UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM TA-1

UNIFORM FORM FOR REGISTRATION AS A TRANSFER AGENT AND FOR AMENDMENTTO REGISTRATION PURSUANT TO SECTION 17A OF THESECURITIES EXCHANGE ACT OF 1934
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GENERAL: Form TA-1 is to be used to register or amend registration as a transfer agent with the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation or the Securities and Exchange Commission pursuant to Section 17A of the Securities Exchange Act of 1934. Read all instructions before completing this form. Please print or type all responses.
Form Version:3.2.0
1(a).  Filer CIK: 0001448300
1(c). Live/Test Filing?
X Live    Test
1(e). Is this filing an amendment to a previous filing?
X Yes
1(e)(i).  File Number: 084-06331

2. Appropriate regulatory agency (check one):
X Securities and Exchange Commission
   Board of Governors of the Federal Reserve System
   Federal Deposit Insurance Corporation
   Comptroller of the Currency
   Office of Thrift Supervision

3(a).  Full Name of Registrant:
Putnam Investor Services, Inc.
3(a)(i).  Previous name, if being amended:

3(b).  Financial Industry Number Standard (FINS) number:338483
3(c).  Address of principal office where transfer agent activities are, or will be, performed:
3(c)(i).  Address 1
7 Shattuck Rd
3(c)(ii).  Address 2

3(c)(iii).  City
Andover
3(c)(iv).  State or Country
MA
MASSACHUSETTS
3(c)(v).  Postal Code
01810
3(d). Address of principal office where transfer agent activities are, or will be, performed:
X Yes    No
If `yes,` provide address(es):
3(d)(i).  Address 1
One Post Office Square
3(d)(ii).  Address 2

3(d)(iii).  City
Boston
3(d)(iv).  State or Country
MA
MASSACHUSETTS
3(d)(v).  Postal Code
02109
3(e).  Telephone Number (Include Area Code)
617-292-1000

4. Does registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Question 3(c) above?
   Yes X No
If `yes,` provide address(es):

5. Does registrant act, or will it act, as a transfer agent solely for its own securities and/or securities of an affiliate(s)?
   Yes X No

6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions?
   Yes X No
If `yes,` provide the name(s) and address(es) of all service companies engaged, or that will be engaged, by the registrant to perform its transfer agent functions:

7. Has registrant been engaged, or will it be engaged, as a service company by a named transfer agent to perform transfer agent functions?
   Yes X No
If `yes,` provide the name(s) and File Number(s) of the named transfer agent(s) for which the registrant has been engaged, or will be engaged, as a service company to perform transfer agent functions:

Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select `Not Applicable.`

8. Is registrant a:
X Corporation
   Partnership
   Sole Proprietorship
   Other
   Not Applicable

Section for Initial Registration and for Amendments Reporting Additional Persons. (Corporation or Partnership)

8(a)(i).  Full Name: Putnam U.S. Holdings, LLC
8(a)(ii).  Relationship Start Date: 12/30/2008
8(a)(iii).  Title or Status: Parent of Registrant
8(a)(iv). Ownership Code:
   NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
X E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Putnam Investments, LLC
8(a)(ii).  Relationship Start Date: 12/04/2007
8(a)(iii).  Title or Status: Ultimate Putnam parent company
8(a)(iv). Ownership Code:
   NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
X E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Great-West Life Co. Inc.
8(a)(ii).  Relationship Start Date: 08/03/2007
8(a)(iii).  Title or Status: Parent of Putnam Investments, LLC
8(a)(iv). Ownership Code:
   NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
X E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Robert L. Reynolds
8(a)(ii).  Relationship Start Date: 10/16/2008
8(a)(iii).  Title or Status: President
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Steven D. Krichmar
8(a)(ii).  Relationship Start Date: 10/16/2008
8(a)(iii).  Title or Status: Senior Managing Director
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Douglas L. Wooden
8(a)(ii).  Relationship Start Date: 10/16/2008
8(a)(iii).  Title or Status: Senior Managing Director
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date: 02/28/2009

8(a)(i).  Full Name: Clare Richer
8(a)(ii).  Relationship Start Date: 12/01/2008
8(a)(iii).  Title or Status: Chief Financial Officer
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:


9.  Does any person or entity not named in the answer to Question 8:
9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant; or . . . .
   Yes X No    NA
9(a)(i).  Exact name of each person or entity:

9(a)(ii).  Description of the Agreement or other basis:

9(b). wholly or partially finance the business of applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others ? . . . . . . . . . . . . . . . . . . . . . . . . . .
   Yes X No
9(b)(i).  Exact name of each person or entity:

9(b)(ii).  Description of the Agreement or other basis:


10.  Applicant and Control Affiliate Disciplinary History:
The following definitions apply for purposes of answering this Question 10
Control affiliate - An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority.
Investment or investment related - Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker-dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association).
Involved - Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act.
10(a).  In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contender (`no contest`) to:
10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting or extortion?
   Yes X No
10(a)(2). any other felony?
   Yes X No
10(b).  Has any court in the past ten years:
10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity?
   Yes X No
10(b)(2). found that the applicant or a control affiliate was involved in a violation of investment-related statutes or regulations?
X Yes    No
10(b)(2)(i).  The individuals named in the action or claim:
IPC Investment Corporation
10(b)(2)(ii).  Title of Action 10(b)(2)(iii).  Date of Action
Druiven, et al.
 07/02/1996
10(b)(2)(iv).  The Court or body taking the Action and location:
Ontario Court of Justice, Ontario Canada
10(b)(2)(v).  Description of the action or claim:
Plaintiffs commenced an action against Associated Financial Planners, LTD (AFP), a predecessor company of AFP Wealth Management, Inc., which amalgamated into IPC Investment Corporation (IPC) on June 1, 2001, and against Bruce Warrington and Moneysem Financial Consultants, Inc., with respect to losses alleged to have been sustained in making ill-obtained judgment against Warrington in July 1996, continuing to advance other claims against him and claims for accounting, damages for restitution, and quantum merit against AFP. The civil court found AFP negligent in its duties to adequately supervise Warrington's outside business activities.
10(b)(2)(vi).  Disposition of action or claim:
Judgment entered against AFP in the amount of $469,000.000, including interest.
10(c).  Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:
10(c)(1). found the applicant or a control affiliate to have made a false statement or omission?
X Yes    No
10(c)(1)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(1)(ii).  Title of Action 10(c)(1)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 11/13/2003
10(c)(1)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(1)(v).  Description of the action or claim:
On November 13,2003, the SEC entered an order making findings and imposing partial relief, including a final censure, remedial undertakings and a cease and desist order pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940 and Sections 9(b) and 9(f) of the Investment Company Act of 1940 and rule 17J-1(c) under the Investment Company Act of 1940 in connection with the personal trading of employees who allegedly engaged in excessive short-term trading (market timing) of Putnam Mutual Funds, and Putnam's failure to reasonably supervise such employees or to properly disclose such actions. Four of the individuals traded in mutual funds over which they had investment authority. In connection with this order, Putnam has agreed to undertake corporate governance, compliance, and ethics reforms.
10(c)(1)(vi).  Disposition of action or claim:
On April 8,2004, Putnam entered into a settlement agreement with SEC pursuant to which it agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders of the funds.
10(c)(1)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(1)(ii).  Title of Action 10(c)(1)(iii).  Date of Action
In The Matter of Putnam Investments Management, LLC
 03/23/2005
10(c)(1)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(1)(v).  Description of the action or claim:
On March 23, 2005 Putnam entered into a settlement agreement with the SEC with respect to the SEC's inquiry concerning Putnam's alleged failure to adequately disclose certain brokerage practices. These practices involved the allocation of brokerage to broker-dealer who sold shares of Putnam mutual funds. The settlement order states that Putnam failed to fully and effectively disclose to the Boards of Trustees and to shareholders of the Putnam funds the specifics of its preferred marketing arrangements with certain brokerage firms selling Putnam fund shares. Putnam ceased directing brokerage to broker=dealers in connection with the sale of the fund shares as of January 1, 2004.
10(c)(1)(vi).  Disposition of action or claim:
Under the settlement, Putnam paid a civil penalty in the amount of $40 million and disgorgement in the amount of $1. The total amount of the payment was paid to certain Putnam Funds.
10(c)(1)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(1)(ii).  Title of Action 10(c)(1)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 09/28/2007
10(c)(1)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(1)(v).  Description of the action or claim:
On September 28,2007, the SEC entered and order making findings and imposing remedial sanctions and a cease and desist order pursuant to Section 203(e) of the Investment Advisers Acts of 1940 and Sections 9(b) and (f) of the Investment Company Act of 1940. The SEC found that Putnam violated Section 19(a) of the Investment Company Act of 1940 and Rule 19A-1 there under in connection with certain notices for shareholder distributions for four closed end investment companies: The Putnam Master Intermediate Trust, Putnam Premier Income Trust, Putnam Master Income Trust, and Putnam Managed High Yield Trust. The settlement order states that during the period from August 1, 2000 through May 31, 2002 these funds made distributions to shareholders partly funded from shareholder capital and that although Putnam, as administrator to the funds, sent written notices with these distributions, the notices did not contain the information required by Rule 19A-1 under The Investment Company Act of 1940.
10(c)(1)(vi).  Disposition of action or claim:
Under the settlement, Putnam paid civil penalty in the amount of $350,000.
10(c)(2). found the applicant or a control affiliate to have been involved in a violation of its regulations or statutes?
X Yes    No
10(c)(2)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(2)(ii).  Title of Action 10(c)(2)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 11/13/2003
10(c)(2)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(2)(v).  Description of the action or claim:
On November 13, 2003, the SEC entered an order making findings and imposing partial relief, including a final censure, remedial undertakings and a cease and desist order pursuant to Sections 203(e) and 203(k) of The Investments Advisers Act of 1940 and Sections 9(b) and 9(f) of the Investment Company Act of 1940. The SEC found that Putnam violated Sections 203(e)(6), 206(1), 206(2) and 204A of the Investment Advisers Act of 1940 and Rule 17J-1(c) under the Investment Company Act of 1940 in connection with the personal trading of employees who allegedly engaged in excessive short-term trading (market timing) of Putnam Mutual Funds, and Putnam's failure to reasonably supervise such employees or to properly disclose such actions. Four of the individuals traded in mutual funds over which they had investment authority. In connection with this order, Putnam has agreed to undertake corporate governance, compliance, and ethics reforms.
10(c)(2)(vi).  Disposition of action or claim:
On April 8, 2004, Putnam entered into a settlement agreement with SEC pursuant to which it agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders of the funds.
10(c)(2)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(2)(ii).  Title of Action 10(c)(2)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 03/23/2005
10(c)(2)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(2)(v).  Description of the action or claim:
On March 23, 2005 Putnam entered into a settlement agreement with the SEC with respect to the SEC's inquiry concerning Putnam's alleged failure to adequately disclose certain brokerage practices. These practices involved the allocation of brokerage to broker-dealer who sold shares of Putnam mutual funds. The settlement order states that Putnam failed to fully and effectively disclose to the Boards of Trustees and to shareholders of the Putnam funds the specifics of its preferred marketing arrangements with certain brokerage firms selling Putnam fund shares. Putnam ceased directing brokerage to broker=dealers in connection with the sale of the fund shares as of January 1, 2004.
10(c)(2)(vi).  Disposition of action or claim:
Under the settlement, Putnam paid a civil penalty in the amount of $40 million and disgorgement in the amount of $1. The total amount of the payment was paid to certain Putnam Funds.
10(c)(2)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(2)(ii).  Title of Action 10(c)(2)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 09/07/2006
10(c)(2)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(2)(v).  Description of the action or claim:
On September 7, 2006, the SEC entered an order making findings and imposing relief including censure, remedial sanctions and a cease and desist order pursuant to Sections 203(e) and 203(k) of The Investment Advisers Act of 1940. The SEC found that Putnam violated Section 205(a) of The Investment Advisers Act in connection with the entering into or performing an advisory contract with the Putnam Research Fund (The Fund), a registered investment company, which provided for performance-based compensation to be computed based on the fund's daily net asset value over the quarter rather than based on the average net asset value for the 36 month performance period used for calculating the fee, as required by Rule 205 under The Advisers Act.
10(c)(2)(vi).  Disposition of action or claim:
Putnam discontinued the method used for calculating the performance fee and reimbursed the fund for excess fees and interest totaling $1,307,842.
10(c)(2)(i).  The individuals named in the action or claim:
Putnam Investment Management, LLC
10(c)(2)(ii).  Title of Action 10(c)(2)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 09/28/2007
10(c)(2)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(c)(2)(v).  Description of the action or claim:
On September 28,2007, the SEC entered and order making findings and imposing remedial sanctions and a cease and desist order pursuant to Section 203(e) of the Investment Advisers Acts of 1940 and Sections 9(b) and (f) of the Investment Company Act of 1940. The SEC found that Putnam violated Section 19(a) of the Investment Company Act of 1940 and Rule 19A-1 there under in connection with certain notices for shareholder distributions for four closed end investment companies: The Putnam Master Intermediate Trust, Putnam Premier Income Trust, Putnam Master Income Trust, and Putnam Managed High Yield Trust. The settlement order states that during the period from August 1, 2000 through May 31, 2002 these funds made distributions to shareholders partly funded from shareholder capital and that although Putnam, as administrator to the funds, sent written notices with these distributions, the notices did not contain the information required by Rule 19A-1 under The Investment Company Act of 1940.
10(c)(2)(vi).  Disposition of action or claim:
Under the settlement, Putnam paid civil penalty in the amount of $350,000.
10(c)(3). found the applicant or a control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?
   Yes X No
10(c)(4). entered an order denying, suspending or revoking the applicant`s or a control affiliate`s registration or otherwise disciplined it by restricting its activities?
   Yes X No
10(d).  Has any other Federal regulatory agency or any state regulatory agency:
10(d)(1). ever found the applicant or a control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical?
X Yes    No
10(d)(1)(i).  The individuals named in the action or claim:
Putnam Investment Management,LLC
10(d)(1)(ii).  Title of Action 10(d)(1)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 04/08/2004
10(d)(1)(iv).  The Court or body taking the Action and location:
Massachusetts Securities Division
10(d)(1)(v).  Description of the action or claim:
On April 8, 2004, the Commonwealth of Massachusetts entered into a consent order with Putnam pursuant to an offer of settlement, the consent order found that Putnam violated Sections 101 and 102 of the Massachusetts Uniform Securities Act in connection with the personal trading of employees and certain DC/401K plans who allegedly engaged in excessive short-term trading. In connection with the consent order, Putnam admitted certain facts solely for the purpose of resolving the administrative proceeding.
10(d)(1)(vi).  Disposition of action or claim:
Pursuant to the consent order, Putnam agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders and the funds.
10(d)(2). ever found the applicant or a control affiliate to have been involved in a violation of investment-related regulations or statutes?
X Yes    No
10(d)(2)(i).  The individuals named in the action or claim:
Putnam U.S. Holdings I, LLC
10(d)(2)(ii).  Title of Action 10(d)(2)(iii).  Date of Action
Class A Share Issue
 07/29/2008
10(d)(2)(iv).  The Court or body taking the Action and location:
United States Department of Labor
10(d)(2)(v).  Description of the action or claim:
On July 29, 2008, the Department of Labor entered into a settlement agreement with Putnam U.S. Holdings I, LLC concerning allegations that Putnam inappropriately offered, as investment options under the Putnam Investment Profit Sharing Retirement Plan, Class A shares in certain Putnam mutual funds which carried 12b-1 fees which were paid to Putnam Retail Management Limited Partnership, an affiliate of Putnam, in violation of sections 404(a)(1)(A), 406(a)(1)(D), 406(b)(1) and 406(b)(2) of ERISA.
10(d)(2)(vi).  Disposition of action or claim:
Under the settlement, Putnam paid $270,000 in restitution to the Putnam Investments Profit Sharing Retirement Plan and a civil penalty of $27,000.
10(d)(2)(i).  The individuals named in the action or claim:
GWFS Equities, Inc.
10(d)(2)(ii).  Title of Action 10(d)(2)(iii).  Date of Action
In re: GWFS Equities, Inc.
 03/05/2001
10(d)(2)(iv).  The Court or body taking the Action and location:
State of Florida Division of Securities and Investor Protection
10(d)(2)(v).  Description of the action or claim:
Matter related to GWFS's failure of renew the Florida branch office location within prescribed time while continuing to conduct business.
10(d)(2)(vi).  Disposition of action or claim:
Final Order- Stipulation and Consent Agreement to cease and desist and payment of administrative fine of $5,000.00; state agreed to approve branch office application upon receipt of fine.
10(d)(2)(i).  The individuals named in the action or claim:
GWFS Equities, Inc.
10(d)(2)(ii).  Title of Action 10(d)(2)(iii).  Date of Action
In re: GWFS Equities, Inc.
 06/22/1993
10(d)(2)(iv).  The Court or body taking the Action and location:
Michigan Securities Department
10(d)(2)(v).  Description of the action or claim:
GWFS, formerly known as Benefitscorp Equities, Inc., failed to respond to an inquiry from the Michigan Securities Department regarding the activities of an agent.
10(d)(2)(vi).  Disposition of action or claim:
Benefitscorp Equities filed a consent order and paid a fine of $2,000.
10(d)(3). ever found the applicant or a control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
   Yes X No
10(d)(4). in the past ten years entered an order against the applicant or a control affiliate in connection with investment-related activity?
X Yes    No
10(d)(4)(i).  The individuals named in the action or claim:
Putnam Investment Management,LLC
10(d)(4)(ii).  Title of Action 10(d)(4)(iii).  Date of Action
In The Matter Of Putnam Investment Management, LLC
 04/08/2004
10(d)(4)(iv).  The Court or body taking the Action and location:
Massachusetts Securities Division
10(d)(4)(v).  Description of the action or claim:
On April 8, 2004, the Commonwealth of Massachusetts entered into a consent order with Putnam pursuant to an offer of settlement, the consent order found that Putnam violated Sections 101 and 102 of the Massachusetts Uniform Securities Act in connection with the personal trading of employees and certain DC/401K plans who allegedly engaged in excessive short-term trading. In connection with the consent order, Putnam admitted certain facts solely for the purpose of resolving the administrative proceeding.
10(d)(4)(vi).  Disposition of action or claim:
Pursuant to the consent order, Putnam agreed to pay a total of $193.5 million in penalties and restitution, with $153.5 million being paid to shareholders and the funds.
10(d)(4)(i).  The individuals named in the action or claim:
Putnam Retail Management Limited Partnership
10(d)(4)(ii).  Title of Action 10(d)(4)(iii).  Date of Action
Putnam Retail Management Limited Partnership CRD No. 7325
 10/03/2006
10(d)(4)(iv).  The Court or body taking the Action and location:
National Association Of Securities Dealers
10(d)(4)(v).  Description of the action or claim:
Putnam Retail Management Limited Partnership entered into an Acceptance, Waiver and Consent (AWC) with the NASD regarding allegations that Putnam violated NASD Conduct Rules 2830(1)5,2820(g)4 and 2110 by paying for or reimbursing guest meals and ground transportation expenses during the period of 2001 to 2004 and providing and paying for entertainment at two training and educational meetings. In addition, the AWC resolved allegations that Putnam violated Rules 3010 and 2110 by failing to properly supervise its non-cash compensation spending and failing to enforce its policies and procedures to ensure compliance with the NASD's non-cash compensation rules.
10(d)(4)(vi).  Disposition of action or claim:
Under the AWC, Putnam received a censure and paid a fine of $175,000.
10(d)(4)(i).  The individuals named in the action or claim:
Putnam U.S. Holdings I, LLC
10(d)(4)(ii).  Title of Action 10(d)(4)(iii).  Date of Action
Class A Share Issue
 07/29/2008
10(d)(4)(iv).  The Court or body taking the Action and location:
United States Department of Labor
10(d)(4)(v).  Description of the action or claim:
On July 29, 2008, the Department of Labor entered into a settlement agreement with Putnam U.S. Holdings I, LLC concerning allegations that Putnam inappropriately offered, as investment options under the Putnam Investment Profit Sharing Retirement Plan, Class A shares in certain Putnam mutual funds which carried 12b-1 fees which were paid to Putnam Retail Management Limited Partnership, an affiliate of Putnam, in violation of sections 404(a)(1)(A), 406(a)(1)(D), 406(b)(1) and 406(b)(2) of ERISA.
10(d)(4)(vi).  Disposition of action or claim:
Under the settlement, Putnam paid $270,000 in restitution to the Putnam Investments Profit Sharing Retirement Plan and a civil penalty of $27,000.
10(d)(5). ever denied, suspended, or revoked the applicant`s or a control affiliate`s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities?
   Yes X No
10(d)(6). ever revoked or suspended the applicant`s or a control affiliate`s license as an attorney or accountant?
   Yes X No
10(e).  Has any self-regulatory organization or commodities exchange ever:
10(e)(1). found the applicant or a control affiliate to have made a false statement or omission?
   Yes X No
10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules?
X Yes    No
10(e)(2)(i).  The individuals named in the action or claim:
Putnam Retail Management Limited Partnership
10(e)(2)(ii).  Title of Action 10(e)(2)(iii).  Date of Action
Putnam Retail Management Limited Partnership CRD No. 7325
 10/03/2006
10(e)(2)(iv).  The Court or body taking the Action and location:
National Association Of Securities Dealers
10(e)(2)(v).  Description of the action or claim:
Putnam Retail Management Limited Partnership entered into an Acceptance, Waiver and Consent (AWC) with the NASD regarding allegations that Putnam violated NASD Conduct Rules 2830(1)5,2820(g)4 and 2110 by paying for or reimbursing guest meals and ground transportation expenses during the period of 2001 to 2004 and providing and paying for entertainment at two training and educational meetings. In addition, the AWC resolved allegations that Putnam violated Rules 3010 and 2110 by failing to properly supervise its non-cash compensation spending and failing to enforce its policies and procedures to ensure compliance with the NASD's non-cash compensation rules.
10(e)(2)(vi).  Disposition of action or claim:
Under the AWC, Putnam received a censure and paid a fine of $175,000.
10(e)(2)(i).  The individuals named in the action or claim:
GWFS Equities, Inc.
10(e)(2)(ii).  Title of Action 10(e)(2)(iii).  Date of Action
In re: GWFS Equities, Inc.
 05/29/1985
10(e)(2)(iv).  The Court or body taking the Action and location:
National Association of Securities Dealers
10(e)(2)(v).  Description of the action or claim:
A routine exam of American Capital Planning, Inc., discovered that the firm was in violation of SEC Rule 15c3-1 (net capital rule). The violation was incurred due to the improper treatment of concessions receivable and related concessions payable.
10(e)(2)(vi).  Disposition of action or claim:
Monetary fine of $1,000.00
10(e)(2)(i).  The individuals named in the action or claim:
Putnam Retail Management, Limited Partnership
10(e)(2)(ii).  Title of Action 10(e)(2)(iii).  Date of Action
In re: Putnam Retail Management Limited Partnership
 05/05/1972
10(e)(2)(iv).  The Court or body taking the Action and location:
NASD-District Business Conduct Committee of District 13
10(e)(2)(v).  Description of the action or claim:
The Committee found reason to believe that Putnam Retail management had violated Section 1 of Article III of the Rules of Fair Practice during the period 12/1968 - 2/1971 through its failure to comply with one or more provisions of Regulation T of the Board of Governors of the Federal Reserve System
10(e)(2)(vi).  Disposition of action or claim:
The matter was settled upon the imposition of a censure and fine of $500.00
10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business?
   Yes X No
10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities?
   Yes X No
10(f). Has any foreign government, court, regulatory agency, or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud?
X Yes    No
10(f)(1)(i).  The individuals named in the action or claim:
Investors Group Financial Services, Inc.
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: Investors Group Financial Services, Inc.
 10/18/2006
10(f)(1)(iv).  The Court or body taking the Action and location:
Nova Scotia Securities Commission
10(f)(1)(v).  Description of the action or claim:
Action related to failure of Investors Group Financial Services, Inc., and its then affiliate. LES Services Investors LTD, which amalgamated with Investors Group Financial Services, Inc., on January 1, 2006, to file termination notices within prescribed time periods and failing to reinstate a salesperson's registration before conducting registerable activity. Also related failure by LES Services Investors LTD to be registered in Nova Scotia when trading with clients.
10(f)(1)(vi).  Disposition of action or claim:
Settlement with payment of $25,000 fine and costs of $2,500 approved by staff of Nova Scotia Securities Commission.
10(f)(1)(i).  The individuals named in the action or claim:
IPC Securities Corporation
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: IPC Securities Corporation
 01/01/2006
10(f)(1)(iv).  The Court or body taking the Action and location:
Nova Scotia Securities Commission
10(f)(1)(v).  Description of the action or claim:
Nova Scotia Securities Commission (NSSC) found that IPC Securities Corporation was in violation of Sections 22,134,135, and 135A of the Securities Act (Nova Scotia) in connection with allowing approved person to operation out of the Wolfville office prior to receiving an exemption request from the NSSC.
10(f)(1)(vi).  Disposition of action or claim:
Pursuant to a settlement agreement with NSSC, IPC Securities Corporation paid an administrative penalty of $10,000 and costs of $2,500.
10(f)(1)(i).  The individuals named in the action or claim:
Investors Group Financial Services, Inc.
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: Investors Group Financial Services, Inc.
 01/09/2006
10(f)(1)(iv).  The Court or body taking the Action and location:
New Brunswick Securities Commission
10(f)(1)(v).  Description of the action or claim:
New Brunswick Securities Commission (NBSC) alleged that Investors Group Financial Services, Inc., had violated Section 45 of the Securities Act (New Brunswick) - Trading in Securities without Registration. The unregistered activity was conducted by salespersons of LES Services Investors LTD, an affiliate that amalgamated with IGFS on January 1, 2006.
10(f)(1)(vi).  Disposition of action or claim:
NBSC issued an order on January 19, 2006 approving a settlement agreement where IGFS paid a penalty and costs of $68,200.
10(f)(1)(i).  The individuals named in the action or claim:
I.G. Investment Management, LTD (IGM)
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: I.G. Investment Management, LTD (IGM)
 12/22/2004
10(f)(1)(iv).  The Court or body taking the Action and location:
Manatoba Securities Commission and Ontario Securities Commission
10(f)(1)(v).  Description of the action or claim:
Matter related to market timing trading conducted by one institutional investor (whose relationship was terminated by IGM in 2001) in certain investors group funds under management by IGM. The manager implemented measures to reduce harm to other investors in the funds from market timing activity, but these measures did not recognize all the costs of the client's trading activity.
10(f)(1)(vi).  Disposition of action or claim:
Under terms of a settlement agreement with the Manatoba Securities Commission and the Ontario Securities Commission, IGM paid restitution of $19.2 million to investors of the funds in which the market timing had occurred.
10(f)(1)(i).  The individuals named in the action or claim:
IPC Securities Corporation (IPC)
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: IPC Securities Corporation (IPC)
 03/18/2004
10(f)(1)(iv).  The Court or body taking the Action and location:
Investment Dealers Assocation of Canada (IDA)
10(f)(1)(v).  Description of the action or claim:
Pursuant to settlement agreement, IPC admitted that they (a) failed to maintain adequate records of supervisor activity in accordance with IDA requirements concerning head office account supervision and thereby contravened IDA by-law 29.27 principal trading done on its behalf, contrary to IDA by law 29.27(A)(1) and (VI) and (c) failed to maintain its risk adjusted capital at a level greater than zero calculated in accordance with IDA Form 1, contrary to IDA by-law 17.1.
10(f)(1)(vi).  Disposition of action or claim:
IDA paid a monetary fine of $100,000.00
10(f)(1)(i).  The individuals named in the action or claim:
M.R.S. Trust Company (MRST)
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: M.R.S. Trust Company
 02/24/2004
10(f)(1)(iv).  The Court or body taking the Action and location:
Manatoba Securities Commission
10(f)(1)(v).  Description of the action or claim:
Pursuant to a settlement agreement with the Manatoba Securities Commission, MRST confirmed that other than acting as trustee of the Locked-in funds, the company did not participate in and was not aware of a pension and RSP scheme that facilitated the improper withdrawal of locked-in funds from various Manatoba-resident plan holders' pension and registered plans.
10(f)(1)(vi).  Disposition of action or claim:
Upon approval of the settlement agreement, MRST made a voluntary payment of $35,000 to the Treasury of the Province of Manatoba.
10(f)(1)(i).  The individuals named in the action or claim:
IPC Investment Corporation (IPC)
10(f)(1)(ii).  Title of Action 10(f)(1)(iii).  Date of Action
In re: IPC Investment Corporation
 12/06/2001
10(f)(1)(iv).  The Court or body taking the Action and location:
New Brunswick Securities Commission (NBSC)
10(f)(1)(v).  Description of the action or claim:
Matter related to unregistered trading activity conducted by a salesperson of an affiliate, Henry Hicks and Associates, LTD, which amalgamated with IPC effective May 16, 2001.
10(f)(1)(vi).  Disposition of action or claim:
IPC paid a monetary penalty of $14,400, including administrative costs.
10(g). Is the applicant or a control affiliate now the subject of any proceeding that could result in a yes answer to questions 10(a) - 10(f)?
X Yes    No
10(g)(1)(i).  The individuals named in the action or claim:
Putnam Fiduciary Trust Company
10(g)(1)(ii).  Title of Action 10(g)(1)(iii).  Date of Action
Department of Labor Global Crossing Investigation
 02/09/2004
10(g)(1)(iv).  The Court or body taking the Action and location:
United States Department of Labor
10(g)(1)(v).  Description of the action or claim:
The Department of Labor is investigating whether Putnam Fiduciary Trust Company (PFTC) violated its fiduciary duty under the Employee Retirement Income Security Act (ERISA) as the directed trustee of a former client's retirement accounts prior to 2002. The DOL is investigating whether PFTC, as directed trustee, violated any ERISA duties it owed to the former client's retirement accounts by not questioning directions to continue maintaining the former client's stock fund within the retirement plan and allowing plan participants to continue investing in the former client's stock during 2001. The DOL believes that PFTC, as the directed trustee, had an obligation to take action on behalf of the participants in the retirement plan in the event that continued investment of plan assets in company stock became imprudent.
10(g)(1)(vi).  Disposition of action or claim:
N/A
10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate?
X Yes    No
10(h)(1)(i).  The individuals named in the action or claim:
Putnam Fiduciary Trust Company
10(h)(1)(ii).  Title of Action 10(h)(1)(iii).  Date of Action
In re: Tyco/Marine Harvest, et al.
 05/21/2002
10(h)(1)(iv).  The Court or body taking the Action and location:
N/A
10(h)(1)(v).  Description of the action or claim:
In early 2002, Putnam Fiduciary Trust Company (PFTC), the transfer agent for the Putnam funds, received applications to establish accounts in the names of several corporate entities, such as Tyco. Inc., and Marine Harvest, Inc., along with checks issued payable to the corporate entities. The checks were used to fund investments in the new accounts. The accounts were substantially depleted through the use of check writing drafts. Subsequently, PFTC became aware that the investment checks had been intercepted, the endorsements of the corporate payees had been forged, and the accounts had been established without the knowledge or authorization of the corporate payees. The corporate payees pursued forgery claims through the banks off of which the checks were drawn.
10(h)(1)(vi).  Disposition of action or claim:
PFTC filed a claim under its Fidelity Bond and recovered $697,120.28.
10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it?
   Yes X No

ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a)
SIGNATURE: The Registrant submitting this Form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.
11(a).  Signature of Official responsible for Form:
Mark Trenchard
 11(b).  Telephone Number:
617-760-3601
11(c).  Title of Signing Officer:
Managing Director
 11(d).  Date Signed (Month/Day/Year)
01/06/2010