Management Statement Regarding Compliance with Certain Provisions
of the Investment Company Act of 1940

We, as members of management of Putnam Fiduciary Trust Company on
behalf of The Putnam Funds (the Funds), are responsible for
complying with the requirements of subsections (b) and (c) of
Rule 17f-2, Custody of Investments by Registered Management
Investment Companies, of the Investment Company Act of 1940.  We
are also responsible for establishing and maintaining effective
internal control over compliance with those requirements.  We
have performed an evaluation of the Funds compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of March
26, 2004, and from September 26, 2003 through March 26, 2004.

Based on this evaluation, we assert that the Funds were in
compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 of the Investment Company Act of 1940 as of March 26,
2004, and from September 26, 2003 through March 26, 2004, with
respect to securities reflected in the investment accounts of the
Funds.


Putnam Fiduciary Trust Company


By:



Paul Bucuvalas
Managing Director Custody
Services



March 30, 2005