rev. Bonds
     2,000,000 (Tomball Regl. Hosp.), 6s, 7/1/29     Baa2             2,015,000
       800,000 (Tomball Regl. Hosp.), 6s, 7/1/25     Baa2               807,000
       800,000 (Tomball Reg. Hosp.), 6s, 7/1/19      Baa2               818,000
               Tyler, Hlth. Fac. Dev. Corp.
               Rev. Bonds  (Mother Frances Hosp.)
       745,000 5s, 7/1/08                            Baa1               785,975
       500,000 5s, 7/1/07                            Baa1               528,750
                                                                 --------------
                                                                     37,919,652

Utah (2.8%)
- -------------------------------------------------------------------------------
       750,000 Carbon Cnty., Solid Waste Disp.
               Rev. Bonds (Laidlaw Env.), Ser. A,
               7 1/2s, 2/1/10                        BB-                766,875
     5,000,000 Intermountain Power Agency
               Rev. Bonds, Ser. A, FSA, 5s, 7/1/11   Aaa              5,525,000
     8,000,000 Tooele Cnty., Harbor & Term. Dist.
               Port Fac. Rev. Bonds (Union
               Pacific), Ser. A, 5.7s, 11/1/26       BBB              7,910,000
     1,000,000 UT Cnty., Env. Impt. Rev. Bonds
               (Marathon Oil Project), 5.05s,
               11/1/17                               Baa1             1,056,250
                                                                 --------------
                                                                     15,258,125

Vermont (0.2%)
- -------------------------------------------------------------------------------
     1,000,000 VT Hsg. Fin. Agcy. Rev. Bonds, Ser.
               19A, FSA, 4.62s, 5/1/29               Aaa              1,043,750

Virginia (1.0%)
- -------------------------------------------------------------------------------
     1,500,000 Fredericksburg, Indl. Dev. Auth.
               Rev. Bonds (Medicorp Hlth. Syst.),
               Ser. B, 5 1/8s, 6/15/33               A3               1,455,000
     1,000,000 James Cnty., Indl. Dev. Auth.
               Rev. Bonds (1st. Mtge.
               Williamsburg), Ser. A, 6 1/8s,
               3/1/32                                BB-/P            1,000,000
     3,900,000 Pocahontas Parkway Assn. Toll Rd.
               Rev. Bonds, Ser. A, 5 1/2s, 8/15/28   BB               3,027,375
                                                                 --------------
                                                                      5,482,375

Washington (1.3%)
- -------------------------------------------------------------------------------
     5,000,000 King Cnty., G.O. Bonds, Ser. C,
               6 1/4s, 1/1/32                        Aa1              5,612,500
     1,600,000 Port of Seattle, Special Fac.
               Rev. Bonds (Northwest Airlines,
               Inc.), 7 1/4s, 4/1/30                 B+/P             1,490,000
                                                                 --------------
                                                                      7,102,500

West Virginia (0.3%)
- -------------------------------------------------------------------------------
     2,500,000 Princeton, Hosp. Rev. Bonds (Cmnty.
               Hosp. Assn., Inc.), 6.1s, 5/1/29      Ba3              1,806,250

Wisconsin (1.7%)
- -------------------------------------------------------------------------------
               Badger Tobacco Settlement
               Asset Securitization Corp.
               Rev. Bonds
     3,000,000 7s, 6/1/28                            Baa2             2,850,000
     3,000,000 6 3/8s, 6/1/32                        Baa2             2,606,250
     3,900,000 WI State Hlth. & Edl. Fac. Auth.
               Rev. Bonds (Wheaton Franciscan),
               5 3/4s, 8/15/30                       A2               3,987,750
                                                                 --------------
                                                                      9,444,000
                                                                 --------------
               Total Municipal bonds and notes
               (cost $547,630,362)                                 $540,844,772

Preferred stocks (1.2%) (a)
Number of shares                                                          Value
- -------------------------------------------------------------------------------
     2,000,000 Charter Mac. Equity Trust 144A
               Ser. A, 6.625% cum. pfd.                              $2,140,000
     4,000,000 MuniMae Tax Exempt Bond Subsidiary,
               LLC 144A 6.875% cum. pfd.                              4,320,000
                                                                 --------------
               Total Preferred stocks
               (cost $6,000,000)                                     $6,460,000
- -------------------------------------------------------------------------------
               Total Investments
               (cost $553,630,362)                                 $547,304,772
- -------------------------------------------------------------------------------

  (a) Percentages indicated are based on portfolio market value.

(RAT) The Moody's or Standard & Poor's ratings indicated are believed to
      be the most recent ratings available at October 31, 2003 for the
      securities listed. Ratings are generally ascribed to securities at the
      time of issuance. While the agencies may from time to time revise such
      ratings, they undertake no obligation to do so, and the ratings do not
      necessarily represent what the agencies would ascribe to these
      securities at October 31, 2003. Securities rated by Putnam are indicated
      by "/P" and are not publicly rated. Ratings are not covered by the
      Report of independent accountants.

(NON) Non-income-producing security.

(RES) Restricted, excluding 144A securities, as to public resale. The
      total market value of restricted securities held at October 31, 2003
      $24,166,300 or 4.4% of portfolio market value.

      The rates shown on VRDN, mandatory put bonds, and Floating Rate Bonds
      (FRB) are the current interest rates shown at October 31, 2003.

      The rates shown on IFB which are securities paying interest rates that
      vary inversely to changes in the market interest rates, are the current
      interest rates at October 31, 2003.

      The fund had the following industry group concentrations greater than
      10% at October 31, 2003
      (as a percentage of portfolio market value):

         Health care             26.5%
         Utilities               20.2
         Transportation          14.0

      The fund had the following insurance concentrations greater than 10% at
      October 31, 2003
      (as a percentage of portfolio market value):

         MBIA                    14.6%
         AMBAC                   12.8

      The accompanying notes are an integral part of these financial
      statements.


Statement of assets and liabilities
October 31, 2003

Assets
- -------------------------------------------------------------------------------
Investments in securities, at value (identified cost
$553,630,362) (Note 1)                                           $547,304,772
- -------------------------------------------------------------------------------
Cash                                                                   22,571
- -------------------------------------------------------------------------------
Interest and other receivables                                     10,107,796
- -------------------------------------------------------------------------------
Receivable for securities sold                                      2,553,000
- -------------------------------------------------------------------------------
Total assets                                                      559,988,139

Liabilities
- -------------------------------------------------------------------------------
Distributions payable to shareholders                               2,242,301
- -------------------------------------------------------------------------------
Accrued preferred shares distributions payable (Note 1)                48,393
- -------------------------------------------------------------------------------
Payable for securities purchased                                    4,633,527
- -------------------------------------------------------------------------------
Payable for compensation of Manager (Note 2)                          973,814
- -------------------------------------------------------------------------------
Payable for investor servicing and custodian fees (Note 2)             44,863
- -------------------------------------------------------------------------------
Payable for Trustee compensation and expenses (Note 2)                 52,451
- -------------------------------------------------------------------------------
Payable for administrative services (Note 2)                            5,585
- -------------------------------------------------------------------------------
Other accrued expenses                                                121,866
- -------------------------------------------------------------------------------
Total liabilities                                                   8,122,800
- -------------------------------------------------------------------------------
Series A, B and C remarketed preferred shares: (8,000 shares
authorized; 1,750 shares issued at $100,000 per share (Note 4)    175,000,000
- -------------------------------------------------------------------------------
Net assets                                                       $376,865,339

Represented by
- -------------------------------------------------------------------------------
Paid-in capital -- common shares (Note 1)                        $434,708,664
- -------------------------------------------------------------------------------
Undistributed net investment income (Note 1)                          913,954
- -------------------------------------------------------------------------------
Accumulated net realized loss on investments (Note 1)             (52,431,689)
- -------------------------------------------------------------------------------
Net unrealized depreciation of investments                         (6,325,590)
- -------------------------------------------------------------------------------
Total -- Representing net assets applicable to common shares
outstanding                                                      $376,865,339

Computation of net asset value
- -------------------------------------------------------------------------------
Net asset value per common share ($376,865,339 divided by
47,206,343 shares)                                                      $7.98
- -------------------------------------------------------------------------------

The accompanying notes are an integral part of these financial statements.


Statement of operations
Year ended October 31, 2003

Interest income:                                                  $33,747,210
- -------------------------------------------------------------------------------

Expenses:
- -------------------------------------------------------------------------------
Compensation of Manager (Note 2)                                    3,808,647
- -------------------------------------------------------------------------------
Investor servicing and custodian fees (Note 2)                        335,730
- -------------------------------------------------------------------------------
Trustee compensation and expenses (Note 2)                             15,737
- -------------------------------------------------------------------------------
Administrative services (Note 2)                                        8,167
- -------------------------------------------------------------------------------
Preferred share remarketing agent fees                                453,494
- -------------------------------------------------------------------------------
Other                                                                 142,552
- -------------------------------------------------------------------------------
Total expenses                                                      4,764,327
- -------------------------------------------------------------------------------
Expense reduction (Note 2)                                            (26,382)
- -------------------------------------------------------------------------------
Net expenses                                                        4,737,945
- -------------------------------------------------------------------------------
Net investment income                                              29,009,265
- -------------------------------------------------------------------------------
Net realized loss on investments (Notes 1 and 3)                  (26,004,045)
- -------------------------------------------------------------------------------
Net realized loss on futures contracts (Note 1)                    (1,103,407)
- -------------------------------------------------------------------------------
Net unrealized appreciation of investments during the year         33,501,746
- -------------------------------------------------------------------------------
Net gain on investments                                             6,394,294
- -------------------------------------------------------------------------------
Net increase in net assets resulting from operations              $35,403,559
- -------------------------------------------------------------------------------

Distributions to Series A, B, and C remarketed
preferred shareholders: (Note 1)
- -------------------------------------------------------------------------------
From tax exempt income                                             (1,911,395)
- -------------------------------------------------------------------------------
Net increase in net assets resulting from operations
applicable to common shareholders                                 $33,492,164
- -------------------------------------------------------------------------------

The accompanying notes are an integral part of these financial statements.


Statement of changes in net assets

                                                        Year ended October 31
Increase (decrease) in net assets                       2003             2002
- -------------------------------------------------------------------------------
Operations:
- -------------------------------------------------------------------------------
Net investment income                            $29,009,265      $32,937,590
- -------------------------------------------------------------------------------
Net realized loss on investments                 (27,107,452)      (3,409,597)
- -------------------------------------------------------------------------------
Net unrealized appreciation (depreciation)
of investments                                    33,501,746      (30,443,946)
- -------------------------------------------------------------------------------
Net increase (decrease) in net assets
resulting from operations                         35,403,559         (915,953)

Distributions to Series A, B, and C
remarketed preferred shareholders: (Note 1)
- -------------------------------------------------------------------------------
From tax exempt income                            (1,911,395)      (2,589,647)
- -------------------------------------------------------------------------------
Net increase (decrease) in net assets
resulting from operations applicable to
common shareholders                               33,492,164       (3,505,600)
- -------------------------------------------------------------------------------

Distributions to common shareholders: (Note 1)
- -------------------------------------------------------------------------------
From tax exempt income                           (26,907,616)     (26,888,250)
- -------------------------------------------------------------------------------
Increase from issuance of common shares in
connection with reinvestment of
distributions                                             --          419,191
- -------------------------------------------------------------------------------
Total increase (decrease) in net assets            6,584,548      (29,974,659)

Net assets
- -------------------------------------------------------------------------------
Beginning of year                                370,280,791      400,255,450
- -------------------------------------------------------------------------------
End of year (including undistributed net
investment income of $913,954 and $726,898,
respectively)                                   $376,865,339     $370,280,791
- -------------------------------------------------------------------------------

Number of fund shares
- -------------------------------------------------------------------------------
Common shares outstanding at beginning of
year                                              47,206,343       47,155,237
- -------------------------------------------------------------------------------
Shares issued in connection with
reinvestment of distributions                             --           51,106
- -------------------------------------------------------------------------------
Common shares outstanding at end of year          47,206,343       47,206,343
- -------------------------------------------------------------------------------
Remarketed preferred shares outstanding at
beginning and end of year                              1,750            1,750
- -------------------------------------------------------------------------------

The accompanying notes are an integral part of these financial statements.


<TABLE>
<CAPTION>
Financial highlights
(For a common share outstanding throughout the period)

Per-share                                                                         Year ended October 31
operating performance                             2003            2002            2001            2000            1999
- -----------------------------------------------------------------------------------------------------------------------
<S>                                             <C>             <C>             <C>             <C>             <C>
Net asset value,
beginning of period
(common shares)                                  $7.84           $8.49           $8.44           $8.77           $9.82
- -----------------------------------------------------------------------------------------------------------------------
Investment operations:
- -----------------------------------------------------------------------------------------------------------------------
Net investment income (a)                          .61             .70             .72             .75             .80
- -----------------------------------------------------------------------------------------------------------------------
Net realized and unrealized
gain (loss) on investments                         .14            (.73)            .04            (.16)           (.96)
- -----------------------------------------------------------------------------------------------------------------------
Total from investment operations                   .75            (.03)            .76             .59            (.16)
- -----------------------------------------------------------------------------------------------------------------------
Distributions to preferred shareholders:
- -----------------------------------------------------------------------------------------------------------------------
From net investment income                        (.04)           (.05)           (.12)           (.16)           (.13)
- -----------------------------------------------------------------------------------------------------------------------
Total from investment
operations: (applicable to
common shareholders)                               .71            (.08)            .64             .43            (.29)
- -----------------------------------------------------------------------------------------------------------------------
Distributions to common shareholders:
- -----------------------------------------------------------------------------------------------------------------------
From net investment income:                       (.57)           (.57)           (.59)           (.76)           (.76)
- -----------------------------------------------------------------------------------------------------------------------
Total distributions                               (.57)           (.57)           (.59)           (.76)           (.76)
- -----------------------------------------------------------------------------------------------------------------------
Net asset value, end of period
(common shares)                                  $7.98           $7.84           $8.49           $8.44           $8.77
- -----------------------------------------------------------------------------------------------------------------------
Market price, end of period
(common shares)                                  $7.34           $7.43           $8.44           $9.63           $9.81
- -----------------------------------------------------------------------------------------------------------------------
Total return at market price (%)
(common shares) (b)                               6.44           (5.57)          (6.21)           6.84           (7.72)
- -----------------------------------------------------------------------------------------------------------------------

Ratios and supplemental data
- -----------------------------------------------------------------------------------------------------------------------
Net assets, end of period
(common shares) (in thousands)                $376,865        $370,281        $400,255        $396,212        $408,419
- -----------------------------------------------------------------------------------------------------------------------
Ratio of expenses to
average net assets (%)(c)(d)                      1.27            1.25            1.22            1.27            1.23
- -----------------------------------------------------------------------------------------------------------------------
Ratio of net investment income
to average net assets (%)(c)                      7.21            7.84            7.01            6.97            7.12
- -----------------------------------------------------------------------------------------------------------------------
Portfolio turnover (%)                           40.82           20.44           17.95           16.72           12.88
- -----------------------------------------------------------------------------------------------------------------------

</TABLE>

(a) Per share net investment income has been determined on the basis of
    the weighted average number of shares outstanding during the period.

(b) Total return assumes dividend reinvestment.

(c) Ratios reflect net assets available to common shares only; net
    investment income ratio also reflects reduction for dividend payments to
    preferred shareholders.

(d) Includes amounts paid through expense offset arrangements (Note 2).

    The accompanying notes are an integral part of these financial
    statements.


Notes to financial statements
October 31, 2003

Note 1
Significant accounting policies

Putnam Managed Municipal Income Trust (the "fund") is registered under
the Investment Company Act of 1940, as amended, as a diversified,
closed-end management investment company. The fund's investment
objective is to seek a high level of current income exempt from federal
income tax. The fund intends to achieve its objective by investing in a
diversified portfolio of tax-exempt municipal securities which Putnam
Investment Management, LLC ("Putnam Management"), the fund's manager, an
indirect wholly-owned subsidiary of Putnam, LLC, believes does not
involve undue risk to income or principal. Up to 50% of the fund's
assets may consist of high-yield tax-exempt municipal securities that
are below investment grade and involve special risk considerations. The
fund also uses leverage by issuing preferred shares in an effort to
increase the income to the common shares.

The following is a summary of significant accounting policies
consistently followed by the fund in the preparation of its financial
statements. The preparation of financial statements is in conformity
with accounting principles generally accepted in the United States of
America and requires management to make estimates and assumptions that
affect the reported amounts of assets and liabilities in the financial
statements and the reported amounts of increases and decreases in net
assets from operations during the reporting period. Actual results could
differ from those estimates.

A) Security valuation Tax-exempt bonds and notes are valued on the basis
of valuations provided by an independent pricing service, approved by
the Trustees. Such services use information with respect to transactions
in bonds, quotations from bond dealers, market transactions in
comparable securities and various relationships between securities in
determining value. Restricted securities are valued at fair value
following procedures approved by the Trustees. Such valuations and
procedures are reviewed periodically by the Trustees.

B) Security transactions and related investment income Security
transactions are recorded on the trade date (date the order to buy or
sell is executed). Gains or losses on securities sold are determined on
the identified cost basis.

Interest income is recorded on the accrual basis. All premiums/discounts
are amortized/accreted on a yield-to-maturity basis. The premium in
excess of the call price, if any, is amortized to the call date;
thereafter, any remaining premium is amortized to maturity.

C) Futures and options contracts The fund may use futures and options
contracts to hedge against changes in the values of securities the fund
owns or expects to purchase. The fund may also write options on
securities it owns or in which it may invest to increase its current
returns.

The potential risk to the fund is that the change in value of futures
and options contracts may not correspond to the change in value of the
hedged instruments. In addition, losses may arise from changes in the
value of the underlying instruments, if there is an illiquid secondary
market for the contracts, or if the counterparty to the contract is
unable to perform. When the contract is closed, the fund records a
realized gain or loss equal to the difference between the value of the
contract at the time it was opened and the value at the time it was
closed. Realized gains and losses on purchased options are included in
realized gains and losses on investment securities.

Futures contracts are valued at the quoted daily settlement prices
established by the exchange on which they trade. The fund and the broker
agree to exchange an amount of cash equal to the daily fluctuation in
the value of the futures contract. Such receipts or payments are known
as "variation margin." Exchange traded options are valued at the last
sale price, or if no sales are reported, the last bid price for
purchased options and the last ask price for written options. Options
traded over-the-counter are valued using prices supplied by dealers.

D) Federal taxes It is the policy of the fund to distribute all of its
income within the prescribed time and otherwise comply with the
provisions of the Internal Revenue Code applicable to regulated
investment companies. It is also the intention of the fund to distribute
an amount sufficient to avoid imposition of any excise tax under Section
4982 of the Internal Revenue Code of 1986, as amended. Therefore, no
provision has been made for federal taxes on income, capital gains or
unrealized appreciation on securities held nor for excise tax on income
and capital gains.

At October 31, 2003, the fund had a capital loss carryover of
$50,158,346 available to the extent allowed by tax law to offset future
net capital gain, if any. The amount of the carryover and the expiration
dates are:

Loss Carryover  Expiration
- --------------------------------
   $11,188,485  October 31, 2005
     2,894,998  October 31, 2006
     3,629,209  October 31, 2007
     1,237,146  October 31, 2008
     1,641,465  October 31, 2009
     3,729,886  October 31, 2010
    25,837,157  October 31, 2011

E) Distributions to shareholders Distributions to common and preferred
shareholders from net investment income are recorded by the fund on the
ex-dividend date. Distributions from capital gains, if any, are recorded
on the ex-dividend date and paid at least annually. Dividends on
remarketed preferred shares become payable when, as and if declared by
the Trustees. Each dividend period for the remarketed preferred shares
is generally a 28-day period for Series A and Series B shares, and a
7-day period for Series C shares. The applicable dividend rate for the
remarketed preferred shares on October 31, 2003 was 0.81% for Series A,
0.92% for Series B and 0.98% for Series C. The amount and character of
income and gains to be distributed are determined in accordance with
income tax regulations, which may differ from generally accepted
accounting principles. These differences include temporary and permanent
differences of the expiration of a capital loss carryover, dividends
payable, defaulted bond interest, realized gains and losses on certain
futures contracts and straddle loss deferrals. Reclassifications are
made to the fund's capital accounts to reflect income and gains
available for distribution (or available capital loss carryovers) under
income tax regulations. For the year ended October 31, 2003, the fund
reclassified $3,198 to decrease undistributed net investment income and
$317,415 to decrease paid-in-capital, with an decrease to accumulated
net realized losses of $320,613.

The tax basis components of distributable earnings and the federal tax
cost as of period end were as follows:

Unrealized appreciation            $21,797,633
Unrealized depreciation            (27,917,893)
                                  ------------
Net unrealized depreciation         (6,120,260)
Undistributed tax-exempt
income                               3,545,655
Undistributed ordinary income           45,159
Capital loss carryforward          (50,158,346)
Cost for federal income
tax purposes                      $553,425,032

F) Determination of net asset value Net asset value of the common shares
is determined by dividing the value of all assets of the fund, less all
liabilities and the liquidation preference of any outstanding remarketed
preferred shares, by the total number of common shares outstanding as of
period end.


Note 2
Management fee, administrative
services and other transactions

Putnam Management is paid for management and investment advisory
services quarterly based on the average net assets of the fund. Such fee
is based on 0.70% of the average weekly net assets.

If dividends payable on remarketed preferred shares during any dividend
payment period plus any expenses attributable to remarketed preferred
shares for that period exceed the fund's gross income attributable to
the proceeds of the remarketed preferred shares during that period, then
the fee payable to Putnam Management for that period will be reduced by
the amount of the excess (but not more than .70% of the liquidation
preference of the remarketed preferred shares outstanding during the
period).

The fund reimburses Putnam Management an allocated amount for the
compensation and related expenses of certain officers of the fund and
their staff who provide administrative services to the fund. The
aggregate amount of all such reimbursements is determined annually by
the Trustees.

Custodial functions for the fund's assets are provided by Putnam
Fiduciary Trust Company (PFTC), a subsidiary of Putnam, LLC. Investor
servicing agent functions are provided by Putnam Investor Services, a
division of PFTC.

The fund has entered into an arrangement with PFTC whereby credits
realized as a result of uninvested cash balances are used to reduce a
portion of the fund's expenses. For the year ended October 31, 2003, the
fund's expenses were reduced by $26,382 under these arrangements.

Each independent Trustee of the fund receives an annual Trustee fee, of
which $733 has been allocated to the fund, and an additional fee for
each Trustees meeting attended. Trustees receive additional fees for
attendance at certain committee meetings.

The fund has adopted a Trustee Fee Deferral Plan (the "Deferral Plan")
which allows the Trustees to defer the receipt of all or a portion of
Trustees fees payable on or after July 1, 1995. The deferred fees remain
invested in certain Putnam funds until distribution in accordance with
the Deferral Plan.

The fund has adopted an unfunded noncontributory defined benefit pension
plan (the "Pension Plan") covering all Trustees of the fund who have
served as a Trustee for at least five years. Benefits under the Pension
Plan are equal to 50% of the Trustee's average total retainer and
meeting fees for the three years preceding retirement. Pension expense
for the fund is included in Trustee compensation and expenses in the
Statement of operations. Accrued pension liability is included in
Payable for Trustee compensation and expenses in the Statement of assets
and liabilities.

Note 3
Purchases and sales of securities

During the year ended October 31, 2003, cost of purchases and proceeds
from sales of investment securities other than short-term investments
aggregated $227,587,273 and $215,390,036, respectively. There were no
purchases and sales of U.S. government obligations.

Note 4
Preferred shares

The Series A (550), Series B (550)and Series C (650) shares are
redeemable at the option of the fund on any dividend payment date at a
redemption price of $100,000 per share, plus an amount equal to any
dividends accumulated on a daily basis but unpaid through the redemption
date (whether or not such dividends have been declared) and, in certain
circumstances, a call premium.

Under the Investment Company Act of 1940, the fund is required to
maintain asset coverage of at least 200% with respect to the remarketed
preferred shares as of the last business day of each month in which any
such shares are outstanding. Additionally, the fund is required to meet
more stringent asset coverage requirements under terms of the remarketed
preferred shares and the shares' rating agencies. Should these
requirements not be met, or should dividends accrued on the remarketed
preferred shares not be paid, the fund may be restricted in its ability
to declare dividends to common shareholders or may be required to redeem
certain of the remarketed preferred shares. At October 31, 2003, no such
restrictions have been placed on the fund.

Note 5
Regulatory matters and litigation

On November 13, 2003, Putnam Management agreed to entry of an order
by the Securities and Exchange Commission (SEC) in partial
resolution of administrative and cease-and-desist proceedings
initiated by the SEC on October 28, 2003 in connection with alleged
excessive short-term trading by at least six Putnam Management
investment professionals. The SEC's findings reflect that four of
those employees engaged in such trading in funds over which they had
investment decision-making responsibility and had access to
non-public information regarding, among other things, current
portfolio holdings, and valuations. The six individuals no longer
have investment responsibilities with Putnam Management. Under the
order, Putnam Management will make restitution for losses
attributable to excessive short-term trading by Putnam employees,
institute new employee trading restrictions and enhanced employee
trading compliance, retain an independent compliance consultant, and
take other remedial actions. Putnam Management neither admitted nor
denied the order's findings, which included findings that Putnam
Management willfully violated provisions of the federal securities
laws. A civil monetary penalty and other monetary relief, if any,
will be determined at a later date. If a hearing is necessary to
determine the amounts of such penalty or other relief, Putnam
Management will be precluded from arguing that it did not violate
the federal securities laws in the manner described in the SEC
order, the findings set forth in the SEC order will be accepted as
true by the hearing officer and additional evidence may be
presented. Putnam Management, and not the investors in any Putnam
fund, will bear all costs, including restitution, civil penalties
and associated legal fees. Administrative proceedings instituted by
the Commonwealth of Massachusetts on October 28, 2003 against Putnam
Management in connection with alleged market timing activities by
Putnam employees and by participants in some Putnam-administered
401(k) plans are pending. Putnam Management has committed to make
complete restitution for any losses suffered by Putnam shareholders
as a result of any improper market-timing activities by Putnam
employees or within Putnam-administered 401(k) plans.

The SEC's and Commonwealth's 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. In addition, Marsh & McLennan
Companies, Inc., Putnam Management's parent company, has engaged
counsel to conduct a separate review of Putnam Management's policies
and controls related to short-term trading.



Federal tax information
(Unaudited)

The fund has designated 100% of dividends paid from net investment
income during the fiscal year as tax exempt for Federal income tax
purposes.

The Form 1099 you receive in January 2004 will show the tax status of
all distributions paid to your account in calendar 2003.


Results of October 7, 2003 shareholder meeting
(Unaudited)

An annual meeting of shareholders of the fund was held on October 7,
2003. At the meeting, each of the nominees for Trustees was elected, as
follows:

                                            Common shares

                                                          Votes
                                     Votes for          withheld
- -----------------------------------------------------------------
Jameson Adkins Baxter               40,520,151           902,275
Charles B. Curtis                   40,532,196           890,229
Ronald J. Jackson                   40,526,248           896,178
Paul L. Joskow                      40,527,069           895,357
Elizabeth T. Kennan                 40,508,704           913,722
Lawrence J. Lasser*                 40,531,410           891,016
John H. Mullin III                  40,543,758           878,668
George Putnam, III                  40,524,063           898,362
A.J.C. Smith                        40,500,558           921,868
W. Thomas Stephens                  40,516,541           905,884
W. Nicholas Thorndike               40,493,265           929,161

                                            Preferred Shares

                                                          Votes
                                     Votes for          withheld
- -----------------------------------------------------------------
Jameson Adkins Baxter                    1,620                 0
Charles B. Curtis                        1,620                 0
John A. Hill                             1,620                 0
Ronald J. Jackson                        1,620                 0
Paul L. Joskow                           1,620                 0
Elizabeth T. Kennan                      1,620                 0
Lawrence J. Lasser*                      1,620                 0
John H. Mullin III                       1,620                 0
Robert E. Patterson                      1,620                 0
George Putnam, III                       1,620                 0
A.J.C. Smith                             1,620                 0
W. Thomas Stephens                       1,620                 0
W. Nicholas Thorndike                    1,620                 0

 All tabulations are rounded to nearest whole number.

*Mr. Lasser resigned from the Board of Trustees of the Putnam funds on
 November 3, 2003.


About the Trustees

Jameson A. Baxter (9/6/43), Trustee since 1994

Ms. Baxter is the President of Baxter Associates, Inc., a private
investment firm that she founded in 1986.

Ms. Baxter serves as a Director of ASHTA Chemicals, Inc., Banta
Corporation (a printing and digital imaging firm), Ryerson Tull, Inc. (a
steel service corporation), Advocate Health Care, and BoardSource,
formerly the National Center for Nonprofit Boards. She is Chairman
Emeritus of the Board of Trustees, Mount Holyoke College, having served
as Chairman for five years and as a board member for thirteen years.
Until 2002, Ms. Baxter was a Director of Intermatic Corporation (a
manufacturer of energy control products).

Ms. Baxter has held various positions in investment banking and
corporate finance, including Vice President and Principal of the Regency
Group, and Vice President of and Consultant to First Boston Corporation.
She is a graduate of Mount Holyoke College.

Charles B. Curtis (4/27/40), Trustee since 2001

Mr. Curtis is President and Chief Operating Officer of the Nuclear
Threat Initiative (a private foundation dealing with national security
issues) and serves as Senior Advisor to the United Nations Foundation.

Mr. Curtis is a member of the Council on Foreign Relations and the
Trustee Advisory Council of the Applied Physics Laboratory, Johns
Hopkins University. Until 2003, Mr. Curtis was a member of the Electric
Power Research Institute Advisory Council and the University of Chicago
Board of Governors for Argonne National Laboratory. Prior to 2002, Mr.
Curtis was a Member of the Board of Directors of the Gas Technology
Institute and the Board of Directors of the Environment and Natural
Resources Program Steering Committee, John F. Kennedy School of
Government, Harvard University. Until 2001, Mr. Curtis was a member of
the Department of Defense Policy Board and Director of EG&G Technical
Services, Inc. (a fossil energy research and development support
company).

Prior to May 1997, Mr. Curtis was Deputy Secretary of Energy. He served
as Chairman of the Federal Energy Regulatory Commission from 1977 to
1981 and has held positions on the staff of the U.S. House of
Representatives, the U.S. Treasury Department, and the Securities and
Exchange Commission.

John A. Hill (1/31/42), Trustee since 1985 and Chairman since 2000

Mr. Hill is Vice Chairman and Managing Director of First Reserve
Corporation, a private equity buyout firm that specializes in energy
investments in the diversified worldwide energy industry.

Mr. Hill is a Director of Devon Energy Corporation, TransMontaigne Oil
Company, Continuum Health Partners of New York, and various private
companies controlled by First Reserve Corporation, as well as a Trustee
of TH Lee Putnam Investment Trust (a closed-end investment company). He
is also a Trustee of Sarah Lawrence College.

Prior to acquiring First Reserve Corporation in 1983, Mr. Hill held
executive positions in investment banking and investment management with
several firms and with the federal government, including Deputy
Associate Director of the Office of Management and Budget, and Deputy
Director of the Federal Energy Administration. He is active in various
business associations, including the Economic Club of New York, and
lectures on energy issues in the United States and Europe. Mr. Hill
holds a B.A. degree in Economics from Southern Methodist University and
pursued graduate studies there as a Woodrow Wilson Fellow.

Ronald J. Jackson (12/17/43), Trustee since 1996

Mr. Jackson is a private investor.

Mr. Jackson is President of the Kathleen and Ronald J. Jackson
Foundation (a charitable trust). He is also a member of the Board of
Overseers of WGBH (a public television and radio station) as well as a
member of the Board of Overseers of the Peabody Essex Museum.

Mr. Jackson is the former Chairman, President, and Chief Executive
Officer of Fisher-Price, Inc. (a major toy manufacturer), from which he
retired in 1993. He previously served as President and Chief Executive
Officer of Stride-Rite, Inc. (a manufacturer and distributor of
footwear) and of Kenner Parker Toys, Inc. (a major toy and game
manufacturer). Mr. Jackson was President of Talbots, Inc. (a distributor
of women's apparel) and has held financial and marketing positions with
General Mills, Inc. and Parker Brothers (a toy and game company). Mr.
Jackson is a graduate of the University of Michigan Business School.

Paul L. Joskow (6/30/47), Trustee since 1997

Dr. Joskow is the Elizabeth and James Killian Professor of Economics and
Management, and Director of the Center for Energy and Environmental
Policy Research at the Massachusetts Institute of Technology.

Dr. Joskow serves as a Director of National Grid Transco (a UK-based
holding company with interests in electric and gas transmission and
distribution, and telecommunications infrastructure). He also serves on
the board of the Whitehead Institute for Biomedical Research (a
non-profit research institution) and has been President of the Yale
University Council since 1993. Prior to February 2002, he was a Director
of State Farm Indemnity Company (an automobile insurance company) and
prior to March 2000 he was a Director of New England Electric System (a
public utility holding company).

Dr. Joskow has published five books and numerous articles on topics in
industrial organization, government regulation of industry, and
competition policy. He is active in industry restructuring,
environmental, energy, competition, and privatization policies --
serving as an advisor to governments and corporations worldwide. Dr.
Joskow holds a Ph.D. and M. Phil from Yale University and B.A. from
Cornell University.

Elizabeth T. Kennan (2/25/38), Trustee since 1992

Dr. Kennan is a partner in and Chairman of Cambus-Kenneth Bloodstock,
LLC (cattle and thoroughbred horses). She is President Emeritus of Mount
Holyoke College.

Dr. Kennan serves as a Trustee of Northeast Utilities and is a Director
of Talbots, Inc. She has served as Director on a number of other boards,
including Bell Atlantic, Chastain Real Estate, Shawmut Bank, Berkshire
Life Insurance, and Kentucky Home Life Insurance. She is a Trustee of
Centre College and of Midway College in Midway, Kentucky. She is also a
member of The Trustees of Reservations. Dr. Kennan has served on the
oversight committee of the Folger Shakespeare Library, as President of
Five Colleges Incorporated, as a Trustee of Notre Dame University, and
is active in various educational and civic associations.

As a member of the faculty of Catholic University for twelve years,
until 1978, Dr. Kennan directed the post-doctoral program in Patristic
and Medieval Studies, taught history, and published numerous articles.
Dr. Kennan holds a Ph.D. from the University of Washington in Seattle,
an M.S. from St. Hilda's College at Oxford University, and an A.B. from
Mount Holyoke College. She holds several honorary doctorates.

John H. Mullin, III (6/15/41), Trustee since 1997

Mr. Mullin is the Chairman and CEO of Ridgeway Farm (a limited liability
company engaged in timber and farming).

Mr. Mullin serves as a Director of Alex. Brown Realty, Inc., The Liberty
Corporation (a broadcasting company), Progress Energy, Inc. (a utility
company, formerly known as Carolina Power & Light), and Sonoco Products,
Inc. (a packaging company). Mr. Mullin is Trustee Emeritus of Washington
& Lee University, where he served as Chairman of the Investment
Committee. Prior to May 2001, he was a Director of Graphic Packaging
International Corp.

Mr. Mullin also served as a Director of Dillon, Read & Co., Inc. until
October 1997 and The Ryland Group, Inc. until January 1998. Mr. Mullin
is a graduate of Washington & Lee University and The Wharton Graduate
School, University of Pennsylvania.

Robert E. Patterson (3/15/45), Trustee since 1984

Mr. Patterson is Senior Partner of Cabot Properties, L.P. and Chairman
of Cabot Properties, Inc.

Mr. Patterson serves as Chairman of the Joslin Diabetes Center, as a
Trustee of Sea Education Association, and as a Director of Brandywine
Trust Company. Prior to December 2001, he was President and Trustee of
Cabot Industrial Trust (a publicly traded real estate investment trust).
Prior to February 1998, Mr. Patterson was Executive Vice President and
Director of Acquisitions of Cabot Partners Limited Partnership (a
registered investment advisor involved in institutional real estate
investments). Prior to 1990, he served as Executive Vice President of
Cabot, Cabot & Forbes Realty Advisors, Inc. (the predecessor company of
Cabot Partners) and as a Senior Vice President of the Beal Companies (a
real estate management, investment, and development firm).

Mr. Patterson practiced law and held various positions in state
government, and was the founding Executive Director of the Massachusetts
Industrial Finance Agency. Mr. Patterson is a graduate of Harvard
College and Harvard Law School.

W. Thomas Stephens (9/2/42), Trustee since 1997

Mr. Stephens serves on a number of corporate boards.

Mr. Stephens serves as a Director of Xcel Energy Incorporated (a public
utility company), TransCanada Pipelines Limited, Norske Canada, Inc. (a
paper manufacturer), and Qwest Communications. Until 2003, Mr. Stephens
was a Director of Mail-Well, Inc. (a diversified printing company). He
served as Chairman of Mail-Well until 2001 and as CEO of
MacMillan-Bloedel, Ltd. (a forest products company) until 1999.

Prior to 1996, Mr. Stephens was Chairman and Chief Executive Officer of
Johns Manville Corporation. He holds B.S. and M.S. degrees from the
University of Arkansas.

W. Nicholas Thorndike (3/28/33), Trustee since 1992

Mr. Thorndike serves on the boards of various corporations and
charitable organizations.

Mr. Thorndike is a Director of Courier Corporation (a book publisher and
manufacturer) and The Providence Journal Co. (a newspaper publisher). He
is also a Trustee of Northeastern University and an honorary Trustee of
Massachusetts General Hospital, where he previously served as Chairman
and President. Prior to September 2000, he was a Director of Bradley
Real Estate, Inc.; prior to April 2000, he was a Trustee of Eastern
Utilities Associates; and prior to December 2001, he was a Trustee of
Cabot Industrial Trust.

Mr. Thorndike has also served as Chairman of the Board and Managing
Partner of Wellington Management Company/Thorndike, Doran, Paine & Lewis
(a registered investment advisor that manages mutual funds and
institutional assets), as a Trustee of the Wellington Group of Funds
(currently The Vanguard Group), and as Chairman and a Director of Ivest
Fund, Inc. Mr. Thorndike is a graduate of Harvard College.

George Putnam, III* (8/10/51), Trustee since 1984 and President
since 2000

Mr. Putnam is President of New Generation Research, Inc. (a publisher of
financial advisory and other research services), and of New Generation
Advisers, Inc. (a registered investment advisor to private funds). Mr.
Putnam founded the New Generation companies in 1986.

Mr. Putnam is a Director of The Boston Family Office, LLC (a registered
investment advisor). He is a Trustee of St. Mark's School, Shore Country
Day School, and until 2002 was a Trustee of the Sea Education
Association.

Mr. Putnam previously worked as an attorney with the law firm of Dechert
Price & Rhoads in Philadelphia. He is a graduate of Harvard College,
Harvard Business School, and Harvard Law School.

A.J.C. Smith* (4/13/34), Trustee since 1986

Mr. Smith is Chairman of Putnam Investments and a Director of Marsh &
McLennan Companies, Inc.

Mr. Smith is also a Director of Trident Corp. (a limited partnership
with over thirty institutional investors). He is also a Trustee of the
Carnegie Hall Society, the Educational Broadcasting Corporation, and the
National Museums of Scotland. He is Chairman of the Central Park
Conservancy and a Member of the Board of Overseers of the Joan and
Sanford I. Weill Graduate School of Medical Sciences of Cornell
University. Prior to May 2000 and November 1999, Mr. Smith was Chairman
and CEO, respectively, of Marsh & McLennan Companies, Inc.

  The address of each Trustee is One Post Office Square, Boston, MA 02109.

  As of October 31, 2003, there were 102 Putnam Funds.

  Each Trustee serves for an indefinite term, until his or her
  resignation, retirement at age 72, death, or removal.

* Trustees who are or may be deemed to be "interested persons" (as
  defined in the Investment Company Act of 1940) of the fund, Putnam
  Management, Putnam Retail Management, or Marsh & McLennan Companies,
  Inc., the parent company of Putnam, LLC and its affiliated companies.
  Messrs. Putnam, III, and Smith are deemed "interested persons" by virtue
  of their positions as officers or shareholders of the fund or Putnam
  Management, Putnam Retail Management, or Marsh & McLennan Companies,
  Inc. George Putnam, III is the President of your fund and each of the
  other Putnam funds. Mr. Smith serves as a Director of Marsh & McLennan
  Companies, Inc.


Officers

In addition to George Putnam, III, the other officers of the
fund are shown below:

Charles E. Porter (7/26/38)
Executive Vice President, Treasurer and
Principal Financial
Officer
Since 1989

Managing Director, Putnam Investments
and Putnam Management

Patricia C. Flaherty (12/1/46)
Senior Vice President
Since 1993

Senior Vice President, Putnam Investments and Putnam
Management

Karnig H. Durgarian (1/13/56)
Vice President and Principal Executive Officer
Since 2002

Senior Managing Director, Putnam Investments

Steven D. Krichmar (6/27/58)
Vice President and Principal Financial Officer
Since 2002

Managing Director, Putnam Investments. Prior to July 2001,
Partner, PricewaterhouseCoopers LLP

Michael T. Healy (1/24/58)
Assistant Treasurer and Principal
Accounting Officer
Since 2000

Managing Director, Putnam Investments

Beth S. Mazor (4/6/58)
Vice President
Since 2002

Senior Vice President, Putnam Investments

Gordon H. Silver (7/3/47)
Vice President
Since 1990

Senior Managing Director, Putnam Investments, Putnam
Management and Putnam Retail Management

Mark C. Trenchard (6/5/62)
Vice President and BSA Compliance Officer
Since 2002

Senior Vice President, Putnam Investments

William H. Woolverton (1/17/51)
Vice President and Chief Legal Officer
Since 2003

Managing Director, Putnam Investments, Putnam Management and
Putnam Retail Management

Judith Cohen (6/7/45)
Clerk and Assistant Treasurer
Since 1993

Clerk and Assistant Treasurer, The Putnam Funds

The address of each Officer is One Post Office Square, Boston, MA 02109.


Fund information

About Putnam Investments

One of the largest mutual fund families in the United States, Putnam
Investments has a heritage of investment leadership dating back to Judge
Samuel Putnam, whose Prudent Man Rule has defined fiduciary tradition
and practice since 1830. Founded over 65 years ago, Putnam Investments
was built around the concept that a balance between risk and reward is
the hallmark of a well-rounded financial program. We presently manage
over 100 mutual funds in growth, value, blend, fixed income, and
international.

Investment Manager

Putnam Investment
Management, LLC
One Post Office Square
Boston, MA 02109

Marketing Services

Putnam Retail Management
One Post Office Square
Boston, MA 02109

Custodian

Putnam Fiduciary Trust Company

Legal Counsel

Ropes & Gray LLP

Independent Auditors

KPMG LLP

Trustees

John A. Hill, Chairman
Jameson Adkins Baxter
Charles B. Curtis
Ronald J. Jackson
Paul L. Joskow
Elizabeth T. Kennan
John H. Mullin III
Robert E. Patterson
George Putnam, III
A.J.C. Smith
W. Thomas Stephens
W. Nicholas Thorndike

Officers

George Putnam, III
President

Charles E. Porter
Executive Vice President,
Treasurer and Principal Financial Officer

Patricia C. Flaherty
Senior Vice President

Karnig H. Durgarian
Vice President and Principal Executive Officer

Steven D. Krichmar
Vice President and Principal Financial Officer

Michael T. Healy
Assistant Treasurer and Principal Accounting Officer

Beth S. Mazor
Vice President

Gordon H. Silver
Vice President

Mark C. Trenchard
Vice President and
BSA Compliance Officer

William H. Woolverton
Vice President and
Chief Legal Officer

Judith Cohen
Clerk and Assistant Treasurer


Call 1-800-225-1581 weekdays from 9:00 a.m. to 5:00 p.m. Eastern Time,
or visit our Web site (www.putnaminvestments.com) anytime for up-to-date
information about the fund's NAV.


[LOGO OMITTED]

PUTNAM INVESTMENTS

The Putnam Funds
One Post Office Square
Boston, Massachusetts 02109

PRSRT STD
U.S. POSTAGE PAID
PUTNAM
INVESTMENTS


Do you want to save paper and receive this document faster?
Shareholders can sign up for email delivery of shareholder reports on
www.putnaminvestments.com.

203415  052  12/03



Item 2. Code of Ethics:
- -----------------------
All officers of the Fund, including its principal executive, financial and
accounting officers, are employees of Putnam Investment Management, LLC,
the Fund's investment manager.  As such they are subject to a comprehensive
Code of Ethics adopted and administered by Putnam Investments which is
designed to protect the interests of the firm and its clients.  The Fund
has adopted a Code of Ethics which incorporates the Code of Ethics of
Putnam Investments with respect to all of its officers and Trustees who are
employees of Putnam Investment Management, LLC.  For this reason, the Fund
has not adopted a separate code of ethics governing its principal
executive, financial and accounting officers.

Item 3. Audit Committee Financial Expert:
- -----------------------------------------
The Funds' Audit and Pricing Committee is comprised solely of Trustees
who are "independent" (as such term has been defined by the Securities
and Exchange Commission ("SEC") in regulations implementing Section 407
of the Sarbanes-Oxley Act (the "Regulations")).  The Trustees believe
that each of the members of the Audit and Pricing Committee also possess
a combination of knowledge and experience with respect to financial
accounting matters, as well as other attributes, that qualify them for
service on the Committee.  In addition, the Trustees have determined
that all members of the Funds' Audit and Pricing Committee meet the
financial literacy requirements of the New York Stock Exchange's rules
and that Mr. Patterson and Mr. Stephens qualify as "audit committee
financial experts" (as such term has been defined by the Regulations)
based on their review of their pertinent experience and education.
Certain other Trustees, although not on the Audit and Pricing Committee,
would also qualify as "audit committee financial experts."  The SEC has
stated that the designation or identification of a person as an audit
committee financial expert pursuant to this Item 3 of Form N-CSR does
not impose on such person any duties, obligations or liability that are
greater than the duties, obligations and liability imposed on such
person as a member of the Audit and Pricing Committee and the Board of
Trustees in the absence of such designation or identification.

Item 4. Principal Accountant Fees and Services:
- -----------------------------------------------
Not applicable

Items 5-6. [Reserved]
- ---------------------

Item 7. Disclosure of Proxy Voting Policies and Procedures For Closed End
- -------------------------------------------------------------------------
        Management Investment Companies:
        --------------------------------

Proxy Voting Guidelines of the Putnam Funds
- -------------------------------------------
The proxy voting guidelines below summarize the Funds' positions on
various issues of concern to investors, and give a general indication of
how Fund portfolio securities will be voted on proposals dealing with a
particular issue. The Funds' proxy voting service is instructed to vote
all proxies relating to Fund portfolio securities in accordance with
these guidelines, except as otherwise instructed by the Proxy
Coordinator.

The proxy voting guidelines are just that - guidelines. The guidelines
are not exhaustive and do not include all potential voting issues.
Because proxy issues and the circumstances of individual companies are
so varied, there may be instances when the Funds may not vote in strict
adherence to these guidelines. For example, the proxy voting service is
expected to bring to the Proxy Coordinator's attention proxy questions
that are company-specific and of a non-routine nature and, although
covered by the guidelines, may be more appropriately handled on a
case-by-case basis.

Similarly, Putnam Management's investment professionals, as part of
their ongoing review and analysis of all Fund portfolio holdings, are
responsible for monitoring significant corporate developments, including
proxy proposals submitted to shareholders, and notifying the Proxy
Coordinator of circumstances where the interests of Fund shareholders
may warrant a vote contrary to these guidelines. In such instances, the
investment professionals will submit a written recommendation to the
Proxy Coordinator and the person or persons designated by Putnam
Management's Legal and Compliance Department to assist in processing
referral items pursuant to the Funds' "Proxy Voting Procedures."  The
Proxy Coordinator, in consultation with the Senior Vice President,
Executive Vice President and/or the Chair of the Board Policy and
Nominating Committee, as appropriate, will determine how the Funds'
proxies will be voted. When indicated, the Chair of the Board Policy
and Nominating Committee may consult with other members of the Committee
or the full board of Trustees.

The following guidelines are grouped according to the types of proposals
generally presented to shareholders. Part I deals with proposals which
have been approved and recommended by a company's board of directors.
Part II deals with proposals submitted by shareholders for inclusion in
proxy statements. Part III addresses unique considerations pertaining
to foreign issuers.

I. Board-Approved Proposals
- ---------------------------
The vast majority of matters presented to shareholders for a vote
involve proposals made by a company itself (sometimes referred to as
"management proposals"), which have been approved and recommended by its
board of directors. In view of the enhanced corporate governance
practices currently being implemented in public companies and the Funds'
intent to hold corporate boards accountable for their actions in
promoting shareholder interests, the Funds' proxies generally will be
voted in support of decisions reached by independent boards of
directors. Accordingly, the Funds' proxies will be voted for
board-approved proposals, except as follows:

A. Matters Relating to the Board of Directors
- ---------------------------------------------
The board of directors has the important role of overseeing management
and its performance on behalf of shareholders. The Funds' proxies will
be voted for the election of the company's nominees for directors and
for board-approved proposals on other matters relating to the board of
directors (provided that such nominees and other matters have been
approved by an independent nominating committee), except as follows:

* The Funds will withhold votes for the entire board of directors if

* The board does not have a majority of independent directors; or

* The board does not have nominating, audit and compensation committees
composed solely of independent directors.

Commentary:  While these requirements will likely become mandatory for
most public companies in the near future as a result of pending NYSE and
NASDAQ rule proposals, the Funds' Trustees believe that there is no
excuse for public company boards that fail to implement these vital
governance reforms at their next annual meeting. For these purposes, an
"independent director" is a director who meets all requirements to serve
as an independent director of a company under the pending NYSE rule
proposals (i.e., no material business relationships with the company, no
present or recent employment relationship with the company (including
employment of immediate family members) and, in the case of audit
committee members, no compensation for non-board services). As
indicated below, the Funds will generally vote on a case-by-case basis
on board-approved proposals where the board fails to meet these basic
independence standards.

* The Funds will withhold votes for any nominee for director who is
considered an independent director by the company and who has received
compensation from the company other than for service as a director
(e.g., investment banking, consulting, legal or financial advisory
fees).

Commentary:  The Funds' Trustees believe that receipt of compensation
for services other than service as a director raises significant
independence issues. The Funds will withhold votes for any nominee for
director who is considered an independent director by the company and
who receives such compensation.

* The Funds will withhold votes for the entire board of directors if the
board has more than 19 members or fewer than five members, absent
special circumstances.

Commentary:  The Funds' Trustees believe that the size of the board of
directors can have a direct impact on the ability of the board to govern
effectively. Boards that have too many members can be unwieldy and
ultimately inhibit their ability to oversee management performance.
Boards that have too few members can stifle innovation and lead to
excessive influence by management.

* The Funds will vote on a case-by-case basis in contested elections of
directors.

* The Funds will withhold votes for any nominee for director who attends
less than 75% of board and committee meetings without valid reasons for
the absences (i.e., illness, personal emergency, etc.).

Commentary:  Being a director of a company requires a significant time
commitment to adequately prepare for and attend the company's board and
committee meetings. Directors must be able to commit the time and
attention necessary to perform their fiduciary duties in proper fashion,
particularly in times of crisis.

The Funds' Trustees are concerned about over-committed directors. In
some cases, directors may serve on too many boards to make a meaningful
contribution. This may be particularly true for senior executives of
public companies (or other directors with substantially full-time
employment) who serve on more than a few outside boards. The Funds may
withhold votes from such directors on a case-by-case basis where it
appears that they may be unable to discharge their duties properly
because of excessive commitments.

* The Funds will withhold votes for any nominee for director of a public
company (Company A) who is employed as a senior executive of another
public company (Company B) if a director of Company B serves as a senior
executive of Company A (commonly referred to as an "interlocking
directorate").

Commentary:  The Funds' Trustees believe that interlocking directorships
are inconsistent with the degree of independence required for outside
directors of public companies.

Board independence depends not only on its members' individual
relationships, but also the board's overall attitude toward management.
Independent boards are committed to good corporate governance practices
and, by providing objective independent judgment, enhancing shareholder
value. The Funds may withhold votes on a case-by-case basis from some or
all directors that, through their lack of independence, have failed to
observe good corporate governance practices or, through specific
corporate action, have demonstrated a disregard for the interest of
shareholders.

* The Funds will vote against  proposals to classify a board, absent
special circumstances indicating that shareholder interests would be
better served by this structure.

Commentary:  Under a typical classified board structure, the directors
are divided into three classes, with each class serving a three-year
term. The classified board structure results in directors serving
staggered terms, with usually only a third of the directors up for
re-election at any given annual meeting. The Funds' Trustees generally
believe that it is appropriate for directors to stand for election each
year, but recognize that, in special circumstances, shareholder
interests may be better served under a classified board structure.

B. Executive Compensation
- -------------------------
The Funds generally favor compensation programs that relate executive
compensation to a company's long-term performance. The Funds will vote
on a case-by-case basis on board-approved proposals relating to
executive compensation, except as follows:

* Except where the Funds are otherwise withholding votes for the entire
board of directors, the Funds will vote for stock option plans which
will result in an average annual dilution of 1.67% or less (including
all equity-based plans).

* The Funds will vote against stock option plans that permit replacing
or repricing of underwater options (and against any proposal to
authorize such replacement or repricing of underwater options).

* The Funds will vote against stock option plans that permit issuance of
options with an exercise price below the stock's current market price.

* Except where the Funds are otherwise withholding votes for the entire
board of directors, the Funds will vote for employee stock purchase
plans that have the following features:  (1) the shares purchased under
the plan are acquired for no less than 85% of their market value, (2)
the offering period under the plan is 27 months or less, and (3)
dilution is 10% or less.

Commentary:  Companies should have compensation programs that are
reasonable and that align shareholder and management interests over the
longer term. Further, disclosure of compensation programs should provide
absolute transparency to shareholders regarding the sources and amounts
of, and the factors influencing, executive compensation. Appropriately
designed equity-based compensation plans can be an effective way to
align the interests of long-term shareholders with the interests of
management. The Funds may vote against executive compensation proposals
on a case-by-case basis where compensation is excessive by reasonable
corporate standards, or where a company fails to provide transparent
disclosure of executive compensation. In voting on proposals relating to
executive compensation, the Funds will consider whether the proposal has
been approved by an independent compensation committee of the board.

C. Capitalization
- -----------------
Many proxy proposals involve changes in a company's capitalization,
including the authorization of additional stock, the repurchase of
outstanding stock or the approval of a stock split. The management of a
company's capital structure involves a number of important issues,
including cash flow, financing needs and market conditions that are
unique to the circumstances of each company. As a result, the Funds will
vote on a case-by-case basis on board-approved proposals involving
changes to a company's capitalization, except that where the Funds are
not otherwise withholding votes from the entire board of directors:

* The Funds will vote for proposals relating to the authorization of
additional common stock (except where such proposals relate to a
specific transaction).

* The Funds will vote for proposals to effect stock splits (excluding
reverse stock splits.)

* The Funds will vote for proposals authorizing share repurchase
programs.

Commentary:  A company may decide to authorize additional shares of
common stock for reasons relating to executive compensation or for
routine business purposes. For the most part, these decisions are best
left to the board of directors and senior management. The Funds will
vote on a case-by-case basis, however, on other proposals to change a
company's capitalization, including the authorization of common stock
with special voting rights, the authorization or issuance of common
stock in connection with a specific transaction (e.g., an acquisition,
merger or reorganization) or the authorization or issuance of preferred
stock. Actions such as these involve a number of considerations that may
impact a shareholder's investment and warrant a case-by-case
determination.

D. Acquisitions, Mergers, Reincorporations, Reorganizations and
   Other Transactions
- ---------------------------------------------------------------
Shareholders may be confronted with a number of different types of
transactions, including acquisitions, mergers, reorganizations involving
business combinations, liquidations and sale of all or substantially all
of a company's assets, which may require their consent. Voting on such
proposals involves considerations unique to each transaction. As a
result, the Funds will vote on a case-by-case basis on board-approved
proposals to effect these types of transactions, except as follows:

* The Funds will vote for mergers and reorganizations involving business
combinations designed solely to reincorporate a company in Delaware.

Commentary:  A company may reincorporate into another state through a
merger or reorganization by setting up a "shell" company in a different
state and then merging the company into the new company. While
reincorporation into states with extensive and established corporate
laws - notably Delaware - provides companies and shareholders with a
more well-defined legal framework, generally speaking, shareholders must
carefully consider the reasons for a reincorporation into another
jurisdiction, including especially offshore jurisdictions.

E. Anti-Takeover Measures
- -------------------------
Some proxy proposals involve efforts by management to make it more
difficult for an outside party to take control of the company without
the approval of the company's board of directors. These include adoption
of a shareholder rights plan, requiring supermajority voting on
particular issues, adoption of fair price provisions, issuance of blank
check preferred stock and creating a separate class of stock with
disparate voting rights. Such proposals may adversely affect shareholder
rights, lead to management entrenchment, or create conflicts of
interest. As a result, the Funds will vote against board-approved
proposals to adopt such anti-takeover measures, except as follows:

* The Funds will vote on a case-by-case basis on proposals to ratify or
approve shareholder rights plans (commonly referred to as "poison
pills"); and

* The Funds will vote on a case-by-case basis on proposals to adopt fair
price provisions.

Commentary:  The Funds' Trustees recognize that poison pills and fair
price provisions may enhance shareholder value under certain
circumstances. As a result, the Funds will consider proposals to approve
such matters on a case-by-case basis.

F. Other Business Matters
- -------------------------
Many proxies involve approval of routine business matters, such as
changing the company's name, ratifying the appointment of auditors and
procedural matters relating to the shareholder meeting. For the most
part, these routine matters do not materially affect shareholder
interests and are best left to the board of directors and senior
management of the company. The Funds will vote for board-approved
proposals approving such matters, except as follows:

* The Funds will vote on a case-by-case basis on proposals to amend a
company's charter or bylaws (except for charter amendments necessary or
to effect stock splits to change a company's name or to authorize
additional shares of common stock).

* The Funds will vote against authorization to transact other
unidentified, substantive business at the meeting.

* The Funds will vote on a case-by-case basis on other business matters
where the Funds are otherwise withholding votes for the entire board of
directors.

Commentary:  Charter and bylaw amendments and the transaction of other
unidentified, substantive business at a shareholder meeting may directly
affect shareholder rights and have a significant impact on shareholder
value. As a result, the Funds do not view such items as routine business
matters. Putnam Management's investment professionals and the Funds'
proxy voting service may also bring to the Proxy Coordinator's attention
company-specific items which they believe to be non-routine and
warranting special consideration. Under these circumstances, the Funds
will vote on a case-by-case basis.

II. Shareholder Proposals
- -------------------------
SEC regulations permit shareholders to submit proposals for inclusion in
a company's proxy statement. These proposals generally seek to change
some aspect of a company's corporate governance structure or to change
some aspect of its business operations. The Funds will vote in
accordance with the recommendation of the company's board of directors
on all shareholder proposals, except as follows:

* The Funds will vote for shareholder proposals to declassify a board,
absent special circumstances which would indicate that shareholder
interests are better served by a classified board structure.

* The Funds will vote for shareholder proposals to require shareholder
approval of shareholder rights plans.

* The Funds will vote for shareholder proposals that are consistent with
the Fund's proxy voting guidelines for board-approved proposals.

* The Funds will vote on a case-by-case basis on other shareholder
proposals where the Funds are otherwise withholding votes for the entire
board of directors.

Commentary:  In light of the substantial reforms in corporate governance
that are currently underway, the Funds' Trustees believe that effective
corporate reforms should be promoted by holding boards of directors -
and in particular, their independent directors - accountable for their
actions, rather than imposing additional legal restrictions on board
governance through piecemeal proposals. Generally speaking, shareholder
proposals relating to business operations are often motivated primarily
by political or social concerns, rather than the interests of
shareholders as investors in an economic enterprise. As stated above,
the Funds' Trustees believe that boards of directors and management are
responsible for ensuring that their businesses are operating in
accordance with high legal and ethical standards and should be held
accountable for resulting corporate behavior. Accordingly, the Funds
will generally support the recommendations of boards that meet the basic
independence and governance standards established in these guidelines.
Where boards fail to meet these standards, the Funds will generally
evaluate shareholder proposals on a case-by-case basis.

III. Voting Shares of Foreign Issuers
- -------------------------------------
Many of the Funds invest on a global basis and, as a result, they may be
required to vote shares held in foreign issuers - i.e., issuers that are
incorporated under the laws of a foreign jurisdiction and that are not
listed a U.S. securities exchange or the NASDAQ stock market. Because
foreign issuers are incorporated under the laws of countries and
jurisdictions outside the U.S., protection for shareholders may vary
significantly from jurisdiction to jurisdiction. Laws governing foreign
issuers may, in some cases, provide substantially less protection for
shareholders. As a result, the foregoing guidelines, which are premised
on the existence of a sound corporate governance and disclosure
framework, may not be appropriate under some circumstances for foreign
issuers. The Funds will vote proxies of foreign issuers in accordance
with the foregoing guidelines where applicable, except as follows:

* The Funds will vote for shareholder proposals calling for a majority
of the directors to be independent of management.

* The Funds will vote for shareholder proposals seeking to increase the
independence of board nominating, audit and compensation committees.

* The Funds will vote for shareholder proposals that implement corporate
governance standards similar to those established under U.S. federal law
and the listing requirements of U.S. stock exchanges, and that do not
otherwise violate the laws of the jurisdiction under which the company
is incorporated.

* The Funds will vote on case-by-case basis on proposals relating to (1)
the issuance of common stock in excess of 20% of a company's outstanding
common stock where shareholders do not have preemptive rights, or (2)
the issuance of common stock in excess of 100% of a company's
outstanding common stock where shareholders have preemptive rights.

Commentary:  In many non-U.S. markets, shareholders who vote proxies for
shares of a foreign issuer are not able to trade in that company's stock
within a given period of time on or around the shareholder meeting date.
This practice is known as "share blocking."  In countries where share
blocking is practiced, the Funds will vote proxies only with direction
from Putnam Management's investment professionals.


As adopted March 14, 2003




Proxy Voting Procedures of the Putnam Funds
- -------------------------------------------

The Role of the Funds' Trustees
- -------------------------------
The Trustees of the Putnam Funds exercise control of the voting of
proxies through their Board Policy and Nominating Committee, which is
composed entirely of independent Trustees. The Board Policy and
Nominating Committee oversees the proxy voting process and participates,
as needed, in the resolution of issues which need to be handled on a
case-by-case basis. The Committee annually reviews and recommends for
approval by the Trustees guidelines governing the Funds' proxy votes,
including how the Funds vote on specific proposals and which matters are
to be considered on a case-by-case basis. The Trustees are assisted in
this process by their independent administrative staff ("Fund
Administration"), independent legal counsel, and an independent proxy
voting service. The Trustees also receive assistance from Putnam
Investment Management, LLC ("Putnam Management"), the Funds' investment
adviser, on matters involving investment judgments. In all cases, the
ultimate decision on voting proxies rests with the Trustees, acting as
fiduciaries on behalf of the shareholders of the Funds.

The Role of the Proxy Voting Service
- ------------------------------------
The Funds have engaged an independent proxy voting service to assist in
the voting of proxies. The proxy voting service is responsible for
coordinating with the Funds' custodians to ensure that all proxy
materials received by the custodians relating to the Funds' portfolio
securities are processed in a timely fashion. To the extent applicable,
the proxy voting service votes all proxies in accordance with the proxy
voting guidelines established by the Trustees. The proxy voting service
will refer proxy questions to the Proxy Coordinator (described below)
for instructions under circumstances where: (1) the application of the
proxy voting guidelines is unclear, (2) a particular proxy question is
not covered by the guidelines, or (3) the guidelines call for specific
instructions on a case-by-case basis. The proxy voting service is also
requested to call to the Proxy Coordinator's attention specific proxy
questions which, while governed by a guideline, appear to involve
unusual or controversial issues. The Funds also utilize research
services relating to proxy questions provided by the proxy voting
service and by other firms.

The Role of the Proxy Coordinator
- ---------------------------------
Each year, a member of Fund Administration is appointed Proxy
Coordinator to assist in the coordination and voting of the Funds'
proxies. The Proxy Coordinator will deal directly with the proxy voting
service and, in the case of proxy questions referred by the proxy voting
service, will solicit voting recommendations and instructions from Fund
Administration, the Chair of the Board Policy and Nominating Committee,
and Putnam Management's investment professionals, as appropriate. The
Proxy Coordinator is responsible for ensuring that these questions and
referrals are responded to in a timely fashion and for transmitting
appropriate voting instructions to the proxy voting service.

 Voting Procedures for Referral Items
- -------------------------------------
As discussed above, the proxy voting service will refer proxy questions
to the Proxy Coordinator under certain circumstances. When the
application of the proxy voting guidelines is unclear or a particular
proxy question is not covered by the guidelines (and does not involve
investment considerations), the Proxy Coordinator will assist in
interpreting the guidelines and, as appropriate, consult with the Senior
Vice President of Fund Administration, the Executive Vice President of
Fund Administration and the Chair of the Board Policy and Nominating
Committee on how the Funds' shares will be voted.

For proxy questions that require a case-by-case analysis pursuant to the
guidelines or that are not covered by the guidelines but involve
investment considerations, the Proxy Coordinator will refer such
questions, through a written request, to Putnam Management's investment
professionals for a voting recommendation. Such referrals will be made
in cooperation with the person or persons designated by Putnam
Management's Legal and Compliance Department to assist in processing
such referral items. In connection with each such referral item, the
Legal and Compliance Department will conduct a conflicts of interest
review, as described below under "Conflicts of Interest," and provide a
conflicts of interest report (the "Conflicts Report") to the Proxy
Coordinator describing the results of such review. After receiving a
referral item from the Proxy Coordinator, Putnam Management's investment
professionals will provide a written recommendation to the Proxy
Coordinator and the person or persons designated by the Legal and
Compliance Department to assist in processing referral items. Such
recommendation will set forth (1) how the proxies should be voted, (2)
the basis and rationale for such recommendation, and (3) any contacts
the investment professionals have had with respect to the referral item
with non-investment personnel of Putnam Management or with outside
parties (except for routine communications from proxy solicitors). The
Proxy Coordinator will then review the investment professionals'
recommendation and the Conflicts Report with the Senior Vice President
and/or Executive Vice President in determining how to vote the Funds'
proxies. The Proxy Coordinator will maintain a record of all proxy
questions that have been referred to Putnam Management's investment
professionals, the voting recommendation and the Conflicts Report.

In some situations, the Proxy Coordinator, the Senior Vice President
and/or the Executive Vice President may determine that a particular
proxy question raises policy issues requiring consultation with the
Chair of the Board Policy and Nominating Committee who, in turn, may
decide to bring the particular proxy question to the Committee or the
full board of Trustees for consideration.

Conflicts of Interest
- ---------------------
Occasions may arise where a person or organization involved in the proxy
voting process may have a conflict of interest. A conflict of interest
may exist, for example, if Putnam Management has a business relationship
with (or is actively soliciting business from) either the company
soliciting the proxy or a third party that has a material interest in
the outcome of a proxy vote or that is actively lobbying for a
particular outcome of a proxy vote. Any individual with knowledge of a
personal conflict of interest (e.g., familial relationship with company
management) relating to a particular referral item shall disclose that
conflict to the Proxy Coordinator and the Legal and Compliance
Department and otherwise remove himself or herself from the proxy voting
process. The Legal and Compliance Department will review each item
referred to Putnam Management's investment professionals to determine if
a conflict of interest exists and will provide the Proxy Coordinator
with a Conflicts Report for each referral item that (1) describes any
conflict of interest; (2) discusses the procedures used to address such
conflict of interest; and (3) discloses any contacts from parties
outside Putnam Management (other than routine communications from proxy
solicitors) with respect to the referral item not otherwise reported in
an investment professional's recommendation. The Conflicts Report will
also include written confirmation that any recommendation from an
investment professional provided under circumstances where a conflict of
interest exists was made solely on the investment merits and without
regard to any other consideration.

As adopted March 14, 2003



Item 8. [Reserved]
- ------------------

Item 9. Controls and Procedures:
- --------------------------------

(a) The registrant's principal executive officer and principal financial
officers have concluded, based on their evaluation of the effectiveness
of the design and operation of the registrant's disclosure controls and
procedures as of a date within 90 days of the filing date of this report
on Form N-CSR, that the design and operation of such procedures are
effective to provide reasonable assurance that information required to
be disclosed by the investment company in the reports that it files or
submits under the Securities Exchange Act of 1934 is recorded,
processed, summarized, and reported within the time periods specified in
the Commission's rules and forms.

(b) Changes in internal control over financial reporting:
Not applicable

Item 10. Exhibits:
- ------------------

(a)  The Code of Ethics of The Putnam Funds, which incorporates the
Code of Ethics of Putnam Investments, is filed herewith.

(b) A separate certification for each principal executive officer and
principal financial officer of the registrant as required by Rule 30a-2
under the Investment Company Act of 1940, as amended, and the officer
certifications as required by Section 906 of the Sarbanes-Oxley Act of 2002
are filed herewith.


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934
an the Investment Company Act of 1940, the registrant has duly
caused this report to be signed on its behalf by the undersigned,
thereunto duly authorized.

NAME OF REGISTRANT

By (Signature and Title):            /s/Michael T. Healy
                                     --------------------------
                                     Michael T. Healy
                                     Principal Accounting Officer
Date: December 23, 2003



Pursuant to the requirements of the Securities Exchange Act of 1934
an the Investment Company Act of  1940, this report has been signed
below by the following persons on behalf of the registrant and in
the capacities and on the dates indicated.

By (Signature and Title):            /s/Karnig H. Durgarian
                                     ---------------------------
                                     Karnig H. Durgarian
                                     Principal Executive Officer
Date: December 23, 2003



By (Signature and Title):            /s/Charles E. Porter
                                     ---------------------------
                                     Charles E. Porter
                                     Principal Financial Officer
Date: December 23, 2003



By (Signature and Title):            /s/Steven D. Krichmar
                                     ---------------------------
                                     Steven D. Krichmar
                                     Principal Financial Officer
Date: December 23, 2003

</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-99.CERT
<SEQUENCE>3
<FILENAME>exnn2.txt
<DESCRIPTION>EX-99.CERT
<TEXT>
Certifications
- --------------
I, Charles E. Porter, a principal financial officer of the funds listed
on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on
Attachment A:

2. Based on my knowledge, each report does not contain any untrue
statements of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which
such statements were made, not misleading with respect to the period
covered by each report;

3. Based on my knowledge, the financial statements, and other financial
information included in each report, fairly present in all material
respects the financial condition, results of operations, changes in net
assets, and cash flows (if the financial statements are required to
include a statement of cash flows) of the registrant as of, and for, the
periods presented in each report;

4. Each registrant's other certifying officers and I are responsible for
establishing and maintaining disclosure controls and procedures (as
defined in rule 30a-3(c) under the Investment Company Act) for the
registrants and have:

a) designed such disclosure controls and procedures, or caused such
disclosure controls and procedures to be designed under our supervision,
to ensure that material information relating to the registrant,
including its consolidated subsidiaries, is made known to us by others
within those entities, particularly during the period in which each
report are being prepared;

b) evaluated the effectiveness of the registrant's disclosure controls
and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of a date
within 90 days prior to the filing date of this report (the "Evaluation
Date") based on such evaluation; and

c) disclosed in this report any change in the registrant's internal
control over financial reporting that occurred during the registrant's
most recent fiscal half-year (the registrant's second fiscal half-year
in the case of an annual report) that has materially affected, or is
reasonably likely to materially affect, the registrant's internal
control over financial reporting.

5. Each registrant's other certifying officers and I have disclosed to
each registrant's auditors and the audit committee of each registrant's
board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or
operation of internal controls over financial reporting which are
reasonably likely to adversely affect each registrant's ability to
record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other
employees who have a significant role in each registrant's internal
controls.

/s/Charles E. Porter        Date: December 23, 2003
- ----------------------      ------------------------
Charles E. Porter, Principal Financial Officer




Certifications
- --------------
I, Karnig H. Durgarian, the principal executive officer of the funds
listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on
Attachment A:

2. Based on my knowledge, each report does not contain any untrue
statements of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which
such statements were made, not misleading with respect to the period
covered by each report;

3. Based on my knowledge, the financial statements, and other financial
information included in each report, fairly present in all material
respects the financial condition, results of operations, changes in net
assets, and cash flows (if the financial statements are required to
include a statement of cash flows) of the registrant as of, and for, the
periods presented in each report;

4. Each registrant's other certifying officers and I are responsible for
establishing and maintaining disclosure controls and procedures (as
defined in rule 30a-3(c) under the Investment Company Act) for the
registrants and have:

a) designed such disclosure controls and procedures, or caused such
disclosure controls and procedures to be designed under our supervision,
to ensure that material information relating to the registrant,
including its consolidated subsidiaries, is made known to us by others
within those entities, particularly during the period in which each
report are being prepared;

b) evaluated the effectiveness of the registrant's disclosure controls
and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of a date
within 90 days prior to the filing date of this report (the "Evaluation
Date") based on such evaluation; and

c) disclosed in this report any change in the registrant's internal
control over financial reporting that occurred during the registrant's
most recent fiscal half-year (the registrant's second fiscal half-year
in the case of an annual report) that has materially affected, or is
reasonably likely to materially affect, the registrant's internal
control over financial reporting.

5. Each registrant's other certifying officers and I have disclosed to
each registrant's auditors and the audit committee of each registrant's
board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or
operation of internal controls over financial reporting which are
reasonably likely to adversely affect each registrant's ability to
record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other
employees who have a significant role in each registrant's internal
controls.

/s/Karnig H. Durgarian      Date: December 23, 2003
- ----------------------      ------------------------
Karnig H. Durgarian, Principal Executive Officer




Certifications
- --------------
I, Steven D. Krichmar, a principal financial officer of the funds listed
on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on
Attachment A:

2. Based on my knowledge, each report does not contain any untrue
statements of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which
such statements were made, not misleading with respect to the period
covered by each report;

3. Based on my knowledge, the financial statements, and other financial
information included in each report, fairly present in all material
respects the financial condition, results of operations, changes in net
assets, and cash flows (if the financial statements are required to
include a statement of cash flows) of the registrant as of, and for, the
periods presented in each report;

4. Each registrant's other certifying officers and I are responsible for
establishing and maintaining disclosure controls and procedures (as
defined in rule 30a-3(c) under the Investment Company Act) for the
registrants and have:

a) designed such disclosure controls and procedures, or caused such
disclosure controls and procedures to be designed under our supervision,
to ensure that material information relating to the registrant,
including its consolidated subsidiaries, is made known to us by others
within those entities, particularly during the period in which each
report are being prepared;

b) evaluated the effectiveness of the registrant's disclosure controls
and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of a date
within 90 days prior to the filing date of this report (the "Evaluation
Date") based on such evaluation; and

c) disclosed in this report any change in the registrant's internal
control over financial reporting that occurred during the registrant's
most recent fiscal half-year (the registrant's second fiscal half-year
in the case of an annual report) that has materially affected, or is
reasonably likely to materially affect, the registrant's internal
control over financial reporting.

5. Each registrant's other certifying officers and I have disclosed to
each registrant's auditors and the audit committee of each registrant's
board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or
operation of internal controls over financial reporting which are
reasonably likely to adversely affect each registrant's ability to
record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other
employees who have a significant role in each registrant's internal
controls.

/s/Steven D. Krichmar       Date: December 23, 2003
- ----------------------      ------------------------
Steven D. Krichmar, Principal Financial Officer



Attachment A
- --------------
Period(s) ended October 31, 2003

002 The Putnam Fund for Growth and Income
004 Putnam Income Fund
005 Putnam Global Equity Fund
008 Putnam Convertible Income-Growth Trust
041 Putnam Global Income Trust
052 Putnam Managed Municipal Income Trust
072 Putnam Master Income Trust
183 Putnam Municipal Bond Fund
184 Putnam California Investment Grade Municipal Trust
185 Putnam New York Investment Grade Municipal Trust
2IE Putnam Growth Fund
2II Putnam Capital Opportunities Fund
2MI Putnam Tax Smart Equity Fund
2OV Putnam Mid Cap Value Fund
582 Putnam Municipal Opportunities Trust
840 Putnam Utilities Growth and Income Fund

</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-99.906 CERT
<SEQUENCE>4
<FILENAME>exnos3.txt
<DESCRIPTION>EX-99.906 CERT
<TEXT>
Section 906 Certifications
- ---------------------------
I, Charles E. Porter, a principal financial officer of the Funds listed
on Attachment A, certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period
ended October 31, 2003 fully complies with the requirements of Section
13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on
Attachment A for the period ended October 31, 2003 fairly presents, in all
material respects, the financial condition and results of operations of
the Funds listed on Attachment A.

/s/Charles E. Porter        Date: December 23, 2003
- ----------------------      ------------------------
Charles E. Porter, Principal Financial Officer




Section 906 Certifications
- ---------------------------
I, Karnig H. Durgarian, the principal executive officer of the Funds
listed on Attachment A, certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period
ended October 31, 2003 fully complies with the requirements of Section
13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on
Attachment A for the period ended October 31, 2003 fairly presents, in all
material respects, the financial condition and results of operations of
the Funds listed on Attachment A.

/s/Karnig H. Durgarian      Date: December 23, 2003
- ----------------------      ------------------------
Karnig H. Durgarian, Principal Executive Officer



Section 906 Certifications
- ---------------------------
I, Steven D. Krichmar, a principal financial officer of the Funds listed
on Attachment A, certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period
ended October 31, 2003 fully complies with the requirements of Section
13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on
Attachment A for the period ended October 31, 2003 fairly presents, in all
material respects, the financial condition and results of operations of
the Funds listed on Attachment A.

/s/Steven D. Krichmar       Date: December 23, 2003
- ----------------------      ------------------------
Steven D. Krichmar, Principal Financial Officer




Attachment A
- --------------
Period(s) ended October 31, 2003

002 The Putnam Fund for Growth and Income
004 Putnam Income Fund
005 Putnam Global Equity Fund
008 Putnam Convertible Income-Growth Trust
041 Putnam Global Income Trust
052 Putnam Managed Municipal Income Trust
072 Putnam Master Income Trust
183 Putnam Municipal Bond Fund
184 Putnam California Investment Grade Municipal Trust
185 Putnam New York Investment Grade Municipal Trust
2IE Putnam Growth Fund
2II Putnam Capital Opportunities Fund
2MI Putnam Tax Smart Equity Fund
2OV Putnam Mid Cap Value Fund
582 Putnam Municipal Opportunities Trust
840 Putnam Utilities Growth and Income Fund

</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-99.CODE ETH
<SEQUENCE>5
<FILENAME>md.txt
<TEXT>

THE PUTNAM FUNDS

Code of Ethics


Each of The Putnam Funds (the "Funds") has determined to adopt this Code
of Ethics with respect to certain types of personal securities
transactions by officers and Trustees of the Funds which might be deemed
to create possible conflicts of interest and to establish reporting
requirements and enforcement procedures with respect to such
transactions.

I. Rules Applicable to Officers and Trustees
   Affiliated with Putnam Investments, Inc.

A.  Incorporation of Adviser's Code of Ethics.  The provisions of the
Code of Ethics for employees of Putnam Investments, Inc. and its
Subsidiaries (the "Putnam Investments Code of Ethics"), which is
attached as Appendix A hereto, are hereby incorporated herein as the
Funds' Code of Ethics applicable to officers and Trustees of the Funds
who are employees of the Funds or officers, directors or employees of
Putnam Investments, Inc. or its subsidiaries.  A violation of the Putnam
Investments Code of Ethics shall constitute a violation of the Funds'
Code.

B.  Reports.  Officers and Trustees of each of the Funds who are made
subject to the Putnam Investments Code of Ethics pursuant to the
preceding paragraph shall file the reports required by the Putnam
Investments Code of Ethics with the Compliance Director designated
therein.  A report filed with the Compliance Director shall be deemed to
be filed with each of the Funds of which the reporting individual is an
officer or Trustee.

C.  Review.  (1)  The Compliance Director shall compare the reported
personal securities transactions with completed and contemplated
portfolio transactions of each of the Funds to determine whether a
violation of this Code may have occurred.  Before making any
determination that a violation has been committed by any person, the
Compliance Director shall give such person an opportunity to supply
additional explanatory material.

(2)  If the Compliance Director determines that a violation of this Code
has or may have occurred, he shall submit his written determination,
together with the confidential quarterly report and any additional
explanatory material provided by the individual, to the Chairman of the
Funds, who shall make an independent determination of whether a
violation has occurred.

D.  Sanctions.  If the Chairman of the Funds finds that a violation has
occurred, he shall report the violation and any sanction imposed under
the Putnam Code of Ethics to the Trustees of the Funds who may impose
such additional sanctions as they deem appropriate.  If a securities
transaction of the Chairman is under consideration, the Vice Chairman of
the Funds shall act in all respects in the manner prescribed herein for
the Chairman.


II. Rules Applicable to Unaffiliated Trustees

A.  Definitions.

(1) "Beneficial ownership" shall be interpreted in the same manner as
    it would be in determining whether a person is subject to the provisions
    of Section 16 of the Securities Exchange Act of 1934 and the rules and
    regulations thereunder.  Application of this definition is explained in
    more detail in Exhibit A hereto.

(2) "Control" means the power to exercise a controlling influence over
    the management or policies of a company, unless such power is solely the
    result of an official position with such company.

(3) "Interested Trustee" means a Trustee of a Fund who is an "interested
    person" of the Fund within the meaning of the Investment Company Act.

(4) "Purchase or sale of a security" includes, among other things, the
    writing of an option to purchase or sell a security.

(5) "Security" shall have the same meaning as that set forth in Section
    2(a)(36) of the Investment Company Act (in effect, all securities)
    except that it shall not include securities issued by the Government of
    the United States or an agency thereof, bankers' acceptances, bank
    certificates of deposit, commercial paper and shares of registered
    open-end investment companies.

(6) "Unaffiliated Trustee" means a Trustee who is not made subject to
    the Putnam Investments Code of Ethics pursuant to Part I hereof.

B. Prohibited Purchases and Sales.  No Unaffiliated Trustee of any of
the Funds shall purchase or sell, directly or indirectly, any security
in which he has or by reason of such transaction acquires, any direct or
indirect beneficial ownership and which to his actual knowledge at the
time of such purchase or sale:

(1) is being considered for purchase or sale by the Fund;

(2) is being purchased or sold by the Fund; or

(3) was purchased or sold by the Fund within the most recent five days
if such person participated in the recommendation to, or the decision
by, Putnam Management to purchase or sell such security for the Fund.


C.  Exempted Transactions.  The prohibitions of Section   II-B of this
Code shall not apply to:

(1)  purchases or sales effected in any account over which the
Unaffiliated Trustee has no direct or indirect influence or control;

(2)  purchases or sales which are non-volitional on the part of either
the Unaffiliated Trustee or the Fund;

(3)  purchases which are part of an automatic dividend reinvestment
plan;

(4)  purchases effected upon the exercise of rights issued by an issuer
pro rata to all holders of a class of its securities, to the extent such
rights were acquired from such issuer, and sales of such rights so
acquired;

(5)  purchases or sales other than those exempted in (1) through (4)
above which do not cause the Unaffiliated Trustee to gain improperly a
personal benefit through his relationship with the Fund and are only
remotely potentially harmful to a Fund because they would be very
unlikely to affect a highly institutional market, and are previously
approved by the Compliance Director under the Putnam Code of Ethics or
the Chairman of the Funds, which approval shall be confirmed in writing.


D.  Reporting.  (1)  Whether or not one of the exemptions listed in
Section II-C applies, every Unaffiliated Trustee of a Fund shall file
with the Chairman of the Funds a report containing the information
described in Section II-D(2) of this Code with respect to transactions
in any security in which such Unaffiliated Trustee has, or by reason of
such transaction acquires, any direct or indirect beneficial ownership,
if such Trustee, at the time of that transaction, knew or, in the
ordinary course of fulfilling his official duties as a Trustee of the
Fund, should have known that, during the 15-day period immediately
preceding or after the date of the transaction by the Trustee:

(a)  such security was or is to be purchased or sold by the Fund or

(b)  such security was or is being considered for purchase or sale by the Fund;

provided, however, that an Unaffiliated Trustee shall not be required to
make a report with respect to transactions effected for any account over
which such person does not have any direct or indirect influence or
control.

(2)  Every report shall be made not later than 10 days after the end of
the calendar quarter in which the transaction to which the report
relates was effected, and shall contain the following information:

(a)  The date of the transaction, the title and the number of shares, and the
     principal amount of each security involved;

(b)  The nature of the transaction (i.e., purchase, sale or any other type of
     acquisition or disposition);

(c)  The price at which the transaction was effected; and

(d)  The name of the broker, dealer or bank with or through whom the
     transaction was effected.

(3)  Every report concerning a purchase or sale prohibited under Section
II-B hereof with respect to which the reporting person relies upon one
of the exemptions provided in Section IIC shall contain a brief
statement of the exemption relied upon and the circumstances of the
transaction.

(4)  Any such report may contain a statement that the report shall not
be construed as an admission by the person making such report that he
has any direct or indirect beneficial ownership in the security to which
the report relates.

(5)  Notwithstanding anything to the contrary contained herein, an
Unaffiliated Trustee who is an Interested Trustee shall also file the
reports required by Rule 17j-1(c)(1) under the Investment Company Act of
1940.


E.  Review.  (1)  The Chairman of the Funds shall compare the reported
personal securities transactions with completed and contemplated
portfolio transactions of the Funds to determine whether any transaction
("Reviewable Transactions") listed in Section II-B (disregarding
exemptions provided by Section II-C(1) through (5)) may have occurred.

(2)  If the Chairman determines that a Reviewable Transaction may have
occurred, he shall then determine whether a violation of this Code may
have occurred, taking into account all the exemptions provided under
Section II-C.  Before making any determination that a violation has
occurred, the Chairman shall give the person involved an opportunity to
supply additional information regarding the transaction in question.

F.  Sanctions.  If the Chairman determines that a violation of this Code
has occurred, he shall so advise a committee consisting of the
Unaffiliated Trustees, other than the person whose transaction is under
consideration, and shall provide the committee with a report of the
matter, including any additional information supplied by such person.
The committee may impose such sanction as it deems appropriate.


III.  Miscellaneous.

A.  Amendments to The Putnam Companies Code of Ethics.  Any amendment to
the Putnam Companies Code of Ethics shall be deemed an amendment to
Section I-A of this Code effective 30 days after written notice of such
amendment shall have been received by the Chairman of the Funds, unless
the Trustees of the Funds expressly determine that such amendment shall
become effective at an earlier or later date or shall not be adopted.

B.  Records.  The Funds shall maintain records in the manner and to the
extent set forth below, which records may be maintained on microfilm
under the conditions described in Rule 31a-2(f)(1) under the Investment
Company Act and shall be available for examination by representatives of
the Securities and Exchange Commission.

(1)  A copy of this Code and any other code which is, or at any time
within the past five years has been, in effect shall be preserved in an
easily accessible place;

(2)  A record of any violation of this Code and of any action taken as a
result of such violation shall be preserved in an easily accessible
place for a period of not less than five years following the end of the
fiscal year in which the violation occurs;

(3)  A copy of each report made by an officer or Trustee pursuant to
this Code shall be preserved for a period of not less than five years
from the end of the fiscal year in which it is made, the first two years
in an easily accessible place; and

(4)  A list of all person who are, or within the past five years have
been, required to make reports pursuant to this Code shall be maintained
in an easily accessible place.


C.  Confidentiality.  All reports of securities transactions and any
other information filed with any Fund pursuant to this Code shall be
treated as confidential, but are subject to review as provided herein
and by personnel of the Securities and Exchange Commission.

D.  Interpretation of Provisions.  The Directors and Trustees may from
time to time adopt such interpretations of this Code as they deem
appropriate.

E.  Delegation by Chairman.  The Chairman of the Funds may from time to
time delegate any or all of his responsibilities under this Code, either
generally or as to specific instances, to such officer or Trustee of the
Funds as he may designate.


As revised
July 8, 1994




Code of Ethics

PUTNAM INVESTMENTS

[SCALE LOGO OMITTED]


It is the personal responsibility of every Putnam employee to avoid any
conduct that could create a conflict, or even the appearance of a
conflict, with our clients, or to do anything that could damage or erode
the trust our clients place in Putnam and its employees.

44156  9/2003



* Table of Contents

Overview                                                            iii

Preamble                                                            vii

Definitions:   Code of Ethics                                        ix

Section I.   Personal Securities Rules for All Employees              1

A.   Restricted List                                                  1
B.   Prohibited Transactions                                          6
C.   Discouraged Transactions                                        10
D.   Exempted Transactions                                           11

Section II.  Additional Special Rules for Personal Securities
             Transactions of Access Persons and Certain Investment
             Professionals                                           13

Section III. Prohibited Conduct for All Employees                    19

Section IV.  Special Rules for Officers and Employees of Putnam
             Investments Limited.                                    31

Section V.   Reporting Requirements for All Employees                33

Section VI.  Education Requirements                                  37

Section VII. Compliance and Appeal Procedures                        39

Appendix A                                                           41

Preamble                                                             43
Definitions: Insider Trading                                         45
Section 1.   Rules Concerning Inside Information                     47
Section 2.   Overview of Insider Trading                             51


Appendix B.  Policy Statement Regarding Employee Trades in
             Shares of Putnam Closed-End Funds                       57

Appendix C.  Clearance Form for Portfolio Manager Sales Out of
             Personal Account of Securities Also Held by Fund
             (For compliance with "Contra-Trading" Rule)             59

Appendix D.  Procedures for Approval of New Financial Instruments    61

Appendix E.  AIMR Code of Ethics and Standards of Professional
             Responsibility                                          63

Index                                                                71


* Overview

Every Putnam employee is required, as a condition of continued
employment, to read, understand, and comply with the entire Code of
Ethics. Additionally, employees are expected to comply with the policies
and procedures contained within the Putnam Employee Handbook, which can
be accessed on-line through www.ibenefitcenter.com.  This Overview is
provided only as a convenience and is not intended to substitute for a
careful reading of the complete document.

It is the personal responsibility of every Putnam employee to avoid any
conduct that could create a conflict, or even the appearance of a
conflict, with our clients, or do anything that could damage or erode
the trust our clients place in Putnam and its employees. This is the
spirit of the Code of Ethics. In accepting employment at Putnam, every
employee accepts the absolute obligation to comply with the letter and
the spirit of the Code of Ethics. Failure to comply with the spirit of
the Code of Ethics is just as much a violation of the Code as failure to
comply with the written rules of the Code.

The rules of the Code cover activities, including personal securities
transactions, of Putnam employees, certain family members of employees,
and entities (such as corporations, trusts, or partnerships) that
employees may be deemed to control or influence.

Sanctions will be imposed for violations of the Code of Ethics.
Sanctions may include bans on personal trading, reductions in salary
increases or bonuses, disgorgement of trading profits, suspension of
employment, and termination of employment.

- -- Insider trading:

   Putnam employees are forbidden to buy or sell any security while
   either Putnam or the employee is in possession of non-public
   information ("inside information") concerning the security or the
   issuer. A violation of Putnam's insider trading policies may result
   in criminal and civil penalties, including imprisonment and
   substantial fines.

- -- Conflicts of interest:

   The Code of Ethics imposes limits on activities of Putnam employees
   where the activity may conflict with the interests of Putnam or its
   clients. These include limits on the receipt and solicitation of
   gifts and on service as a fiduciary for a person or entity outside of
   Putnam.

   For example, Putnam employees generally may not accept gifts over
   $100 in total value in a calendar year from any entity or any
   supplier of goods or services to Putnam. In addition, a Putnam
   employee may not serve as a director of any corporation without prior
   approval of the Code of Ethics Officer, and Putnam employees may not
   be members of investment clubs.

- -- Confidentiality:

   Information about Putnam clients and Putnam investment activity and
   research is proprietary and confidential and may not be disclosed or
   used by any Putnam employee outside Putnam without a valid business
   purpose.

- -- Personal securities trading:

   Putnam employees may not buy or sell any security for their own
   account without clearing the proposed transaction in advance through
   the on-line pre-clearance system or with the Code of Ethics
   Administrator.

   Certain securities are excepted from this requirement (e.g., Marsh &
   McLennan stock and shares of open-end (not closed-end) Putnam Funds).

   Clearance must be obtained in advance, between 11:30 a.m. and 4:00
   p.m. EST on the day of the trade.  Clearance may be obtained between
   9:00 a.m. and 4:00 p.m. on the day of the trade for up to 1,000
   shares of stock of an issuer whose capitalization exceeds $5 billion.
   A clearance is valid only for the day it is obtained.  The Code also
   strongly discourages excessive trading by employees for their own
   account (i.e., more than 10 trades in any calendar quarter). Trading
   in excess of this level will be reviewed with the Code of Ethics
   Oversight Committee.

- -- Short Selling:

   Putnam employees are prohibited from short selling any security,
   whether or not it is held in a Putnam client portfolio, except that
   short selling against broad market indexes and "against the box" are
   permitted.

- -- Confirmations of trading and periodic account statements:

   All Putnam employees must have their brokers send confirmations of
   personal securities transactions, including transactions of immediate
   family members and accounts over which the employee has investment
   discretion, to the Code of Ethics Officer. Employees must contact the
   Code of Ethics Administrator to obtain an authorization letter from
   Putnam for setting up a personal brokerage account.


- -- Quarterly and annual reporting:

   Certain Putnam employees (so-called "Access Persons" as defined by
   the SEC and in the Code of Ethics) must report all their securities
   transactions in each calendar quarter to the Code of Ethics Officer
   within 10 days after the end of the quarter.   All Access Persons
   must disclose all personal securities holdings upon commencement of
   employment and thereafter on an annual basis.  You will be notified
   if these requirements apply to you. If these requirements apply to
   you and you fail to report as required, salary increases and bonuses
   will be reduced.

- -- IPOs and private placements:

   Putnam employees may not buy any securities in an initial public
   offering or in a private placement, except in limited circumstances
   when prior written authorization is obtained.

- -- Procedures for Approval of New Financial Instruments:

   No new types of securities or instruments may be purchased for any
   Putnam fund or other client account without the prior approval of the
   Risk Management Committee.

- -- Personal securities transactions by Access Persons and certain investment
   professionals:

   The Code imposes several special restrictions on personal securities
   transactions by Access Persons and certain investment professionals,
   which are summarized as follows:

- -- "60-Day Holding Period". No Access Person shall purchase and then sell at a
   profit, or sell and then repurchase at a lower price, any security or
   related derivative security within 60 calendar days.

- -- "7-Day" Rule. Before a portfolio manager places an order to buy a security
   for any portfolio he manages, he must sell from his personal account any
   such security or related derivative security purchased within the preceding
   7 calendar days and disgorge any profit from the sale.

- -- "Blackout" Rules. No portfolio manager may sell any security or
   related derivative security for her personal account until 7 calendar
   days have passed since the most recent purchase of that security or
   related derivative security by any portfolio she manages. No portfolio
   manager may buy any security or related derivative security for his
   personal account until 7 calendar days have passed since the most recent
   sale of that security or related derivative security by any portfolio he
   manages.

- -- "Contra-Trading" Rule. No portfolio manager may sell out of her personal
   account any security or related derivative security that is held in any
   portfolio she manages unless she has received the written approval of a
   CIO and the Code of Ethics Officer.

- -- No manager may cause a Putnam client to take action for the manager's own
   personal benefit.

- -- SIMILAR RULES LIMIT PERSONAL SECURITIES TRANSACTIONS BY ANALYSTS,
   CO-MANAGERS, AND CHIEF INVESTMENT OFFICERS. PLEASE READ THESE RULES
   CAREFULLY. YOU ARE RESPONSIBLE FOR UNDERSTANDING THE RESTRICTIONS.

This Overview is qualified in its entirety by the provisions of the Code
of Ethics. The Code requires that all Putnam employees read, understand,
and comply with the entire Code of Ethics.


* Preamble

It is the personal responsibility of every Putnam employee to avoid any
conduct that would create a conflict, or even the appearance of a
conflict, with our clients, or embarrass Putnam in any way. This is the
spirit of the Code of Ethics. In accepting employment at Putnam, every
employee also accepts the absolute obligation to comply with the letter
and the spirit of the Code of Ethics. Failure to comply with the spirit
of the Code of Ethics is just as much a violation of the Code as failure
to comply with the written rules of the Code.

Sanctions will be imposed for violations of the Code of Ethics,
including the Code's reporting requirements. Sanctions may include bans
on personal trading, reductions in salary increases or bonuses,
disgorgement of trading profits, suspension of employment and
termination of employment.

Putnam Investments is required by law to adopt a Code of Ethics. The
purposes of the law  are to ensure that companies and their employees
comply with all applicable laws and to prevent abuses in the investment
advisory business that can arise when conflicts of interest exist
between the employees of an investment adviser and its clients. Having
an effective Code of Ethics is good business practice, as well. By
adopting and enforcing a Code of Ethics, we strengthen the trust and
confidence reposed in us by demonstrating that, at Putnam, client
interests come before personal interests.

Putnam has had a Code of Ethics for many years. The first Putnam Code
was written more than 30 years ago by George Putnam. It has been revised
periodically, and was re-drafted in its entirety in 1989 to take account
of legal and regulatory developments in the investment advisory
business. Since 1989, the Code has been revised regularly to reflect
developments in our business and the law.

The Code that follows represents a balancing of important interests. On
the one hand, as a registered investment adviser, Putnam owes a duty of
undivided loyalty to its clients, and must avoid even the appearance of
a conflict that might be perceived as abusing the trust they have placed
in Putnam. On the other hand, Putnam does not want to prevent
conscientious professionals from investing for their own account where
conflicts do not exist or are so attenuated as to be immaterial to
investment decisions affecting Putnam clients.

When conflicting interests cannot be reconciled, the Code makes clear
that, first and foremost, Putnam employees owe a fiduciary duty to
Putnam clients. In most cases, this means that the affected employee
will be required to forego conflicting personal securities transactions.
In some cases, personal investments will be permitted, but only in a
manner which, because of the circumstances and applicable controls,
cannot reasonably be perceived as adversely affecting Putnam client
portfolios or taking unfair advantage of the relationship Putnam
employees have to Putnam clients.

The Code contains specific rules prohibiting defined types of conflicts.
Because every potential conflict cannot be anticipated in advance, the
Code also contains certain general provisions prohibiting conflict
situations. In view of these general provisions, it is critical that any
individual who is in doubt about the applicability of the Code in a
given situation seek a determination from the Code of Ethics Officer
about the propriety of the conduct in advance. The procedures for
obtaining such a determination are described in Section VII of the Code.

It is critical that the Code be strictly observed. Not only will
adherence to the Code ensure that Putnam renders the best possible
service to its clients, it will ensure that no individual is liable for
violations of law.

It should be emphasized that adherence to this policy is a fundamental
condition of employment at Putnam. Every employee is expected to adhere
to the requirements of this Code of Ethics despite any inconvenience
that may be involved. Any employee failing to do so may be subject to
such disciplinary action, including financial penalties and termination
of employment, as determined by the Code of Ethics Oversight Committee
or the Chief Executive Officer of Putnam Investments.


* Definitions:   Code of Ethics

The words given below are defined specifically for the purposes of Putnam's
Code of Ethics.

Gender references in the Code of Ethics alternate.

Rule of construction regarding time periods. Unless the context
indicates otherwise, time periods used in the Code of Ethics shall be
measured inclusively, i.e., including the dates from and to which the
measurement is made.

Access Persons. Access Persons are (i) all officers of Putnam Investment
Management, LLC (the investment manager of Putnam's mutual funds), (ii)
all employees within Putnam's Investment Division, and (iii) all other
employees of Putnam who, in connection with their regular duties, have
access to information regarding purchases or sales of portfolio
securities by a Putnam mutual fund, or who have access to information
regarding recommendations with respect to such purchases or sales.

Code of Ethics Administrator. The individual designated by the Code of
Ethics Officer to assume responsibility for day-to-day,
non-discretionary administration of this Code.  The current Code of
Ethics Administrator is Laura Rose, who can be reached at extension
11104.

Code of Ethics Officer. The Putnam officer who has been assigned the
responsibility of enforcing and interpreting this Code. The Code of
Ethics Officer shall be the General Counsel or such other person as is
designated by the President of Putnam Investments. If the Code of Ethics
Officer is unavailable, the Deputy Code of Ethics Officer (to be
appointed by the Code of Ethics Officer) shall act in his stead.

Code of Ethics Oversight Committee. Has oversight responsibility for
administering the Code of Ethics. Members include the Code of Ethics
Officer, the Head of Investments, and other members of Putnam's senior
management approved by the Chief Executive Officer of Putnam.

Immediate family. Spouse, minor children, or other relatives living in
the same household as the Putnam employee.

Policy Statements. The Policy Statement Concerning Insider Trading
Prohibitions attached to the Code as Appendix A and the Policy Statement
Regarding Employee Trades in Shares of Putnam Closed-End Funds attached
to the Code as Appendix B.

Private placement. Any offering of a security not to the public, but to
sophisticated investors who have access to the kind of information which
would be contained in a prospectus, and which does not require
registration with the relevant securities authorities.

Purchase or sale of a security. Any acquisition or transfer of any
interest in the security for direct or indirect consideration, and
includes the writing of an option.

Putnam. Any or all of Putnam Investments, Inc., and its subsidiaries,
any one of which shall be a "Putnam company."

Putnam client. Any of the Putnam Funds, or any advisory, trust, or other
client of Putnam.

Putnam employee (or "employee"). Any employee of Putnam.

Restricted List. The list established in accordance with Rule 1 of
Section I.A.

Security. Any type or class of equity or debt security and any rights
relating to a security, such as put and call options, warrants, and
convertible securities. Unless otherwise noted, the term "security" does
not include: currencies, direct and indirect obligations of the U.S.
government and its agencies, commercial paper, certificates of deposit,
repurchase agreements, bankers' acceptances, any other money market
instruments, shares of open-end mutual funds (including Putnam open-end
mutual funds), exchange traded index funds containing a portfolio or
securities of 25 or more issuers (e.g., SPDRs, WEBs, QQQs), securities
of The Marsh & McLennan Companies, Inc., commodities, and any option on
a broad-based market index or an exchange-traded futures contract or
option thereon.

Transaction for a personal account (or "personal securities
transaction"). Securities transactions: (a) for the personal account of
any employee; (b) for the account of a member of the immediate family of
any employee; (c) for the account of a partnership in which a Putnam
employee or immediate family member is a general partner or a partner
with investment discretion; (d) for the account of a trust in which a
Putnam employee or immediate family member is a trustee with investment
discretion; (e) for the account of a closely-held corporation in which a
Putnam employee or immediate family member holds shares and for which he
has investment discretion; and (f) for any account other than a Putnam
client account which receives investment advice of any sort from the
employee or immediate family member, or as to which the employee or
immediate family member has investment discretion.


* Section I.   Personal Securities Rules for All Employees

A.   Restricted List

RULE 1

No Putnam employee shall purchase or sell for his personal account any
security without prior clearance obtained through Putnam's Intranet
pre-clearance system (in the "Workplace Community" section of
ibenefitcenter.com) or from the Code of Ethics Administrator. No
clearance will be granted for securities appearing on the Restricted
List. Securities shall be placed on the Restricted List in the following
circumstances:

(a) when orders to purchase or sell such security have been entered for any
    Putnam client, or the security is being actively considered for purchase
    or sale for any Putnam client;

(b) with respect to voting securities of corporations in the banking, savings
    and loan, communications, or gaming (i.e., casinos) industries, when
    holdings of Putnam clients exceed 7% (for public utilities, the threshold
    is 4%);

(c) when, in the judgment of the Code of Ethics Officer, other circumstances
    warrant restricting personal transactions of Putnam employees in a
    particular security;

(d) the circumstances described in the Policy Statement Concerning Insider
    Trading Prohibitions, attached as Appendix A.

Reminder: Securities for an employee's "personal account" include
securities owned by certain family members of a Putnam employee. Thus,
this Rule prohibits certain trades by family members of Putnam
employees. See Definitions.

Compliance with this rule does not exempt an employee from complying
with any other applicable rules of the Code, such as those described in
Section III. In particular, Access Persons and certain investment
professionals must comply with the special rules set forth in Section
II.

EXCEPTIONS

A. "Large Cap" Exception. If a security appearing on the Restricted List is
   an equity security for which the issuer has a market capitalization
   (defined as outstanding shares multiplied by current price per share) of
   over $5 billion, then a Putnam employee may purchase or sell up to 1,000
   shares of the security per day for his personal account. This exception
   does not apply if the security appears on the Restricted List in the
   circumstances described in subpart (b), (c), or (d) of Rule 1.

B. Investment Grade Or Higher Fixed-Income Exception. If a security being
   traded or considered for trade for a Putnam client is a non-convertible
   fixed-income security which bears a rating of BBB (Standard & Poor's) or
   Baa (Moody's) or any comparable rating or higher, then a Putnam employee
   may purchase or sell that security for his personal account without regard
   to the activity of Putnam clients. This exception does not apply if the
   security has been placed on the Restricted List in the circumstances
   described in subpart (b), (c), or (d) of Rule 1.

C. Pre-Clearing Transactions Effected by Share Subscription. The purchase and
   sale of securities made by subscription rather than on an exchange are
   limited to issuers having a market capitalization of $5 billion or more
   and are subject to a 1,000 share limit. The following are procedures to
   comply with Rule 1 when effecting a purchase or sale of shares by
   subscription:

(a) The Putnam employee must pre-clear the trade on the day he or she submits a
    subscription to the issuer, rather than on the actual day of the trade
    since the actual day of the trade typically will not be known to the
    employee who submits the subscription. At the time of pre-clearance, the
    employee will be told whether the purchase is permitted (in the case of a
    corporation having a market capitalization of $5 billion or more), or not
    permitted (in the case of a smaller capitalization issuer).

(b) The subscription for any purchase or sale of shares must be reported on
    the employee's quarterly personal securities transaction report, noting
    the trade was accomplished by subscription.

(c) As no brokers are involved in the transaction, the confirmation requirement
    will be waived for these transactions, although the Putnam employee must
    provide the Legal and Compliance Department with any transaction summaries
    or statements sent by the issuer.


 SANCTION GUIDELINES

A. Failure to Pre-Clear a Personal Trade

1. First violation: One month trading ban with written warning that a future
   violation will result in a longer trading ban.

2. Second violation: Three month trading ban and written notice to Managing
   Director of the employee's division.

3. Third violation: Six month trading ban with possible longer or permanent
   trading ban based upon review by Code of Ethics Oversight Committee.

B. Failure to Pre-Clear Securities on the Restricted List

1. First violation: Disgorgement of any profit from the transaction, one month
   trading ban, and written warning that a future violation will result in a
   longer trading ban.

2. Second violation: Disgorgement of any profit from the transaction, three
   month trading ban, and written notice to Managing Director of the
   employee's division.

3. Third violation: Disgorgement of any profit from the transaction, and six
   month trading ban with possible longer or permanent trading ban based upon
   review by Code of Ethics Oversight Committee.

NOTE: These are the sanction guidelines for successive failures to
pre-clear personal trades within a 2-year period.  The Code of Ethics
Oversight Committee retains the right to increase or decrease the
sanction for a particular violation in light of the circumstances.  The
Committee's belief that an employee intentionally has violated the Code
of Ethics will result in more severe sanctions than outlined in the
guidelines above.  The sanctions described in Paragraph B apply to
Restricted List securities that are: (i) small cap stocks (i.e., stocks
not entitled to the "Large Cap" exception) and (ii) large cap stocks
that exceed the daily 1,000 share maximum permitted under the "Large
Cap" exception. Failure to pre-clear an otherwise permitted trade of up
to 1,000 shares of a large cap security is subject to the sanctions
described above in Paragraph A.

IMPLEMENTATION

A. Maintenance of Restricted List. The Restricted List shall be maintained by
   the Code of Ethics Administrator.

B. Consulting Restricted List.  An employee wishing to trade any security for
   his personal account shall first obtain clearance through Putnam's
   Intranet pre-clearance system.  The system may be accessed from your
   desktop computer through the Putnam ibenefitcenter
   (https://www.ibenefitcenter.com) Workplace Community tab, Employee
   Essentials menu.  Employees may pre-clear all securities between 11:30 a.m.
   and 4:00 p.m. EST, and may pre-clear purchases or sales of up to 1,000
   shares of issuers having a market capitalization of more than $5 billion
   between 9:00 a.m. and 4:00 p.m. EST.   Requests to make personal securities
   transactions may not be made using the system or presented to the Code of
   Ethics Administrator after 4:00 p.m.

The pre-clearance system will inform the employee whether the security
may be traded and whether trading in the security is subject to the
"Large Cap" limitation.  The response of the pre-clearance system as to
whether a security appears on the Restricted List and, if so, whether it
is eligible for the exceptions set forth after this Rule shall be final,
unless the employee appeals to the Code of Ethics Officer, using the
procedure described in Section VII, regarding the request to trade a
particular security.

A clearance is only valid for trading on the day it is obtained.  Trades
in securities listed on Asian or European stock exchanges, however, may
be executed within one business day after pre-clearance is obtained.

If a security is not on the Restricted List, other classes of securities
of the same issuer (e.g., preferred or convertible preferred stock) may
be on the Restricted List.  It is the employee's responsibility to
identify with particularity the class of securities for which permission
is being sought for a personal investment.

If the pre-clearance system does not recognize a security, or if an
employee is unable to use the system or has any questions with respect
to the system or pre-clearance, the employee may consult the Code of
Ethics Administrator.  The Code of Ethics Administrator shall not have
authority to answer any questions about a security other than whether
trading is permitted.  The response of the Code of Ethics Administrator
as to whether a security appears on the Restricted List and, if so,
whether it is eligible for the exceptions set forth after this Rule
shall be final, unless the employee appeals to the Code of Ethics
Officer, using the procedure described in Section VII, regarding the
request to trade a particular security.

C. Removal of Securities from Restricted List. Securities shall be removed
   from the Restricted List when: (a) in the case of securities on the
   Restricted List pursuant to Rule 1(a), they are no longer being purchased
   or sold for a Putnam client or actively considered for purchase or sale
   for a Putnam client; (b) in the case of securities on the Restricted List
   pursuant to Rule 1(b), the holdings of Putnam clients fall below the
   applicable threshold designated in that Rule, or at such earlier time as
   the Code of Ethics Officer deems appropriate; or (c) in the case of
   securities on the Restricted List pursuant to Rule 1(c) or 1(d), when
   circumstances no longer warrant restrictions on personal trading.

COMMENTS

1. Pre-Clearance. Subpart (a) of this Rule is designed to avoid the conflict
   of interest that might occur when an employee trades for his personal
   account a security that currently is being traded or is likely to be
   traded for a Putnam client. Such conflicts arise, for example, when the
   trades of an employee might have an impact on the price or availability
   of a particular security, or when the trades of the client might have an
   impact on price to the benefit of the employee. Thus, exceptions involve
   situations where the trade of a Putnam employee is unlikely to have an
   impact on the market.

2. Regulatory Limits. Owing to a variety of federal statutes and regulations
   in the banking, savings and loan, communications, and gaming industries, it
   is critical that accounts of Putnam clients not hold more than 10% of the
   voting securities of any issuer (5% for public utilities). Because of the
   risk that the personal holdings of Putnam employees may be aggregated with
   Putnam holdings for these purposes, subpart (b) of this Rule limits personal
   trades in these areas. The 7% limit (4% for public utilities) will allow the
   regulatory limits to be observed.

3. Options. For the purposes of this Code, options are treated like the
   underlying security. See Definitions. Thus, an employee may not purchase,
   sell, or "write" option contracts for a security that is on the Restricted
   List. A securities index will not be put on the Restricted List simply
   because one or more of its underlying securities have been put on the
   Restricted List.  The exercise of an options contract (the purchase or
   writing of which was previously pre-cleared) does not have to be
   pre-cleared.  Note, however, that the sale of securities obtained through
   the exercise of options must be pre-cleared.

4. Involuntary Transactions. "Involuntary" personal securities transactions
   are exempted from the Code. Special attention should be paid to this
   exemption. (See Section I.D.)

5. Tender Offers. This Rule does not prohibit an employee from tendering
   securities from his personal account in response to an any-and-all tender
   offer, even if Putnam clients are also tendering securities. A Putnam
   employee is, however, prohibited from tendering securities from his
   personal account in response to a partial tender offer, if Putnam clients
   are also tendering securities.

B. Prohibited Transactions


RULE 1

Putnam employees are prohibited from short selling any security, whether
or not the security is held in a Putnam client portfolio.

EXCEPTIONS

Short selling against broad market indexes (such as the Dow Jone
Industrial Average, the NASDAQ index and the S&P 100 and 500 indexes)
and short selling "against the box" are permitted.

RULE 2

No Putnam employee shall purchase any security for her personal account
in an initial public offering.

EXCEPTION

Pre-existing Status Exception. A Putnam employee shall not be barred by
this Rule or by Rule 1(a) of Section I.A. from purchasing securities for
her personal account in connection with an initial public offering of
securities by a bank or insurance company when the employee's status as
a policyholder or depositor entitles her to purchase securities on terms
more favorable than those available to the general public, in connection
with the bank's conversion from mutual or cooperative form to stock
form, or the insurance company's conversion from mutual to stock form,
provided that the employee has had the status entitling her to purchase
on favorable terms for at least two years. This exception is only
available with respect to the value of bank deposits or insurance
policies that an employee owns before the announcement of the initial
public offering. This exception does not apply, however, if the security
appears on the Restricted List in the circumstances set forth in
subparts (b), (c), or (d) of Section I.A., Rule 1.

IMPLEMENTATION

A. General Implementation. An employee shall inquire, before any purchase
   of a security for her personal account, whether the security to be
   purchased is being offered pursuant to an initial public offering. If
   the security is offered through an initial public offering, the employee
   shall refrain from purchasing that security for her personal account
   unless the exception applies.


B. Administration of Exception. If the employee believes the exception
   applies, she shall consult the Code of Ethics Administrator concerning
   whether the security appears on the Restricted List and if so, whether
   it is eligible for this exception.

COMMENTS

1. The purpose of this rule is twofold. First, it is designed to prevent a
   conflict of interest between Putnam employees and Putnam clients who
   might be in competition for the same securities in a limited public
   offering. Second, the rule is designed to prevent Putnam employees from
   being subject to undue influence as a result of receiving "favors" in
   the form of special allocations of securities in a public offering from
   broker-dealers who seek to do business with Putnam.

2. Purchases of securities in the immediate after-market of an initial
   public offering are not prohibited, provided they do not constitute
   violations of other portions of the Code of Ethics. For example,
   participation in the immediate after-market as a result of a special
   allocation from an underwriting group would be prohibited by Section III,
   Rule 3 concerning gifts and other "favors."

3. Public offerings subsequent to initial public offerings are not deemed
   to create the same potential for competition between Putnam employees
   and Putnam clients because of the pre-existence of a market for the
   securities.

RULE 3

No Putnam employee shall purchase any security for his personal account
in a limited private offering or private placement.

COMMENTS

1. The purpose of this Rule is to prevent a Putnam employee from investing
   in securities for his own account pursuant to a limited private offering
   that could compete with or disadvantage Putnam clients, and to prevent
   Putnam employees from being subject to efforts to curry favor by those
   who seek to do business with Putnam.

2. Exemptions to the prohibition will generally not be granted where the
   proposed investment relates directly or indirectly to investments by a
   Putnam client, or where individuals involved in the offering (including
   the issuers, broker, underwriter, placement agent, promoter, fellow
   investors and affiliates of the foregoing) have any prior or existing
   business relationship with Putnam or a Putnam employee, or where the
   Putnam employee believes that such individuals may expect to have a
   future business relationship with Putnam or a Putnam employee.

3. An exemption may be granted, subject to reviewing all the facts and
   circumstances, for investments in:

(a) Pooled investment funds, including hedge funds, subject to the condition
    that an employee investing in a pooled investment fund would have no
    involvement in the activities or decision-making process of the fund
    except for financial reports made in the ordinary course of the fund's
    business.

(b) Private placements where the investment cannot relate, or be expected
    to relate, directly or indirectly to Putnam or investments by a Putnam
    client.

4. Employees who apply for an exemption will be expected to disclose to the
   Code of Ethics Officer in writing all facts and relationships relating to
   the proposed investment.

5. Limited partnership interests are frequently sold in private placements.
   An employee should assume that investment in a limited partnership is
   barred by these rules, unless the employee has obtained, in advance of
   purchase, a written exemption under the ad hoc exemption set forth in
   Section I.D., Rule 2. The procedure for obtaining an ad hoc exemption is
   described in Section VII, Part 4.

6. Applications to invest in private placements will be reviewed by the Code
   of Ethics Oversight Committee. This review will take into account, among
   other factors, the considerations described in the preceding comments.

RULE 4

No Putnam employee shall purchase or sell any security for her personal
account or for any Putnam client account while in possession of
material, nonpublic information concerning the security or the issuer.

EXCEPTIONS

NONE. Please read Appendix A, Policy Statement Concerning Insider
Trading Prohibitions.

RULE 5

No Putnam employee shall purchase from or sell to a Putnam client any
securities or other property for his personal account, nor engage in any
personal transaction to which a Putnam client is known to be a party, or
which transaction may have a significant relationship to any action
taken by a Putnam client.

EXCEPTIONS

None.

IMPLEMENTATION

It shall be the responsibility of every Putnam employee to make inquiry
prior to any personal transaction sufficient to satisfy himself that the
requirements of this Rule have been met.

COMMENT

This rule is required by federal law. It does not prohibit a Putnam
employee from purchasing any shares of an open-end Putnam fund. The
policy with respect to employee trading in closed-end Putnam funds is
attached as Appendix B.

RULE 6

No Putnam employee shall engage in market timing strategies within
Putnam mutual funds, including within Putnam's Profit Sharing Retirement
Plan accounts and deferred compensation accounts.

EXCEPTIONS

None.

COMMENTS

"Market timing" occurs when a person frequently purchases and sells
shares of mutual funds based upon the activity of equity markets on the
days that the purchases and sales are effected.  Putnam has determined
that market timing has  a detrimental effect on the performance of the
mutual funds managed by Putnam, and Putnam has taken steps to reduce
instances of market timing by brokers and shareholders in the mutual
funds.  Putnam therefore expects that Putnam employees will avoid making
frequent trades into and out of the Putnam mutual funds, including
transactions made within Putnam's Profit Sharing Retirement Plan and
other deferred compensation vehicles.

C. Discouraged Transactions

RULE 1

Putnam employees are strongly discouraged from engaging in naked option
transactions for their personal accounts.

EXCEPTIONS

None.

COMMENT

Naked option transactions are particularly dangerous, because a Putnam
employee may be prevented by the restrictions in this Code of Ethics
from "covering" the naked option at the appropriate time. All employees
should keep in mind the limitations on their personal securities trading
imposed by this Code when contemplating such an investment strategy.
Engaging in naked options transactions on the basis of material,
nonpublic information is prohibited. See Appendix A, Policy Statement
Concerning Insider Trading Prohibitions.

RULE 2

Putnam employees are strongly discouraged from engaging in excessive
trading for their personal accounts.

EXCEPTIONS

None.

COMMENTS

1. Although a Putnam employee's excessive trading may not itself constitute
   a conflict of interest with Putnam clients, Putnam believes that its
   clients' confidence in Putnam will be enhanced and the likelihood of
   Putnam achieving better investment results for its clients over the
   long term will be increased if Putnam employees rely on their investment
   -- as opposed to trading -- skills in transactions for their own account.
   Moreover, excessive trading by a Putnam employee for his or her own
   account diverts an employee's attention from the responsibility of
   servicing Putnam clients, and increases the possibilities for transactions
   that are in actual or apparent conflict with Putnam client transactions.

2. Although this Rule does not define excessive trading, employees should
   be aware that if their trades exceed 10 trades per quarter the trading
   activity will be reviewed by the Code of Ethics Oversight Committee.

D. Exempted Transactions

RULE 1

Transactions which are involuntary on the part of a Putnam employee are
exempt from the prohibitions set forth in Sections I.A., I.B., and I.C.

EXCEPTIONS

None.

COMMENTS

1. This exemption is based on categories of conduct that the Securities and
   Exchange Commission does not consider "abusive."

2. Examples of involuntary personal securities transactions include:

(a) sales out of the brokerage account of a Putnam employee as a result
    of bona fide margin call, provided that withdrawal of collateral by the
    Putnam employee within the ten days previous to the margin call was not
    a contributing factor to the margin call;

(b) purchases arising out of an automatic dividend reinvestment program of
    an issuer of a publicly traded security.

3. Transactions by a trust in which the Putnam employee (or a member of
his immediate family) holds a beneficial interest, but for which the
employee has no direct or indirect influence or control with respect to
the selection of investments, are involuntary transactions. In addition,
these transactions do not fall within the definition of "personal
securities transactions." See Definitions.

4. A good-faith belief on the part of the employee that a transaction
was involuntary will not be a defense to a violation of the Code of
Ethics. In the event of confusion as to whether a particular transaction
is involuntary, the burden is on the employee to seek a prior written
determination of the applicability of this exemption. The procedures for
obtaining such a determination appear in Section VII, Part 3.

RULE 2

Transactions which have been determined in writing by the Code of Ethics
Officer before the transaction occurs to be no more than remotely
potentially harmful to Putnam clients because the transaction would be
very unlikely to affect a highly institutional market, or because the
transaction is clearly not related economically to the securities to be
purchased, sold, or held by a Putnam client, are exempt from the
prohibitions set forth in Sections I.A., I.B., and I.C.

EXCEPTIONS

N.A.

IMPLEMENTATION

An employee may seek an ad hoc exemption under this Rule by following
the procedures in Section VII, Part 4.

COMMENTS

1. This exemption is also based upon categories of conduct that the
   Securities and Exchange Commission does not consider "abusive."

2. The burden is on the employee to seek a prior written determination
   that the proposed transaction meets the standards for an ad hoc
   exemption set forth in this Rule.


* Section II. Additional Special Rules for Personal Securities
              Transactions of Access Persons and Certain Investment
              Professionals

Access Persons (including all Investment Professionals and other employees
as defined on page ix)

RULE 1 ("60-DAY" RULE)

No Access Person shall purchase and then sell at a profit, or sell and
then repurchase at a lower price, any security or related derivative
security within 60 calendar days.

EXCEPTIONS

None, unless prior written approval from the Code of Ethics Officer is
obtained. Exceptions may be granted on a case-by-case basis when no
abuse is involved and the equities of the situation support an
exemption. For example, although an Access Person may buy a stock as a
long-term investment, that stock may have to be sold involuntarily due
to unforeseen activity such as a merger.

IMPLEMENTATION

1. The 60-Day Rule applies to all Access Persons, as defined in the
   Definitions section of the Code.

2. Calculation of whether there has been a profit is based upon the
   market prices of the securities.  The calculation is not net of
   commissions or other sales charges.

3. As an example, an Access Person would not be permitted to sell a
   security at $12 that he purchased within the prior 60 days for $10.
   Similarly, an Access Person would not be permitted to purchase a
   security at $10 that she had sold within the prior 60 days for $12.
   If the proposed transaction would be made at a loss, it would be
   permitted if the pre-clearance requirements are met. See, Section I,
   Rule 1.

COMMENTS

1. The prohibition against short-term trading profits by Access Persons
   is designed to minimize the possibility that they will capitalize
   inappropriately on the market impact of trades involving a client
   portfolio about which they might possibly have information.

2. Although Chief Investment Officers, Portfolio Managers, and Analysts
   may sell securities at a profit within 60 days of purchase in order to
   comply with the requirements of the 7-Day Rule applicable to them
   (described below), the profit will have to be disgorged to charity
   under the terms of the 7-Day Rule.

3. Access Persons occasionally make a series of transactions in securities
   over extended periods of time. For example, an Access Person bought
   100 shares of Stock X on Day 1 at $100 per share and then bought 50
   additional shares on Day 45 at $95 per share. On Day 75, the Access
   Person sold 20 shares at $105 per share. The question arises whether
   the Access Person violated the 60-Day Rule. The characterization of
   the employee's tax basis in the shares sold determines the analysis.
   If, for personal income tax purposes, the Access Person characterizes
   the shares sold as having a basis of $100 per share (i.e., shares
   purchased on Day 1), the transaction would be consistent with the 60-Day
   Rule. However, if the tax basis in the shares is $95 per share (i.e.,
   shares purchased on Day 45), the transaction would violate the 60-Day Rule.

Certain Investment Professionals

RULE 2 ("7-DAY" RULE)

(a) Portfolio Managers: Before a portfolio manager (including a Chief
Investment Officer with respect to an account he manages) places an
order to buy a security for any Putnam client portfolio that he manages,
he shall sell any such security or related derivative security purchased
in a transaction for his personal account within the preceding seven
calendar days.

(b) Co-Managers: Before a portfolio manager places an order to buy a
security for any Putnam client he manages, his co-manager shall sell any
such security or related derivative security purchased in transaction
for his personal account within the preceding seven calendar days.

(c) Analysts: Before an analyst makes a buy recommendation for a
security (including designation of a security for inclusion in the
portfolio of the Putnam Research Fund), he shall sell any such security
or related derivative security purchased in a transaction for his
personal account within the preceding seven calendar days.

EXCEPTIONS

None.

COMMENTS

1. This Rule applies to portfolio managers (including Chief Investment
Officers with respect to accounts they manage) in connection with any
purchase (no matter how small) in any client account managed by that
portfolio manager or CIO (even so-called "clone accounts").  In
particular, it should be noted that the requirements of this rule also
apply with respect to purchases in client accounts, including "clone
accounts," resulting from "cash flows."  To comply with the requirements
of this rule, it is the responsibility of each portfolio manager or CIO
to be aware of the placement of all orders for purchases of a security
by client accounts that he or she manages for 7 days following the
purchase of that security for his or her personal account.

2. An investment professional who must sell securities to be in
compliance with the   7-Day Rule must absorb any loss and disgorge to
charity any profit resulting from the sale.

3. This Rule is designed to avoid even the appearance of a conflict of
interest between an investment professional and a Putnam client. A more
stringent rule is warranted because, with their greater knowledge and
control, these investment professionals are in a better position than
other employees to create an appearance of manipulation of Putnam client
accounts for personal benefit.

4. "Portfolio manager" is used in this Section as a functional label,
and is intended to cover any employee with authority to authorize a
trade on behalf of a Putnam client, whether or not such employee bears
the title "portfolio manager." "Analyst" is also used in this Section as
a functional label, and is intended to cover any employee who is not a
portfolio manager but who may make recommendations regarding investments
for Putnam clients.

RULE 3 ("BLACKOUT RULE")

(a) Portfolio Managers: No portfolio manager (including a Chief
Investment Officer with respect to an account she manages) shall: (i)
sell any security or related derivative security for her personal
account until seven calendar days have elapsed since the most recent
purchase of that security or related derivative security by any Putnam
client portfolio she manages or co-manages; or (ii) purchase any
security or related derivative security for her personal account until
seven calendar days have elapsed since the most recent sale of that
security or related derivative security from any Putnam client portfolio
that she manages or co-manages.

(b) Analysts: No analyst shall: (i) sell any security or related
derivative security for his personal account until seven calendar days
have elapsed since his most recent buy recommendation for that security
or related derivative security (including designation of a security for
inclusion in the portfolio of the Putnam Research Fund); or (ii)
purchase any security or related derivative security for his personal
account until seven calendar days have elapsed since his most recent
sell recommendation for that security or related derivative security
(including the removal of a security from the portfolio of the Putnam
Research Fund).

EXCEPTIONS

None.

COMMENTS

1. This Rule applies to portfolio managers (including Chief Investment
Officers with respect to accounts they manage) in connection with to any
transaction (no matter how small) in any client account managed by that
portfolio manager or CIO (even so-called "clone accounts").  In
particular, it should be noted that the requirements of this rule also
apply with respect to transactions in client accounts, including "clone
accounts," resulting from "cash flows."  In order to comply with the
requirements of this rule, it is the responsibility of each portfolio
manager and CIO to be aware of all transactions in a security by client
accounts that he or she manages that took place within the 7 days
preceding a transaction in that security for his or her personal
account.

2. This Rule is designed to prevent a Putnam portfolio manager or
analyst from engaging in personal investment conduct that appears to be
counter to the investment strategy she is pursuing or recommending on
behalf of a Putnam client.

3. Trades by a Putnam portfolio manager for her personal account in the
"same direction" as the Putnam client portfolio she manages, and trades
by an analyst for his personal account in the "same direction" as his
recommendation, do not present the same danger, so long as any "same
direction" trades do not violate other provisions of the Code or the
Policy Statements.

RULE 4 ("CONTRA TRADING" RULE)

(a) Portfolio Managers: No portfolio manager shall, without prior
clearance, sell out of his personal account securities or related
derivative securities held in any Putnam client portfolio that he
manages or co-manages.

(b) Chief Investment Officers: No Chief Investment Officer shall,
without prior clearance, sell out of his personal account securities or
related derivative securities held in any Putnam client portfolio
managed in his investment group.

EXCEPTIONS

None, unless prior clearance is given.

IMPLEMENTATION

A. Individuals Authorized to Give Approval. Prior to engaging in any
   such sale, a portfolio manager shall seek approval, in writing, of the
   proposed sale. In the case of a portfolio manager or director, prior
   written approval of the proposed sale shall be obtained from a Chief
   Investment Officer to whom he reports or, in his absence, another Chief
   Investment Officer. In the case of a Chief Investment Officer, prior
   written approval of the proposed sale shall be obtained from another
   Chief Investment Officer. In addition to the foregoing, prior written
   approval must also be obtained from the Code of Ethics Officer.

B. Contents of Written Approval. In every instance, the written approval
   form attached as Appendix C (or such other form as the Code of Ethics
   Officer shall designate) shall be used. The written approval should be
   signed by the Chief Investment Officer giving approval and dated the
   date such approval was given, and shall state, briefly, the reasons why
   the trade was allowed and why the investment conduct pursued by the
   portfolio manager, director, or chief investment officer was deemed
   inappropriate for the Putnam client account controlled by the individual
   seeking to engage in the transaction for his personal account. Such
   written approval shall be sent by the Chief Investment Officer approving
   the transaction to the Code of Ethics Officer within twenty-four hours
   or as promptly as circumstances permit. Approvals obtained after a
   transaction has been completed or while it is in process will not
   satisfy the requirements of this Rule.

COMMENT

This Rule, like Rule 3 of this Section, is designed to prevent a Putnam
portfolio manager from engaging in personal investment conduct that
appears to be counter to the investment strategy that he is pursuing on
behalf of a Putnam client.

RULE 5

No portfolio manager shall cause, and no analyst shall recommend, a
Putnam client to take action for the portfolio manager's or analyst's
own personal benefit.

EXCEPTIONS

None.

COMMENTS

1. A portfolio manager who trades in, or an analyst who recommends,
   particular securities for a Putnam client account in order to support
   the price of securities in his personal account, or who "front runs" a
   Putnam client order is in violation of this Rule. Portfolio managers
   and analysts should be aware that this Rule is not limited to personal
   transactions in securities (as that word is defined in "Definitions").
   Thus, a portfolio manager or analyst who "front runs" a Putnam client
   purchase or sale of obligations of the U.S. government is in violation
   of this Rule, although U.S. government obligations are excluded from
   the definition of "security."

2. This Rule is not limited to instances when a portfolio manager or
   analyst has malicious intent. It also prohibits conduct that creates an
   appearance of impropriety. Portfolio managers and analysts who have
   questions about whether proposed conduct creates an appearance of
   impropriety should seek a prior written determination from the Code of
   Ethics Officer, using the procedures described in Section VII, Part 3.


* Section III.   Prohibited Conduct for All Employees

RULE 1

All employees must comply with applicable laws and regulations as well
as company policies. This includes tax, antitrust, political
contribution, and international boycott  laws.  In addition, no employee
at Putnam may engage in fraudulent conduct of any kind.

EXCEPTIONS

None.

COMMENTS

1. Putnam may report to the appropriate legal authorities conduct by
   Putnam employees that violates this rule.

2. It should also be noted that the U.S. Foreign Corrupt Practices Act
   makes it a criminal offense to make a payment or offer of payment to
   any non-U.S. governmental official, political party, or candidate to
   induce that person to affect any governmental act or decision, or to
   assist Putnam's obtaining or retaining business.

RULE 2

No Putnam employee shall conduct herself in a manner which is contrary
to the interests of, or in competition with, Putnam or a Putnam client,
or which creates an actual or apparent conflict of interest with a
Putnam client.

EXCEPTIONS

None.

COMMENTS

1. This Rule is designed to recognize the fundamental principle that Putnam
   employees owe their chief duty and loyalty to Putnam and Putnam clients.

2. It is expected that a Putnam employee who becomes aware of an investment
   opportunity that she believes is suitable for a Putnam client who she
   services will present it to the appropriate portfolio manager, prior to
   taking advantage of the opportunity herself.

RULE 3

No Putnam employee shall seek or accept gifts, favors, preferential
treatment, or special arrangements of material value from any
broker-dealer, investment adviser, financial institution, corporation,
or other entity, or from any existing or prospective supplier of goods
or services to Putnam or Putnam Funds. Specifically, any gift over $100
in value, or any accumulation of gifts which in aggregate exceeds $100
in value from one source in one calendar year, is prohibited. Any Putnam
employee who is offered or receives an item prohibited by this Rule must
report the details in writing to the Code of Ethics Officer.

EXCEPTIONS

None.

COMMENTS

1. This rule is intended to permit only proper types of customary business
   amenities. Listed below are examples of items that would be permitted
   under proper circumstances and of items that are prohibited under this
   rule. These examples are illustrative and not all-inclusive.
   Notwithstanding these examples, a Putnam employee may not, under any
   circumstances, accept anything that could create the appearance of any
   kind of conflict of interest. For example, acceptance of any
   consideration is prohibited if it would create the appearance of a
   "reward" or inducement for conducting Putnam business either with the
   person providing the gift or his employer.

2. This rule also applies to gifts or "favors" of material value that an
   investment professional may receive from a company or other entity being
   researched or considered as a possible investment for a Putnam client
   account.

3. Among items not considered of "material value" which, under proper
   circumstances, would be considered permissible are:

(a) Occasional lunches or dinners conducted for business purposes;

(b) Occasional cocktail parties or similar social gatherings conducted for
    business purposes;

(c) Occasional attendance at theater, sporting or other entertainment events
    conducted for business purposes; and

(d) Small gifts, usually in the nature of reminder advertising, such as pens,
    calendars, etc., with a value of no more than $100.

4. Among items which are considered of "material value" and which are
   prohibited are:

(a) Entertainment of a recurring nature such as sporting events, theater,
    golf games, etc.;

(b) The cost of transportation to a locality outside the Boston metropolitan
    area, and lodging while in another locality, unless such attendance and
    reimbursement arrangements have received advance written approval of the
    Code of Ethics Officer;

(c) Personal loans to a Putnam employee on terms more favorable than those
    generally available for comparable credit standing and collateral; and

(d) Preferential brokerage or underwriting commissions or spreads or
    allocations of shares or interests in an investment for the personal
    account of a Putnam employee.

5. As with any of the provisions of the Code of Ethics, a sincere belief by
   the employee that he was acting in accordance with the requirements of
   this Rule will not satisfy his obligations under the Rule. Therefore, an
   employee who is in doubt concerning the propriety of any gift or "favor"
   should seek a prior written determination from the Code of Ethics Officer,
   as provided in Part 3 of Section VII.

RULE 4

No Putnam employee may pay, offer, or commit to pay any amount of
consideration which might be or appear to be a bribe or kickback in
connection with Putnam's business.

EXCEPTIONS

None.

COMMENT

Although the rule does not specifically address political contributions,
Putnam employees should be aware that it is against corporate policy to
use company assets to fund political contributions of any sort, even
where such contributions may be legal. No Putnam employee should offer
or agree to make any political contributions (including political
dinners and similar fund-raisers) on behalf of Putnam, and no employee
will be reimbursed by Putnam for such contributions made by the employee
personally.

RULE 5

No contributions may be made with corporate funds to any political party
or campaign, whether directly or by reimbursement to an employee for the
expense of such a contribution. No Putnam employee shall solicit any
charitable, political or other contributions using Putnam letterhead or
making reference to Putnam in the solicitation. No Putnam employee shall
personally solicit any such contribution while on Putnam business.

EXCEPTIONS

None.

COMMENT

1. Putnam has established a political action committee (PAC) that contributes
   to worthy candidates for political office. Any request received by a
   Putnam employee for a political contribution must be directed to Putnam's
   Legal and Compliance Department.

2. This rule does not prohibit solicitation on personal letterhead by Putnam
   employees. Nonetheless, Putnam employees should use discretion in
   soliciting contributions from individuals or entities who provide services
   to Putnam. There should never be a suggestion that any service provider
   must contribute to keep Putnam's business.

RULE 6

No unauthorized disclosure may be made by any employee or former
employee of any trade secrets or proprietary information of Putnam or of
any confidential information. No information regarding any Putnam client
portfolio, actual or proposed securities trading activities of any
Putnam client, or Putnam research shall be disclosed outside the Putnam
organization without a valid business purpose.

EXCEPTIONS

None.

COMMENT

All information about Putnam and Putnam clients is strictly
confidential. Putnam research information should not be disclosed
unnecessarily and never for personal gain.

RULE 7

No Putnam employee shall serve as officer, employee, director, trustee
or general partner of a corporation or entity other than Putnam, without
prior approval of the Code of Ethics Officer.

EXCEPTION

Charitable or Non-profit Exception. This Rule shall not prevent any
Putnam employee from serving as officer, director, or trustee of a
charitable or not-for-profit institution, provided that the employee
abides by the spirit of the Code of Ethics and the Policy Statements
with respect to any investment activity for which she has any discretion
or input as officer, director, or trustee.  The pre-clearance and
reporting requirements of the Code of Ethics do not apply to the trading
activities of such charitable or not-for-profit institutions for which
an employee serves as an officer, director, or trustee.

COMMENTS

1. This Rule is designed to ensure that Putnam cannot be deemed an affiliate
   of any issuer of securities by virtue of service by one of its officers
   or employees as director or trustee.

2. Certain charitable or not-for-profit institutions have assets (such as
   endowment funds or employee benefit plans) which require prudent
   investment. To the extent that a Putnam employee (because of her position
   as officer, director, or trustee of an outside entity) is charged with
   responsibility to invest such assets prudently, she may not be able to
   discharge that duty while simultaneously abiding by the spirit of the
   Code of Ethics and the Policy Statements. Employees are cautioned that
   they should not accept service as an officer, director, or trustee of an
   outside charitable or not-for-profit entity where such investment
   responsibility is involved, without seriously considering their ability
   to discharge their fiduciary duties with respect to such investments.

RULE 8

No Putnam employee shall serve as a trustee, executor, custodian, any
other fiduciary, or as an investment adviser or counselor for any
account outside Putnam.

EXCEPTIONS

Charitable or Religious Exception. This Rule shall not prevent any
Putnam employee from serving as fiduciary with respect to a religious or
charitable trust or foundation, so long as the employee abides by the
spirit of the Code of Ethics and the Policy Statements with respect to
any investment activity over which he has any discretion or input.  The
pre-clearance and reporting requirements of the Code of Ethics do not
apply to the trading activities of such a religious or charitable trust
or foundation.

Family Trust or Estate Exception.  This Rule shall not prevent any
Putnam employee from serving as fiduciary with respect to a family trust
or estate, so long as the employee abides by all of the Rules of the
Code of Ethics with respect to any investment activity over which he has
any discretion.

COMMENT

The roles permissible under this Rule may carry with them the obligation
to invest assets prudently. Once again, Putnam employees are cautioned
that they may not be able to fulfill their duties in that respect while
abiding by the Code of Ethics and the Policy Statements.

RULE 9

No Putnam employee may be a member of any investment club.

EXCEPTIONS

None.

COMMENT

This Rule guards against the danger that a Putnam employee may be in
violation of the Code of Ethics and the Policy Statements by virtue of
his personal securities transactions in or through an entity that is not
bound by the restrictions imposed by this Code of Ethics and the Policy
Statements.  Please note that this restriction also applies to the
spouse of a Putnam employee and any relatives of a Putnam employee
living in the same household as the employee, as their transactions are
covered by the Code of Ethics (see page x).

RULE 10

No Putnam employee may become involved in a personal capacity in
consultations or negotiations for corporate financing, acquisitions or
other transactions for outside companies (whether or not held by any
Putnam client), nor negotiate nor accept a fee in connection with these
activities without obtaining the prior written permission of the
president of Putnam Investments.

EXCEPTIONS

None.

RULE 11

No new types of securities or instruments may be purchased for a Putnam
fund or other client account without following the procedures set forth
in Appendix D.

EXCEPTIONS

None.

COMMENT

See Appendix D.

RULE 12

No employee may create or participate in the creation of any record that
is intended to mislead anyone or to conceal anything that is improper.
In addition, all employees responsible for the preparation, filing, or
distribution of any regulatory filings or public communications must
ensure that such filings or communications are timely, complete, fair,
accurate, and understandable.

EXCEPTIONS

None.

COMMENTS

1. In many cases, this is not only a matter of company policy and ethical
   behavior but also required by law. Our books and records must accurately
   reflect the transactions represented and their true nature. For example,
   records must be accurate as to the recipient of all payments; expense
   items, including personal expense reports, must accurately reflect the
   true nature of the expense. No unrecorded fund or asset shall be
   established or maintained for any reason.

2. All financial books and records must be prepared and maintained in
   accordance with Generally Accepted Accounting Principles and Putnam's
   existing accounting controls, to the extent applicable.

RULE 13

No employee should have any direct or indirect (including by a family
member or close relative) personal financial interest (other than normal
investments not material to the employee in the entity's publicly traded
securities) in any business, with which Putnam has dealings unless such
interest is disclosed and approved by the Code of Ethics Officer.

RULE 14

No employee shall, with respect to any affiliate of Putnam that provides
investment advisory services and is listed below in Comment 4 to this
Rule, as revised from time to time (each an "NPA"),

(a) directly or indirectly seek to influence the purchase, retention, or
disposition of, or exercise of voting, consent, approval or similar
rights with respect to, any portfolio security in any account or fund
advised by the NPA and not by Putnam,

(b) transmit any information regarding the purchase, retention or
disposition of, or exercise of voting, consent, approval or similar
rights with respect to, any portfolio security held in a Putnam or NPA
client account to any personnel of the NPA,

(c) transmit any trade secrets, proprietary information, or confidential
information of Putnam to the NPA without a valid business purpose,

(d) use confidential information or trade secrets of the NPA for the
benefit of the employee, Putnam, or any other NPA, or

(e) breach any duty of loyalty to the NPA by virtue of service as a
director or officer of the NPA.

COMMENTS

1. Sections (a) and (b) of the Rule are designed to help ensure that the
   portfolio holdings of Putnam clients and clients of the NPA need not be
   aggregated for purposes of determining beneficial ownership under
   Section 13(d) of the Securities Exchange Act or applicable regulatory
   or contractual investment restrictions that incorporate such definition
   of beneficial ownership. Persons who serve as directors or officers of
   both Putnam and an NPA would take care to avoid even inadvertent
   violations of Section (b). Section (a) does not prohibit a Putnam
   employee who serves as a director or officer of the NPA from seeking
   to influence the modification or termination of a particular investment
   product or strategy in a manner that is not directed at any specific
   securities. Sections (a) and (b) do not apply when a Putnam affiliate
   serves as an adviser or subadviser to the NPA or one of its products,
   in which case normal Putnam aggregation rules apply.

2. As a separate entity, any NPA may have trade secrets or confidential
   information that it would not choose to share with Putnam. This choice
   must be respected.

3. When Putnam employees serve as directors or officers of an NPA, they are
   subject to common law duties of loyalty to the NPA, despite their Putnam
   employment. In general, this means that when performing their duties as
   NPA directors or officers, they must act in the best interest of the NPA
   and its shareholders. Putnam's Legal and Compliance Department will assist
   any Putnam employee who is a director or officer of an NPA and has
   questions about the scope of his or her responsibilities to the NPA.

4. Entities that are currently non-Putnam affiliates within the scope of this
   Rule are: Cisalpina Gestioni, S.p.A., PanAgora Asset Management Inc.,
   PanAgora Asset Management Ltd., Nissay Asset Management Co., Ltd.,
   Thomas H. Lee Partners, L.P., Ampega Asset Management, GMBH, and Sceptre
   Investment Counsel, Ltd.

RULE 15

No employee shall use computer hardware, software, data, Internet,
electronic mail, voice mail, electronic messaging ("e-mail" or "cc:
Mail"), or telephone communications systems in a manner that is
inconsistent with their use as set forth in policy statements governing
their use that are adopted from time to time by Putnam. No employee
shall introduce a computer "virus" or computer code that may result in
damage to Putnam's information or computer systems.

EXCEPTIONS

None.

COMMENT

Putnam's policy statements relating to these matters are contained in
the "Computer System and Network Responsibilities" section of the
"Employment Issues" category within the Employee Handbook.  The on-line
Employee Handbook is located in the Putnam ibenefitcenter
(https://www.ibenefitcenter.com) at the "Policies and Procedures"
section of the "Workplace Community" tab.

RULE 16

All employees must follow and abide by the spirit of the Code of Ethics
and the Standards of Professional Conduct of the Association of
Investment Management and Research (AIMR).  The texts of the AIMR Code
of Ethics and Standards of Professional Conduct are set forth in Exhibit
E.

RULE 17

Except as provided below, no employee may disclose to any outside
organization or person any non-public personal information about any
individual who is a current or former shareholder of any Putnam retail
or institutional fund, or current or former client of a Putnam company.
All employees shall follow the security procedures as established from
time to time by a Putnam company to protect the confidentiality of all
shareholder and client account information.

Except as Putnam's Legal and Compliance Department may expressly
authorize, no employee shall collect any non-public personal information
about a prospective or current shareholder of a Putnam Fund or
prospective or current client of a Putnam company, other than through an
account application (or corresponding information provided by the
shareholder's financial representative) or in connection with executing
shareholder or client transactions, nor shall any information be
collected other than the following:  name, address, telephone number,
social security number, and investment, broker, and transaction
information.

EXCEPTIONS

Putnam Employees.  Non-public personal information may be disclosed to
Putnam employees in connection with processing transactions or
maintaining accounts for shareholders of a Putnam fund and clients of a
Putnam company, to the extent that access to such information is
necessary to the performance of that employee's job functions.

Shareholder Consent Exception.  Non-public personal information about a
shareholder's or client's account may be provided to a non-Putnam
organization at the specific request of the shareholder or client or
with the shareholder's or client's prior written consent.

Broker or Adviser Exception.  Non-public personal information about a
shareholder's or client's account may be provided to the shareholder's
or client's broker of record.

Third Party Service Provider Exception.  Non-public personal information
may be disclosed to a service provider that is not affiliated with a
Putnam fund or Putnam company only when such disclosure is necessary for
the service provider to perform the specific services contracted for,
and only (a) if the service provider executes Putnam's standard
confidentiality agreement, or (b) pursuant to an agreement containing a
confidentiality provision that has been approved by the Legal and
Compliance Department.  Examples of such service providers include proxy
solicitors and proxy vote tabulators, mail services and providers of
other administrative services, and Information Services Division
consultants who have access to non-public personal information.

COMMENTS

1. Non-public personal information is any information that personally
   identifies a shareholder of a Putnam fund or client of a Putnam company
   and is not derived from publicly available sources.  This privacy policy
   applies to shareholders or clients that are individuals, not institutions.
   However, as a general matter, all information that we receive about a
   shareholder of a Putnam fund or client of a Putnam company shall be
   treated as confidential.  No employee may sell or otherwise provide
   shareholder or client lists or any other information relating to a
   shareholder or client to any marketing organization.2.   All Putnam
   employees with access to shareholder or client account information must
   be trained in and follow Putnam's security procedures designed to
   safeguard that information from unauthorized use.  For example, a
   telephone representative must be trained in and follow Putnam's security
   procedures to verify the identity of a caller requesting account
   information.

3. Any questions regarding this privacy policy should be directed to Putnam's
   Legal and Compliance Department.  A violation of this policy will be subject
   to the sanctions imposed for violations of Putnam's Code of Ethics.

4. Employees must report any violation of this policy or any possible breach
   of the confidentiality of client information (whether intentional or
   accidental) to the Managing Director in charge of the employee's business
   unit.  Managing Directors who are notified of such a violation or possible
   breach must immediately report it in writing to Putnam's General Counsel
   and, in the event of a breach of computerized data, Putnam's Chief
   Technology Officer.

RULE 18

No employee may engage in any money laundering activity or facilitate
any money-laundering activity through the use of any Putnam account or
client account.  Any situations giving rise to a suspicion that
attempted money laundering may be occurring in any account must be
reported immediately to the Managing Director in charge of the
employee's business unit.  Managing Directors who are notified of such a
suspicion of money laundering activity must immediately report it in
writing to Putnam's General Counsel and Chief Financial Officer.

RULE 19

All employees must comply with the record retention requirements
applicable to the business unit.

COMMENT

Employees should check with their managers or the Chief Administrative
Officer of their division to determine what record retention
requirements apply to their business unit.


* Section IV.   Special Rules for Officers and Employees of Putnam
                Investments Limited
RULE 1

In situations subject to Section I.A., Rule 1 (Restricted List Personal
Securities Transactions), the Putnam Investments Limited. ("PIL") employee
must obtain clearance not only as provided in that rule, but also from PIL's
Compliance Officer or her designee, who must approve the transaction before
any trade is placed and record the approval.

EXCEPTIONS

None.

IMPLEMENTATION

Putnam's Code of Ethics Administrator in Boston (the "Boston
Administrator") has also been designated the Assistant Compliance
Officer of PIL and has been delegated the right to approve or disapprove
personal securities transactions in accordance with the foregoing
requirement. Therefore, approval from the Code of Ethics Administrator
for PIL employees to make personal securities investments constitutes
approval under the Code of Ethics and also for purposes of compliance
with IMRO, the U.K. self-regulatory organization that regulates PIL.

The position of London Code of Ethics Administrator (the "London
Administrator") has also been created (Jane Barlow is the current London
Administrator). All requests for clearances must be made by e-mail to
the Boston Administrator copying the London Administrator. The e-mail
must include the number of shares to be bought or sold and the name of
the broker(s) involved. Where time is of the essence clearances can be
made by telephone to the Boston Administrator but they must be followed
up by e-mail.

Both the Boston and London Administrators will maintain copies of all
clearances for inspection by senior management and regulators.

RULE 2

No PIL employee may trade with any broker or dealer unless that broker
or dealer has sent a letter to the London Administrator agreeing to
deliver copies of trade confirmations to PIL. No PIL employee may enter
into any margin or any other special dealing arrangement with any
broker-dealer without the prior written consent of the PIL Compliance
Officer.

EXCEPTIONS

None.

IMPLEMENTATION

PIL employees will be notified separately of this requirement once a
year by the PIL Compliance Officer, and are required to provide an
annual certification of compliance with the Rule.

All PIL employees must inform the London Administrator of the names of
all brokers and dealers with whom they trade prior to trading. The
London Administrator will send a letter to the broker(s) in question
requesting them to agree to deliver copies of confirms to PIL. The
London Administrator will forward copies of the confirms to the Boston
Administrator. PIL employees may trade with a broker only when the
London Administrator has received the signed agreement from that broker.

RULE 3

For purposes of the Code of Ethics, including Putnam's Policy Statement
on Insider Trading Prohibitions, PIL employees must also comply with
Part V of the Criminal Justice Act 1993 on insider dealing.

EXCEPTIONS

None.

IMPLEMENTATION

To ensure compliance with U.K. insider dealing legislation, PIL
employees must observe the relevant procedures set forth in PIL's
Compliance Manual, a copy of which is sent to each PIL employee, and
sign an annual certification as to compliance.


* Section V.   Reporting Requirements for All Employees

Reporting of Personal Securities Transactions

RULE 1

Each Putnam employee shall ensure that broker-dealers send all
confirmations of securities transactions for his personal accounts to
the Code of Ethics Officer. (For the purpose of this Rule, "securities"
shall include securities of The Marsh & McLennan Companies, Inc., and
any option on a security or securities index, including broad-based
market indexes.)

EXCEPTIONS

None.

IMPLEMENTATION

1. Putnam employees must instruct their broker-dealers to send
   confirmations to Putnam and must follow up with the broker-dealer
   on a reasonable basis to ensure that the instructions are being
   followed. Putnam employees should contact the Code of Ethics
   Administrator to obtain a letter from Putnam authorizing the setting
   up of a personal brokerage account. Confirmations should be submitted
   to the Code of Ethics Administrator. (Specific procedures apply to
   employees of Putnam Investments Limited ("PIL"). Employees of PIL
   should contact the London Code of Ethics Administrator.) Failure of a
   broker-dealer to comply with the instructions of a Putnam employee to
   send confirmations shall be a violation by the Putnam employee of this
   Rule.

COMMENTS

1. "Transactions for personal accounts" is defined broadly to include more
   than transaction in accounts under an employee's own name. See Definitions.

2. A confirmation is required for all personal securities transactions,
   whether or not exempted or excepted by this Code.

3. To the extent that a Putnam employee has investment authority over
   securities transactions of a family trust or estate, confirmations of
   those transactions must also be made, unless the employee has received a
   prior written exception from the Code of Ethics Officer.

RULE 2

Every Access Person shall file a quarterly report, within ten calendar
days of the end of each quarter, recording all purchases and sales of
any securities for personal accounts as defined in the Definitions. (For
the purpose of this Rule, "securities" shall include any option on a
security or securities index, including broad-based market indexes.)

EXCEPTIONS

None.

IMPLEMENTATION

All employees required to file such a report will receive by e-mail a
blank form at the end of the quarter from the Code of Ethics
Administrator. The form will specify the information to be reported. The
form shall also contain a representation that employees have complied
fully with all provisions of the Code of Ethics.

COMMENT

1. The date for each transaction required to be disclosed in the quarterly
   report is the trade date for the transaction, not the settlement date.

2. If the requirement to file a quarterly report applies to you and you
   fail to report within the required 10-day period, salary increases and
   bonuses will be reduced in accordance with guidelines stated in the form.

Reporting of Personal Securities Holdings

RULE 3

Access Persons must disclose all personal securities holdings to the
Code of Ethics Officer upon commencement of employment and thereafter on
an annual basis.

EXCEPTIONS

None.

COMMENT

These requirements are mandated by SEC regulations and are designed to
facilitate the monitoring of personal securities transactions.  Putnam's
Code of Ethics Administrator will provide Access Persons with the form
for making these reports and the specific information that must be
disclosed at the time that the disclosure is required.

Other Reporting Policies

The following rules are designed to ensure that Putnam's internal
Control and Reporting professionals are aware of all items that might
need to be addressed by Putnam or reported to appropriate entities.

RULE 4

If a Putnam employee suspects that fraudulent or other irregular
activity might be occurring at Putnam, the activity must be reported
immediately to the Managing Director in charge of that employee's
business unit.  Managing Directors who are notified of any such activity
must immediately report it in writing to Putnam's Chief Financial
Officer or Putnam's General Counsel.


RULE 5

Putnam employees must report all communications from regulatory or
government agencies (federal, state, or local) to the Managing Director
in charge of their business unit.  Managing Directors who are notified
of any such communication must immediately report it in writing to
Putnam's Chief Financial Officer or Putnam's General Counsel.

RULE 6

All claims, circumstances or situations that could give rise to a claim
against Putnam that come to the attention of a Putnam employee must be
reported through the employee's management structure up to the Managing
Director in charge of the employee's business unit.  Managing Directors
who are notified of any such claim, circumstance or situation that might
give rise to a claim against Putnam for more than $100,000 must
immediately report in writing it to Putnam's Chief Financial Officer or
Putnam's General Counsel.

RULE 7

All possible violations of law or regulations at Putnam that come to the
attention of a Putnam employee must be reported immediately to the
Managing Director in charge of the employee's business unit.  Managing
Directors who are notified of any such activity must immediately report
it in writing to Putnam's Chief Financial Officer or Putnam's General
Counsel.

RULE 8

Putnam employees must report all requests by anyone for Putnam to
participate in or cooperate with an international boycott to the
Managing Director in charge of their business unit.  Managing Directors
who are notified of any such request must immediately report it in
writing to Putnam's Chief Financial Officer or Putnam's General Counsel.

RULE 9

If a Putnam employee believes that there has been a violation of any of
the rules of the Code of Ethics, that employee must promptly notify the
Code of Ethics Officer, Bill Woolverton, or the Deputy Code of Ethics
Officer, Andy Hachey, of the violation.


* Section VI.   Education Requirements

Every Putnam employee has an obligation to fully understand the
requirements of the Code of Ethics. The Rules set forth below are
designed to enhance this understanding.

RULE 1

A copy of the Code of Ethics will be distributed to every Putnam
employee periodically.  All Access Persons will be required to certify
periodically that they have read, understood, and will comply with the
provisions of the Code of Ethics, including the Code's Policy Statement
Concerning Insider Trading Prohibitions.

RULE 2

Every investment professional will attend a meeting periodically at
which the Code of Ethics will be reviewed.


* Section VII.   Compliance and Appeal Procedures

1. Assembly of Restricted List. The Code of Ethics Administrator will
   coordinate the assembly and maintenance of the Restricted List. The
   list will be assembled each day by 11:30 a.m. EST.  No employee may
   engage in a personal securities transaction without prior clearance
   on any day, even if the employee believes that the trade will be
   subject to an exception.  Note that pre-clearance may be obtained
   after 9:00 a.m. for purchases or sales of up to 1,000 shares of
   issuers having a market capitalization in excess of $5 billion.

2. Consultation of Restricted List. It is the responsibility of each
   employee to pre-clear through the pre-clearance system or consult
   with the Code of Ethics Administrator prior to engaging in a personal
   securities transaction, to determine if the security he proposes to
   trade is on the Restricted List and, if so, whether it is subject to
   the "Large Cap" limitation.  The pre-clearance system and the Code of
   Ethics Administrator will be able to tell an employee whether a security
   is on the Restricted List.  No other information about the Restricted
   List is available through the pre-clearance system.  The Code of Ethics
   Administrator shall not be authorized to answer any questions about the
   Restricted List, or to render an opinion about the propriety of a
   particular personal securities transaction. Any such questions shall be
   directed to the Code of Ethics Officer.

3. Request for Determination. An employee who has a question concerning the
   applicability of the Code of Ethics to a particular situation shall
   request a determination from the Code of Ethics Officer before engaging
   in the conduct or personal securities transaction about which he has a
   question.

   If the question pertains to a personal securities transaction, the request
   shall state for whose account the transaction is proposed, the relationship
   of that account to the employee, the security proposed to be traded, the
   proposed price and quantity, the entity with whom the transaction will
   take place (if known), and any other information or circumstances of the
   trade that could have a bearing on the Code of Ethics Officer's
   determination. If the question pertains to other conduct, the request for
   determination shall give sufficient information about the proposed conduct
   to assist the Code of Ethics Officer in ascertaining the applicability of
   the Code. In every instance, the Code of Ethics Officer may request
   additional information, and may decline to render a determination if the
   information provided is insufficient.

   The Code of Ethics Officer shall make every effort to render a determination
   promptly.

   No perceived ambiguity in the Code of Ethics shall excuse any violation.
   Any person who believes the Code to be ambiguous in a particular situation
   shall request a determination from the Code of Ethics Officer.

4. Request for Ad Hoc Exemption. Any employee who wishes to obtain an ad hoc
   exemption under Section I.D., Rule 2, shall request from the Code of Ethics
   Officer an exemption in writing in advance of the conduct or transaction
   sought to be exempted. In the case of a personal securities transaction,
   the request for an ad hoc exemption shall give the same information about
   the transaction required in a request for determination under Part 3 of
   this Section, and shall state why the proposed personal securities
   transaction would be unlikely to affect a highly institutional market, or
   is unrelated economically to securities to be purchased, sold, or held by
   any Putnam client. In the case of other conduct, the request shall give
   information sufficient for the Code of Ethics Officer to ascertain whether
   the conduct raises questions of propriety or conflict of interest (real or
   apparent).

   The Code of Ethics Officer shall make every effort to promptly render a
   written determination concerning the request for an ad hoc exemption.

5. Appeal to Code of Ethics Officer with Respect to Restricted List. If an
   employee ascertains that a security that he wishes to trade for his
   personal account appears on the Restricted List, and thus the transaction
   is prohibited, he may appeal the prohibition to the Code of Ethics Officer
   by submitting a written memorandum containing the same information as would
   be required in a request for a determination. The Code of Ethics Officer
   shall make every effort to respond to the appeal promptly.

6. Information Concerning Identity of Compliance Personnel. The names of Code
   of Ethics personnel are available by contacting the Legal and Compliance
   Department.



Appendix A

Policy Statement Concerning Insider Trading Prohibitions


PUTNAM INVESTMENTS

[SCALE LOGO OMITTED]


* Preamble

Putnam has always forbidden trading on material nonpublic information
("inside information") by its employees. Tougher federal laws make it
important for Putnam to restate that prohibition in the strongest
possible terms, and to establish, maintain, and enforce written policies
and procedures to prevent the misuse of material nonpublic information.

Unlawful trading while in possession of inside information can be a
crime. Today, federal law provides that an individual convicted of
trading on inside information go to jail for some period of time. There
is also significant monetary liability for an inside trader; the
Securities and Exchange Commission can seek a court order requiring a
violator to pay back profits and penalties of up to three times those
profits. In addition, private plaintiffs can seek recovery for harm
suffered by them. The inside trader is not the only one subject to
liability. In certain cases, "controlling persons" of inside traders
(including supervisors of inside traders or Putnam itself) can be liable
for large penalties.

Section 1 of this Policy Statement contains rules concerning inside
information. Section 2 contains a discussion of what constitutes
unlawful insider trading.

Neither material nonpublic information nor unlawful insider trading is
easy to define. Section 2 of this Policy Statement gives a general
overview of the law in this area. However, the legal issues are complex
and must be resolved by the Code of Ethics Officer. If an employee has
any doubt as to whether she has received material nonpublic information,
she must consult with the Code of Ethics Officer prior to using that
information in connection with the purchase or sale of a security for
his own account or the account of any Putnam client, or communicating
the information to others. A simple rule of thumb is if you think the
information is not available to the public at large, don't disclose it
to others and don't trade securities to which the inside information
relates. If an employee has failed to consult the Code of Ethics
Officer, Putnam will not excuse employee misuse of inside information on
the ground that the employee claims to have been confused about this
Policy Statement or the nature of the information in his possession.

If Putnam determines, in its sole discretion, that an employee has
failed to abide by this Policy Statement, or has engaged in conduct that
raises a significant question concerning insider trading, he will be
subject to disciplinary action, including termination of employment.

THERE ARE NO EXCEPTIONS TO THIS POLICY STATEMENT AND NO ONE IS EXEMPT.


* Definitions:   Insider Trading

Gender references in Appendix A alternate.

Code of Ethics Administrator. The individual designated by the Code of
Ethics Officer to assume responsibility for day-to-day,
non-discretionary administration of this Policy Statement.

Code of Ethics Officer. The Putnam officer who has been assigned the
responsibility of enforcing and interpreting this Policy Statement. The
Code of Ethics Officer shall be the General Counsel or such other person
as is designated by the President of Putnam Investments. If he is
unavailable, the Deputy Code of Ethics Officer (to be appointed by the
Code of Ethics Officer) shall act in his stead.

Immediate family. Spouse, minor children or other relatives living in
the same household as the Putnam employee.

Purchase or sale of a security. Any acquisition or transfer of any
interest in the security for direct or indirect consideration, including
the writing of an option.

Putnam. Any or all of Putnam Investments, LLC, and its subsidiaries, any
one of which shall be a "Putnam company."

Putnam client. Any of the Putnam Funds, or any advisory or trust client
of Putnam.

Putnam employee (or "employee"). Any employee of Putnam.

Security. Anything defined as a security under federal law. The term
includes any type of equity or debt security, any interest in a business
trust or partnership, and any rights relating to a security, such as put
and call options, warrants, convertible securities, and securities
indices. (Note: The definition of "security" in this Policy Statement
varies significantly from that in the Code of Ethics. For example, the
definition in this Policy Statement specifically includes securities of
The Marsh & McLennan Companies, Inc.)

Transaction for a personal account (or "personal securities
transaction"). Securities transactions: (a) for the personal account of
any employee; (b) for the account of a member of the immediate family of
any employee; (c) for the account of a partnership in which a Putnam
employee or immediate family member is a partner with investment
discretion; (d) for the account of a trust in which a Putnam employee or
immediate family member is a trustee with investment discretion; (e) for
the account of a closely-held corporation in which a Putnam employee or
immediate family member holds shares and for which he has investment
discretion; and (f) for any account other than a Putnam client account
which receives investment advice of any sort from the employee or
immediate family member, or as to which the employee or immediate family
member has investment discretion.

Officers and employees of Putnam Investments Limited ("PIL") must also
consult the relevant procedures on compliance with U.K. insider dealing
legislation set forth in PEL's Compliance Manual (see Rule 3 of Section
IV of the Code of Ethics).


* Section 1.   Rules Concerning Inside Information

RULE 1

No Putnam employee shall purchase or sell any security listed on the
Inside Information List (the "Red List") either for his personal account
or for a Putnam client.

IMPLEMENTATION

When an employee contacts the Code of Ethics Administrator seeking
clearance for a personal securities transaction, the Code of Ethics
Administrator's response as to whether a security appears on the
Restricted List will include securities on the Red List.

COMMENT

This Rule is designed to prohibit any employee from trading a security
while Putnam may have inside information concerning that security or the
issuer. Every trade, whether for a personal account or for a Putnam
client, is subject to this Rule.

RULE 2

No Putnam employee shall purchase or sell any security, either for a
personal account or for the account of a Putnam client, while in
possession of material, nonpublic information concerning that security
or the issuer, without the prior written approval of the Code of Ethics
Officer.

IMPLEMENTATION

In order to obtain prior written approval of the Code of Ethics Officer,
a Putnam employee should follow the reporting steps prescribed in Rule
3.

COMMENTS

1. Rule 1 concerns the conduct of an employee when Putnam possesses
   material nonpublic information. Rule 2 concerns the conduct of an
   employee who herself possesses material, nonpublic information about
   a security that is not yet on the Red List.

2. If an employee has any question as to whether information she possesses
   is material and/or nonpublic information, she must contact the Code of
   Ethics Officer in accordance with Rule 3 prior to purchasing or selling
   any security related to the information or communicating the information
   to others. The Code of Ethics Officer shall have the sole authority to
   determine what constitutes material, nonpublic information for the
   purposes of this Policy Statement. An employee's mistaken belief that
   the information was not material nonpublic information will not excuse a
   violation of this Policy Statement.

RULE 3

Any Putnam employee who believes he may have received material,
nonpublic information concerning a security or the issuer shall
immediately report the information to the Code of Ethics Officer and to
no one else. After reporting the information, the Putnam employee shall
comply strictly with Rule 2 by not trading in the security without the
prior written approval of the Code of Ethics Officer and shall: (a) take
precautions to ensure the continued confidentiality of the information;
and (b) refrain from communicating the information in question to any
person.

EXCEPTION

This rule shall not apply to material, nonpublic information obtained by
Putnam employees who are directors or trustees of publicly traded
companies, to the extent that such information is received in their
capacities as directors or trustees, and then only to the extent such
information is not communicated to anyone else within the Putnam
organization.

IMPLEMENTATION

1. In order to make any use of potential material, nonpublic information,
   including purchasing or selling a security or communicating the
   information to others, an employee must communicate that information
   to the Code of Ethics Officer in a way designed to prevent the spread
   of such information. Once the employee has reported potential material,
   nonpublic information to the Code of Ethics Officer, the Code of Ethics
   Officer will evaluate whether information constitutes material,
   nonpublic information, and whether a duty exists that makes use of such
   information improper. If the Code of Ethics Officer determines either
   (a) that the information is not material or is public, or (b) that use
   of the information is proper, he will issue a written approval to the
   employee specifically authorizing trading while in possession of the
   information, if the employee so requests. If the Code of Ethics Officer
   determines (a) that the information may be nonpublic and material, and
   (b) that use of such information may be improper, he will place the
   security that is the subject of such information on the Red List.

2. An employee who reports potential inside information to the Code of
   Ethics Officer should expect that the Code of Ethics Officer will need
   significant information to make the evaluation described in the foregoing
   paragraph, including information about (a) the manner in which the employee
   acquired the information, and (b) the identity of individuals to whom the
   employee has revealed the information, or who have otherwise learned the
   information. The Code of Ethics Officer may place the affected security or
   securities on the Red List pending the completion of his evaluation.

3. If an employee possesses documents, disks, or other materials containing
   the potential inside information, an employee must take precautions to
   ensure the confidentiality of the information in question. Those
   precautions include (a) putting documents containing such information out
   of the view of a casual observer, and (b) securing files containing such
   documents or ensuring that computer files reflecting such information are
   secure from viewing by others.


* Section 2.   Overview of Insider Trading

A. Introduction

   This section of the Policy Statement provides guidelines for employees as
   to what may constitute inside information. It is possible that in the
   course of her employment, an employee may receive inside information. No
   employee should misuse that information, either by trading for her own
   account or by communicating the information to others.

B. What constitutes unlawful insider trading?

   The basic definition of unlawful insider trading is trading on material,
   nonpublic information (also called "inside information") by an individual
   who has a duty not to "take advantage" of the information. What does this
   definition mean? The following sections help explain the definition.

1. What is material information?

   Trading on inside information is not a basis for liability unless the
   information is material. Information is "material" if a reasonable person
   would attach importance to the information in determining his course of
   action with respect to a security. Information which is reasonably likely
   to affect the price of a company's securities is "material," but effect on
   price is not the sole criterion for determining materiality. Information
   that employees should consider material includes but is not limited to:
   dividend changes, earnings estimates, changes in previously released
   earnings estimates, reorganization, recapitalization, asset sales, plans
   to commence a tender offer, merger or acquisition proposals or agreements,
   major litigation, liquidity problems, significant contracts, and
   extraordinary management developments.

   Material information does not have to relate to a company's business. For
   example, a court considered as material certain information about the
   contents of a forthcoming newspaper column that was expected to affect the
   market price of a security. In that case, a reporter for The Wall Street
   Journal was found criminally liable for disclosing to others the dates
   that reports on various companies would appear in the Journal's "Heard on
   the Street" column and whether those reports would be favorable or not.


2. What is nonpublic information?

   Information is nonpublic until it has been effectively communicated to,
   and sufficient opportunity has existed for it to be absorbed by, the
   marketplace. One must be able to point to some fact to show that the
   information is generally public. For example, information found in a
   report filed with the Securities and Exchange Commission, or appearing
   in Dow Jones, Reuters Economic Services, The Wall Street Journal, or
   other publications of general circulation would be considered public.

3. Who has a duty not to "take advantage" of inside information?

   Unlawful insider trading occurs only if there is a duty not to "take
   advantage" of material nonpublic information. When there is no such duty,
   it is permissible to trade while in possession of such information.
   Questions as to whether a duty exists are complex, fact-specific, and
   must be answered by a lawyer.

a. Insiders and Temporary Insiders. Corporate "insiders" have a duty not to
   take advantage of inside information. The concept of "insider" is broad.
   It includes officers, directors, and employees of a corporation. In
   addition, a person can be a "temporary insider" if she enters into a
   special confidential relationship with a corporation and as a result is
   given access to information concerning the corporation's affairs. A
   temporary insider can include, among others, accounting firms, consulting
   firms, law firms, banks and the employees of such organizations. Putnam
   would generally be a temporary insider of a corporation it advises or for
   which it performs other services, because typically Putnam clients expect
   Putnam to keep any information disclosed to it confidential.

EXAMPLE

An investment adviser to the pension fund of a large publicly-traded
corporation, Acme, Inc., learns from an Acme employee that Acme will not
be making the minimum required annual contribution to the pension fund
because of a serious downturn in Acme's financial situation. The
information conveyed is material and nonpublic.

COMMENT

Neither the investment adviser, its employees, nor clients can trade on
the basis of that information, because the investment adviser and its
employees could be considered "temporary insiders" of Acme.

b. Misappropriators. Certain people who are not insiders (or temporary
   insiders) also have a duty not to deceptively take advantage of inside
   information. Included in this category is an individual who
   "misappropriates" (or takes for his own use) material, nonpublic
   information in violation of a duty owed either to the corporation
   that is the subject of inside information or some other entity. Such
   a misappropriator can be held liable if he trades while in possession
   of that material, nonpublic information.

EXAMPLE

The chief financial officer of Acme, Inc., is aware of Acme's plans to
engage in a hostile takeover of Profit, Inc. The proposed hostile
takeover is material and nonpublic.

COMMENT

The chief financial officer of Acme cannot trade in Profit, Inc.'s stock
for his own account. Even though he owes no duty to Profit, Inc., or its
shareholders, he owes a duty to Acme not to "take advantage" of the
information about the proposed hostile takeover by using it for his
personal benefit.

c. Tippers and Tippees. A person (the "tippee") who receives material,
   nonpublic information from an insider or misappropriator (the "tipper")
   has a duty not to trade while in possession of that information if he
   knew or should have known that the information was provided by the tipper
   for an improper purpose and in breach of a duty owed by the tipper. In
   this context, it is an improper purpose for a person to provide such
   information for personal benefit, such as money, affection, or friendship.

EXAMPLE

The chief executive officer of Acme, Inc., tells his daughter that
negotiations concerning a previously-announced acquisition of Acme have
been terminated. This news is material and, at the time the father tells
his daughter, nonpublic. The daughter sells her shares of Acme.

COMMENT

The father is a tipper because he has a duty to Acme and its
shareholders not to "take advantage" of the information concerning the
breakdown of negotiations, and he has conveyed the information for an
"improper" purpose (here, out of love and affection for his daughter).
The daughter is a "tippee" and is liable for trading on inside
information because she knew or should have known that her father was
conveying the information to her for his personal benefit, and that her
father had a duty not to "take advantage" of Acme information.

A person can be a tippee even if he did not learn the information
directly from the tipper, but learned it from a previous tippee.

EXAMPLE

An employee of a law firm which works on mergers and acquisitions learns
at work about impending acquisitions. She tells her friend and her
friend's stockbroker about the upcoming acquisitions on a regular basis.
The stockbroker tells the brother of a client on a regular basis, who in
turn tells two friends, A and B. A and B buy shares of the companies
being acquired before public announcement of the acquisition, and
regularly profit from such purchases. A and B do not know the employee
of the law firm. They do not, however, ask about the source of the
information.

COMMENT

A and B, although they have never heard of the tipper, are tippees
because they did not ask about the source of the information, even
though they were experienced investors, and were aware that the "tips"
they received from this particular source were always right.

C. Who can be liable for insider trading?

   The categories of individuals discussed above (insiders, temporary
   insiders, misappropriators or tippees) can be liable if they trade while
   in possession of material nonpublic information.

   In addition, individuals other than those who actually trade on inside
   information can be liable for trades of others. A tipper can be liable
   if (a) he provided the information in exchange for a personal benefit in
   breach of a duty and (b) the recipient of the information (the "tippee")
   traded while in possession of the information.

   Most importantly, a controlling person can be liable if the controlling
   person "knew or recklessly disregarded" the fact that the controlled
   person was likely to engage in misuse of inside information and failed to
   take appropriate steps to prevent it. Putnam is a "controlling person" of
   its employees. In addition, certain supervisors may be "controlling
   persons" of those employees they supervise.

EXAMPLE

A supervisor of an analyst learns that the analyst has, over a long
period of time, secretly received material inside information from Acme,
Inc.'s chief financial officer. The supervisor learns that the analyst
has engaged in a number of trades for his personal account on the basis
of the inside information. The supervisor takes no action.

COMMENT

Even if he is not liable to a private plaintiff, the supervisor can be
liable to the Securities and Exchange Commission for a civil penalty of
up to three times the amount of the analyst's profit. (Penalties are
discussed in the following section.)

D. Penalties for Insider Trading

   Penalties for misuse of inside information are severe, both for individuals
   involved in such unlawful conduct and their employers. A person who
   violates the insider trading laws can be subject to some or all of the
   penalties below, even if he does not personally benefit from the violation.
   Penalties include:

- -- jail sentences (of which at least one to three years must be served)

- -- criminal penalties for individuals of up to $1,000,000, and for corporations
   of up to $2,500,000

- -- injunctions permanently preventing an individual from working in the
   securities industry

- -- injunctions ordering an individual to pay over profits obtained from
   unlawful insider trading

- -- civil penalties of up to three times the profit gained or loss avoided
   by the trader, even if the individual paying the penalty did not trade
   or did not benefit personally

- -- civil penalties for the employer or other controlling person of up to the
   greater of $1,000,000 or three times the amount of profit gained or loss
   avoided

- -- damages in the amount of actual losses suffered by other participants in
   the market for the security at issue.

Regardless of whether penalties or money damages are sought by others,
Putnam will take whatever action it deems appropriate (including
dismissal) if Putnam determines, in its sole discretion, that an
employee appears to have committed any violation of this Policy
Statement, or to have engaged in any conduct which raises significant
questions about whether an insider trading violation has occurred.


* Appendix B.   Policy Statement Regarding Employee Trades in Shares of
                Putnam Closed-End Funds

1. Pre-clearance for all employees

Any purchase or sale of Putnam closed-end fund shares by a Putnam
employee must be pre-cleared by the Code of Ethics Officer or, in his
absence, the Deputy Code of Ethics Officer. A list of the closed-end
funds can be obtained from the Code of Ethics Administrator. Trading in
shares of closed-end funds is subject to all the rules of the Code of
Ethics.

2. Special Rules Applicable to Managing Directors of Putnam Investment
   Management, LLC and officers of the Putnam Funds

Please be aware that any employee who is a Managing Director of Putnam
Investment Management, Inc. (the investment manager of the Putnam mutual
funds) and officers of the Putnam Funds will not receive clearance to
engage in any combination of purchase and sale or sale and purchase of
the shares of a given closed-end fund within six months of each other.
Therefore, purchases should be made only if you intend to hold the
shares more than six months; no sales of fund shares should be made if
you intend to purchase additional shares of that same fund within six
months.

You are also required to file certain forms with the Securities and
Exchange Commission in connection with purchases and sales of Putnam
closed-end funds. Please contact the Code of Ethics Officer or Deputy
Code of Ethics Officer for further information.

3. Reporting by all employees

As with any purchase or sale of a security, duplicate confirmations of
all such purchases and sales must be forwarded to the Code of Ethics
Officer by the broker-dealer utilized by an employee. If you are
required to file a quarterly report of all personal securities
transactions, this report should include all purchases and sales of
closed-end fund shares.

Please contact the Code of Ethics Officer or Deputy Code of Ethics
Officer if there are any questions regarding these matters.


* Appendix C.   Clearance Form for Portfolio Manager Sales Out of Personal
  Account of Securities Also Held by Fund (For compliance with
  "Contra-Trading" Rule)

TO:   Code of Ethics Officer

FROM:
      -------------------------------------------
DATE:
      -------------------------------------------

RE:   Personal Securities Transaction of
                                         ------------------------------

This serves as prior written approval of the personal securities
transaction described below:

NAME OF PORTFOLIO MANAGER CONTEMPLATING PERSONAL TRADE:

- -------------------------------------------------------------------------

SECURITY TO BE TRADED:

- -------------------------------------------------------------------------

AMOUNT TO BE TRADED:
                    -----------------------------------------------------

FUND HOLDING SECURITIES:
                        -------------------------------------------------

AMOUNT HELD BY FUND:
                    -----------------------------------------------------

REASON FOR PERSONAL TRADE:
                          -----------------------------------------------

SPECIFIC REASON SALE OF SECURITIES IS INAPPROPRIATE FOR FUND:

- -------------------------------------------------------------------------

- -------------------------------------------------------------------------

(Please attach additional sheets if necessary.)

CIO APPROVAL:                                               DATE:
             ----------------------------------------------      --------

LEGAL/COMPLIANCE APPROVAL:                                  DATE:
                          ---------------------------------      --------

* Appendix D.   Procedures for Approval of New Financial Instruments

1. Summary

a. Putnam has adopted procedures for the introduction of new instruments and
   securities, focusing on, but not limited to, derivatives.

b. No new types of securities or instruments may be purchased for any
   Putnam fund or other client account without the approval of Putnam's New
   Securities Review Committee ("NSRC").

c. Putnam publishes from time to time a list of approved derivatives. The
   purchase of any derivative not listed is prohibited without specific
   authorization from the NSRC.

2. Procedures

a. Introduction. The purchase and sale of financial instruments that have not
   been used previously at Putnam raise significant investment, business,
   operational, and compliance issues. In order to address these issues in a
   comprehensive manner, Putnam has adopted the following procedures for
   obtaining approval of the use of new instruments or investments. In
   addition, to provide guidance regarding the purchase of derivatives,
   Putnam publishes from time to time a list of approved derivatives. Only
   derivatives listed may be used for Putnam funds or accounts unless
   specifically authorized by the NSRC.

b. Process of approval. An investment professional wishing to purchase a new
   type of investment should discuss it with the Investment Division's
   Administrative office (the current contact is Julie Malloy). Investment
   Division Administration will coordinate a review of a new instrument by
   appropriate NSRC members from an investment, operational and compliance
   perspective, including the review of instruments by the Administrative
   Services Division of PFTC. Based on this review, the NSRC will then
   approve or disapprove the proposed new investment. Investment
   professionals must build in adequate time for this review before planned
   use of a new instrument. Further, the approval of the NSRC is only a
   general one. Individual fund and account guidelines must be reviewed in
   accordance with standard compliance procedures to determine whether
   purchase is permitted. In addition, if the instrument involves legal
   documentation, that documentation must be reviewed and be completed before
   trading. The NSRC may prepare a compliance and operational manual for the
   new derivative.

3. Violations

a. Putnam's Operating Committee has determined that adherence to rigorous
   internal controls and procedures for novel securities and instruments is
   necessary to protect Putnam's business standing and reputation. Violation
   of these procedures will be treated as violation of both compliance
   guidelines and Putnam's Code of Ethics.  Putnam encourages questions and
   expects that these guidelines will be interpreted conservatively.


Appendix E.  AIMR Code of Ethics and Standards of Professional Conduct

The Code of Ethics (Full Text)

Members of the Association for Investment Management and Research shall:


1. Act with integrity, competence, dignity, and in an ethical manner when
   dealing with the public, clients, prospects, employers, employees, and
   fellow members.

2. Practice and encourage others to practice in a professional and ethical
   manner that will reflect credit on members and their profession.

3. Strive to maintain and improve their competence and the competence
   of others in the profession.

4. Use reasonable care and exercise independent professional judgment.


The Standards of Professional Conduct

All members of the Association for Investment Management and Research and
the holders of and candidates for the Chartered Financial Analyst designation
are obligated to conduct their activities in accordance with the following Code
of Ethics. Disciplinary sanctions may be imposed for violations of the Code and
Standards.


Fundamental Responsibilities

Relationships with and Responsibilities to a Profession

Relationships with and Responsibilities to an Employer

Relationships with and Responsibilities to Clients and Prospects

Relationships with and Responsibilities to the Public

Standards of Practice Handbook


Standard I: Fundamental Responsibilities

Members shall:

A. Maintain knowledge of and comply with all applicable laws, rules, and
regulations (including AIMR's Code of Ethics and Standards of Professional
Conduct) of any government, governmental agency, regulatory organization,
licensing agency, or professional association governing the members'
professional activities.

B. Not knowingly participate in or assist any violation of such laws, rules, or
regulations.

Standard II: Relationships with and Responsibilities to the Profession

A. Use of Professional Designation.

1. AIMR members may reference their membership only in a dignified and
judicious manner. The use of the reference may be accompanied by an
accurate explanation of the requirements that have been met to obtain
membership in these organizations.

2. Those who have earned the right to use the Chartered Financial Analyst
designation may use the marks "Chartered Financial Analyst" or "CFA" and
are encouraged to do so, but only in a proper, dignified, and judicious
manner. The use of the designation may be accompanied by an accurate
explanation of the requirements that have been met to obtain the right to
use the designation.

3. Candidates in the CFA Program, as defined in the AIMR Bylaws, may
reference their participation in the CFA Program, but the reference must
clearly state that an individual is a candidate in the CFA Program and
cannot imply that the candidate has achieved any type of partial
designation.

B. Professional Misconduct.

1. Members shall not engage in any professional conduct involving
dishonesty, fraud, deceit, or misrepresentation or commit any act that
reflects adversely on their honesty, trustworthiness, or professional
competence.

2. Members and candidates shall not engage in any conduct or commit any
act that compromises the integrity of the CFA designation or the integrity
or validity of the examinations leading to the award of the right to use
the CFA designation.

C. Prohibition against Plagiarism.

Members shall not copy or use, in substantially the same form as the
original, material prepared by another without acknowledging and
identifying the name of the author, publisher, or source of such
material. Members may use, without acknowledgment, factual information
published by recognized financial and statistical reporting services or
similar sources.

Standard III: Relationships with and Responsibilities to the Employer

A. Obligation to Inform Employer of Code and Standards. Members shall:

1. Inform their employer in writing, through their direct supervisor,
that they are obligated to comply with the Code and Standards and are
subject to disciplinary sanctions for violations thereof.

2. Deliver a copy of the Code and Standards to their employer if the
employer does not have a copy.

B. Duty to Employer. Members shall not undertake any independent
practice that could result in compensation or other benefit in
competition with their employer unless they obtain written consent from
both their employer and the persons or entities for whom they undertake
independent practice.

C. Disclosure of Conflicts to Employer. Members shall:

1. Disclose to their employer all matters, including beneficial
ownership of securities or other investments, that reasonably could be
expected to interfere with their duty to their employer or ability to
make unbiased and objective recommendations.

2. Comply with any prohibitions on activities imposed by their employer if a
conflict of interest exists.

D. Disclosure of Additional Compensation Arrangements. Members shall
disclose to their employer in writing all monetary compensation or other
benefits that they receive for their services that are in addition to
compensation or benefits conferred by a member's employer.

E. Responsibilities of Supervisors. Members with supervisory
responsibility, authority, or the ability to influence the conduct of
others shall exercise reasonable supervision over those subject to their
supervision or authority to prevent any violation of applicable
statutes, regulations, or provisions of the Code and Standards. In so
doing, members are entitled to rely on reasonable procedures to detect
and prevent such violations.

Standard IV: Relationships with and Responsibilities to Clients and
Prospects

A. Investment Process.

A.1 Reasonable Basis and Representations. Members shall:

a.  Exercise diligence and thoroughness in making investment
recommendations or in taking investment actions.

b. Have a reasonable and adequate basis, supported by appropriate
research and investigation, for such recommendations or actions.

c. Make reasonable and diligent efforts to avoid any material
misrepresentation in any research report or investment recommendation.

d. Maintain appropriate records to support the reasonableness of such
recommendations or actions.

A.2  Research Reports. Members shall:

a. Use reasonable judgment regarding the inclusion or exclusion of relevant
factors in research reports.

b. Distinguish between facts and opinions in research reports.

c. Indicate the basic characteristics of the investment involved when
preparing for public distribution a research report that is not directly
related to a specific portfolio or client.

A.3  Independence and Objectivity. Members shall use reasonable care and
judgment to achieve and maintain independence and objectivity in making
investment recommendations or taking investment action.

B. Interactions with Clients and Prospects.

B.1  Fiduciary Duties. In relationships with clients, members shall use
particular care in determining applicable fiduciary duty and shall
comply with such duty as to those persons and interests to whom the duty
is owed. Members must act for the benefit of their clients and place
their clients' interests before their own.

B.2  Portfolio Investment Recommendations and Actions. Members shall:

a. Make a reasonable inquiry into a client's financial situation,
investment experience, and investment objectives prior to making any
investment recommendations and shall update this information as
necessary, but no less frequently than annually, to allow the members to
adjust their investment recommendations to reflect changed
circumstances.

b. Consider the appropriateness and suitability of investment
recommendations or actions for each portfolio or client. In determining
appropriateness and suitability, members shall consider applicable
relevant factors, including the needs and circumstances of the portfolio
or client, the basic characteristics of the investment involved, and the
basic characteristics of the total portfolio. Members shall not make a
recommendation unless they reasonably determine that the recommendation
is suitable to the client's financial situation, investment experience,
and investment objectives.

c. Distinguish between facts and opinions in the presentation of investment
recommendations.

d. Disclose to clients and prospects the basic format and general
principles of the investment processes by which securities are selected
and portfolios are constructed and shall promptly disclose to clients
and prospects any changes that might significantly affect those
processes.

B.3  Fair Dealing. Members shall deal fairly and objectively with all
clients and prospects when disseminating investment recommendations,
disseminating material changes in prior investment recommendations, and
taking investment action.

B.4  Priority of Transactions. Transactions for clients and employers
shall have priority over transactions in securities or other investments
of which a member is the beneficial owner so that such personal
transactions do not operate adversely to their clients' or employer's
interests. If members make a recommendation regarding the purchase or
sale of a security or other investment, they shall give their clients
and employer adequate opportunity to act on their recommendations before
acting on their own behalf. For purposes of the Code and Standards, a
member is a "beneficial owner" if the member has

a. a direct or indirect pecuniary interest in the securities;

b. the power to vote or direct the voting of the shares of the securities or
investments;

c. the power to dispose or direct the disposition of the security or
investment.

B.5  Preservation of Confidentiality. Members shall preserve the
confidentiality of information communicated by clients, prospects, or
employers concerning matters within the scope of the client-member,
prospect-member, or employer-member relationship unless a member
receives information concerning illegal activities on the part of the
client, prospect, or employer.

B.6  Prohibition against Misrepresentation. Members shall not make any
statements, orally or in writing, that misrepresent

a. the services that they or their firms are capable of performing;

b. their qualifications or the qualifications of their firm;

c. the member's academic or professional credentials.

Members shall not make or imply, orally or in writing, any assurances or
guarantees regarding any investment except to communicate accurate
information regarding the terms of the investment instrument and the
issuer's obligations under the instrument.

B.7  Disclosure of Conflicts to Clients and Prospects. Members shall
disclose to their clients and prospects all matters, including
beneficial ownership of securities or other investments, that reasonably
could be expected to impair the members' ability to make unbiased and
objective recommendations.

B.8  Disclosure of Referral Fees. Members shall disclose to clients and
prospects any consideration or benefit received by the member or
delivered to others for the recommendation of any services to the client
or prospect.

Standard V: Relationships with and Responsibilities to the Public

A. Prohibition against Use of Material Nonpublic Information. Members
who possess material nonpublic information related to the value of a
security shall not trade or cause others to trade in that security if
such trading would breach a duty or if the information was
misappropriated or relates to a tender offer. If members receive
material nonpublic information in confidence, they shall not breach that
confidence by trading or causing others to trade in securities to which
such information relates. Members shall make reasonable efforts to
achieve public dissemination of material nonpublic information disclosed
in breach of a duty.

B. Performance Presentation.

1. Members shall not make any statements, orally or in writing, that
misrepresent the investment performance that they or their firms have
accomplished or can reasonably be expected to achieve.

2. If members communicate individual or firm performance information
directly or indirectly to clients or prospective clients, or in a manner
intended to be received by clients or prospective clients, members shall
make every reasonable effort to assure that such performance information
is a fair, accurate, and complete presentation of such performance.


* Index

"7-Day Rule"
for transactions by managers, analysts and CIOs, 14

"60-Day Rule", 13

Access Persons
  definition, ix
  special rules on trading, 13, 33

AIMR Code of Ethics and Standards of
   Professional Conduct, 63

Analysts
special rules on trading by, 13

Appeals
Procedures, 39

Bankers' acceptances
excluded from securities, x

Blackout rule
on trading by portfolio managers, analysts and CIOs, 15

Boycotts
reporting of requests to participate, 35

Bribes, 21

CDs
excluded from securities, x

Claims against Putnam
reporting of, 35

Clearance
how long pre-clearance is valid, 4
required for personal securities transactions, 1

Closed-end funds
rules on trading, 57

Commercial paper
excluded from securities, x

Commodities (other than securities indices)
excluded from securities, x

Computer use
compliance with corporate policies required, 27

Confidentiality
required of all employees, 22, 27

Confirmations
of personal transactions required, 33

Conflicts of interest
with Putnam and Putnam clients prohibited, 19

Contra-trading rule
transactions by managers and CIOs, 16

Convertible securities
defined as securities, x

Currencies
excluded as securities, x

Director
serving as for another entity prohibited, 23

Employee
serving as for another entity prohibited, 23

Excessive trading (over 10 trades)
by employees strongly discouraged, 10

Exchange traded index funds, excluded from securities, x

Exemptions
basis for, 11

Family members
covered in personal securities transactions, x, 45

Fiduciary
serving as for another entity prohibited, 23

Fraudulent or irregular activities
reporting of, 35

Gifts
restrictions on receipt of by employees, 19

Government or regulatory agencies
reporting of communications from, 35

Holdings
disclosure of by Access Persons, 34

Initial public offerings/IPOs
purchases in prohibited, 6

Insider trading
policy statement and explanations, 41
prohibited, 9

Investment clubs
prohibited, 24

Investment Grade Exception
for clearance of fixed income securities on Restricted List, 2

Involuntary personal securities transactions
exempted, 11
exemption defined, 6

Large Cap Exception
for clearance of securities on Restricted List, 1

Market Timing, prohibition against, 9

Marsh & McLennan Companies stock
excluded from securities, x

Money market instruments
excluded from securities, x

Mutual fund shares (open end)
excluded from securities, x

Naked options
by employees discouraged, 10

New financial instruments
procedures for approval, 61

Non-Putnam affiliates (NPAs)
transactions and relationships with, 25

Officer
serving as for another entity prohibited, 26

Options
defined as securities, x
relationship to securities on Restricted or Red Lists, 5

Partner
serving as general partner of another entity prohibited, 23

Partnerships
covered in personal securities transactions, x, 45

Personal securities transaction
defined, x, 45

Pink sheet reports
quarterly reporting requirements, 34

Political contributions, 22

Portfolio managers
special rules on trading by, 13

Privacy Policy, 27

Private offerings or placements
purchases of prohibited, 7

Putnam Investments Limited
special rules for, 31

Quarterly Report of securities transactions, 34

Repurchase agreements
excluded from securities, x

Sale
defined, x, 45

Sanctions, viii
for failure to pre-clear properly, 3

Shares by subscription
procedures to preclear the purchase and sales of Shares by Subscription, 2

Short sales
by employees prohibited conduct, 6

Tender offers
partial exemption from clearance rules, 6

Trustee
serving as for another entity prohibited, 23

Trusts
covered in personal securities transactions, x, 45

U.S. government obligations
excluded from securities, x

Violations of Law
reporting of, 35

Warrants
defined as securities, x

</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
-----END PRIVACY-ENHANCED MESSAGE-----
