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<TYPE>EX-99
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<FILENAME>closed77e.txt
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77E

Regulatory matters and litigation.  On April 8, 2004, Putnam
Management entered into agreements with the Securities and
Exchange Commission 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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