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<TYPE>EX-99
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<FILENAME>legal052.txt
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77E  Regulatory matters and litigation

Putnam Management has entered into agreements with the Securities
and Exchange Commission  and the Massachusetts Securities
Division settling charges connected with excessive short term
trading by Putnam employees and, in the case of the charges
brought by the Massachusetts Securities Division, by participants
in some Putnam administered 401(k) plans.  Pursuant to these
settlement agreements, Putnam Management will pay a total of
$193.5 million in penalties and restitution, with $153.5 million
being paid to certain open end funds and their shareholders. The
amount will be allocated to shareholders and funds pursuant to a
plan developed by an independent consultant, and will be paid
following approval of the plan by the SEC and the Massachusetts
Securities Division.

The Securities and Exchange Commissions and Massachusetts
Securities Divisions allegations and related matters also serve
as the general basis for numerous lawsuits, including purported
class action lawsuits filed against Putnam Management and certain
related parties, including certain Putnam funds.  Putnam
Management will bear any costs incurred by Putnam funds in
connection with these lawsuits.  Putnam Management believes that
the likelihood that the pending private lawsuits and purported
class action lawsuits will have a material adverse financial
impact on the fund is remote, and the pending actions are not
likely to materially affect its ability to provide investment
management services to its clients, including the Putnam funds.

Putnam Management and Putnam Retail Management are named as
defendants in a civil suit in which the plaintiffs allege that
the management and distribution fees paid by certain Putnam funds
were excessive and seek recovery under the Investment Company Act
of 1940.  Putnam Management and Putnam Retail Management have
contested the plaintiffs claims and the matter is currently
pending in the U.S. District Court for the District of
Massachusetts.  Based on currently available information, Putnam
Management believes that this action is without merit and that it
is unlikely to have a material effect on Putnam Managements and
Putnam Retail Managements ability to provide services to their
clients, including the fund.



85B Additional Information About Errors and Omissions Insurance
Policy

While no claims with respect to the Registrant/Series were filed
under such policy during the period, requests under such policy
for reimbursement of certain costs related to actions involving
claims of market timing activity in certain Putnam Funds have
been submitted by the investment manager of the
Registrant/Series.


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