852 Putnam New Opportunities Fund attachment
12/31/04 Semi-annual

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.

The fund may experience increased redemptions as a result of
these matters, which could result in increased transaction costs
and operating expenses.

In connection with its investigation of certain brokerage
matters, the staff of the Philadelphia district office of the
SEC has raised the question whether, in years prior to 2004,
Putnam Management fully and effectively disclosed its practices
relating to the allocation of brokerage on mutual fund portfolio
transactions to brokerdealers who sold shares of the funds.
Putnam Management ceased directing brokerage to broker-dealers
in connection with the sale of fund shares as of January 1,
2004. Putnam Management and the Philadelphia office negotiated
an offer of settlement under which Putnam Management would pay a
civil penalty in the amount of $40 million and disgorgement in
the amount of $1, and the total amount would be distributed to
certain Putnam funds. The offer of settlement is subject to
final documentation and approval by the Commissioners and the
staff of the SEC. Discussions with the staff with respect
to the offer of settlement are ongoing.