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<SEC-DOCUMENT>0000928816-04-001441.txt : 20041229
<SEC-HEADER>0000928816-04-001441.hdr.sgml : 20041229
<ACCEPTANCE-DATETIME>20041229151702
ACCESSION NUMBER:		0000928816-04-001441
CONFORMED SUBMISSION TYPE:	N-CSR
PUBLIC DOCUMENT COUNT:		5
CONFORMED PERIOD OF REPORT:	20041031
FILED AS OF DATE:		20041229
DATE AS OF CHANGE:		20041229
EFFECTIVENESS DATE:		20041229

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:		041230914

	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

10-31-04

[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:

During the past several months, Putnam has introduced a number of
reforms for the benefit of shareholders, including increasing the amount
of disclosure for our funds. We are now including additional information
about your fund's management team. Following the Outlook for Your Fund,
we list any changes in your fund's Portfolio Leader and Portfolio
Members during the prior year period, the current Portfolio Leader's and
Portfolio Members' other fund management responsibilities at Putnam, and
the dollar range of fund shares owned by these individuals.

We are also pleased to announce that three new Trustees have joined your
fund's Board of Trustees. Nominated by your fund's independent Trustees,
these individuals have had outstanding careers as leaders in the
investment management industry. Myra R. Drucker is a Vice Chair of the
Board of Trustees of Sarah Lawrence College and serves as Chair of the
New York Stock Exchange (NYSE) Pension Managers Advisory Committee and
as a Trustee of Commonfund, a not-for-profit asset management firm.
Richard B. Worley is Managing Partner of Permit Capital LLC, an
investment management firm. Both Ms. Drucker and Mr. Worley are
independent Trustees (i.e., Trustees who are not "interested persons" of
your fund or its investment advisor). Charles E. Haldeman, Jr., the
third new Trustee, is President and Chief Executive Officer of Putnam
Investments.

During the period covered by the following report, Putnam Managed
Municipal Income Trust delivered strong results. In the following pages,
the fund managers discuss fund performance, strategy, and their outlook
for fiscal 2005.

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 15, 2004



Report from Fund Management

Fund highlights

 * For the fiscal year ended October 31, 2004, Putnam Managed Municipal
   Income Trust's total return was 9.76% at net asset value (NAV) and 6.35%
   at market price.

 * The fund's benchmark, the Lehman Municipal Bond Index, returned 6.02%
   for the period.

 * The average return for the Lipper High Yield Municipal Debt Funds
   category (closed-end) was 8.57%.

 * See the Performance Summary beginning on page 10 for additional fund
   performance, comparative performance, and Lipper data.

- --------------------------------------------------
TOTAL RETURN FOR
PERIODS ENDED 10/31/04
- --------------------------------------------------
                                         Market
(inception 2/24/89)          NAV         price
- --------------------------------------------------
1 year                      9.76%         6.35%
- --------------------------------------------------
5 years                    34.49          7.12
Annual average              6.11          1.39
- --------------------------------------------------
10 years                   79.54         64.16
Annual average              6.03          5.08
- --------------------------------------------------
Annual average
(life of fund)              7.02          5.75
- --------------------------------------------------

Data is historical. Past performance does not guarantee 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. Performance assumes
reinvestment of distributions and does not account for taxes.

FUND PROFILE

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


Performance commentary

An emphasis on higher-yielding, lower-rated bonds helped Putnam Managed
Municipal Income Trust outperform its benchmark and Lipper peer group
for the 12 months ended October 31, 2004, based on results at NAV.
Results versus the fund's benchmark were particularly favorable as its
benchmark comprises only investment-grade bonds, while the fund's
broader mandate allowed it to own higher-yielding, lower-rated bonds.
This segment of the market outperformed investment-grade bonds due to an
improving economy, rising investor demand, and relatively low supply. It
is important to note that a fund's performance at market price may
differ from its results at NAV. Although market price performance
generally reflects investment results, it may also be influenced by
several other factors, including changes in investor perceptions of the
fund or its investment advisor, market conditions, fluctuations in
supply and demand for the fund's shares, and changes in fund
distributions.


Market overview

The bond market experienced some volatility as yields varied widely
during the fund's fiscal year, which began in November 2003. During the
first six months of the fiscal year, yields fell and bond prices, which
move in the opposite direction of yields, rose. Then in mid-March, the
bond market began to anticipate a change in monetary policy. Treasury
bonds sold off sharply and pushed yields upward, as strong economic
growth and rising corporate profitability increased the likelihood that
the Federal Reserve Board (Fed) would raise short-term interest rates at
its June 30 meeting. Interestingly, when the Fed announced what had been
a widely anticipated 25-basis-point increase, the bond market reversed
course, and yields trended downward, despite two subsequent rate
increases during the fiscal year of 25 basis points each. Over the
one-year period, long-term bond yields have fallen while short-term
rates have risen. This resulted in a flattening of the yield curve --
that is, shorter- and longer-term interest rates began to converge.

Among uninsured bonds and bonds rated A and below, yield spreads
tightened, and bond prices rose. These higher-yielding securities
provided attractive income streams that contributed to the fund's total
return during the period. Municipal bonds issued by the State of
California were generally strong performers. The state's economy
improved to such an extent that three bond-rating agencies -- Moody's,
Standard & Poor's, and Fitch -- upgraded the state's credit rating.
Tobacco settlement bonds performed fairly well during the period. Yields
on these bonds varied with the results of ongoing legal battles but
declined overall for the year, and their prices rose accordingly.
Airline-related industrial development bonds (IDBs) performed poorly, in
general, as the industry continued to face financial difficulties
exacerbated by record high oil prices.

- -------------------------------------------------------------------------------
MARKET SECTOR PERFORMANCE 12 MONTHS ENDED 10/31/04
- -------------------------------------------------------------------------------
Bonds
- -------------------------------------------------------------------------------
Lehman Municipal Bond Index (tax-exempt bonds)                          6.02%
- -------------------------------------------------------------------------------
Lehman Government Bond Index (U.S. Treasury and agency
securities)                                                             4.83%
- -------------------------------------------------------------------------------
Lehman Intermediate Treasury Bond Index
(intermediate-maturity U.S. Treasury bonds)                             3.26%
- -------------------------------------------------------------------------------
Lehman Aggregate Bond Index (broad bond market)                         5.53%
- -------------------------------------------------------------------------------
Stocks
- -------------------------------------------------------------------------------
S&P 500 Index (broad stock market)                                      9.42%
- -------------------------------------------------------------------------------
S&P Utilities Index (utilities stocks)                                 24.11%
- -------------------------------------------------------------------------------
Russell 2000 Growth Index (small-company growth stocks)                 5.53%
- -------------------------------------------------------------------------------
These indexes provide an overview of performance in different market
sectors for the 12 months ended 10/31/04.
- -------------------------------------------------------------------------------

Strategy overview

Because we believe that the Fed is likely to continue to raise
short-term interest rates through mid-2005, we are positioning the
portfolio more defensively. This involves shortening the fund's
duration, which means reducing its sensitivity to changes in interest
rates. To accomplish this, we began the process of selling longer-term
bonds and replacing them with shorter-term bonds, which have a shorter
duration. Meanwhile, we continued to trim and diversify the fund's
positions in uninsured bonds and bonds rated A and below, which have
performed strongly. We maintained a neutral position, relative to the
fund's benchmark, in California municipal bonds, which were in high
demand as that state got its fiscal house in order and its debt rating
was upgraded by the major bond-rating agencies. The fund maintained an
overweight position in tobacco settlement bonds relative to its
benchmark. We closely monitored developments in that sector. The fund
had less exposure to airline-related IDBs during the period than did its
peers, a positive amid continued uncertainty in that industry.

Prior to the beginning of the fund's fiscal year, the fund emphasized
non-callable bonds -- bonds that the issuer is not permitted to redeem
(or call) before the maturity date. These issues performed well as rates
fell through March 2004, but during the spring, we began to moderate
this position, selling non-callable bonds and purchasing callable issues
scheduled to mature in the 15- to 20-year range. We believe callable
bonds may perform better than non-callable bonds if interest rates rise
and the yield curve flattens further.

[GRAPHIC OMITTED: horizontal bar chart THE FUND'S MATURITY AND DURATION
COMPARED]

THE FUND'S MATURITY AND DURATION COMPARED

                        10/31/03      4/30/04         10/31/04

Average effective
maturity in years         9.2           8.0              6.6

Duration in years         8.2           7.5              6.1

Footnotes read:
This chart compares changes in the fund's duration (a measure of its
sensitivity to interest-rate changes) and its average effective
maturity (a weighted average of the holdings' maturities).

Average effective maturity also takes into account put and call
features, where applicable, and reflects prepayments for mortgage-backed
securities.


How fund holdings affected performance

During the reporting period, the fund's relative performance benefited
from its emphasis on higher-yielding, lower-rated issues. Two factors
drove strong relative performance in this market segment: The first
factor was the improving economic climate, which increased confidence in
the relative financial stability of many lower-rated bond issuers. The
risk that a company or municipality will default on its bond payments
generally decreases in an improving economy. As a result, the outlook
for several issuers represented in the portfolio was upgraded by rating
agencies, lifting the price of the bonds. The second factor was investor
demand for higher-yielding municipal debt, which increased while supply
remained relatively small, driving up prices of these bonds. It is also
important to note that we have been working to manage the fund's risk
exposure in this area through thorough fundamental analysis of every
issuer and by diversifying holdings across a number of issuers,
locations, and industry sectors.

For much of the year the fund was more conservatively positioned than
its peers in terms of its duration -- a measure of the fund's
sensitivity to interest rates. We began shortening duration in the first
half of the fiscal year in an effort to preserve the fund's principal
value from an increase in interest rates that we saw ahead. In fact,
long-term rates declined, in spite of the Federal Reserve Board's
tightening, but we maintained a moderately defensive duration during
most of the period. Although this caused the fund to miss some capital
appreciation, we continue to believe our cautious approach is warranted.
Moreover, the benefits that accrued from our emphasis on yield more than
compensated for the negative effects of our conservative duration and
poor performance from two distressed holdings during the year.

[GRAPHIC OMITTED: pie chart CREDIT QUALITY OVERVIEW]

CREDIT QUALITY OVERVIEW

Aaa -- (34.6%)

Aa -- (2.1%)

A -- (11.7%)

Baa -- (27.4%)

Ba -- (14.8%)

B -- (4.6%)

Other -- (4.8%)

Footnote reads:
As a percentage of market value as of 10/31/04. A bond rated Baa or
higher is considered investment grade. The chart reflects Moody's
ratings; percentages may include bonds not rated by Moody's but
considered by Putnam Management to be of comparable quality. Ratings
will vary over time.


The fund has maintained a somewhat greater emphasis on tobacco
settlement bonds than its index and peers, which proved advantageous in
spite of the volatile market environment for these bonds. Payments from
these high-yielding issues are secured by income promised to various
states through legal settlements from tobacco companies. This income
could be jeopardized as a result of multibillion-dollar judgments
against the tobacco companies, and prices in this sector have shifted as
concerns about litigation overshadowed optimism. Our analyst believes
that, despite several highly visible lawsuits against the tobacco
industry, litigation risk is receding from where it was in 1999. Also,
cigarette consumption levels appear to be holding steady. Considering
the risks, we have diversified the fund's investments in tobacco
settlement bonds and we remain watchful of the situation. Holdings
include Badger Tobacco Settlement Asset Securitization Corp. revenue
bonds, issued in Wisconsin, and Golden State Tobacco Securitization
Corp. revenue bonds, issued in California. The Golden State bonds give
the fund a special advantage because they are double backed. If the
tobacco companies default on their payments, the State of California has
promised to step in and pay the interest and principal, so these bonds
offer less risk than other tobacco settlement bonds. They also benefited
during the latter half of the fiscal year when California's bond rating
was raised, lifting the price of most of the state's debt securities.

Although some airline-related industrial development bonds (IDBs) remain
in the portfolio, we trimmed these issues and the fund's remaining
position is relatively small. IDBs are bonds issued by municipalities
but backed by the company benefiting from the financing. Investor
perceptions about the backing company's health, or that of its industry
group, affect the prices of these bonds, not the rating of the
municipality issuing them. The airline industry has been under a cloud
for several years, although it regained some ground last year. However,
the industry continues to grapple with high operating costs and strong
competition among carriers, which is keeping the price of airline
tickets down. These problems, plus the ongoing threat of terrorism, make
us cautious on the industry, so we limited the fund's airline-related
investments to a relatively small position in what we believe to be the
strongest carriers.

The fund's health-care holdings generally made positive contributions to
performance. One strong contributor was a bond issued by the California
Statewide Community Development Authority for The Front Porch, which
operates long-term care facilities in California and is currently moving
forward with plans to renovate an older facility, Walnut Manor, located near
the Disney theme park. Although The Front Porch is taking on considerable
debt, the company has a history of successful development and marketing of
comparable facilities, which are well located. The prerefunding of a
formerly distressed holding also boosted performance. The fund held Oklahoma
Development Financing Authority Revenue Bonds issued for Hillcrest
Healthcare, which had a relatively low bond rating and a history of
operating difficulties. The entire system was purchased recently by Ardent
Health Services, a for-profit hospital manager expanding its operations in
acute care facilities. The bonds rose in value when Ardent announced plans
to prerefund the outstanding issues. Prerefunding occurs when an issuer
raises the money to refinance an older, higher-coupon bond by issuing new
bonds at current lower interest rates. This money is then invested in a
secure investment, usually U.S. Treasury securities, that mature at the
older bond's first call date, when it is used to pay off the old bonds. This
added security is often perceived as a credit upgrade by the market, and can
boost the price of the older bonds.

Although high-yielding municipal securities generally performed well
during the fiscal year, a few individual securities experienced
difficulties. These were Hoover Group IDBs, which were sold, and Gilroy
Revenue Bonds for Bonfante Gardens Park in California, which are still
in the portfolio. The Gilroy bonds were issued to fund a theme park that
suffered from poor attendance. The park hopes to reduce its debt by
selling some surrounding land. The price of the bonds has fallen, but we
remain hopeful that current negotiations with the issuer will have a
positive outcome.

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 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.

Judging from the flattened yield curve, the bond market appears to have
largely shrugged off the recent Fed rate hikes. However, we believe that
interest rates all along the yield curve are more likely to rise than
fall. After the close of the fiscal period, the Fed again raised the
discount rate by 25 basis points, or one quarter of a percentage point.
Going forward, we anticipate greater increases for bonds with shorter
maturities because we believe the Fed will continue to raise short-term
rates incrementally through mid-2005. This also suggests further
flattening of the yield curve. The fund is positioned defensively in
terms of duration, and we will continue to monitor and adjust the fund's
duration as seems appropriate. We believe inflation will remain low,
despite the threat posed by high oil prices. We also anticipate that the
rate of GDP growth will slow during the next two quarters, as the
effects of the Fed's tightening policy are felt.

In general, these signs indicate that we are headed into a more
challenging environment for bond investing. Our task will be to continue
to search for the most attractive opportunities among tax-exempt
securities, and to balance the pursuit of attractive current income with
prudent risk management.

The views expressed in this report are exclusively those of Putnam
Management. They are not meant as investment advice. 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. Mutual funds that invest in bonds are
subject to certain risks, including interest-rate risk, credit risk, and
inflation risk. As interest rates rise, the prices of bonds fall.
Long-term bonds are more exposed to interest-rate risk than short-term
bonds. Unlike bonds, bond funds have ongoing fees and expenses.
Lower-rated bonds may offer higher yields in return for more risk.


Your fund's management

Your fund is managed by the members of the Putnam Tax Exempt
Fixed-Income Team. David Hamlin is the Portfolio Leader, and Paul Drury,
Susan McCormack, and James St. John are Portfolio Members of your fund.
The Portfolio Leader and Portfolio Members coordinate the team's
management of the fund.

For a complete listing of the members of the Putnam Tax Exempt
Fixed-Income Team, including those who are not Portfolio Leaders or
Portfolio Members of your fund, visit Putnam's Individual Investor Web
site at www.putnaminvestments.com.

Fund ownership

The table below shows fund ownership, in dollar ranges, by the fund's
Portfolio Leader and Portfolio Members. Information shown is for the
current and prior year ended November 30.

<TABLE>
<CAPTION>

- -------------------------------------------------------------------------------------------------------------
FUND PORTFOLIO LEADER AND PORTFOLIO MEMBERS
- -------------------------------------------------------------------------------------------------------------
                                    $1 -        $10,001 -    $50,001 -   $100,001 -     $500,001 - $1,000,001
                    Year     $0     $10,000     $50,000     $100,000     $500,000     $1,000,000     and over
- -------------------------------------------------------------------------------------------------------------
<S>                <C>      <C>    <C>         <C>         <C>          <C>          <C>          <C>
David Hamlin        2004      *
- -------------------------------------------------------------------------------------------------------------
Portfolio Leader    2003      *
- -------------------------------------------------------------------------------------------------------------
Paul Drury          2004      *
- -------------------------------------------------------------------------------------------------------------
Portfolio Member    2003      *
- -------------------------------------------------------------------------------------------------------------
Susan McCormack     2004      *
- -------------------------------------------------------------------------------------------------------------
Portfolio Member    2003      *
- -------------------------------------------------------------------------------------------------------------
James St. John      2004      *
- -------------------------------------------------------------------------------------------------------------
Portfolio Member    2003      *
- -------------------------------------------------------------------------------------------------------------
</TABLE>

Other funds managed by the Portfolio Leader and Portfolio Members

David Hamlin is the Portfolio Leader and Paul Drury, Susan McCormack,
and James St. John are Portfolio Members for Putnam's tax-exempt funds
for the following states: Arizona, California, Florida, Massachusetts,
Michigan, Minnesota, New Jersey, New York, Ohio, and Pennsylvania. The
same group also manages Putnam AMT-Free Insured Municipal Fund*, Putnam
California Investment Grade Municipal Trust, Putnam High Yield Municipal
Trust, Putnam Investment Grade Municipal Trust, Putnam Municipal Bond
Fund, Putnam Municipal Income Fund, Putnam Municipal Opportunities
Trust, Putnam New York Investment Grade Municipal Trust, Putnam Tax
Exempt Income Fund, Putnam Tax-Free Health Care Fund, and Putnam
Tax-Free High Yield Fund.

David Hamlin, Paul Drury, Susan McCormack, and James St. John may also
manage other accounts advised by Putnam Management or an affiliate.

Changes in your fund's Portfolio Leader and Portfolio Members

During the year ended October 31, 2004, Portfolio Member Richard Wyke
left your fund's management team.

Footnote reads:
*Formerly Putnam Tax-Free Insured Fund.


Performance summary

This section shows your fund's performance during its fiscal year, which
ended October 31, 2004. 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. Data represents past performance. Past performance does not
guarantee 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.

<TABLE>
<CAPTION>
- ------------------------------------------------------------------------------------
TOTAL RETURN AND COMPARATIVE INDEX RESULTS FOR PERIODS ENDED 10/31/04
- ------------------------------------------------------------------------------------
                                                                   Lipper
                                                                   High Yield
                                                     Lehman        Municipal
                                                     Municipal     Debt Funds
                                       Market        Bond          (closed-end)
                          NAV          price         Index         category average*
- ------------------------------------------------------------------------------------
<S>                     <C>          <C>            <C>            <C>
1 year                   9.76%         6.35%         6.02%            8.57%
- ------------------------------------------------------------------------------------
5 years                 34.49          7.12         41.48            33.12
Annual average           6.11          1.39          7.19             5.85
- ------------------------------------------------------------------------------------
10 years                79.54         64.16         97.69            82.00
Annual average           6.03          5.08          7.05             6.14
- ------------------------------------------------------------------------------------
Annual average
Life of fund
(since 2/24/89)          7.02          5.75          7.30             5.99
- ------------------------------------------------------------------------------------
</TABLE>

Performance assumes reinvestment of distributions and does not account
for taxes.

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

* Over the 1-, 5-, and 10-year periods ended 10/31/04, there were 14,
  12, and 12 funds, respectively, in this Lipper category.

<TABLE>
<CAPTION>
- ---------------------------------------------------------------------
TOTAL RETURN FOR PERIODS ENDED 9/30/04 (MOST RECENT CALENDAR QUARTER)
- ---------------------------------------------------------------------
                                   NAV             Market price
- ---------------------------------------------------------------------
<S>                               <C>                 <C>
1 year                             8.35%               2.64%
- ---------------------------------------------------------------------
5 years                           30.25                4.42
Annual average                     5.43                0.87
- ---------------------------------------------------------------------
10 years                          73.76               57.73
Annual average                     5.68                4.66
- ---------------------------------------------------------------------
Annual average
Life of fund
(since 2/24/89)                    6.99                5.73
- ---------------------------------------------------------------------
</TABLE>

<TABLE>
<CAPTION>
- -------------------------------------------------------------------------------------------------------------
PRICE AND DISTRIBUTION INFORMATION 12 MONTHS ENDED 10/31/04
- -------------------------------------------------------------------------------------------------------------
<S>                                             <C>                     <C>                    <C>
Distributions from common shares
- -------------------------------------------------------------------------------------------------------------
Number                                                                   12
- -------------------------------------------------------------------------------------------------------------
Income 1                                                                 $0.5013
- -------------------------------------------------------------------------------------------------------------
Capital gains 1                                                          --
- -------------------------------------------------------------------------------------------------------------
Total                                                                    $0.5013
- -------------------------------------------------------------------------------------------------------------
                                                  Series A                Series B                 Series C
Distributions from prefer shares                 (550 shares)           (550 shares)             (650 shares)
- -------------------------------------------------------------------------------------------------------------
Income 1                                         $1,137.98               $1,216.21                $1,129.99
- -------------------------------------------------------------------------------------------------------------
Capital gains 1                                  --                      --                       --
- -------------------------------------------------------------------------------------------------------------
Total                                            $1,137.98               $1,216.21                $1,129.99
- -------------------------------------------------------------------------------------------------------------
Share value (common shares)                                                 NAV                 Market price
- -------------------------------------------------------------------------------------------------------------
10/31/03                                                                  $7.98                    $7.34
- -------------------------------------------------------------------------------------------------------------
10/31/04                                                                   8.18                     7.29
- -------------------------------------------------------------------------------------------------------------
Current return (common shares, end of period)
- -------------------------------------------------------------------------------------------------------------
Current dividend rate 2                                                   6.12%                    6.86%
- -------------------------------------------------------------------------------------------------------------
Taxable equivalent 3                                                       9.42                    10.55
- -------------------------------------------------------------------------------------------------------------
</TABLE>

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 2004. 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
exchanges such as the American Stock Exchange and the New York 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 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.

Proxy voting

Putnam is committed to managing our mutual funds in the best interests
of our shareholders. The Putnam funds' proxy voting guidelines and
procedures, as well as information regarding how your fund voted proxies
relating to portfolio securities during the 12-month period ended June
30, 2004, are available on the Putnam Individual Investor Web site,
www.putnaminvestments.com/individual, and on the SEC's Web site,
www.sec.gov. If you have questions about finding forms on the SEC's Web
site, you may call the SEC at 1-800-SEC-0330. You may also obtain the
Putnam funds' proxy voting guidelines and procedures at no charge by
calling Putnam's Shareholder Services at 1-800-225-1581.

Fund portfolio holdings

For periods ending on or after July 9, 2004, the fund will file a
complete schedule of its portfolio holdings with the SEC for the first
and third quarters of each fiscal year on Form N-Q. Shareholders may
obtain the fund's Forms N-Q on the SEC's Web site at www.sec.gov. In
addition, the fund's Forms N-Q may be reviewed and copied at the SEC's
public reference room in Washington, D.C. You may call the SEC at
1-800-SEC-0330 for information about the SEC's Web site or the operation
of the public reference room.


A guide to the financial statements

These sections of the report, as well as the accompanying Notes,
preceded by the Report of Independent Registered Public Accounting Firm,
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 the fund's net investment gain or loss, 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.


Report of Independent Registered
Public Accounting Firm

To 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, 2004, 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 periods presented. 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 the standards of the Public
Company Accounting Oversight Board (United States). 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, 2004 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, 2004, 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 periods
presented, in conformity with accounting principles generally accepted
in the United States of America.

/S/ KPMG LLP


Boston, Massachusetts
December 7, 2004


The fund's portfolio
October 31, 2004

Key to Abbreviations
- -------------------------------------------------------------------------------
AMBAC                 AMBAC Indemnity Corporation
COP                   Certificate of Participation
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

Alabama (0.3%)
- -------------------------------------------------------------------------------
    $1,500,000 Butler, Indl. Dev. Board Rev. Bonds
               (Solid Waste Disp. James River
               Corp.), 8s, 9/1/28                    BB+             $1,540,680

Arizona (1.7%)
- -------------------------------------------------------------------------------
     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              1,000,180
     1,000,000 AZ Hlth. Fac. Auth. Hosp. Syst.
               Rev. Bonds (John C. Lincoln Hlth.
               Network), 6 3/8s, 12/1/37             BBB              1,050,000
     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             1,905,750
       500,000 Cochise Cnty., Indl. Dev. Auth.
               Rev. Bonds (Sierra Vista Regl. Hlth.
               Ctr.), Ser. A, 6.2s, 12/1/21          BB+/P              512,500
     3,000,000 Coconino Cnty., Poll. Control
               Rev. Bonds (Tuscon/Navajo Elec.
               Pwr.), Ser. A,  7 1/8s, 10/1/32       Ba3              3,120,000
       560,000 Scottsdale, Indl. Dev. Auth.
               Rev. Bonds (Westminster Village),
               7 7/8s, 6/1/09                        AAA/P              590,302
     1,000,000 Scottsdale, Indl. Dev. Auth. Hosp.
               Rev. Bonds (Scottsdale Hlth. Care),
               5.8s, 12/1/31                         A3               1,053,750
                                                                 --------------
                                                                      9,232,482

Arkansas (1.7%)
- -------------------------------------------------------------------------------
     4,600,000 AR State Hosp. Dev. Fin. Auth.
               Rev. Bonds (Washington Regl. Med.
               Ctr.), 7 3/8s, 2/1/29                 Baa3             5,094,500
     1,000,000 Little Rock G.O. Bonds (Cap. Impt.),
               FSA,  3.95s, 4/1/19                   Aaa              1,015,000
     2,750,000 Northwest Regl. Arpt. Auth.
               Rev. Bonds,  7 5/8s, 2/1/27           BB/P             2,973,438
                                                                 --------------
                                                                      9,082,938

California (12.6%)
- -------------------------------------------------------------------------------
       250,000 Association of Bay Area Governments
               (ABAG) Fin. Auth. for Nonprofit
               Corps. Rev. Bonds (San Diego Hosp.
               Assn.), Ser. C, 5 3/8s, 3/1/21        Baa1               257,813
     1,700,000 CA Hlth. Fac. Auth. IFB (Catholic
               Hlth. Care West), AMBAC, 8.806s,
               7/1/17                                Aaa              1,772,250
               CA State Dept. of Wtr. Resources
               Rev. Bonds, Ser. A
     1,000,000 6s, 5/1/15                            A2               1,160,000
    20,000,000 AMBAC, 5 1/2s, 5/1/13                 Aaa             22,925,000
     3,000,000 5 1/2s, 5/1/11                        A2               3,390,000
     2,250,000 CA Statewide Cmnty. Dev. Auth. Apt.
               Dev. Rev. Bonds (Irvine Apt.
               Cmntys.), Ser. A-3,  5.1s, 5/15/25    Baa2             2,385,000
     3,000,000 CA Statewide Cmnty. Dev. Auth. COP
               (The  Internext Group), 5 3/8s,
               4/1/30                                BBB-             2,988,750
     1,000,000 Capistrano, Unified School Dist.
               Cmnty. Fac. Special Tax (No 98-2
               Ladera), 5.7s, 9/1/20                 BB/P             1,027,500
               Chula Vista, Cmnty. Fac. Dist.
               Special Tax  Rev. Bonds
       300,000 (No 07-I-Otay Ranch Village Eleven),
               5 7/8s, 9/1/34                        BB-/P              308,250
       300,000 (No. 07-I Otay Ranch Village
               Eleven), 5.8s, 9/1/28                 BB-/P              307,500
     1,250,000 Chula Vista, Cmnty. Fac. Dist.
               Special Tax Rev. Bonds (No. 08-1
               Otay Ranch Village Six),  6s, 9/1/33  BB-/P            1,260,938
    10,775,000 Corona, COP (Vista Hosp. Syst.),
               zero %, 7/1/29 (In default) (NON)     D/P                215,500
       750,000 Folsom, Special Tax Rev. Bonds
               (Cmnty. Facs. Dist. No. 10), 5 7/8s,
               9/1/28                                BB/P               763,125
     1,970,000 Gilroy, Rev. Bonds (Bonfante Gardens
               Park),  8s, 11/1/25                   D/P              1,393,775
     2,500,000 Golden State Tobacco Securitization
               Corp. Rev. Bonds, Ser. B, 5 5/8s,
               6/1/38                                A-               2,653,125
     1,100,000 Murrieta, Cmnty. Fac. Dist. Special
               Tax (No. 2 The Oaks Impt. Area A),
               6s, 9/1/34                            BB-/P            1,120,625
       650,000 Orange Cnty., Cmnty. Fac. Dist.
               Special Tax Rev. Bonds (No. 02-1
               Ladera Ranch), Ser. A,  5.55s,
               8/15/33                               BB+/P              663,000
     1,250,000 Sacramento, Special Tax (North
               Natomas Cmnty. Fac.), Ser. 4-C, 6s,
               9/1/33                                BB+/P            1,292,188
     7,000,000 San Bernardino Cnty.,
               Certificates of Participation (Med.
               Ctr. Fin.), Ser. A, MBIA, 6 1/2s,
               8/1/28                                Aaa              7,387,170
     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              8,940,050
     2,520,000 Santaluz Cmnty., Facs. Dist. No. 2
               Special Tax Rev. Bonds (Impt. Area
               No. 1), Ser. B,  6 3/8s, 9/1/30       BB+/P            2,583,000
     4,000,000 Thousand Oaks, Cmnty. Fac. Dist.
               Special Tax Rev. Bonds (Marketplace
               94-1), zero %, 9/1/14                 B/P              1,980,000
     2,500,000 Vallejo, COP (Marine World
               Foundation),  7.2s, 2/1/26            BBB-/P           2,568,750
                                                                 --------------
                                                                     69,343,309

Colorado (1.9%)
- -------------------------------------------------------------------------------
     3,015,000 CO Hlth. Fac. Auth.
               Rev. Bonds (Evangelical Lutheran),
               3.05s, 10/1/05                        A3               3,038,487
               CO Hwy. Auth. Rev. Bonds (E-470 Pub.
               Hwy.), Ser. B
    15,500,000 zero %, 9/1/35                        Baa3             1,608,125
    16,500,000 zero %, 9/1/34                        Baa3             1,835,625
               Denver, City & Cnty. Arpt.
               Rev. Bonds
     1,050,000 Ser. D, AMBAC, 7 3/4s, 11/15/13       AAA              1,303,313
     2,500,000 MBIA, 5 1/2s, 11/15/25                Aaa              2,659,375
                                                                 --------------
                                                                     10,444,925

Connecticut (1.6%)
- -------------------------------------------------------------------------------
               CT State Hlth. & Edl. Fac. Auth.
               VRDN
     7,000,000 Ser. U, 1.64s, 7/1/33                 VMIG1            7,000,000
     2,000,000 (Yale U.), Ser. U2, 1.64s, 7/1/33     VMIG1            2,000,000
                                                                 --------------
                                                                      9,000,000

District of Columbia (0.7%)
- -------------------------------------------------------------------------------
     4,000,000 DC Tobacco Settlement Fin. Corp.
               Rev. Bonds, 6 1/2s, 5/15/33           BBB              3,780,000

Florida (3.7%)
- -------------------------------------------------------------------------------
     2,000,000 Cap. Trust Agcy. Rev. Bonds
               (Seminole Tribe Convention), Ser. A,
               10s, 10/1/33                          B/P              2,467,500
     1,500,000 CFM Cmnty. Dev. Dist. Rev. Bonds,
               Ser. A,  6 1/4s, 5/1/35               BB-/P            1,539,375
               Fishhawk, Cmnty. Dev. Dist. II
               Rev. Bonds
       500,000 Ser. A, 6 1/8s, 5/1/34                BB-/P              510,625
     1,025,000 Ser. B, 5s, 11/1/07                   BB-/P            1,035,250
       770,000 FL State Mid-Bay Bridge Auth.
               Rev. Bonds, Ser. A, 6.05s, 10/1/22    BBB/P              796,950
       500,000 Fleming Island, Plantation Cmnty.
               Dev. Dist. Special Assmt.
               Rev. Bonds, Ser. B, 7 3/8s, 5/1/31    BB/P               541,250
       480,000 Gateway Svcs. Cmnty. Dev. Dist.
               Special Assmt. Bonds (Stoneybrook),
               5 1/2s, 7/1/08                        BB-/P              492,600
       500,000 Heritage Harbor, South Cmnty. Dev.
               Distr. Rev. Bonds, Ser. A, 6 1/2s,
               5/1/34                                BB-/P              526,875
       575,000 Heritage Isle at Viera, Cmnty. Dev.
               Dist. Special Assmt., Ser. B, 5s,
               11/1/09                               BB/P               577,875
     1,250,000 Islands at Doral III, Cmnty. Dev.
               Dist. Special Assmt. Rev. Bonds,
               Ser. 04-A, 5.9s, 5/1/35               BB               1,265,625
     1,000,000 Lee Cnty., Indl. Dev. Auth.
               Rev. Bonds (Alliance Cmnty.
               Project), Ser. C, 5 1/2s, 11/15/29    BBB-               970,000
     1,335,000 Miami Beach, Hlth. Fac. Auth. Hosp.
               Rev. Bonds (Mount Sinai Med. Ctr.),
               Ser. A, 6.7s, 11/15/19                BB               1,391,738
        40,000 Oakstead Cmnty. Dev. Dist. Cap.
               Impt. Rev. Bonds, Ser. B, 6 1/2s,
               5/1/07                                BB/P                40,750
     1,500,000 Reunion West, Cmnty. Dev. Dist.
               Special Assmt., 6 1/4s, 5/1/36        BB-/P            1,526,250
     1,500,000 South Miami, Hlth. Fac. Auth.
               Rev. Bonds (Baptist Hlth.), 5 1/4s,
               11/15/33                              Aa3              1,543,125
     1,500,000 St. Johns Cnty., Hlth. Care Indl.
               Dev. Auth. Rev. Bonds (Glenmoor St.
               Johns Project), Ser. A,  8s, 1/1/30   B-/P             1,573,125
     1,000,000 Sterling Hill, Cmnty. Dev. Dist.
               Rev. Bonds, Ser. B, 5 1/2s, 11/1/10   BB-/P            1,017,500
     1,250,000 Westchester Cmnty. Dev. Dist. No. 1
               Special Assmt. (Cmnty.
               Infrastructure), 6 1/8s, 5/1/35       BB-/P            1,271,875
     1,250,000 World Commerce Cmnty. Dev. Dist.
               Special Assmt., Ser. A-1, 6 1/2s,
               5/1/36                                BB-/P            1,270,313
                                                                 --------------
                                                                     20,358,601

Georgia (1.9%)
- -------------------------------------------------------------------------------
     4,000,000 Burke Cnty., Poll. Control Dev.
               Auth. Mandatory Put Bonds (GA Power
               Co.), 4.45s, 12/1/08                  A2               4,245,000
       425,000 Fulton Cnty., Res. Care Fac.
               Rev. Bonds (Canterbury Court), Class
               A, 6 1/8s, 2/15/34                    B+/P               427,656
       700,000 GA Med. Ctr. Hosp. Auth. IFB, MBIA,
               10.777s, 8/1/10                       Aaa                704,319
     2,500,000 Muni. Elec. Auth. Rev. Bonds, AMBAC,
               5s, 1/1/26                            Aaa              2,718,750
     2,145,000 Rockdale Cnty., Dev. Auth. Solid
               Waste Disp. Rev. Bonds (Visay Paper,
               Inc.), 7.4s, 1/1/16                   B+/P             2,217,051
                                                                 --------------
                                                                     10,312,776

Hawaii (0.3%)
- -------------------------------------------------------------------------------
     1,760,000 HI Dept. of Trans. Special Fac.
               Rev. Bonds (Continental Airlines,
               Inc.), 7s, 6/1/20                     B                1,496,000

Illinois (1.4%)
- -------------------------------------------------------------------------------
     3,500,000 Chicago, G.O. Bonds, Ser. A, AMBAC,
               5 5/8s, 1/1/39                        Aaa              3,836,875
     3,250,000 IL Dev. Fin. Auth. Hosp. Rev. Bonds
               (Adventist Hlth. Syst./Sunbelt
               Obligation), 5.65s, 11/15/24          A                3,400,312
       500,000 IL Hlth. Fac. Auth. Rev. Bonds (St.
               Benedict), Ser. 03A-1, 6.9s,
               11/15/33                              B+/P               508,750
                                                                 --------------
                                                                      7,745,937

Indiana (2.0%)
- -------------------------------------------------------------------------------
     2,500,000 IN State Dev. Fin. Auth. Env. Impt.
               Rev. Bonds (USX Corp.), 5.6s,
               12/1/32                               Baa1             2,543,750
     6,500,000 IN Trans. Fin. Auth. Arpt. Facs.
               Lease Rev. Bonds, Ser. A, AMBAC, 5s,
               11/1/16                               Aaa              6,825,000
     1,750,000 Rockport, Poll. Control Mandatory
               Put Bonds (Indiana Michigan Pwr.
               Co.), Ser. C, 2 5/8s, 10/1/06         Baa2             1,745,625
                                                                 --------------
                                                                     11,114,375

Iowa (0.9%)
- -------------------------------------------------------------------------------
               IA Fin. Auth. Hlth. Care Fac.
               Rev. Bonds (Care Initiatives)
     2,940,000 9 1/4s, 7/1/25                        BBB-/P           3,564,750
     1,350,000 9.15s, 7/1/09                         BBB-/P           1,581,188
                                                                 --------------
                                                                      5,145,938

Kentucky (0.6%)
- -------------------------------------------------------------------------------
     1,000,000 Boone Cnty., Poll. Control
               Rev. Bonds (Dayton Pwr. & Lt. Co.),
               Ser. A, 6 1/2s, 11/15/22              Baa3             1,018,370
     1,700,000 KY Econ. Dev. Fin. Auth. Rev. Bonds
               (Norton Hlth. Care, Inc.), Ser. A,
               6 1/2s, 10/1/20                       BBB/P            1,853,000
       460,000 Scott Cnty., Indl. Dev. Rev. Bonds
               (Hoover Group, Inc.), 8 1/2s,
               11/1/14                               Ba3                253,000
                                                                 --------------
                                                                      3,124,370

Louisiana (0.8%)
- -------------------------------------------------------------------------------
     1,140,000 LA Pub. Fac. Auth. Hosp. Rev. Bonds
               (Lake Charles Memorial Hosp.),
               8 5/8s, 12/1/30                       CCC/P              919,125
       500,000 Tangipahoa Parish Hosp. Svcs.
               Rev. Bonds (North Oaks Med. Ctr.),
               Ser. A, 5s, 2/1/25                    A                  502,500
     2,750,000 W. Feliciana Parish, Poll. Control
               Rev. Bonds (Gulf States Util. Co.),
               Ser. C, 7s, 11/1/15                   Ba1              2,825,433
                                                                 --------------
                                                                      4,247,058

Maine (0.8%)
- -------------------------------------------------------------------------------
     1,965,000 ME State Hsg. Auth. Rev. Bonds,
               Ser. D-2-AMT,  5s, 11/15/27           Aa1              2,070,619
     2,000,000 Rumford, Solid Waste Disp.
               Rev. Bonds (Boise Cascade Corp.),
               6 7/8s, 10/1/26                       Ba2              2,115,000
                                                                 --------------
                                                                      4,185,619

Maryland (0.5%)
- -------------------------------------------------------------------------------
     1,000,000 MD State Hlth. & Higher Edl. Fac.
               Auth. Rev. Bonds (Medstar Hlth.),
               5 3/4s, 8/15/15                       Baa2             1,102,500
     1,850,000 Westminster, Econ. Dev. Rev. Bonds
               (Carroll Lutheran Village), Ser. A,
               5 7/8s, 5/1/21                        BB/P             1,882,375
                                                                 --------------
                                                                      2,984,875

Massachusetts (6.4%)
- -------------------------------------------------------------------------------
       600,000 Boston, Indl. Dev. Fin. Auth.
               Rev. Bonds (Springhouse, Inc.), 6s,
               7/1/28                                BB-/P              563,250
               MA State Hlth. & Edl. Fac. Auth.
               Rev. Bonds
     2,000,000 (Civic Investments), Ser. A, 9s,
               12/15/15                              BB/P             2,300,000
     1,185,000 (Norwood Hosp.), Ser. C, 7s, 7/1/14   Ba2              1,499,025
     1,200,000 (Jordan Hosp.), Ser. E, 6 3/4s,
               10/1/33                               BBB-             1,260,000
     2,225,000 (UMass Memorial), Ser. C, 6 5/8s,
               7/1/32                                Baa2             2,364,063
     1,875,000 (UMass Memorial), Ser. C, 6 1/2s,
               7/1/21                                Baa2             2,017,969
     1,500,000 (Caritas Christi Oblig. Group),
               Ser. A,  5 1/4s, 7/1/08               BBB              1,591,875
               MA State Hsg. Fin. Agcy. Rev. Bonds
               (Rental Mtge.)
     2,000,000 Ser. C, AMBAC, 5 5/8s, 7/1/40         Aaa              2,062,500
    15,290,000 Ser. A, AMBAC, 5 1/2s, 7/1/40         Aaa             15,729,588
               MA State Indl. Fin. Agcy. Rev. Bonds
       500,000 (1st Mtge. Stone Institution &
               Newton),  7.9s, 1/1/24                BB-/P              510,840
     1,000,000 (1st Mtge. Brookhaven), Ser. A, 7s,
               1/1/15                                BBB/P            1,027,500
     1,000,000 (1st Mtge. Brookhaven), Ser. A, 7s,
               1/1/09                                BBB/P            1,035,000
     1,550,000 (1st Mtge. Berkshire Retirement),
               Ser. A,  6 5/8s, 7/1/16               BBB-             1,571,313
     1,500,000 (1st Mtge. Brookhaven), Ser. B,
               5 1/4s, 1/1/17                        BBB/P            1,507,500
                                                                 --------------
                                                                     35,040,423

Michigan (3.0%)
- -------------------------------------------------------------------------------
       500,000 Flint, Hosp. Bldg. Auth. Rev. Bonds
               (Hurley Med. Ctr.), 6s, 7/1/20        Baa3               508,125
       350,000 Garden City, Hosp. Fin. Auth.
               Rev. Bonds (Garden City Hosp. OB
               Group), Ser. A, 5 3/4s, 9/1/17        Ba2                330,750
     1,100,000 Macomb Cnty., Hosp. Fin. Auth.
               Rev. Bonds (Mt. Clemens Gen. Hosp.),
               Ser. B, 5 7/8s, 11/15/34              BB               1,027,125
     1,500,000 MI State Hosp. Fin. Auth. Rev. Bonds
               (Oakwood Hosp.), Ser. A, 6s, 4/1/22   A2               1,631,250
     2,000,000 Midland Cnty., Econ. Dev. Corp.
               Rev. Bonds, 6 3/4s, 7/23/09           Ba3              2,087,500
     1,700,000 Pontiac, Hosp. Fin. Auth. Rev. Bonds
               (NOMC Obligation Group), Ser. B, 6s,
               8/1/18                                Ba1              1,515,125
     2,975,000 Warren Cons. School Dist. G.O.
               Bonds, FSA,  5 3/8s, 5/1/18           Aaa              3,279,938
     6,670,000 Waterford, Econ. Dev. Corp.
               Rev. Bonds (Canterbury Hlth.), 6s,
               1/1/39                                B-/P             4,935,800
     2,000,000 Wayne Charter Cnty., Special Arpt.
               Fac. Rev. Bonds (Northwest Airlines,
               Inc.), 6s, 12/1/29                    B+/P             1,385,000
                                                                 --------------
                                                                     16,700,613

Minnesota (0.8%)
- -------------------------------------------------------------------------------
       500,000 Minneapolis, Rev. Bonds (Walker
               Methodist Sr. Svcs.), Ser. C, 6s,
               11/15/28                              B+/P               390,625
       500,000 Northfield, Hlth. Care Fac.
               Rev. Bonds (Retirement Ctr.),
               Ser. A, 5 3/4s, 5/1/16                B/P                500,620
       400,000 Sauk Rapids Hlth. Care & Hsg. Fac.
               Rev. Bonds (Good Shepherd Lutheran
               Home), 6s, 1/1/34                     B/P                404,000
     3,055,000 St. Paul, Hsg. & Hosp. Redev. Auth.
               Rev. Bonds (Healtheast), Ser. B,
               6 5/8s, 11/1/17                       Ba2              3,086,925
                                                                 --------------
                                                                      4,382,170

Mississippi (0.7%)
- -------------------------------------------------------------------------------
     1,500,000 Lowndes Cnty., Solid Waste Disp. &
               Poll. Control Rev. Bonds
               (Weyerhaeuser Co.), Ser. B,  6.7s,
               4/1/22                                Baa2             1,785,000
     2,250,000 MS Bus. Fin. Corp. Poll. Control
               Rev. Bonds  (Syst. Energy Resources,
               Inc.), 5.9s, 5/1/22                   BBB              2,275,313
                                                                 --------------
                                                                      4,060,313

Missouri (1.2%)
- -------------------------------------------------------------------------------
     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                1,546,875
     1,500,000 Kansas City, Indl. Dev. Auth. Hlth.
               Fac. Rev. Bonds (First Mtg. Bishop
               Spencer), Ser. A,  6 1/2s, 1/1/35     BB-/P            1,530,000
     1,985,000 MO Hsg. Dev. Comm. Rev. Bonds (Home
               Ownership), GNMA/FNMA Coll., 5.55s,
               9/1/34                                AAA              2,171,094
     1,450,000 MO State Hlth. & Edl. Fac. Auth.
               Rev. Bonds (BJC Hlth. Syst.),
               5 1/4s, 5/15/32                       Aa2              1,497,125
                                                                 --------------
                                                                      6,745,094

Montana (0.3%)
- -------------------------------------------------------------------------------
     1,775,000 Forsyth, Poll. Control Mandatory Put
               Bonds (Avista Corp.), AMBAC, 5s,
               12/30/08                              Aaa              1,912,562

Nebraska (0.1%)
- -------------------------------------------------------------------------------
       920,000 Gage Cnty., Indl. Dev. Rev. Bonds
               (Hoover Group, Inc.), 8 1/2s,
               12/1/07                               Ba3                506,000
               Kearney, Indl. Dev. Rev. Bonds
        68,154 (Great Platte River), 8s, 9/1/12      CCC/P               59,124
       791,466 (Brookhaven), zero %, 9/1/12          CCC/P                3,957
                                                                 --------------
                                                                        569,081

Nevada (2.1%)
- -------------------------------------------------------------------------------
     1,000,000 Clark Cnty., Impt. Dist. Special
               Assmt. (Dist. No. 142), 6 3/8s,
               8/1/23                                BB-/P            1,017,500
     5,000,000 Clark Cnty., Indl. Dev. Rev. Bonds
               (Southwest Gas Corp.), Ser. C,
               AMBAC, 5.95s, 12/1/38                 Aaa              5,593,750
     1,595,000 Henderson, Local Impt. Dist. Special
               Assmt. (No. T-14), 3.2s, 3/1/06       BB-/P            1,598,988
       500,000 Henderson, Local Impt. Dist. Special
               Assmt. Bonds (No. T-14), 5.8s,
               3/1/23                                BB-/P              514,375
       875,000 Las Vegas, Local Impt. Board Special
               Assmt. (Dist. No. 607), 5.9s, 6/1/18  BB-/P              901,294
     2,000,000 Washoe Cnty., Wtr. Fac. Mandatory
               Put Bonds (Sierra Pacific Pwr. Co.),
               5s, 7/1/09                            Ba2              2,017,500
                                                                 --------------
                                                                     11,643,407

New Hampshire (1.0%)
- -------------------------------------------------------------------------------
     1,275,000 NH Hlth. & Ed. Fac. Auth. Rev. Bonds
               (Kendal at Hanover), Ser. A, 5s,
               10/1/18                               BBB              1,287,750
     2,565,000 NH State Bus. Fin. Auth. Rev. Bonds
               (Alice Peck Day Hlth. Syst.),
               Ser. A, 7s, 10/1/29                   BBB-/P           2,597,063
     1,750,000 NH State Bus. Fin. Auth. Poll.
               Control Rev. Bonds, 3 1/2s, 7/1/27    Baa2             1,763,125
                                                                 --------------
                                                                      5,647,938

New Jersey (2.7%)
- -------------------------------------------------------------------------------
               NJ Econ. Dev. Auth. Rev. Bonds
     1,300,000 (Cranes Mill), Ser. A, 7 1/2s,
               2/1/27                                BB-/P            1,360,125
     1,250,000 (Cedar Crest Vlg., Inc.), Ser. A,
               7 1/4s, 11/15/31                      BB-/P            1,298,438
     1,500,000 (Newark Arpt. Marriot Hotel), 7s,
               10/1/14                               Ba3              1,558,125
       500,000 (First Mtge. Presbyterian Home),
               Ser. A,  6 3/8s, 11/1/31              BB/P               511,250
     2,500,000 (Cigarette Tax), 5 1/2s, 6/15/24      Baa2             2,559,375
     1,750,000 NJ Econ. Dev. Auth. Solid Waste
               Rev. Bonds (Disp. Waste Management),
               5.3s, 6/1/15                          BBB              1,859,375
               NJ Hlth. Care Fac. Fin. Auth.
               Rev. Bonds
     1,300,000 (Trinitas Hosp. Oblig. Group),
               7 1/2s, 7/1/30                        Baa3             1,465,750
     2,000,000 (United Methodist Homes), Ser. A,
               5 3/4s, 7/1/29                        BB+              1,935,000
     1,250,000 (Atlantic City Med. Ctr.), 5 3/4s,
               7/1/25                                A2               1,320,313
     1,000,000 (Somerset Med. Ctr.), 5 1/2s, 7/1/33  Baa2             1,011,250
                                                                 --------------
                                                                     14,879,001

New Mexico (0.3%)
- -------------------------------------------------------------------------------
     1,740,000 Farmington, Poll. Control Mandatory
               Put Bonds (Pub. Svc. San Juan),
               Class B, 2.1s, 4/1/06                 Baa2             1,726,950

New York (12.6%)
- -------------------------------------------------------------------------------
       500,000 Huntington, Hsg. Auth. Rev. Bonds
               (Gurwin Jewish Sr. Residence),
               Ser. A, 6s, 5/1/39                    B+/P               465,625
     3,600,000 Long Island, Pwr. Auth. NY Elec.
               Syst. Rev. Bonds, Ser. A, 5 3/4s,
               12/1/24                               A-               3,874,500
     2,000,000 Nassau Cnty., Indl. Dev. Agcy.
               Rev. Bonds (Keyspan-Glenwood),
               5 1/4s, 6/1/27                        A                2,047,500
    13,000,000 Nassau Cnty., Interim Fin. Auth.
               Rev. Bonds, Ser. B, MBIA, 5s,
               11/15/10                              Aaa             14,462,500
    10,000,000 NY City, G.O. Bonds, Ser. B, 5 1/4s,
               12/1/09                               A2              11,100,000
     1,500,000 NY City, Indl. Dev. Agcy. Rev. Bonds
               (Visy Paper, Inc.), 7.95s, 1/1/28     B-/P             1,567,500
     3,025,000 NY City, Indl. Dev. Agcy. Special
               Fac. Rev. Bonds (British Airways),
               5 1/4s, 12/1/32                       BB+              2,212,018
     1,490,000 NY City, Indl. Dev. Agency
               Rev. Bonds (Staten Island U. Hosp.
               Project), 6.45s, 7/1/32               Ba3              1,445,300
    10,000,000 NY City, Muni. Wtr. Fin. Auth.
               Rev. Bonds, Ser. C, MBIA, 5 1/2s,
               6/15/17                               Aaa             10,625,000
       900,000 NY State Dorm. Auth. Rev. Bonds
               (Winthrop- U. Hosp. Assn.), Ser. A,
               5 1/2s, 7/1/32                        Baa1               930,375
     2,000,000 Onondaga Cnty., Indl. Dev. Agcy.
               Rev. Bonds (Solvay Paperboard, LLC),
               7s, 11/1/30 (acquired 12/9/98, cost
               $2,000,000) (RES)                     BB-/P            2,117,500
    15,000,000 Port. Auth. NY & NJ Special
               Obligation Rev. Bonds (JFK Intl. Air
               Term. - 6), MBIA, 5.9s, 12/1/17       Aaa             16,406,250
     1,700,000 Suffolk Cnty., Indl. Dev. Agcy.
               Rev. Bonds (Peconic Landing),
               Ser. A, 8s, 10/1/30                   B+/P             1,795,625
                                                                 --------------
                                                                     69,049,693

North Carolina (1.5%)
- -------------------------------------------------------------------------------
               NC Eastern Muni. Pwr. Agcy. Syst.
               Rev. Bonds
     1,500,000 Ser. D, 6 3/4s, 1/1/26                Baa2             1,670,625
     3,000,000 Ser. A, 5 3/4s, 1/1/26                Baa2             3,153,750
       750,000 NC Med. Care Cmnty. Healthcare Fac.
               Rev. Bonds (Deerfield), Ser. A, 5s,
               11/1/23                               A-/P               758,438
               NC State Muni. Pwr. Agcy. Rev. Bonds
               (No. 1, Catawba Elec.)
     1,000,000 Ser. B, 6 1/2s, 1/1/20                Baa1             1,130,000
     1,300,000 Ser. A, 5 1/2s, 1/1/13                Baa1             1,439,750
                                                                 --------------
                                                                      8,152,563

Ohio (2.6%)
- -------------------------------------------------------------------------------
               Cuyahoga Cnty., Rev. Bonds, Ser. A
     1,280,000 6s, 1/1/16                            A1               1,470,400
     2,000,000 6s, 1/1/15                            A1               2,302,500
     3,000,000 OH State Air Quality Dev. Auth.
               Rev. Bonds (Toledo Poll. Control),
               Ser. A, 6.1s, 8/1/27                  Baa2             3,127,500
     5,100,000 OH State Air Quality Dev. Auth.
               VRDN (Columbus Southern), Ser. C,
               1.77s, 12/1/38                        VMIG1            5,100,000
     2,100,000 OH State Solid Waste Rev. Bonds
               (General Motors Corp.), 6.3s,
               12/1/32                               Baa2             2,218,125
                                                                 --------------
                                                                     14,218,525

Oklahoma (2.3%)
- -------------------------------------------------------------------------------
     3,150,000 OK City Arpt. Trust Rev. Bonds Jr.
               Lien 27th Ser., Ser. A, FSA, 5s,
               7/1/18                                Aaa              3,342,938
     1,575,000 OK Dev. Fin. Auth. Rev. Bonds
               (Hillcrest Hlth. Care Syst.),
               Ser. A, U.S. Govt. Coll., 5 5/8s,
               8/15/29                               AAA              1,787,625
     7,000,000 OK State Indl. Dev. Auth. Rev. Bonds
               (Hlth. Syst.-Oblig. Group), Ser. A,
               MBIA, 5 3/4s, 8/15/29                 Aaa              7,612,500
                                                                 --------------
                                                                     12,743,063

Oregon (0.6%)
- -------------------------------------------------------------------------------
     2,000,000 Multnomah Cnty., Hosp. Fac. Auth.
               Rev. Bonds (Terwilliger Plaza),
               6 1/2s, 12/1/29                       BB-/P            2,057,500
     1,000,000 OR State Hsg. & Cmnty. Svcs. Dept.
               Rev. Bonds (Single Family Mtg.),
               Ser. K, 5 5/8s, 7/1/29                Aa2              1,076,250
                                                                 --------------
                                                                      3,133,750

Pennsylvania (7.9%)
- -------------------------------------------------------------------------------
     1,995,000 Carbon Cnty., Indl. Dev. Auth.
               Rev. Bonds (Panther Creek Partners),
               6.65s, 5/1/10                         BBB-             2,162,081
     1,750,000 Dauphin Cnty., Gen. Auth. Rev. Bonds
               (Office & Pkg.), Ser. A, 6s, 1/15/25  D/P                813,750
       350,000 Lebanon Cnty., Hlth. Fac. Auth.
               Rev. Bonds (Good Samaritan Hosp.),
               6s, 11/15/35                          Baa1               360,500
     1,000,000 Lehigh Cnty., Gen. Purpose Auth.
               Rev. Bonds (Lehigh Valley Hosp.
               Hlth. Network), Ser. A, 5 1/4s,
               7/1/32                                A2               1,020,000
       500,000 Monroe Cnty., Hosp. Auth. Rev. Bonds
               (Pocono  Med. Ctr.), 6s, 1/1/43       BBB+               520,625
               PA Convention Ctr. Auth. Rev. Bonds
       750,000 Ser. A, 6 3/4s, 9/1/19                Baa2               769,425
     7,250,000 MBIA, 6.7s, 9/1/14                    Aaa              7,455,175
               PA Econ. Dev. Fin. Auth. Rev. Bonds
     7,750,000 (MacMillan Ltd. Partnership), 7.6s,
               12/1/20                               Baa2             8,355,895
     1,000,000 (Amtrak), Ser. A, 6 3/8s, 11/1/41     A3               1,048,750
               PA State Econ. Dev. Fin. Auth.
               Resource Recvy. Rev. Bonds
     1,750,000 (Colver), Ser. E, 8.05s, 12/1/15      BBB-/P           1,790,478
     1,000,000 (Colver), Ser. D, 7 1/8s, 12/1/15     BBB-             1,023,750
     4,200,000 (Northampton Generating), Ser. A,
               6.6s, 1/1/19                          BBB-             4,252,500
               PA State Higher Edl. Fac. Auth.
               Rev. Bonds
     1,000,000 (Widener U.), 5.4s, 7/15/36           BBB+             1,031,250
       995,000 (Philadelphia College of Osteopathic
               Medicine), 5s, 12/1/07                A                1,060,919
     5,715,000 Philadelphia, Gas Wks. Rev. Bonds
               (1975 Gen. Ordinance 17th), FSA, 5s,
               7/1/07                                Aaa              6,129,338
     2,729,624 Philadelphia, Hosp. & Higher Ed.
               Fac. Auth. Rev. Bonds (Graduate
               Hlth. Syst.), 7 1/4s, 7/1/10 (In
               default) (NON)                        D/P                  3,412
     2,000,000 Philadelphia, Indl. Dev. Auth. VRDN
               (Fox Chase Cancer Ctr.), 1.74s,
               7/1/25                                A-1+             2,000,000
     2,000,000 Philadelphia, Indl. Dev. Auth. Arpt.
               Rev. Bonds (Aero Philadelphia, LLC),
               5 1/2s, 1/1/24                        BB/P             1,852,500
     1,800,000 Sayre, Hlth. Care Fac. Auth.
               Rev. Bonds (Guthrie Hlth.), Ser. A,
               5 7/8s, 12/1/31                       A-               1,874,250
                                                                 --------------
                                                                     43,524,598

South Carolina (1.6%)
- -------------------------------------------------------------------------------
       775,000 Lexington Cnty. Rev. Bonds, 5 1/2s,
               11/1/32                               A2                 801,156
     1,000,000 Lexington Cnty. Hlth. Svcs. Dist.
               Inc. Hosp. Rev. Bonds, 5 1/2s,
               5/1/37                                A2               1,028,750
     3,000,000 Richland Cnty., Rev. Bonds (Intl.
               Paper Co.), Ser. A, 4 1/4s, 10/1/07   Baa2             3,116,250
     1,250,000 SC Hosp. Auth. Rev. Bonds (Med. U.),
               Ser. A, 6 1/2s, 8/15/32               BBB+             1,346,875
     1,000,000 SC Jobs Econ. Dev. Auth. Hosp. Fac.
               Rev. Bonds (Palmetto Hlth.
               Alliance), Ser. A,  7 3/8s, 12/15/21  Baa2             1,241,250
     1,300,000 SC Tobacco Settlement Rev. Mgt.
               Rev. Bonds, Ser. B, 6 3/8s, 5/15/30   BBB              1,213,875
                                                                 --------------
                                                                      8,748,156

South Dakota (0.3%)
- -------------------------------------------------------------------------------
     2,000,000 SD Edl. Enhancement Funding Corp.
               Rev. Bonds, Ser. B, 6 1/2s, 6/1/32    BBB              1,902,500

Tennessee (3.8%)
- -------------------------------------------------------------------------------
    12,000,000 Johnson City, Hlth. & Edl. Fac.
               Hosp. Board Rev. Bonds (First Mtg.-
               Mountain States Hlth.),
               Ser. A, MBIA, 6s, 7/1/21              Aaa             13,635,000
     3,700,000 Johnson City, Hlth. & Edl. Fac.
               Board Hosp. Rev. Bonds (Mountain
               States Hlth.), Ser. A,  7 1/2s,
               7/1/33                                BBB+             4,347,500
       600,000 Johnson City, Hlth. & Edl. Facs.
               Board Retirement Fac. Rev. Bonds
               (Appalachian Christian
               Village), Ser. A, 6 1/4s, 2/15/32     BB-/P              585,750
               Shelby Cnty., Hlth. Edl. & Hsg. Fac.
               Hosp. Board Rev. Bonds (Methodist
               Hlth. Care)
     1,255,000 6 1/2s, 9/1/26                        A3               1,535,806
       745,000 6 1/2s, 9/1/26                        A3                 892,138
                                                                 --------------
                                                                     20,996,194

Texas (6.9%)
- -------------------------------------------------------------------------------
     5,500,000 Alliance, Arpt. Auth. Rev. Bonds
               (Federal Express Corp.), 6 3/8s,
               4/1/21 (SEG)                          Baa2             5,781,875
     4,655,000 Carrollton, Farmers Branch Indpt.
               School Dist. G.O. Bonds, PSFG, 5s,
               2/15/17                               Aaa              4,992,488
     1,000,000 Comal Cnty., Hlth. Fac. Dev. Corp.
               Rev. Bonds (Hlth. Care Syst. -
               McKenna Memorial), Ser. A, 6 1/4s,
               2/1/32                                Baa2             1,028,750
     2,360,000 Dallas-Fort Worth, Intl. Arpt. Fac.
               Impt. Corp. Rev. Bonds (American
               Airlines, Inc.),  6 3/8s, 5/1/35      Caa2             1,342,250
     7,500,000 Harris Cnty., Rev. Bonds, Ser. B,
               FSA, 5s, 8/15/32                      Aaa              8,371,875
     3,000,000 Harris Cnty., Hlth. Fac. Rev. Bonds
               (Memorial Hermann Hlth. Care),
               Ser. A, 6 3/8s, 6/1/29                A2               3,315,000
     3,880,000 Houston, Arpt. Syst. Rev. Bonds
               (Continental Airlines, Inc.),
               Ser. C, 5.7s, 7/15/29                 B-               2,614,150
     2,000,000 Lower Neches Valley Indl. Dev. Swr.
               Auth. Rev. Bonds (Mobil Oil Refining
               Corp.), 6.4s, 3/1/30                  Aaa              2,053,660
     1,400,000 Matagorda Cnty., Navigation Dist. TX
               Poll. Control FRB (American Elec.
               Power), 2.15s, 5/1/30                 Baa2             1,400,000
     2,500,000 Sam Rayburn Muni. Pwr. Agcy.
               Rev. Bonds,  6s, 10/1/21              Baa2             2,706,250
               Tomball, Hosp. Auth. Rev. Bonds
               (Tomball  Regl. Hosp.)
     2,000,000 6s, 7/1/29                            Baa3             1,997,500
       800,000 6s, 7/1/25                            Baa3               800,000
       800,000 6s, 7/1/19                            Baa3               813,000
       745,000 Tyler, Hlth. Fac. Dev. Corp.
               Rev. Bonds (Mother Frances Hosp.),
               5s, 7/1/08                            Baa1               789,700
                                                                 --------------
                                                                     38,006,498

Utah (2.6%)
- -------------------------------------------------------------------------------
               Carbon Cnty., Solid Waste Disp.
               Rev. Bonds (Laidlaw Env.), Ser. A
       750,000 7 1/2s, 2/1/10                        BB-                767,063
       600,000 7.45s, 7/1/17                         BB-/P              610,500
     5,000,000 Intermountain Power Agency
               Rev. Bonds, Ser. A, FSA, 5s, 7/1/11   Aaa              5,575,000
     6,000,000 Tooele Cnty., Harbor & Term. Dist.
               Port Fac. Rev. Bonds (Union
               Pacific), Ser. A, 5.7s, 11/1/26       Baa2             6,127,500
     1,000,000 UT Cnty., Env. Impt. Rev. Bonds
               (Marathon Oil), 5.05s, 11/1/17        Baa1             1,102,500
                                                                 --------------
                                                                     14,182,563

Vermont (0.2%)
- -------------------------------------------------------------------------------
     1,000,000 VT Hsg. Fin. Agcy. Rev. Bonds, Ser.
               19A, FSA, 4.62s, 5/1/29               Aaa             1,048,750

Virginia (0.8%)
- -------------------------------------------------------------------------------
     1,000,000 James Cnty., Indl. Dev. Auth.
               Rev. Bonds (Williamsburg), Ser. A,
               6 1/8s, 3/1/32                        BB-/P            1,035,000
               Roanoke Cnty. Indl. Dev. Auth.
               Rev. Bonds  (Res. Care Fac.), Ser. A
     1,000,000 6.3s, 7/1/35                          B+/P             1,015,000
       500,000 4.4s, 7/1/08                          B+/P               501,875
     2,000,000 Russell Cnty. Indl. Dev. Auth. Poll.
               Control Rev. Bonds (Appalachian Pwr.
               Co.), Ser. I, 2.7s, 11/1/07           Baa2             2,002,500
                                                                 --------------
                                                                      4,554,375

Washington (1.0%)
- -------------------------------------------------------------------------------
     5,000,000 King Cnty., G.O. Bonds, Ser. C,
               6 1/4s, 1/1/32                        Aa1              5,500,000

West Virginia (0.3%)
- -------------------------------------------------------------------------------
     2,250,000 Princeton, Hosp. Rev. Bonds (Cmnty.
               Hosp. Assn., Inc.), 6.1s, 5/1/29      B2               1,681,875

Wisconsin (1.8%)
- -------------------------------------------------------------------------------
               Badger Tobacco Settlement
               Asset Securitization Corp.
               Rev. Bonds
     3,000,000 7s, 6/1/28                            BBB              3,011,250
     3,000,000 6 3/8s, 6/1/32                        BBB              2,808,750
     3,900,000 WI State Hlth. & Edl. Fac. Auth.
               Rev. Bonds (Wheaton Franciscan),
               5 3/4s, 8/15/30                       A2               4,114,500
                                                                 --------------
                                                                      9,934,500
                                                                 --------------
               Total Municipal bonds and notes
               (cost $532,616,116)                                 $543,825,038

Preferred stocks (1.2%) (a)
Number of shares                                                          Value
- -------------------------------------------------------------------------------
    $2,000,000 Charter Mac. Equity Trust 144A
               Ser. A,  6.625% cum. pfd.                             $2,205,000
     4,000,000 MuniMae Tax Exempt Bond Subsidiary,
                LLC 144A 6.875% cum. pfd.                             4,455,000
                                                                 --------------
               Total Preferred stocks
               (cost $6,000,000)                                     $6,660,000

Common stocks (--%) (a) (cost $--)
Number of shares                                                          Value
- -------------------------------------------------------------------------------
        16,910 Hoover Group, Inc. (NON)                                      $2
- -------------------------------------------------------------------------------
               Total Investments
               (cost $538,616,116)                                 $550,485,040
- -------------------------------------------------------------------------------

  (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, 2004 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, 2004. Securities rated by Putnam are indicated
      by "/P". Ratings are not covered by the Report of Independent Registered
      Public Accounting Firm.

(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, 2004
      was $2,117,500 or 0.4% of portfolio market value.

(SEG) A portion of this security was pledged and segregated with the
      custodian to cover margin requirements for futures contracts at October
      31, 2004.

      144A after the name of a security represents those exempt from
      registration under Rule 144A of the Securities Act of 1933. These
      securities may be resold in transactions exempt from registration,
      normally to qualified institutional buyers.

      The rates shown on VRDN, mandatory put bonds and Floating Rate Bonds
      (FRB) are the current interest rates at October 31, 2004.

      The rates shown on IFB and IF COP, which are securities paying interest
      rates that vary inversely to changes in the market interest rates, are
      the current interest rates at October 31, 2004.

      The fund had the following industry group concentrations greater than
      10% at October 31, 2004 (as a percentage of portfolio market value):

      Health care             27.9%
      Education               22.4
      Transportation          11.5

      The fund had the following insurance concentrations greater than 10% at
      October 31, 2004 (as a percentage of portfolio market value):

      MBIA                    14.7%
      AMBAC                   13.4

      The dates shown on mandatory put bonds are the next mandatory put dates.

<TABLE>
<CAPTION>
Futures contracts outstanding at October 31, 2004

                                                        Aggregate        Expiration        Unrealized
                                          Value        face value              date      depreciation
<S>                            <C>               <C>               <C>               <C>
- ------------------------------------------------------------------------------------------------------
U.S. Treasury Note
10 yr (Short)                       $18,851,375       $18,504,665            Dec-04         $(346,710)
- ------------------------------------------------------------------------------------------------------

</TABLE>

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


Statement of assets and liabilities
October 31, 2004

Assets
- -------------------------------------------------------------------------------
Investments in securities, at value (identified cost
$538,616,116) (Note 1)                                           $550,485,040
- -------------------------------------------------------------------------------
Cash                                                                  247,334
- -------------------------------------------------------------------------------
Interest and other receivables                                     10,236,106
- -------------------------------------------------------------------------------
Receivable for securities sold                                      4,070,350
- -------------------------------------------------------------------------------
Total assets                                                      565,038,830

Liabilities
- -------------------------------------------------------------------------------
Payable for variation margin (Note 1)                                  62,250
- -------------------------------------------------------------------------------
Distributions payable to shareholders                               1,968,504
- -------------------------------------------------------------------------------
Accrued preferred shares distribution payable (Note 1)                 99,254
- -------------------------------------------------------------------------------
Payable for securities purchased                                      588,720
- -------------------------------------------------------------------------------
Payable for compensation of Manager (Note 2)                          989,469
- -------------------------------------------------------------------------------
Payable for investor servicing and custodian fees (Note 2)             78,173
- -------------------------------------------------------------------------------
Payable for Trustee compensation and expenses (Note 2)                 59,984
- -------------------------------------------------------------------------------
Payable for administrative services (Note 2)                              789
- -------------------------------------------------------------------------------
Other accrued expenses                                                119,064
- -------------------------------------------------------------------------------
Total liabilities                                                   3,966,207
- -------------------------------------------------------------------------------
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                                                       $386,072,623

Represented by
- -------------------------------------------------------------------------------
Paid-in capital -- common shares (unlimited shares
authorized) (Note 1)                                             $434,703,689
- -------------------------------------------------------------------------------
Undistributed net investment income (Note 1)                        1,099,611
- -------------------------------------------------------------------------------
Accumulated net realized loss on investments (Note 1)             (61,252,891)
- -------------------------------------------------------------------------------
Net unrealized appreciation of investments                         11,522,214
- -------------------------------------------------------------------------------
Total -- Representing net assets applicable to common shares
outstanding                                                      $386,072,623

Computation of net asset value
- -------------------------------------------------------------------------------
Net asset value per common share ($386,072,623 divided by
47,206,343 shares)                                                      $8.18
- -------------------------------------------------------------------------------

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


Statement of operations
Year ended October 31, 2004

Interest income:                                                  $30,347,178
- -------------------------------------------------------------------------------

Expenses:
- -------------------------------------------------------------------------------
Compensation of Manager (Note 2)                                    3,840,217
- -------------------------------------------------------------------------------
Investor servicing fees (Note 2)                                      197,458
- -------------------------------------------------------------------------------
Custodian fees (Note 2)                                               142,899
- -------------------------------------------------------------------------------
Trustee compensation and expenses (Note 2)                             16,401
- -------------------------------------------------------------------------------
Administrative services (Note 2)                                        8,664
- -------------------------------------------------------------------------------
Preferred share remarketing agent fees                                472,417
- -------------------------------------------------------------------------------
Other                                                                 235,330
- -------------------------------------------------------------------------------
Total expenses                                                      4,913,386
- -------------------------------------------------------------------------------
Expense reduction (Note 2)                                            (21,310)
- -------------------------------------------------------------------------------
Net expenses                                                        4,892,076
- -------------------------------------------------------------------------------
Net investment income                                              25,455,102
- -------------------------------------------------------------------------------
Net realized loss on investments (Notes 1 and 3)                   (7,361,559)
- -------------------------------------------------------------------------------
Net realized loss on futures contracts (Note 1)                    (1,045,010)
- -------------------------------------------------------------------------------
Net unrealized appreciation of investments and futures
contracts during the year                                          17,847,804
- -------------------------------------------------------------------------------
Net gain on investments                                             9,441,235
- -------------------------------------------------------------------------------
Net increase in net assets resulting from operations              $34,896,337
- -------------------------------------------------------------------------------

Distributions to Series A, B, and C remarketed preferred shareholders:
(Note 1)
- -------------------------------------------------------------------------------
From tax exempt income                                             (2,026,238)
- -------------------------------------------------------------------------------
From ordinary income                                                   (3,054)
- -------------------------------------------------------------------------------
Net increase in net assets resulting from operations
(applicable to common shareholders)                               $32,867,045
- -------------------------------------------------------------------------------

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


Statement of changes in net assets

                                                        Year ended October 31
- -------------------------------------------------------------------------------
Increase in net assets                                  2004             2003
- -------------------------------------------------------------------------------
Operations:
- -------------------------------------------------------------------------------
Net investment income                            $25,455,102      $29,009,265
- -------------------------------------------------------------------------------
Net realized loss on investments                  (8,406,569)     (27,107,452)
- -------------------------------------------------------------------------------
Net unrealized appreciation of investments        17,847,804       33,501,746
- -------------------------------------------------------------------------------
Net increase in net assets resulting from
operations                                        34,896,337       35,403,559
- -------------------------------------------------------------------------------

Distributions to Series A, B, and C remarketed
preferred shareholders: (Note 1)
- -------------------------------------------------------------------------------
From tax exempt income                            (2,026,238)      (1,911,395)
- -------------------------------------------------------------------------------
From ordinary income                                  (3,054)              --
- -------------------------------------------------------------------------------
Net increase in net assets resulting from
operations (applicable to common
shareholders)                                     32,867,045       33,492,164
- -------------------------------------------------------------------------------

Distributions to common shareholders: (Note 1)
- -------------------------------------------------------------------------------
From tax exempt income                           (23,617,277)     (26,907,616)
- -------------------------------------------------------------------------------
From ordinary income                                 (42,484)              --
- -------------------------------------------------------------------------------
Total increase in net assets                       9,207,284        6,584,548

Net assets
- -------------------------------------------------------------------------------
Beginning of year                                376,865,339      370,280,791
- -------------------------------------------------------------------------------
End of year (including undistributed net
investment income of $1,099,611 and
$913,954, respectively)                         $386,072,623     $376,865,339
- -------------------------------------------------------------------------------

Number of fund shares
- -------------------------------------------------------------------------------
Common shares outstanding at beginning and
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                                       2004            2003            2002            2001            2000
- ---------------------------------------------------------------------------------------------------------------------------------
<S>                                                      <C>             <C>             <C>             <C>             <C>
Net asset value,
beginning of period
(common shares)                                            $7.98           $7.84           $8.49           $8.44           $8.77
- ---------------------------------------------------------------------------------------------------------------------------------
Investment operations:
- ---------------------------------------------------------------------------------------------------------------------------------
Net investment income (a)                                    .54             .61             .70             .72             .75
- ---------------------------------------------------------------------------------------------------------------------------------
Net realized and unrealized
gain (loss) on investments                                   .20             .14            (.73)            .04            (.16)
- ---------------------------------------------------------------------------------------------------------------------------------
Total from investment operations                             .74             .75            (.03)            .76             .59
- ---------------------------------------------------------------------------------------------------------------------------------
Distributions to preferred shareholders:
- ---------------------------------------------------------------------------------------------------------------------------------
From net investment income                                  (.04)           (.04)           (.05)           (.12)           (.16)
- ---------------------------------------------------------------------------------------------------------------------------------
Total from investment
operations: (applicable to
common shareholders)                                         .70             .71            (.08)            .64             .43
- ---------------------------------------------------------------------------------------------------------------------------------
Distributions to
common shareholders:
- ---------------------------------------------------------------------------------------------------------------------------------
From net investment income:                                 (.50)           (.57)           (.57)           (.59)           (.76)
- ---------------------------------------------------------------------------------------------------------------------------------
Total distributions                                         (.50)           (.57)           (.57)           (.59)           (.76)
- ---------------------------------------------------------------------------------------------------------------------------------
Net asset value, end of period
(common shares)                                            $8.18           $7.98           $7.84           $8.49           $8.44
- ---------------------------------------------------------------------------------------------------------------------------------
Market price, end of period
(common shares)                                            $7.29           $7.34           $7.43           $8.44           $9.63
- ---------------------------------------------------------------------------------------------------------------------------------
Total return at market price (%)
(common shares) (b)                                         6.35            6.44           (5.57)          (6.21)           6.84
- ---------------------------------------------------------------------------------------------------------------------------------

Ratios and supplemental data
- ---------------------------------------------------------------------------------------------------------------------------------
Net assets, end of period
(common shares) (in thousands)                          $386,073        $376,865        $370,281        $400,255        $396,212
- ---------------------------------------------------------------------------------------------------------------------------------
Ratio of expenses to
average net assets (%)(c)(d)                                1.28            1.27            1.25            1.22            1.27
- ---------------------------------------------------------------------------------------------------------------------------------
Ratio of net investment income
to average net assets (%)(c)                                6.12            7.21            7.84            7.01            6.97
- ---------------------------------------------------------------------------------------------------------------------------------
Portfolio turnover (%)                                     25.54           40.82           20.44           17.95           16.72
- ---------------------------------------------------------------------------------------------------------------------------------
</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, 2004

Note 1
Significant accounting policies

Putnam Managed Municipal Income Trust (the "fund"), a Massachusetts
business trust, 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 Manage ment, 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 60% 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 at fair
value 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. Other investments 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. Risks may exceed amounts recognized on the statement
of assets and liabilities. 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. If a written call
option is exercised, the premium originally received is recorded as an
addition to sales proceeds. If a written put option is exercised, the
premium originally received is recorded as an addition to the cost of
investments.

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.
Futures and written option contracts outstanding at period end, if any,
are listed after the fund's portfolio.

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 of 1986 (the "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 Code, 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, 2004, the fund had a capital loss carryover of
$58,719,216 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
   25,837,158    October 31, 2011
    8,560,869    October 31, 2012

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, 2004 was 1.42% for Series A,
1.60% for Series B and 1.65% 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 dividends payable, defaulted bond interest, realized and
unrealized gains and losses on certain futures contracts, market
discount 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, 2004, the fund reclassified
$419,608 to increase undistributed net investment income and $4,975 to
decrease paid-in-capital, with an increase to accumulated net realized
losses of $414,633.

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

Unrealized appreciation            $23,949,663
Unrealized depreciation            (11,619,925)
                                  ------------
Net unrealized appreciation         12,329,738
Undistributed tax exempt
income                               2,742,613
Undistributed ordinary income          383,189
Capital loss carryforward          (58,719,216)
Cost for federal income
tax purposes                      $538,155,302

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 attributable to
common and preferred shares outstanding.

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 0.70% 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. Putnam
Investor Services, a division of PFTC, provides investor servicing agent
functions to the fund. During the year ended October 31, 2004, the fund
paid PFTC $340,357 for these services.

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, 2004, the
fund's expenses were reduced by $21,310 under these arrangements.

Each independent Trustee of the fund receives an annual Trustee fee, of
which $758, as a quarterly retainer, 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. The Trustees have terminated the Pension Plan with
respect to any Trustee first elected after 2003.

Note 3
Purchases and sales of securities

During the year ended October 31, 2004, cost of purchases and proceeds
from sales of investment securities other than short-term investments
aggregated $141,857,371 and $135,854,094, respectively. There were no
purchases or sales of U.S. government securities.

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.

It is anticipated that dividends paid to holders of remarketed preferred
shares will be considered tax-exempt dividends under the Internal
Revenue Code of 1986. To the extent that the fund earns taxable income
and capital gains by the conclusion of a fiscal year, it may be required
to apportion to the holders of the remarketed preferred shares
throughout that year additional dividends as necessary to result in an
after-tax equivalent to the applicable dividend rate for the period.
Total additional dividends for the period ended October 31, 2004 were
$1,069.

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, 2004, no such
restrictions have been placed on the fund.

Note 5
Regulatory matters and litigation

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

Putnam Management, and not the investors in any Putnam fund, will bear
all costs, including restitution, civil penalties and associated legal
fees stemming from both of these proceedings. The SEC's and
Massachusetts Securities Division'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.


Federal tax information
(Unaudited)

The fund has designated 99.82% 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 2005 will show the tax status of
all distributions paid to your account in calendar 2004.


Results of October 14, 2004 shareholder meeting
(Unaudited)

An annual meeting of shareholders of the fund was held on October 14,
2004. At the meeting, each of the nominees for Trustees was elected, as
follows:

                                           Common Shares

                                                       Votes
                                    Votes for          withheld
- --------------------------------------------------------------------
Jameson Adkins Baxter               39,183,683         1,111,697
Charles B. Curtis                   39,199,297         1,096,083
Myra R. Drucker                     39,164,006         1,131,374
Charles E. Haldeman, Jr.            39,159,161         1,136,219
Ronald J. Jackson                   39,196,959         1,098,421
Paul L. Joskow                      39,201,103         1,094,277
Elizabeth T. Kennan                 39,166,088         1,129,292
John H. Mullin III                  39,187,417         1,107,963
George Putnam, III                  39,157,946         1,137,434
A.J.C. Smith                        39,162,059         1,133,321
W. Thomas Stephens                  39,183,683         1,111,697
Richard B. Worley                   39,167,511         1,127,869

                                          Preferred Shares

                                                       Votes
                                    Votes for          withheld
- --------------------------------------------------------------------
Jameson Adkins Baxter               1,607              88
Charles B. Curtis                   1,607              88
Myra R. Drucker                     1,607              88
Charles E. Haldeman, Jr.            1,607              88
John A. Hill                        1,607              88
Ronald J. Jackson                   1,607              88
Paul L. Joskow                      1,607              88
Elizabeth T. Kennan                 1,607              88
John H. Mullin III                  1,607              88
Robert E. Patterson                 1,607              88
George Putnam, III                  1,607              88
A.J.C. Smith                        1,607              88
W. Thomas Stephens                  1,607              88
Richard B. Worley                   1,607              88

All tabulations are rounded to nearest whole number.

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).

From August 1997 to December 1999, Mr. Curtis was a Partner at Hogan &
Hartson L.L.P., a Washington, D.C. law firm. 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 SEC.

Myra R. Drucker (1/16/48)

Ms. Drucker is a Vice Chair of the Board of Trustees of Sarah Lawrence
College, a Trustee of Commonfund (a not-for-profit firm specializing in
asset management for educational endowments and foundations) and a
member of the Investment Committee of the Kresge Foundation (a
charitable trust). She is also Chair of the New York Stock Exchange
(NYSE) Pension Managers Advisory Committee and a member of the Executive
Committee of the Committee on Investment of Employee Benefit Assets.
Until August 31, 2004, Ms. Drucker was Managing Director and a member of
the Board of Directors of General Motors Asset Management and Chief
Investment Officer of General Motors Trust Bank. Ms. Drucker also served
as a member of the NYSE Corporate Accountability and Listing Standards
Committee and the NYSE/NASD IPO Advisory Committee.

Prior to joining General Motors Asset Management in 2001, Ms. Drucker
held various executive positions in the investment management industry.
Ms. Drucker served as Chief Investment Officer of Xerox Corporation (a
technology and service company in the document industry), where she was
responsible for the investment of the company 's pension assets. Ms.
Drucker was also Staff Vice President and Director of Trust Investments
for International Paper (a paper, paper distribution, packaging and
forest products company) and previously served as Manager of Trust
Investments for Xerox Corporation. Ms. Drucker received a B.A. degree in
Literature and Psychology from Sarah Lawrence College and pursued
graduate studies in economics, statistics and portfolio theory at Temple
University.

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

Mr. Hill is Vice Chairman 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
advised by an affiliate of Putnam Management). 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 Michigan State University 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) and TransCanada
Corporation (an energy company focused on natural gas transmission and
power services). 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 of Cambus-Kenneth Farm (thoroughbred horse and
cattle breeding). She is President Emeritus of Mount Holyoke College.

Dr. Kennan served as Chairman and is now Lead Director 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 the National Trust for Historic
Preservation, 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 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 The National
Humanities Center and 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. Prior to February
2004, he was a Director of Alex Brown Realty, Inc.

Mr. Mullin is also a past Director of Adolph Coors Company; ACX
Technologies, Inc.; Crystal Brands, Inc.; Dillon, Read & Co., Inc.;
Fisher-Price, Inc.; and The Ryland Group, Inc. 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. (a private equity firm investing in commercial
real estate).

Mr. Patterson serves as Chairman of the Joslin Diabetes Center and as a
Director of Brandywine Trust Company. Prior to June 2003, he was a
Trustee of Sea Education Association. Prior to December 2001, he was
President and Trustee of Cabot Industrial Trust (a publicly traded real
estate investment trust). Prior to February 1998, he was Executive Vice
President and Director of Acquisitions of Cabot Partners Limited
Partnership (a registered investment adviser 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 is Chairman and Chief Executive Officer of Boise Cascade,
L.L.C. (a paper, forest products and timberland assets company). Mr.
Stephens serves as a Director of TransCanada Pipelines Limited. Until
2004, Mr. Stephens was a Director of Xcel Energy Incorporated (a public
utility company), Qwest Communications, and Norske Canada, Inc. (a paper
manufacturer). 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.

Richard B. Worley (11/15/45)

Mr. Worley is Managing Partner of Permit Capital, LLC, an investment
management firm.

Mr. Worley serves on the Executive Committee of the University of
Pennsylvania Medical Center, is a Trustee of The Robert Wood Johnson
Foundation (a philanthropic organization devoted to health care issues)
and is a Director of The Colonial Williamsburg Foundation (a historical
preservation organization). Mr. Worley also serves on the investment
committees of Mount Holyoke College and World Wildlife Fund (a wildlife
conservation organization).

Prior to joining Permit Capital LLC in 2002, Mr. Worley served as Chief
Strategic Officer of Morgan Stanley Investment Management. He previously
served as President, Chief Executive Officer and Chief Investment
Officer of Morgan Stanley Dean Witter Investment Management and as a
Managing Director of Morgan Stanley, a financial services firm. Mr.
Worley also was the Chairman of Miller Anderson & Sherrerd, an
investment management firm.

Mr. Worley holds a B.S. degree from University of Tennessee and pursued
graduate studies in economics at the University of Texas.

Charles E. Haldeman, Jr.* (10/29/48)

Mr. Haldeman is President and Chief Executive Officer of Putnam, LLC
("Putnam Investments"). He is a member of Putnam Investments' Executive
Board of Directors and Advisory Council. Prior to November 2003, Mr.
Haldeman served as Co-Head of Putnam Investments' Investment Division.

Prior to joining Putnam Investments in 2002, Mr. Haldeman held executive
positions in the investment management industry. He previously served as
Chief Executive Officer of Delaware Investments and President & Chief
Operating Officer of United Asset Management. Mr. Haldeman was also a
partner and director of Cooke & Bieler, Inc. (an investment management
firm).

Mr. Haldeman currently serves as a Trustee of Dartmouth College and as
Emeritus Trustee of Abington Memorial Hospital. He is a graduate of
Dartmouth College, Harvard Law School and Harvard Business School. Mr.
Haldeman is also a Chartered Financial Analyst (CFA) charterholder.

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 adviser). 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
LLP (formerly known as 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 the Chairman of Putnam Investments and Consultant to 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 November 2004, Mr. Smith was a Director of Marsh &
McLennan Companies, Inc. 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, 2004, there were 110 Putnam Funds. All Trustees other
than Ms. Drucker and Messrs. Worley and Haldeman serve as Trustees of
all Putnam funds. Ms. Drucker and Messrs. Worley and Haldeman currently
serve as Trustees of 82 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. Haldeman, Putnam, III, and Smith are deemed "interested persons"
  by virtue of their positions as officers of the fund, Putnam Management,
  Putnam Retail Management or Marsh & McLennan Companies, Inc. and as
  shareholders of Marsh & McLennan Companies, Inc. Mr. Putnam, III is the
  President of your fund and each of the other Putnam funds. Mr. Haldeman
  is President and Chief Executive Officer of Putnam Investments. Mr.
  Smith serves as a Consultant to Marsh & McLennan Companies, Inc. and as
  Chairman of Putnam Investments.


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, Associate Treasurer and Principal
Executive Officer
Since 1989

Managing Director, Putnam Investments
and Putnam Management

Jonathan S. Horwitz (6/4/55)
Senior Vice President and Treasurer
Since 2004

Managing Director, Putnam Investments

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

Senior 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

Daniel T. Gallagher (2/27/62)
Vice President and Legal and Compliance Liaison Officer

Since 2004
Vice President, Putnam Investments. Prior to 2004,
Associate, Ropes & Gray LLP; prior to 2000, Law Clerk,
Massachusetts Supreme Judicial Court

Francis J. McNamara, III (8/19/55)
Vice President and Chief Legal Officer
Since 2004

Senior Managing Director, Putnam
Investments, Putnam Management and
Putnam Retail Management. Prior to 2004, General Counsel,
State Street Research & Management Company

James P. Pappas (2/24/53)
Vice President
Since 2004

Managing Director, Putnam Investments and Putnam Management.
During 2002, Chief Operating Officer, Atalanta/Sosnoff
Management Corporation; prior to 2001, President and Chief
Executive Officer, UAM Investment Services, Inc.

Richard S. Robie, III (3/30/60)
Vice President
Since 2004

Senior Managing Director, Putnam
Investments, Putnam Management and
Putnam Retail Management. Prior to 2003, Senior Vice
President, United Asset Management Corporation

Charles A. Ruys de Perez (10/17/57)
Vice President and Chief Compliance Officer
Since 2004

Managing Director, Putnam Investments

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

Senior Vice President, Putnam Investments

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 Registered Public Accounting Firm

KPMG LLP

Trustees

John A. Hill, Chairman
Jameson Adkins Baxter
Charles B. Curtis
Myra R. Drucker
Charles E. Haldeman, Jr.
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
Richard B. Worley

Officers

George Putnam, III
President

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

Jonathan S. Horwitz
Senior Vice President and Treasurer

Steven D. Krichmar
Vice President and Principal Financial Officer

Michael T. Healy
Assistant Treasurer and Principal Accounting Officer

Beth S. Mazor
Vice President

Daniel T. Gallagher
Vice President and Legal and Compliance Liaison Officer

James P. Pappas
Vice President

Richard S. Robie, III
Vice President

Mark C. Trenchard
Vice President and BSA Compliance Officer

Francis J. McNamara, III
Vice President and Chief Legal Officer

Charles A. Ruys de Perez
Vice President and Chief Compliance Officer

Judith Cohen
Clerk and Assistant Treasurer

Call 1-800-225-1581 weekdays from 9 a.m. to 5 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

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216547  12/04


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, Mr. Stephens and Mr. Worley 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:
- -----------------------------------------------
The following table presents fees billed in each of the last two
fiscal years for services rendered to the fund by the fund's
independent auditors:

                    Audit       Audit-Related   Tax       All Other
Fiscal year ended   Fees        Fees            Fees      Fees
- -----------------   ----------  -------------   -------   ---------
October 31, 2004    $34,850     $19,500         $4,150    $68
October 31, 2003    $30,300     $17,950         $3,600    $--

For the fiscal years ended October 31, 2004 and October 31, 2003,
the fund's independent auditors billed aggregate non-audit fees in
the amounts of $23,718 and $21,550, respectively, to the fund,
Putnam Management and any entity controlling, controlled by or
under common control with Putnam Management that provides ongoing
services to the fund.

Audit Fees represents fees billed for the fund's last two fiscal
years.

Audit-Related Fees represents fees billed in the fund's last two
fiscal years for services traditionally performed by the fund's
auditor, including accounting consultation for proposed transactions
or concerning financial accounting and reporting standards and other
audit or attest services not required by statute or regulation.

Tax Fees represent fees billed in the fund's last two fiscal years
for tax compliance, tax planning and tax advice services.  Tax
planning and tax advice services include assistance with tax audits,
employee benefit plans and requests for rulings or technical advice
from taxing authorities.

All Other Fees Fees represent fees billed for services relating
relating interfund trading.

Pre-Approval Policies of the Audit and Pricing Committee.  The Audit
and Pricing Committee of the Putnam funds has determined that, as a
matter of policy, all work performed for the funds by the funds'
independent auditors will be pre-approved by the Committee and will
generally not be subject to pre-approval procedures.

Under certain circumstances, the Audit and Pricing Committee
believes that it may be appropriate for Putnam Investment
Management, LLC ("Putnam Management") and certain of its affiliates
to engage the services of the funds' independent auditors, but only
after prior approval by the Committee.  Such requests are required
to be submitted in writing to the Committee and explain, among other
things, the nature of the proposed engagement, the estimated fees,
and why this work must be performed by that particular audit firm.
The Committee will review the proposed engagement at its next
meeting.

Since May 6, 2003, all work performed by the independent auditors
for the funds, Putnam Management and any entity controlling,
controlled by or under common control with Putnam Management that
provides ongoing services to the fund was pre-approved by the
Committee or a member of the Committee pursuant to the pre-approval
policies discussed above.  Prior to that date, the Committee had a
general policy to pre-approve the independent auditor's engagements
for non-audit services with the funds, Putnam Management and any
entity controlling, controlled by or under common control with
Putnam Management that provides ongoing services to the fund.

The following table presents fees billed by the fund's principal
auditor for services required to be approved pursuant to paragraph
(c)(7)(ii) of Rule 2-01 of Regulation S-X.

                    Audit-Related   Tax   All Other   Total Non-
Fiscal year ended   Fees            Fees  Fees        Audit Fees
- -----------------   -------------   ----  ---------   ----------
October 31, 2004    $--             $--   $--         $--
October 31, 2003    $--             $--   $--         $--

Item 5.  Audit Committee
- ------------------------

(a)  The fund has a separately-designated audit committee
established in accordance with Section 3(a)(58)(A) of the Securities
Exchange Act of 1934, as amended.  The Audit Committee of the fund's
Board of Trustees is composed of the following persons:

Myra R. Drucker
Paul L. Joskow (Chairperson)
Robert E. Patterson
W. Thomas Stephens
Richard B. Worley

(b)  Not applicable

Item 6. Schedule of Investments: Not applicable
- --------------------------------

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 particular issues.  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, a member of the Office of the
Trustees who is appointed to assist in the coordination and voting
of the funds' proxies.

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 that, even if 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
funds' 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 that have been put forth by management and 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
non-U.S. issuers.

The Putnam funds will disclose their proxy votes in accordance with
the timetable established by SEC rules (i.e., not later than August
31 of each year for the most recent 12-month period ended June 30).

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 of the funds' intent to hold corporate boards accountable for
their actions in promoting shareholder interests, the funds' proxies
generally will be voted for the decisions reached by majority
independent boards of directors, except as otherwise indicated in
these guidelines.  Accordingly, the funds' proxies will be voted for
board-approved proposals, except as follows:

Matters relating to the Board of Directors
- ------------------------------------------

Uncontested Election of Directors

The funds' proxies will be voted for the election of a company's
nominees for the board of directors, 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,

* the board has not established independent nominating, audit, and
compensation committees,

* the board has more than 19 members or fewer than five members,
absent special circumstances,

* the board has not acted to implement a policy requested in a
shareholder proposal that received the support of a majority of the
shares of the company at its previous two annual meetings, or

* the board has adopted or renewed a shareholder rights plan
(commonly referred to as a "poison pill") without shareholder
approval during the current or prior calendar year.

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),

* attends less than 75% of board and committee meetings without
valid reasons for the absences (e.g., illness, personal emergency,
etc.),

* as a director of a public company (Company A), 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"), or

* serves on more than five unaffiliated public company boards (for
the purpose of this guideline, boards of affiliated registered
investment companies will count as one board).

Commentary:

Board independence:  Unless otherwise indicated, for the purposes of
determining whether a board has a majority of independent directors
and independent nominating, audit, and compensation committees, an
"independent director" is a director who (1) meets all requirements
to serve as an independent director of a company under the final
NYSE Corporate Governance Rules (e.g., no material business
relationships with the company and no present or recent employment
relationship with the company (including employment of an immediate
family member as an executive officer)), and (2) has not accepted
directly or indirectly any consulting, advisory, or other
compensatory fee from the company other than in his or her capacity
as a member of the board of directors or any board committee.  The
funds' Trustees believe that the receipt of compensation for
services other than service as a director raises significant
independence issues.

Board size:  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.

Time commitment:  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.

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

Corporate governance practices:  Board independence depends not only
on its members' individual relationships, but also on 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 who, 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.

Contested Elections of Directors

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

Classified Boards

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.

Other Board-Related Proposals

The funds will generally vote for board-approved proposals that have
been approved by a majority independent board, and on a case-by-case
basis on board-approved proposals where the board fails to meet the
guidelines' basic independence standards (i.e., majority of
independent directors and independent nominating, audit, and
compensation committees).

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 and
restricted stock plans that will result in an average annual
dilution of 1.67% or less (based on the disclosed term of the plan
and including all equity-based plans).

The funds will vote against stock option and restricted stock
plans that will result in an average annual dilution of greater than
1.67% (based on the disclosed term of the plan and including all
equity-based plans).

The funds will vote against any stock option or restricted stock
plan where the company's actual grants of stock options and
restricted stock under all equity-based compensation plans during
the prior three (3) fiscal years have resulted in an average annual
dilution of greater than 1.67%.

The funds will vote against stock option plans that permit the
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 an employee stock
purchase plan that has 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 a proposal relating to
executive compensation, the funds will consider whether the proposal
has been approved by an independent compensation committee of the
board.

Capitalization
- --------------

Many proxy proposals involve changes in a company's capitalization,
including the authorization of additional stock, the issuance of
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 the 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
and issuance 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 affect a shareholder's
investment and that warrant a case-by-case determination.

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 the 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, shareholders
must carefully consider the reasons for a reincorporation into
another jurisdiction, including especially an offshore jurisdiction.

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 the adoption of a shareholder rights plan, requiring
supermajority voting on particular issues, the adoption of fair
price provisions, the issuance of blank check preferred stock, and
the creation of 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; 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.

Other Business Matters
- ----------------------

Many proxies involve approval of routine business matters, such as
changing a 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 that 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 the company's corporate governance
structure or to change some aspect of its business operations.  The
funds generally 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 funds' 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 NON-U.S. ISSUERS
- ---------------------------------------

Many of the Putnam funds invest on a global basis, and, as a result,
they may be required to vote shares held in non-U.S. issuers - i.e.,
issuers that are incorporated under the laws of foreign
jurisdictions and that are not listed on a U.S. securities exchange
or the NASDAQ stock market.  Because non-U.S. 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 non-U.S. 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 non-U.S. issuers.

In many non-U.S. markets, shareholders who vote proxies of a
non-U.S. issuer are not able to trade in that company's stock 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.

In addition, some non-U.S. markets require that a company's shares
be re-registered out of the name of the local custodian or nominee
into the name of the shareholder for the meeting.  This practice is
known as "share re-registration."  As a result, shareholders,
including the funds, are not able to trade in that company's stock
until the shares are re-registered back in the name of the local
custodian or nominee.  In countries where share re-registration is
practiced, the funds will generally not vote proxies.

The funds will vote proxies of non-U.S. issuers in accordance with
the foregoing guidelines where applicable, except as follows:

Uncontested Election of Directors
- ---------------------------------

Japan

For companies that have established a U.S.-style corporate
structure, the funds will withhold votes for the entire board of
directors if

* the board does not have a majority of outside directors,

* the board has not established nominating and compensation
committees composed of a majority of outside directors, or

* the board has not established an audit committee composed of a
majority of independent directors.

The funds will withhold votes for the appointment of members of a
company's board of statutory auditors if a majority of the members
of the board of statutory auditors is not independent.

Commentary:

Board structure:  Recent amendments to the Japanese Commercial Code
give companies the option to adopt a U.S.-style corporate structure
(i.e., a board of directors and audit, nominating, and compensation
committees).  The funds will vote for proposals to amend a company's
articles of incorporation to adopt the U.S.-style corporate
structure.

Definition of outside director and independent director:  Corporate
governance principles in Japan focus on the distinction between
outside directors and independent directors.  Under these
principles, an outside director is a director who is not and has
never been a director, executive, or employee of the company or its
parent company, subsidiaries or affiliates.  An outside director is
"independent" if that person can make decisions completely
independent from the managers of the company, its parent,
subsidiaries, or affiliates and does not have a material
relationship with the company (i.e., major client, trading partner,
or other business relationship; familial relationship with current
director or executive; etc.).  The guidelines have incorporated
these definitions in applying the board independence standards
above.

Korea

The funds will withhold votes for the entire board of directors if

* the board does not have a majority of outside directors,

* the board has not established a nominating committee composed of
at least a majority of outside directors, or

* the board has not established an audit committee composed of at
least three members and in which at least two-thirds of its members
are outside directors.

Commentary:   For purposes of these guideline, an "outside director"
is a director that is independent from the management or controlling
shareholders of the company, and holds no interests that might
impair performing his or her duties impartially from the company,
management or controlling shareholder.  In determining whether a
director is an outside director, the funds will also apply the
standards included in Article 415-2(2) of the Korean Commercial Code
(i.e., no employment relationship with the company for a period of
two years before serving on the committee, no director or employment
relationship with the company's largest shareholder, etc.) and may
consider other business relationships that would affect the
independence of an outside director.

United Kingdom

The funds will withhold votes for the entire board of directors if

* the board does not have at least a majority of independent
non-executive directors,

* the board has not established nomination committees composed of a
majority of independent non-executive directors, or

* the board has not established compensation and audit committees
composed of (1) at least three directors (in the case of smaller
companies, two directors) and (2) solely of independent
non-executive directors.

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:

Application of guidelines:  Although the U.K.'s Combined Code on
Corporate Governance ("Combined Code") has adopted the "comply and
explain" approach to corporate governance, the funds' Trustees
believe that the guidelines discussed above with respect to board
independence standards are integral to the protection of investors
in U.K. companies.  As a result, these guidelines will be applied in
a prescriptive manner.

Definition of independence:  For the purposes of these guidelines, a
non-executive director shall be considered independent if the
director meets the independence standards in section A.3.1 of the
Combined Code (i.e., no material business or employment
relationships with the company, no remuneration from the company for
non-board services, no close family ties with senior employees or
directors of the company, etc.), except that the funds do not view
service on the board for more than nine years as affecting a
director's independence.

Smaller companies:  A smaller company is one that is below the FTSE
350 throughout the year immediately prior to the reporting year.

Canada

In January 2004, Canadian securities regulators issued proposed
policies that would impose new corporate governance requirements on
Canadian public companies.  The recommended practices contained in
these new corporate governance requirements mirror corporate
governance reforms that have been adopted by the NYSE and other U.S.
national securities exchanges and stock markets.  As a result, the
funds will vote on matters relating to the board of directors of
Canadian issuers in accordance with the guidelines applicable to
U.S. issuers.

Commentary:  Like the U.K.'s Combined Code, the proposed policies on
corporate governance issued by Canadian securities regulators embody
the "comply and explain" approach to corporate governance.  Because
the funds' Trustees believe that the board independence standards
contained in the proxy voting guidelines are integral to the
protection of investors in Canadian companies, these standards will
be applied in a prescriptive manner.

Other Matters
- -------------

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

As adopted December 10, 2004

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. Purchases of Equity Securities by Closed-End Management Investment
- --------------------------------------------------------------------------
        Companies and Affiliated Purchasers: Not applicable
        ------------------------------------

Item 9. Submission of Matters to a Vote of Security Holders:
- ------------------------------------------------------------
        Not applicable

Item 10. Controls and Procedures:
- --------------------------------

(a) The registrant's principal executive officer and principal
financial officer 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 generally 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 11. 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 29, 2004



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/Charles E. Porter
                                     ---------------------------
                                     Charles E. Porter
                                     Principal Executive Officer
Date: December 29, 2004



By (Signature and Title):            /s/Steven D. Krichmar
                                     ---------------------------
                                     Steven D. Krichmar
                                     Principal Financial Officer
Date: December 29, 2004

</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-99.CERT
<SEQUENCE>2
<FILENAME>exnncsr2.txt
<DESCRIPTION>EX-99.CERT
<TEXT>
Certifications
- --------------
I, Charles E. Porter, a 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. The registrant's other certifying officer and I are responsible for
establishing and maintaining disclosure controls and procedures (as
defined in rule 30a-3(c) under the Investment Company Act of 1940) 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 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 quarter that has materially
affected, or is reasonably likely to materially affect, the
registrant's internal control over financial reporting; and

5. The registrant's other certifying officer 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 over financial reporting.

/s/Charles E. Porter        Date: December 23, 2004
- ----------------------      -----------------------
Charles E. Porter, Principal Executive Officer




Certifications
- --------------
I, Steven D. Krichmar, the 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. The registrant's other certifying officer and I are responsible for
establishing and maintaining disclosure controls and procedures (as
defined in rule 30a-3(c) under the Investment Company Act of 1940) 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 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 quarter that has materially
affected, or is reasonably likely to materially affect, the
registrant's internal control over financial reporting; and

5. The registrant's other certifying officer 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 over financial reporting.

/s/Steven D. Krichmar       Date: December 23, 2004
- ----------------------      -----------------------
Steven D. Krichmar, Principal Financial Officer




Attachment A
- --------------
Period(s) ended October 31, 2004

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
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>3
<FILENAME>exnosncsr3.txt
<DESCRIPTION>EX-99.CODE ETH
<TEXT>
Section 906 Certifications
- ---------------------------
I, Charles E. Porter, a 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, 2004 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, 2004 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, 2004
- ----------------------      -----------------------
Charles E. Porter, Principal Executive Officer




Section 906 Certifications
- ---------------------------
I, Steven D. Krichmar, the 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, 2004 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, 2004 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, 2004
- ----------------------      -----------------------
Steven D. Krichmar, Principal Financial Officer




Attachment A
- --------------
Period(s) ended October 31, 2004

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
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>4
<FILENAME>coe1.txt
<TEXT>

working@Putnam                                                August 2004

                            CODE OF ETHICS
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 fund shareholders and other clients, or to do
anything that could damage or erode the trust our fund shareholders and
other clients place in Putnam and its employees.


TABLE OF CONTENTS

OVERVIEW.............................................................iii
PREAMBLE..............................................................vi
DEFINITIONS: Code of Ethics .........................................vii
SECTION I. Personal Securities Rules for All Employees ............... 1
A. Pre-clearance and the Restricted List ............................. 1
B. Prohibited Transactions.............................................5
C. Discouraged Transactions.......................................... 11
D. Exempted Transactions .............................................11
SECTION II. Additional Special Rules for Personal Securities
Transactions of Access Persons and Certain Investment Professionals.. 13
SECTION III. General Rules for All Employees .........................18
SECTION IV. Special Rules for Officers and Employees of Putnam
Investments Limited ................................................. 29
SECTION V. Reporting Requirements for All Employees.................. 31
SECTION VI. Education Requirements ...................................34
SECTION VII. Compliance and Appeal Procedures.........................35
APPENDIX A: Policy Statement Concerning Insider Trading Prohibitions
PREAMBLE ............................................................ 37
DEFINITIONS: Insider Trading..........................................38
SECTION I. Rules Concerning Inside Information .......................39
SECTION II. Overview of Insider Trading ..............................41
APPENDIX B: Policy Statement Regarding Employee Trades in Shares of
Putnam Closed-End Funds ..............................................45
APPENDIX C: Contra-Trading Rule Clearance Form........................46
APPENDIX D: AIMR Code of Ethics and Standards of
Professional Conduct .................................................47
APPENDIX E: Report of Entertainment Form..............................53
INDEX ................................................................55


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 online 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 fund shareholders or other 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 material, 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. An
employee aware of or in possession of inside information must report it
immediately to the Code of Ethics Officer. See Appendix A, Section ll:
Overview of Insider Trading.

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 or other entity 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. Clearance is
facilitated through the online pre-clearance system for equity
securities, and directly with the Code of Ethics Administrator for
fixed-income securities and transactions in Putnam closed-end funds.
Certain securities are exempted from this pre-clearance requirement
(e.g., shares of open-end (not closed-end) mutual funds).

Clearance must be obtained in advance, between 11:30 a.m. and 4:00 p.m.
Eastern Standard Time (EST) on the day of the trade, except in the case
of a trade for up to 1,000 shares of stock of an issuer whose
capitalization exceeds $5 billion, clearance may be obtained between
9:00 a.m. and 4:00 p.m. EST on the day of the trade.  A clearance is
valid only for the day it is obtained. Putnam employees are strongly
discouraged from engaging in excessive trading for their personal
accounts. Beginning with the fourth quarter of 2004, employees will be
prohibited from making more than 25 trades in individual securities.
Trading in excess of this level will be reviewed with the Code of Ethics
Oversight Committee.

Putnam mutual funds

All employees and certain family members are subject to a minimum 90-day
holding period for shares in Putnam's open-end mutual funds. This
restriction does not apply to Putnam's money market funds. Except in
limited circumstances, all employees must hold Putnam open-end fund
shares in accounts at Putnam Preferred Access.

Portfolio managers and others with access to investment information
(so-called "Access Persons") are subject to a minimum one-year holding
period for holding Putnam open-end fund shares.

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. Note, however, that short selling "against the box" or
otherwise hedging an investment in shares of Marsh & McLennan (MMC)
stock is prohibited.

Confirmations of trading and periodic account statements

All Putnam employees must have their brokers send confirmations and
statements 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

Access persons 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 (even those to which pre-clearance may not apply)
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 may be reduced. Egregious conduct, e.g., willful
failures to report, will be subject to harsher sanctions, which may
include termination of employment.

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.

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. (Refer to Section II for details):

* 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 seven 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 seven 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 seven 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 an
appropriate CIO and the Code of Ethics Officer.

* No portfolio 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 as you are responsible for understanding the restrictions.


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 fund shareholders or other 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 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 advisor and its clients. 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.

The Code that follows represents a balancing of important interests. On
the one hand, as a registered investment advisor, 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 below are defined specifically for the purpose 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., beginning on the dates from
which the measurement is made.

Access Persons

Access Persons are (a) employees within Putnam's Investment Division,
and (b) 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 (such as certain Information Services Division employees and
certain members of the Legal and Compliance Department). Each employee
will be informed if he or she is considered a Code of Ethics Access
Person. The Code of Ethics Officer maintains a list of all Access
Persons.

Code of Ethics Administrator

The individual designated by the Code of Ethics Officer to assume
responsibility for day-to-day, nondiscretionary 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
Chief Compliance Officer or such other person as is designated by the
Chief Executive Officer of Putnam Investments. If the Code of Ethics
Officer is unavailable, the Deputy Code of Ethics Officer shall act in
his or her stead. The Code of Ethics Officer is Tony Ruys de Perez. The
Deputy Code of Ethics Officer is Kathleen Griffin.

Code of Ethics Oversight Committee

Has oversight responsibility for administering the Code of Ethics.
Members include the Code of Ethics Officer 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.

Narrow-based derivative

A future, swap, option, or similar derivative instrument whose return is
determined by reference to fewer than 25 underlying issuers. Single
stock futures and exchange traded funds based on fewer than 25 issuers
are included.

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 offered to the public and not requiring
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; this includes the writing of an option.

Putnam

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

Putnam client

Any of the Putnam mutual 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; any rights relating to a
security, such as warrants, convertible securities, and any narrow-based
derivative. Pre-clearance in all trades for any narrow-based derivative
is required.  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. Exchange traded index funds containing a portfolio or
securities of 25 or more issuers (e.g., SPDRs, WEBs, QQQs), commodities,
and any option on a broad-based market index or an exchange-traded
futures contract or option thereon are excluded.

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 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. Pre-clearance and the Restricted List

Rule 1

No Putnam employee shall purchase or sell for his personal account any
security (other than shares of open-end investment companies) without
prior clearance obtained through Putnam's intranet pre-clearance system
(under the @Putnam tab of www.ibenefitcenter.com). Fixed-income
securities must be pre-cleared by calling the Code of Ethics
Administrator, and there are special rules for trading in Putnam
closed-end funds. See Appendix B. Subject to the limited exceptions
below, no clearance will be granted for securities appearing on the

Restricted List. Securities will 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 for any Putnam client, unless the security is a nonconvertible
investment grade rated (BBB by S&P or Baa by Moody's) fixed-income
investment;

(b) When such a security is a voting security of a corporation in the
banking, savings and loan, communications, or gaming (i.e., casinos)
industries, if holdings of Putnam clients in that corporation 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.


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 online at
ibenefitcenter.com. Select Employee Essentials under the @Putnam tab.
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. EST.

Pre-clearance of fixed income securities and Putnam closed-end funds
must be made by calling the Code of Ethics Administrator.

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 any applicable 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.


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. Pre-clearing Transactions Effected by Share Subscription. The
purchase 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) Because 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.

C. Trades in Approved Discretionary Brokerage Accounts. A transaction
does not need to be pre-cleared if it takes place in an account that the
Code of Ethics Officer has approved in writing as exempt from the
pre-clearance requirement. In the sole discretion of the Code of Ethics
Officer accounts that will be considered for exclusion from the
pre-clearance requirement are only those for which an employee's
securities broker or investment advisor has complete discretion (a
discretionary account) and the following conditions are met (i) the
employee certifies annually in writing that the employee has no
influence over the transactions in the discretionary account and is not
aware of the transactions in the discretionary account prior to their
execution, (ii) the compliance department of the employee's broker or
investment advisor certifies annually in writing that the employee has
no influence over the transactions in the discretionary account and is
not aware of the transactions in the discretionary account prior to
their execution; and (iii) each calendar quarter, the broker or
investment advisor sends Putnam's Code of Ethics Administrator copies of
each quarterly statement for the discretionary account. Employees
wishing to seek such an exemption must send a written request to the
Code of Ethics Administrator.


COMMENTS

* Pre-clearance. Subpart (a) of Rule 1 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.

* 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 (5% for public utilities) of any
issuer in those industries. 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.

* 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. The automatic 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.

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

* 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.

* MMC securities. The pre-clearance, reporting and the rules applicable
to personal trading apply to securities of MMC, including MMC shares
held in the Putnam 401(k) plans and in the MMC Stock Purchase Plan.


SANCTION GUIDELINES

A. Failure to Pre-clear a Personal Trade

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

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

* 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

* 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.

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

* 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 two-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 has violated the Code of Ethics intentionally
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: (a) small-cap stocks (i.e., stocks not entitled to
the Large Cap exception) and (b) 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.

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. Employees are
prohibited from hedging investments made in securities of MMC.


EXCEPTIONS

Short selling against broad market indexes (such as the Dow Jones
Industrial Average, the NASDAQ index, and the S&P 100 and 500 indexes)
and short selling against the box are permitted (except that short
selling shares of MMC against the box is not 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

* 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.

* 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.

* 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. Privately placed
limited partnerships are specifically included in this Rule.


COMMENTS

* 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.

* 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.

* 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, and subject to the condition that the hedge fund does
not invest significantly in registered investment companies.

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

* 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.

* 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

Putnam employees may not hold shares of Putnam open-end U.S. mutual
funds other than through accounts maintained at Putnam through Putnam
Preferred Access (PPA). Employees placing purchase orders in shares of
Putnam open-end funds must place such orders through Putnam and not
through an outside broker or other intermediary. Employees redeeming or
exchanging shares of Putnam open-end funds must place those orders
through Putnam and not through an outside broker or other intermediary.
Contact a PPA representative at 1-800-634-1590 for instructions on how
to transfer these funds.

NOTE:

For purposes of this Rule, "employee" includes:

* Members of the immediate family of a Putnam employee who share the
same household as the employee or for whom the Putnam employee has
investment discretion (family member);

* Any trust in which a Putnam employee or family member is a trustee
with investment discretion and in which such Putnam employee or any
family member are collectively beneficiaries;

* Any closely-held entity (such as a partnership, limited liability
company, or corporation) in which a Putnam employee and his or her
family members hold a controlling interest and with respect to which
they have investment discretion; and

* Any account (including any retirement, pension, deferred compensation,
or similar account) in which a Putnam employee or family member has a
substantial economic interest and over which said Putnam employee or
family member exercises investment discretion.


COMMENTS

* These requirements also apply to self-directed IRA accounts holding
Putnam fund shares.

* For Putnam Profit Sharing Plan or other Putnam deferred compensation
accounts, trades may continue to be placed through ibenefitcenter.com.

* These Rules apply to variable insurance accounts, which invest in
Putnam Variable Trust such as the Putnam/Hartford Capital Manager.
Employees must designate Putnam Retail Management as the broker of
record for all such accounts.


EXCEPTION

Retirement, pension, deferred compensation and similar accounts that
cannot be legally transferred to Putnam are not subject to the
requirement. For example, a spouse of a Putnam employee may have a
401(k) plan with her employer that invests in Putnam funds. Any employee
who continues to hold shares in open-end Putnam funds outside of Putnam
must notify the Code of Ethics Officer in writing of the account
information, provide the reason why the account cannot be transferred to
Putnam and arrange for a quarterly statement of transaction in such
account to be sent to the Code of Ethics Administrator.

Rule 7

(a) Employees defined in Rule 6 may not, within a 90-calendar day
period, make a purchase followed by a sale, or a sale followed by a
purchase, of shares of the same open-end Putnam mutual fund even if the
transactions occur in different accounts.

(b) Employees who are Access Persons may not, within a one-year period,
make a purchase followed by a sale, or a sale followed by a purchase, of
shares of the same open-end Putnam mutual fund or of shares of any U.S.
registered mutual fund to which Putnam acts as advisor or sub-advisor
even if the transactions occur in different accounts.


COMMENTS

* This restriction applies across all accounts maintained by an employee
as follows:

An employee who buys shares of an open-end Putnam mutual fund may not
sell any shares of the same mutual fund until 90 calendar days have
passed.

Example. If an employee buys shares of a Putnam fund on Day 1 for a
retail account and then sells (by exchange) shares of the same fund for
his or her Putnam Profit Sharing 401(k) Plan account on Day 85, the
employee has violated the rule.

Similarly, an employee who sells shares of an open-end Putnam mutual
fund may not buy any shares of the same mutual fund until 90 calendar
days have passed.

Example. If an employee sells shares of a Putnam fund on day 1 for a
retail account and then sells (by exchange out) shares of the same fund
for his or her Putnam Profit Sharing 401(k) Plan account on day 85, the
employee may not buy (or exchange in) shares of that fund in any account
until day 176, which is more than 90 days after the most recent sale of
shares of that fund.

* The purpose of these blackout periods restriction is to prevent any
market timing, or appearance of market timing activity.

* This Rule applies to transactions by a Putnam employee in any type of
account, including retail, IRA, variable annuity, college savings 529
plans, Profit Sharing 401(k) Plan, and any deferred compensation
accounts.

* The minimum sanction for an initial violation of the blackout period
shall be disgorgement of any profit made on the transaction. Additional
sanctions may apply, including termination of employment.


EXCEPTIONS

A. This restriction does not apply to Putnam's money market funds and
Putnam Stable Value Fund.

B. Profit Sharing 401(k) Plan Contributions and Payroll Deductions. The
90-day restriction is not triggered by initial allocation of regular
employee or employer contributions or forfeitures to an employee's
account under the terms of Putnam employee benefit plans or a Putnam
payroll deduction direct investment program; later exchanges of these
contributions will be subject to the 90-day blackout period.

C. Systematic Programs. This restriction does not apply with respect to
shares sold or acquired as a result of participation in a systematic
program for contributions, withdrawals or exchanges, provided that an
election to participate in any such program and the participation dates
of the program may not be changed more often than quarterly after the
program is elected by the employee. Access Persons may elect a quarterly
or semiannual rebalancing program although it may only be changed on an
annual basis;

D. Employee Benefit Plan Withdrawals and Distributions. This restriction
does not apply with respect to shares sold for withdrawals, loans or
distributions under the terms of Putnam employee benefit plans;

E. Dividends, Distributions, Mergers, and Share Class Conversions. This
restriction does not apply with respect to the requisitioned shares as a
result of reinvestment of dividends, distributions, mergers, conversions
of share classes, or other similar actions. Subsequent transactions with
respect to the shares will be covered.

F. In special situations, Putnam's Code of Ethics Oversight Committee
may grant exceptions to the blackout periods as a result of death,
disability, or special circumstances (such as, personal hardship), all
as determined from time to time by the Committee. Employees can request
an exception by submitting a written request to the Code of Ethics
Officer.

Rule 8: Good Until Canceled Orders

Good Until Canceled (GTC) Orders and Limit Orders are prohibited.

Any order not executed on the day of pre-clearance must be resubmitted
for pre-clearance before being executed on a subsequent day. "Good until
canceled" or "limit" orders are prohibited because of the potential
failure to pre-clear.

Rule 9: Excessive Trading

Putnam employees are strongly discouraged from engaging in excessive
trading for their personal accounts. Beginning with the fourth quarter
of 2004, employees will be prohibited from making more than 25 trades in
individual securities in any given quarter. Excessive trading within
Putnam open-end mutual funds is prohibited.


COMMENTS

* 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. Short-term trading is strongly discouraged while employees
are encouraged to take a long-term view.

* Employees should be aware that their trading activity is closely
monitored. Ten trades or more per quarter will be discouraged and will
warrant a review memo. Activity exceeding 25 trades per quarter will be
prohibited by the Code of Ethics Oversight Committee. Sanctions will be
imposed such as a trading ban or a more stringent sanction may be
determined at the discretion of the Committee. Different rules apply
with respect to trading in shares of Putnam open-end mutual funds. See
Section I. B, Rule 7 above.

C. Discouraged Transactions

Rule 1

Putnam employees are strongly discouraged from engaging in writing
(selling) naked options for their personal accounts.

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.


EXCEPTIONS

None.

D. Exempted Transactions

Rule 1

Transactions that 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

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

* 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.

* 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.

* 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 4.

Rule 2

Transactions that have been determined in writing by the Code of Ethics
Officer before the transaction occurs to be no more than remotely
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.


IMPLEMENTATION

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


COMMENTS

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

* 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 vii)

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

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

B. 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.

C. 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.


COMMENTS

* 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.

* 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.

* Effective in the fourth quarter of 2004, the 60-Day Rule will become a
Black Out Rule. An Access Person cannot trade a security within 60 days
regardless of tax lot election.

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) Comanagers: Before a portfolio manager places an order to buy a
security for any Putnam client he manages, his comanager shall sell any
such security or related derivative security purchased in a 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.


COMMENTS

* This Rule applies to portfolio managers (including chief investment
officers (CIO) 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 seven days following the
purchase of that security for his or her personal account.

* 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. The recipient charity will
be chosen by the Code of Ethics Officer.

* This Rule is designed to avoid even the appearance of a conflict of
interest between an investment professional and a Putnam client. A
greater burden is placed on these professionals given their positions in
the organization. Transactions executed for the employee's personal
account must be conducted in a manner consistent with the Code of Ethics
and in such a manner as to avoid any actual or perceived conflict of
interest or any abuse of the employee's position of trust and
responsibility.

* "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.


EXCEPTIONS

None.

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 comanages; 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 comanages.

(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).


COMMENTS

* 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 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 seven days preceding a transaction in
that security for his or her personal account.

* 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.

* 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.


EXCEPTIONS

None.

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 comanages

(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 and written approval are 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, for her approval, within
24 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

* 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.

* 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

General Rules for All Employees

Rule 1: Compliance with All Laws, Regulations and Policies

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


EXCEPTIONS

None.

COMMENTS

* Putnam may report to the appropriate legal authorities conduct by
Putnam employees that violates this Rule.

* 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: Conflicts of Interest

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

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

* 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: Gifts and Entertainment Policy

No Putnam employee shall accept anything of material value from any
broker-dealer, financial institution, corporation or other entity, any
existing or prospective supplier of goods or services with a business
relationship to Putnam, or any company or other entity whose securities
are held in or are being considered as investments for the Putnam funds,
or any other client account. Included are gifts, favors, preferential
treatment, special arrangements, or access to special events.


COMMENTS

This Rule is intended to permit the acceptance of only proper types of
customary and limited business amenities.

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.


IMPLEMENTATION

A. Gifts. An employee may not accept small gifts with an aggregate value
of more than $100 in any year from any one source. Any Putnam employee
who is offered or receives an item exceeding $100 in value is prohibited
by this Rule and must report the details to the Code of Ethics Officer.
Any entertainment event provided to an employee where the host is not in
attendance is treated as a gift and is subject to the $100 per year per
source limit.

B. Entertainment. Putnam's rules are designed to permit reasonable,
ordinary business entertainment, but prohibit any events, which may be
perceived as extravagant or involving lavish expenditures.

1. Occasional lunches, dinners, cocktail parties, or comparable
gatherings conducted for business purposes are permitted.

For example, occasional attendance at group functions sponsored by sell
side firms is permitted where the function relates to investments or
other business activity. Occasional attendance at these functions is not
required to be counted against the limits described in paragraph 2(b)
below.

2. Other entertainment events, such as, sporting events, theater,
movies, concerts, or other forms of entertainment conducted for business
purposes, are permitted only under the following conditions:

(i) The host must be present for the event.

(ii) The location of the event must be in the metropolitan area in which
the office of the employee is located.

(iii) Spouses or other family members of the employee may not attend the
entertainment event or any meals before or after the entertainment
event.

(iv) The value of the entertainment event provided to the employee may
not exceed $150, not including the value of any meals that may be
provided to the employee before or after the event.

Acceptance of entertainment events having a market value materially
exceeding the face value of the entertainment including, for example,
attendance at sporting event playoff games, is prohibited. This
prohibition applies even if the face value of tickets to the events is
$150 or less or when the Putnam employee offers to pay for the tickets.
If there is any ambiguity about whether to accept an entertainment event
in these circumstances, please consult the Code of Ethics Officer.

(v) The employee may not accept entertainment events under this
provision (B)(2) more than six times a year and not more than two times
in any year from any single source.

(vi) The Code of Ethics Officer may grant exceptions to these rules. For
example, it may be appropriate for an employee attending a legitimate
conference in a location away from the office to attend a business
entertainment event in that location. All exceptions must be approved in
advance by written request to the Code of Ethics Officer.

3. Any employee attending any entertainment event under (B)(1) or (B)(2)
above must file a Report of Entertainment Form (attached as Appendix E)
with the Code of Ethics Officer within 10 days following the date of the
entertainment event. Failure to file the notice is a violation of the
Code of Ethics.

4. Meals and entertainment, which are part of the regular program at an
investment conference (i.e., open to all participants) are not subject
to the limits of this section (B)(2) above.

C. Among the items that are prohibited are:

1. Any entertainment event attendance, which would reflect badly on
Putnam as a firm of the highest fiduciary and ethical standards. For
example, events involving adult entertainment or gambling must be
avoided.

2. Entertainment involving travel away from the metropolitan area in
which the employee is located. Even in the event an exception is granted
as contemplated by (B)(2)(vi) above, payment by a third party of the
cost of transportation to a location outside the employee's metropolitan
area, lodging while in another location, and any meals not specifically
approved by the Code of Ethics officer, are prohibited;

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

4. Preferential brokerage or underwriting commissions or spreads or
allocations of shares or interests in an investment for the personal
account of a Putnam employee; and

5. Cash or cash equivalents

D. 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 number 3 of Section VII.

E. No Putnam employee may solicit any gift or entertainment from any
person, even if the gift or entertainment, if unsolicited, would be
permitted.

F. The Rule does not prohibit employees on business travel from using
local transportation and arrangements customarily supplied by brokers or
similar entities. For example, it is customary for brokers in developing
markets to make local transportation arrangements. These arrangements
are permitted so long as the expense of lodging and air travel are paid
by Putnam.

Rule 4: Anti-bribery/Kickback Policy

No Putnam employee shall 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
(which are described in Rule 5 below), 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 fundraisers) on
behalf of Putnam, and no employee will be reimbursed by Putnam for such
contributions made by the employee personally.

Rule 5: Political Contributions/Solicitations Policy

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.

COMMENTS

* 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.

* This rule prohibits solicitation on personal letterhead by Putnam
employees except as approved by the Code of Ethics Officer.

* Certain officers and employees of Putnam Retail Management and other
employees involved in Putnam's College Advantage Section 529 Plan with
Ohio Tuition Trust Authority are subject to special rules on political
contributions. For questions on these requirements, please call the Code
of Ethics Administrator.

Rule 6: Confidentiality of Putnam Business Information

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 unless doing so has a valid business purpose and is in
accord with any relevant procedures established by Putnam relating to
such disclosures.


COMMENT

All information about Putnam and Putnam clients is strictly
confidential. Putnam research information should not be disclosed
without proper approval and never for personal gain.

Rule 7: Roles At Other Entities

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. Requests for a role at a
publicly-traded company will be closely reviewed and permission will be
granted on an ad-hoc basis.


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 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 unless the
employee is responsible for day-to-day portfolio management of the
account.


COMMENTS

* 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.

* Positions with public companies are especially problematic and will
normally not be approved.

* 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: Role as Trustee or Fiduciary Outside of Putnam

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


EXCEPTIONS

A. 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 unless the employee is responsible for day-to-day
portfolio management of the account.

B. 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: Investment Clubs

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 vii).

Rule 10: Business Negotiations For Putnam

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: Accurate Records

No employee may create, alter or destroy (or participate in the
creation, alteration or destruction of) any record that is intended to
mislead anyone or to conceal anything that is, or is reasonably believed
to be, 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

* 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.

* 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 12: Interest in Entities Doing Business with Putnam

No employee shall 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 13: Affiliated Entities

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 a Non-Putnam affiliate or 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 unless doing so has a valid business
purpose and is in accord with any relevant procedures established by
Putnam relating to such disclosures,

(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 derived from the employee's
service as a director or officer of the NPA.


COMMENTS

* 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 should 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
advisor or sub-advisor to the NPA or one of its products, in which case
normal Putnam aggregation rules apply.

* 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.

* 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.

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

Rule 14: Computer System/Network Policies

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.


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 online
Employee Handbook is located online at www.ibenefitcenter.com under
Policies and Procedures under the @Putnam tab.


EXCEPTIONS

None.

Rule 15: AIMR Code of Ethics

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 D.


EXCEPTIONS

None.

Rule 16: Privacy Policy

Except as provided below, no employee may disclose to any outside
organization or person any nonpublic 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 nonpublic 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

A. Putnam Employees. Nonpublic 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.

B. Shareholder Consent Exception. Nonpublic 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.

C. Broker or Advisor Exception. Nonpublic personal information about a
shareholder's or client's account may be provided to the shareholder's
or client's broker of record.

D. Third-Party Service Provider Exception. Nonpublic 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 nonpublic
personal information.


COMMENTS

* Nonpublic 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 who 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.

* 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.

* 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.

* 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
chief compliance officer and, in the event of a breach of computerized
data, Putnam's chief technology officer.

Rule 17: Anti-money Laundering Policy

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 chief compliance officer and chief financial officer.

Rule 18: Record Retention

All employees must comply with the record retention requirements
applicable to the business unit. 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 requirements of
Section I.A. 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 the Financial Services Authority, 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 may 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 and statements 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 UK 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 copies of all confirmations for
securities transactions for his personal brokerage accounts, and,
beginning in the fourth quarter 2004, brokerage account statements are
sent to the Putnam Compliance Department's (Code of Ethics
Administrator). (For the purpose of this Rule, securities shall also
include ETFs, futures, and other derivatives on broad-based market
indexes excluded from the pre-clearance requirement.) Statements and
confirmations are required for Putnam funds not held at PPA or in a
Putnam retirement plan, as well as for U.S. mutual funds sub-advised by
Putnam.


EXCEPTION

None.

IMPLEMENTATION

A. Putnam employees must instruct their broker-dealers to send
statements and confirmations to Putnam and must follow up with the
broker-dealer on a reasonable basis to ensure that the instructions are
being followed. For brokerage accounts, Putnam employees should contact
the Code of Ethics Administrator to obtain a letter from Putnam
authorizing the setting up of a personal brokerage account.

B. Statements and confirmations should be submitted to the Code of
Ethics Administrator.

C. Specific procedures apply to employees of PIL. Employees of PIL
should contact the London Code of Ethics Administrator.

D. 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. Similarly, failure by an employee to report the
existence of a personal account (and, if the account is opened after
joining Putnam, failure to obtain proper authorization to establish the
account) shall be a violation of this Rule.

E. Statements and confirmations must also be sent for members of an
employees' immediate family, including statements received with respect
to a family member's 401(k) plan at another employer.


COMMENTS

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

* Statements and confirmations are required for all personal securities
transactions, whether or not exempted or excepted by this Code.

* 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 exchange traded
funds (ETF), futures, and any option on a security or securities index,
including broad-based market indexes excluded from the pre-clearance
requirement and also includes transactions in Putnam open-end funds if
the account for the Putnam funds is not held at PPA or in a Putnam
retirement plan and for transactions in U.S. mutual funds sub-advised by
Putnam.)


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.


COMMENTS

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

* 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. It is the responsibility of the employee to request an early
report if he has knowledge of a planned absence, i.e., vacation or
business trip.

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 within ten
calendar days of hire and thereafter on an annual basis. This
requirement is mandated by SEC regulations and is 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.

Reporting Irregular Activity

Rule 4

If a Putnam employee suspects that fraudulent, illegal, or other
irregular activity (including violations of the Code of Ethics) might be
occurring at Putnam, the activity should 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 financial officer and Putnam's Chief
Compliance Officer.

An employee who does not feel comfortable reporting this activity to the
relevant managing director may instead contact the chief compliance
officer, the Putnam or MMC Ethics hotlines or the ombudsman.

Rule 5

Putnam has established a formal Office of the Ombudsman as an additional
mechanism for an employee to report an impropriety or conduct that is
not in line with the company's value system. The ombudsman is a person
who is authorized to receive complaints or questions confidentially
about alleged acts, omissions, improprieties, and broader systemic
problems within the organization. Communication with the Ombudsman is
confidential.


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
annually 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 employee will annually be required to complete training on
Putnam's Code of Ethics.


SECTION VII

Compliance and Appeal Procedures

A. 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. 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.

B. 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 exception. 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.

C. 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.

D. 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 number 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 reasonable efforts to promptly
render a written determination concerning the request for an ad hoc
exemption.

E. 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.

F. Information Concerning Identity of Compliance Personnel

The names of Code of Ethics personnel are available by contacting the
Legal and Compliance Department and will be published on Putnam's Web
site.

APPENDIX A: Policy Statement Concerning Insider Trading Prohibitions


PREAMBLE

Putnam has always forbidden trading on material nonpublic information
(inside information) by its employees. Tough federal laws make it
important for Putnam to state 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. Federal law provides that an individual convicted of trading on
inside information may go to jail for a 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, as well as penalties substantially greater than 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. An employee aware of or in possession of inside information
must report it immediately to the Code of Ethics Officer. 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.

APPENDIX A

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 chief compliance officer or such other person as is designated by
the chief executive officer of Putnam Investments. If he or she is
unavailable, the Deputy Code of Ethics Officer (to be appointed by the
Code of Ethics Officer) shall act in his or her 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, 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 all securities
of any type.)

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 PIL must also consult
the relevant procedures on compliance with U.K. insider dealing
legislation set forth in PIL's Compliance Manual (See Rule 3 of Section
IV of the Code of Ethics).


APPENDIX A

SECTION I: 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

* 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.

* 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.

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, the
Deputy Code of Ethics Officer or, in their absence, the general counsel
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.


IMPLEMENTATION

A. 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.

B. 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 (and time to gather such 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. In appropriate situations, the Code of Ethics Officer shall
place the affected security or securities on the Red List pending the
completion of his evaluation.

C. 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.

D. Members of the executive board of directors and members of chief
financial officer's staff may not trade securities of MMC in the period
from the end of each calendar quarter to the date of announcement of
MMC's earnings for such quarter.


COMMENTS

While all employees must pre-clear trades of MMC securities and make
sure they are not in possession of material inside information about MMC
when trading, certain employees who may receive information about
Putnam's earnings are subject to the rules above concerning trading
black out periods.


APPENDIX A

SECTION II: Overview of Insider Trading

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.

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. The following
sections help explain the definition.

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 that 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.

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.

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.

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 advisor 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 advisor or its employees, nor its clients can
trade on the basis of that information, because the investment advisor
and its employees could be considered "temporary insiders" of Acme.

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 Investment 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 Investment 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.

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.

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 Investment 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.)

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 types penalties below, even if he does not personally benefit
from the violation. Penalties include:

* Jail sentences, criminal monetary penalties.

* 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 substantially greater than 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.

* 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

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. The
automated pre-clearance system is not available for Putnam closed-end
fund clearance. Trading in shares of closed-end funds is subject to all
the rules of the Code of Ethics. Contact the Code of Ethics
Administrator with these pre-clearance requests.

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
Administrator for further information.

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: Contra-Trading Rule Clearance Form

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: 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:

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

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

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

* 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

Fundamental Responsibilities

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

Relationships with and Responsibilities to the Profession

Use of Professional Designation

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.

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.

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.

Professional Misconduct

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.

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.

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.

Relationships with and Responsibilities to the Employer

Obligation to Inform Employer of Code and Standards

Members shall 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.

Members shall deliver a copy of the Code and Standards to their employer
if the employer does not have a copy.

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.

Disclosure of Conflicts to Employer

Members shall comply with any prohibitions on activities imposed by
their employer if a conflict of interest exists.

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.

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.

Relationships with and Responsibilities to Clients and Prospects

Investment Process

REASONABLE BASIS AND REPRESENTATIONS

* Exercise diligence and thoroughness in making investment
recommendations or in taking investment actions.

* Have a reasonable and adequate basis, supported by appropriate
research and investigation, for such recommendations or actions.

* Make reasonable and diligent efforts to avoid any material
misrepresentation in any research report or investment recommendation.

* Maintain appropriate records to support the reasonableness of such
recommendations or actions.


RESEARCH REPORTS


* Use reasonable judgment regarding the inclusion or exclusion of
relevant factors in research reports.

* Distinguish between facts and opinions in research reports.

* 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.


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.

Interactions with Clients and Prospects

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.


PORTFOLIO INVESTMENT RECOMMENDATIONS AND ACTIONS

Members shall:

* 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.

* 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.

* Distinguish between facts and opinions in the presentation of
investment recommendations.

* 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.

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.


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:

* direct or indirect pecuniary interest in the securities;

* the power to vote or direct the voting of the shares of the securities
or investments;

* the power to dispose or direct the disposition of the security or
investment.


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.


PROHIBITION AGAINST MISREPRESENTATION


Members shall not make any statements, orally or in writing, that
misrepresent

* the services that they or their firms are capable of performing;

* their qualifications or the qualifications of their firm;

* 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.


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.


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.

Relationships with and Responsibilities to the Public

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.


PERFORMANCE PRESENTATION

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. 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.

APPENDIX E: Report of Entertainment Form


This form must be filed with the Putnam Legal and Compliance Department
within 10 days of date of entertainment.

Send to:
Laura Rose
Assistant Vice President and Code of Ethics Administrator
Mailstop L-5

OR

Attach to an e-mail to:
laura_rose@putnam.com

Name of employee:____________________________________________

Name of party providing entertainment:

Firm: _______________________________________________________

Person:______________________________________________________

Date of entertainment:_______________________________________

Describe entertainment provided:_____________________________
(e.g., name and location of restaurant, sporting, or cultural event)

Value of entertainment (excluding meals):____________________

Signature: ____________________________________ Date:_______________


INDEX

7-Day Rule
transactions by portfolio managers,
analysts, and CIOs .......................................................14
60-Day Rule...............................................................13

A

Access Persons
definition ............................................................. vii
special rules on trading..................................................13
AIMR Code of Ethics and Standards of
Professional Conduct .................................................... 47
Analysts
special rules on trading................................................. 14
Appeals
Procedures................................................................36

B

Bankers' acceptances
excluded from securities ...............................................viii
Blackout rule
trading by portfolio managers,
analysts and CIOs........................................................ 15
Boycott
anti-trust and other laws.................................................18
Bribes ...................................................................21

C

Certificates of Deposit
excluded from securities ...............................................viii
Clearance
how long pre-clearance is valid............................................2
required for personal
securities transactions ...................................................1
Closed-end funds
pre-clearance and reporting ..............................................45
Commercial paper
excluded from securities ...............................................viii
Commodities (other than securities indices)
excluded from securities ...............................................viii
Computer use
compliance with corporate
policies required ........................................................26
Confidentiality
required of all employees.............................................22, 26
Confirmations and broker statements
required for personal transactions........................................31
Conflicts of interest
with Putnam and Putnam clients............................................18
Contra-trading rule
transactions by portfolio managers
and CIOs .................................................................16
Convertible securities
defined as securities...................................................viii
Currencies
excluded as securities..................................................viii

D

Definitions..............................................................vii
Director
prohibited to serve for another entity....................................23
Dividend reinvestment program.............................................11

E

Employee
prohibited to serve for another entity ...................................23
Excessive trading (over 25 trades) prohibited ............................10
Exchange traded index funds,
excluded from securities ...............................................viii
Exemptions..........................................................3, 4, 11

F

Family members
covered in personal
securities transactions .........................................viii, 7, 38
Fiduciary
prohibited to serve for another entity....................................23
Fraudulent or irregular activities
reporting ................................................................24

G

Gifts and Entertainment Policy .......................................18, 19
Good-until-canceled orders................................................10

H

Holdings of securities
disclosure by Access Persons..............................................32

I

Initial public offerings/IPOs
purchases are prohibited...................................................5
Insider trading
policy statement and explanations ........................................38
prohibited............................................................iii, 5
Investment clubs
prohibited................................................................23
Involuntary personal securities transactions
exemptions ............................................................4, 11

L

Large Cap Exception
for clearance of securities on
Restricted List............................................................2
Limit Orders..............................................................10

M

Market timing prohibition..................................................9
Money market instruments
excluded from securities............................................... viii

N

Naked options
by employees discouraged..................................................11
Non-Putnam affiliates (NPAs)
transactions and relationships............................................25

O

Officer
prohibited to serve for another entity ...............................22, 23
Options
defined as securities...................................................viii
relationship to securities on
Restricted or Red Lists....................................................3
Ombudsman.................................................................33

P

Partner
prohibited to serve as general partner of
another entity........................................................... 23
Partnerships
covered in personal securities
transactions ...................................................... viii, 37
Personal securities transaction
defined ............................................................viii, 38
Political contributions...................................................21
Portfolio managers
special rules on trading..............................................14, 17
Privacy policy ...........................................................26
Private offerings, purchases in private
placements................................................................ 6
Putnam Investments Limited
special rules ............................................................29

Q

Quarterly Report of securities transactions ..............................32

R

Reporting requirements....................................................31
Repurchase agreements
excluded from securities................................................viii

S

Sanctions ................................................................vi
for failure to pre-clear properly ........................................ 4
Shares by subscription
procedures to preclear trades............................................. 2
Short sales
prohibited conduct........................................................ 5

T

Tender offers .............................................................4
Trustee
prohibited to serve for another entity....................................23
Trusts
covered in personal securities
transactions .......................................................viii, 38

U

U.S. government obligations
excluded from securities................................................viii

V

Violations of Law
reporting ................................................................33

W

Warrants
defined as securities...................................................viii

PUTNAM INVESTMENTS

One Post Office Square
Boston, Massachusetts 02109
1-800-225-1581
www.putnaminvestments.com                                        215845 8/04


</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-99.CODE ETH
<SEQUENCE>5
<FILENAME>co1.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 Trust or Its Subsidiaries

A. Incorporation of Adviser's Code of Ethics.  The provisions of the
Code of Ethics for employees of Putnam Investments Trust 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 Trust 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 Code of Ethics Officer designated
therein.  A report filed with the Code of Ethics Officer shall be deemed
to be filed with each of the Funds of which the reporting individual is
an officer or Trustee.

C. Review and Reporting.

(1) The Code of Ethics Officer shall cause the reported personal
securities transactions to be compared 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
Code of Ethics Officer shall give such person an opportunity to supply
additional explanatory material.

(2) If the Code of Ethics Officer determines that a violation of any
provision of this Code has or may have occurred, he shall submit his
written determination, together with any additional explanatory
material, to the Audit and Pricing Committee of the Funds at its next
meeting.

D. Sanctions.  In addition to reporting violations of this Code to the
Audit and Pricing Committee of the Funds as provided in Section I-C(2),
the Code of Ethics officer shall also report to such Committee any
sanctions imposed with respect to such violations.  The Committee
reserves the right to impose such additional sanctions as it deems
appropriate.

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.

(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 high-quality short-term
debt investments, including repurchase agreements, and shares of
registered open-end investment companies, but shall include any security
convertible into or exchangeable for a security.

(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 Investment 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 of securities effected in any account over which
the Unaffiliated Trustee has no direct or indirect influence or control;

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

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

(4) purchases of securities 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 of securities 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 Legal and Compliance Liaison Officer of the
Funds, in consultation with the Code of Ethics Officer, which approval
shall be confirmed in writing.

D. Reporting.

(1) Whether or not one of the exemptions listed in Section II-C applies
and except as provided in Section II-C(5), every Unaffiliated Trustee of
a Fund shall file with the Funds' Legal and Compliance Liaison Officer a
report containing the information described in Section II-D(2) of this
Code with respect to purchases or sales of 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, the number of shares, the
interest rate and maturity date (if applicable) 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; and

(e) the date that the report is submitted by each Unaffiliated Trustee.

(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 II-C 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 person" of the Funds shall
file the reports required by Rule 17j-1(d)(1) under the Investment
Company Act of 1940 with the Code of Ethics Officer of Putnam
Investments.  Such reports shall be reviewed by such Officer as provided
in Section I-C(1) and any related violations shall be reported by him to
the Audit and Pricing Committee as provided in Section I-C(2).  The
Committee may impose such additional sanctions as it deems appropriate.

E. Review and Reporting.

(1) The Legal and Compliance Liaison Officer of the Funds, in
consultation with the Code of Ethics Officer of Putnam Investments,
shall cause the reported personal securities transactions that he
receives pursuant to Section II-D(1) to be compared 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 Legal and Compliance Liaison Officer 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 Legal and Compliance
Liaison Officer shall give the person involved an opportunity to supply
additional information regarding the transaction in question.

F. Sanctions.  If the Legal and Compliance Liaison determines that a
violation of this Code has occurred, he shall so advise the Funds' Audit
and Pricing Committee, and provide the Committee with a report of the
matter, including any additional information supplied by such person.
The Committee may impose such sanctions as it deems appropriate.

III. Miscellaneous

A. Amendments to the Putnam Investments' Code of Ethics.  Any amendment
to the Putnam Investments' 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 persons 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.

To the extent any record required to be kept by this section is also
required to be kept by Putnam Investments pursuant to the Putnam
Investments' Code of Ethics, Putnam Investments shall maintain such
record on behalf of the Funds as well.

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 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
November 1, 2004

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