<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>5
<FILENAME>legal77e052.txt
<TEXT>

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.

</TEXT>
</DOCUMENT>
