Description of Settlement

On October 28, 2003, the Commonwealth and the SEC commenced separate administrative proceedings against Putnam. The Commonwealth and the SEC issued orders settling these proceedings, respectively, on April 8, 2004 and April 15, 2004 (“Commonwealth Orders”), and on November 13, 2003 and April 8, 2004 (“SEC Orders”). As part of the settlements, Putnam was required to pay such amounts as were necessary to compensate shareholders for losses attributable to market timing and excessive short-term trading in certain affected Putnam mutual funds (“Putnam Funds”). Putnam was required to retain an Independent Assessment Consultant (“IAC”) to calculate such losses. The IAC also calculated losses attributable to excess redemptions in the Putnam Funds.  Putnam also was required to retain an Independent Distribution Consultant (“IDC”) to develop a methodology to distribute the amounts paid by Putnam pursuant to the settlements. Dr. Peter Tufano serves as both the IAC and IDC.

The Commonwealth and the SEC have agreed to distribute the amounts paid by Putnam pursuant to the Commonwealth Orders and the SEC Orders in a common manner and at the same time. The Commonwealth and the SEC approved distribution plans in July 2007.  Prior to any distribution, the Putnam Fair Fund held a total of $153,524,387, plus accumulated interest. This amount will be distributed by the IDC pursuant to the April 8, 2004 SEC Order and the Commonwealth Order in batches over several months starting in August, 2008.

Shareholders who experienced losses, as calculated by the IAC, are eligible to receive a payment. This includes both current and former shareholders in all funds that incurred losses in the relevant period.

The amounts due to each shareholder of record will be aggregated into one payment. This single payment will represent the sum of amounts calculated for each account within each fund, which are then aggregated across funds. As a practical matter, however, this aggregation across funds can occur only within each shareholder category, as defined in the Distribution Plan (i.e. Direct Accounts, Omnibus Accounts, and Retirement Plans). In circumstances where a shareholder holds accounts in multiple shareholder categories, these payments will be made separately. For example, 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.

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.

For additional information, please refer to the "Related Documents" section of this Web site.

If you have any questions, please refer to the "Frequently Asked Questions" (FAQ) sections of this Web site or call the Fair Fund Administrator at (800) 848-9697, Monday through Friday, 8:30 a.m. - 7:00 p.m. Eastern Time.