The distribution payments owed to Putnam shareholders resulted from losses attributable to market timing or excessive short-term trading of Putnam mutual funds by Putnam employees and shareholders in their mutual fund and retirement accounts.

Market timing refers to transactions primarily intended to capitalize on short-term staleness of a fund's net asset value (NAV). Potential market timing transactions are characterized as exhibiting two properties: 1) transactions in a fund whose next-trading-day NAV is "predictable" or forecastable based on information available prior to close of orders on the current trading day (4 PM) and 2) transactions with "relatively short" holding periods.

Short-term trading is a circumstance in which an investor buys and then quickly redeems shares resulting in a rise to costs borne by other shareholders who are the involuntary counterparties to these trades. These costs include administrative costs of processing shareholder transactions, portfolio transaction costs, and, potentially, pressure to hold cash to facilitate large and unexpected shareholder activity, and costs due to accelerations of taxable events.

The time period in which investors were affected by market timing was from the first quarter of 1997 through the 3rd quarter of 2003. Additionally, a "post-period" was defined as Q4 2003 through January 2004 in which investors were indirectly impacted by the amount of redemptions out of Putnam Funds resulting from the market timing situation.

A total of 86 Putnam retail funds were affected by market timing. Of the 86 funds, the market timing was concentrated in 10 of the Putnam retail funds. The remaining funds experienced little or no effect from market timing activities, and were adversely affected by significant fund redemption activity that resulted from publicity related to market timing. Shareholders who held assets in the affected funds during part or all of the affected time period may be eligible to receive a distribution check. It is important to note that the vast majority of shareholders in the affected funds incurred either no losses, or only minimal losses, and therefore will not be entitled to receive any payment.

The Plan has been developed by the Independent Distribution Consultant for the Putnam plan, Professor Peter Tufano, according to a methodology developed in consultation with Putnam and acceptable to the staff of the Securities and Exchange Commission, the independent Trustees of the Putnam funds, and the Massachusetts Securities Division.

Putnam will be distributing in excess of $153 million plus accumulated interest. The amount represents distributions being paid under both the SEC and Massachusetts settlements.

The Putnam Fund Trustees and Putnam have worked very hard with the Independent Distribution Consultant (IDC) to be sure these calculations were completed in a manner that will reimburse shareholders fully and fairly. The shareholders of the Putnam funds can be assured that Putnam is steadfast about our pledge to put their interests first and that our focus is on continuing to improve performance through the delivery of consistent, dependable, and superior investment results.

Since the inception of these events, Putnam has been subject to an intense review by regulatory authorities, the Audit Committee of the Funds' Board of Trustees, and an independent compliance consultant appointed under the SEC settlement agreement. As a result of aggressive action taken by Putnam's corporate parent in coordination with the Funds' Trustees, disciplinary and corrective actions were taken and new management was installed at Putnam in late 2003. To guard against market timing and protect the interests of long-term investors, Putnam has enhanced short-term trading fee policies, "fair value" pricing of our international and global funds, and internal controls to detect and halt market timing activities, and has implemented stricter controls on employee trading.

For tax information related to this Fair Fund distribution, please refer to the "Tax Information" section of the site. As always, you should consult your financial advisor or tax professional to determine the potential tax consequences and appropriate tax treatment for your situation.

Yes. On March 30, 2007, the Securities and Exchange Commission issued a draft of the IDC's Distribution Plan for public comment. In accordance with SEC rules, after the completion of the public comment period, there was a 30-day period during which the SEC considered all such comments. This 30-day consideration period was extended to 75 days by the SEC. The draft Distribution Plan was also posted on Putnam's shareholder site.

Distribution amounts will be calculated as follows:

• The losses are assigned to the funds on a quarterly basis, and payments are distributed based on each shareholder's proportionate holdings in the fund during the quarter in which the losses occurred. Final computations per shareholder are not completed at this time.
  
• A payment threshold of $10 will be applied for direct accounts and retirement plans; $1,000 for Omnibus accounts. Payments due to shareholders under $10 will be remitted back to the affected mutual funds.
  

Because of practical impediments, and in the interest of carrying out the distribution consistently with other similar distributions, there is a need to establish minimum threshold levels of payments to shareholders. The minimum payment amount is $10 for Direct Accounts and Retirement Plans and $1000 for Omnibus Accounts. If the aggregate amount due to a shareholder within each such shareholder category is less than these minimum amounts, it will be considered under the threshold and the shareholder will not be eligible to receive a payment.

Checks began being distributed in batches in August 2008 and will continue into mid-2009.

Shareholders can call (800) 848-9697 to inquire about eligibility.

Shareholders are assured the right, under the plan, to reinvest their distribution amount in the Putnam funds without a sales charge.

For further information, please contact the Fund Administrator at (800) 760-5698.

Yes. However a shareholder with a Direct Account with Putnam who also holds Putnam fund shares through a broker in an Omnibus Account may receive two payments, and these payments cannot be added together for the purpose of payment or calculation of threshold amounts.

A total of 86 Putnam retail funds were affected by market timing. A complete list of affected funds (PDF) is available for download, or by contacting the Fund Administrator, at (800) 760-5698.

Appeals will be accepted only in cases of failure to execute the Distribution Plan in accordance with its terms for purposes of determining eligibility or mechanical errors in calculating the payment to a recipient. Shareholders who seek to make such an appeal should submit their appeal, in writing, to the appeal arbiter at the following address:

Putnam Fair Fund Appeals Arbiter
P.O. Box 990126
Boston, MA 02199-0126

Appeals will be accepted within 60 days from the date that the last batch of checks in the distribution is issued. Please refer to the Related Documents link on this Web site to obtain a copy of the "Putnam Fair Fund Appeal Form" or call the Fair Fund Administrator at 1-800-760-5698.

The approved Plan has been posted (PDF) on the SEC's Web site. Investors can obtain additional information about the distribution process by calling the Fund Administrator at (800) 760-5698.

You may contact the Fund Administrator at (800) 760-5698, Monday through Friday, 8:00 a.m. to 5:00 p.m. Central Time.