Putnam Investment Management LLC

Distribution Status: The SEC has completed the principal distribution of this Fair Fund, which was established to return more than $150 million to investors harmed by undisclosed market timing and excessive short-term trading in certain mutual funds managed by Putnam Investment Management, LLC. The SEC has ordered nine disbursements to investors, totaling more than $144 million. The distribution of the Fair Fund residual in accordance with the terms of the Distribution Plan is expected to occur later this year.

Investors can obtain additional information about the distribution process by visiting the Putnam Fair Fund website or by calling 1-800-848-9697. If you have questions, please contact the SEC's Boston Regional Office at boston@sec.gov.

Background:  On April 8, 2004, the SEC entered an Order against Putnam Investment Management, LLC in connection with market timing and excessive short term trading by Putnam employees, including Putnam investment professionals, in Putnam mutual funds. The Order required, among other things, that Putnam pay $55 million in disgorgement and civil penalties, plus an additional amount, which has been calculated to be $42.9 million. Putnam assented to the Order. Under the terms of the Order, an Independent Distribution Consultant was retained to submit a distribution plan to the SEC for the distribution to investors of a Fair Fund containing approximately $98 million. For more information on the SEC's action, you can read the SEC’s Order in In the Matter of Putnam Investment Management, LLC, IA-2226 (Apr. 8, 2004), and a prior Order in which Putnam assented to other relief, IA-2192 (Nov. 13, 2003).

On March 30, 2007, the SEC published a Notice of Proposed Distribution Plan and Opportunity for Comment in connection with this matter. The Notice advised that all interested parties could obtain a written copy of the proposed Distribution Plan and that all persons who desired to comment on the Distribution Plan could submit their comments, in writing, no later than April 30, 2007. The SEC received and considered public comments on the plan.

On July 20, 2007, the SEC issued an order approving a modified Distribution Plan. On August 18, 2008, the SEC announced that it had ordered the first in a series of disbursements of the Fair Fund to be made to affected investors, and the SEC ordered additional disbursements on December 2, 2008, February 25, 2009, May 28, 2009, July 31, 2009, December 2, 2009, February 2, 2010, November 1, 2010 and March 4, 2011.

http://www.sec.gov/divisions/enforce/claims/putnam.htm