<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>4
<FILENAME>legal77e.txt
<TEXT>

Regulatory matters and litigation.  On November 13, 2003, Putnam
Management agreed to entry of an order by the Securities and
Exchange Commission 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
SECs 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 orders 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 SECs and Commonwealths 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 Managements parent company, has
engaged counsel to conduct a separate review of Putnam
Managements policies and controls related to short-term trading.
The fund may experience increased redemptions as a result of
these matters, which could result in increased transaction costs
and operating expenses.

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</DOCUMENT>
