<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>3
<FILENAME>legal77e074.txt
<TEXT>
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 SECs 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 has agreed to bear any costs
incurred by Putnam funds in connection with these lawsuits.
Based on currently available information, Putnam Management
believes that the likelihood that the pending private lawsuits
and purported class action lawsuits will have a material adverse
financial impact on the fund is remote, and the pending actions
are not likely to materially affect its ability to provide
investment management services to its clients, including the
Putnam funds.

Review of these matters by counsel for Putnam Management and by
separate independent counsel for the Putnam funds and their
independent Trustees is continuing.


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