<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>4
<FILENAME>legal77e074.txt
<TEXT>
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
shareholders and the funds. 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.

The Staff of the SEC has questioned whether certain disclosure
requirements were satisfied in connection with dividend payments
by the fund. Putnam Management is currently engaged in settlement
discussions with the SEC regarding this matter.

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>
