UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Certificate of Accounting of Securities and Similiar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
1. Investment Company Act File Number:
811- See list below
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PR
3. Exact name of investment company as specified in
registration statement:
See list below
4. Address of principal executive office (number, street,
city, zip code):
One Post Office Square, Boston, MA 02109
INSTRUCTIONS
This Form must be completed by investment companies that
have custody of securities or similiar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who,
in compliance with Rule 17f-2 under the Act and applicable
state law, examines securities and similar investments in
the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange
Commission and appropriate state securities administrators
when filing the certificate of accounting required by Rule
17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange
Commissions principal office in Washington, D.C., one copy
with the regional office for the region in which the
investment company's principal business operations are
conducted, and one copy with the appropriate state
administrator(s), if applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC
ACCOUNTANT
FUND NAME FUND FEDERAL SEC 1940 1934 1933
# ID NO. ACT ACT ACT
FILE FILE FILE
NO. NO. NO.
GEORGE PUTNAM FUND OF 001 04- 11/26/3 811-58 2-
BOSTON 6013677 7 10816
THE PUTNAM FUND FOR 002 04- 11/5/57 811- 2-
GROWTH AND INCOME 6013678 781 13644
PUTNAM INVESTORS FUND 003 04- 4/20/34 811- 2-
2713095 159 10783
PUTNAM INCOME FUND 004 04- 10/13/5 811- 2-
6013712 4 653 11147
PUTNAM GLOBAL GROWTH FUND 005 04- 8/31/67 811- 2-
6145734 1403 25258
PUTNAM VISTA FUND 006 04- 5/20/68 811- 2-
2430137 1561 27664
PUTNAM VOYAGER FUND 007 04- 3/13/69 811- 2-
6187125 1682 29546
PUTNAM CONVERTIBLE INCOME 008 04- 6/20/72 811- 2-
GROWTH TRUST 2493360 2280 43384
PUTNAM MONEY MARKET FUND 010 04- 10/18/7 811- 2-
6386436 6 2608 55091
PUTNAM TAX EXEMPT INCOME 011 04- 11/16/7 811- 2-
FUND 6396109 6 2675 57165
PUTNAM EQUITY INCOME FUND 012 04- 6/1/77 811- 2-
6407893 2742 58869
PUTNAM HIGH YIELD TRUST 014 04- 1/23/78 811- 2-
6415410 2796 60492
PUTNAM VT GLOBAL GROWTH 016 04- 5/1/90 811- 33-
FUND 6649095 5346 17486
PUTNAM GLOBAL NATURAL 018 13- 7/1/80 811- 2-
RESOURCES FUND 3035507 3061 67827
PUTNAM NEW JERSEY TAX 019 04- 2/14/90 811- 33-
EXEMPT INCOME FUND 3073948 5977 32550
PUTNAM HEALTH SCIENCES 021 04- 8/8/82 811- 2-
TRUST 6471950 3386 75863
PUTNAM OTC EMERGING 024 04- 11/1/82 811- 2-
GROWTH FUND 6483374 3512 78369
PUTNAM CALIFORNIA TAX 027 04- 6/1/94 811- 2-
EXEMPT INCOME FUND 2786284 3630 81011
PUTNAM PREFERRED INCOME 029 04- 12/30/8 811- 2-
FUND 2811116 3 3873 87053
PUTNAM NEW YORK TAX 030 04- 6/1/94 811- 2-
EXEMPT INCOME FUND 2794490 3741 83909
PUTNAM U.S. GOVERNMENT 032 04- 2/6/84 811- 2-
INCOME TRUST 2811119 3897 87634
PUTNAM AMERICAN 033 04- 2/27/85 811- 2-
GOVERNMENT INCOME FUND 2856297 4178 95127
PUTNAM BALANCED 034 04- 4/4/85 811- 2-
RETIREMENT FUND 6530116 4242 96309
PUTNAM TAX FREE INSURED 035 04- 8/27/85 811- 2-
FUND 2879681 4345 98790
PUTNAM TAX FREE HIGH 036 04- 8/27/85 811- 2-
YIELD FUND 2883599 4345 98790
PUTNAM FLORIDA TAX EXEMPT 037 04- 8/21/90 811- 33-
INCOME FUND 3091965 6129 35677
PUTNAM FEDERAL INCOME 039 04- 5/22/86 811- 33-
TRUST 6540848 4617 3903
PUTNAM GLOBAL 041 04- 2/27/87 811- 33-
GOVERNMENTAL INCOME TRUST 6549525 4524 7232
PUTNAM PENNSYLVANIA TAX 047 04- 7/18/89 811- 33-
EXEMPT INCOME FUND 3057637 5802 28321
PUTNAM ADJUSTABLE RATE 048 04- 11/19/8 811- 33-
U.S. GOVERNMENT FUND 6561111 7 4531 11406
PUTNAM MUNICIPAL INCOME 051 04- 5/11/89 811- 33-
FUND 3039506 5763 26921
PUTNAM MANAGED MUNICIPAL 052 04- 2/16/89 811- 1- 33-
INCOME TRUST 6608976 5740 1015 26292
8
PUTNAM HIGH YIELD 054 04- 5/18/89 811- 1- 33-
MUNICIPAL TRUST 6621377 5795 1022 27889
9
PUTNAM DIVIDEND INCOME 056 04- 9/21/89 811- 1- 33-
FUND 6626126 5852 1029 30234
2
PUTNAM EUROPE GROWTH FUND 057 04- 8/29/90 811- 33-
3083315 5693 25658
PUTNAM INVESTMENT GRADE 058 04- 10/19/8 811- 1- 33-
MUNICIPAL TRUST 6629611 9 5901 1032 30934
7
PUTNAM HIGH YIELD 060 06- 3/20/86 811- 33-
ADVANTAGE FUND 6290063 4616 2710
PUTNAM HIGH INCOME 061 04- 7/9/87 811- 1- 33-
CONVERTIBLE AND BOND FUND 6562068 5133 9537 13858
PUTNAM TAX EXEMPT MONEY 062 04- 10/19/8 811- 33-
MARKET FUND 6561110 7 5215 15238
PUTNAM NEW YORK TAX 063 04- 10/19/8 811- 33-
EXEMPT MONEY MARKET FUND 2980863 7 5335 17344
PUTNAM CALIFORNIA TAX 064 04- 10/19/8 811- 33-
EXEMPT MONEY MARKET FUND 2980836 7 5333 17211
PUTNAM VT VOYAGER FUND 065 04- 1/14/88 811- 33-
2986134 5346 17486
PUTNAM VT GROWTH & INCOME 066 04- 1/14/88 811- 33-
FUND 2986132 5346 17486
PUTNAM VT HIGH YIELD FUND 067 04- 1/14/88 811- 33-
2986135 5346 17486
PUTNAM VT INCOME FUND 068 04- 811- 33-
2986133 5346 17486
PUTNAM VT MONEY MARKET 069 04- 1/14/88 811- 33-
FUND 2986131 5346 17486
PVT GLOBAL ASSET 070 04- 1/14/88 811- 33-
ALLOCATION FUND 6577628 5346 17486
PUTNAM MASTER INCOME 072 04- 12/17/8 811- 1- 33-
TRUST 2993219 7 5375 9774 18169
PUTNAM PREMIER INCOME 073 04- 2/18/88 811- 1- 33-
TRUST 2995046 5452 9816 19648
PUTNAM MASTER 074 04- 4/21/88 811- 1- 33-
INTERMEDIATE INCOME TRUST 6584465 5498 9870 20610
PUTNAM DIVERSIFIED INCOME 075 04- 9/23/88 811- 33-
TRUST 3017475 5635 23623
PUTNAM INTERMEDIATE 076 04- 6/16/88 811- 1- 33-
GOVERNMENT INCOME TRUST 3008388 5556 9931 21847
PUTNAM VT NEW 098 04- 5/1/94 811- 33-
OPPORTUNITIES FUND 3338263 5346 17486
PUTNAM VT UTILITIES 152 04- 5/1/92 811- 33-
GROWTH AND INCOME 3139324 5346 17486
PUTNAM TAX-FREE HEALTH 168 04- 6/19/92 811- 1- 33-
CARE FUND 3153831 6659 1113 47739
2
PUTNAM INVESTMENT GRADE 183 04- 11/19/9 811- 1- 33-
MUNICIPAL TRUST II 6716830 2 7270 1146 53076
8
PUTNAM CALIFORNIA 184 04- 11/19/9 811- 1- 33-
INVESTMENT GRADE 6716831 2 7276 1147 53106
MUNICIPAL TRUST 2
PUTNAM NEW YORK 185 04- 11/19/9 811- 1- 33-
INVESTMENT GRADE 6716832 2 7274 1147 63104
MUNICIPAL TRUST 0
GLOBAL GROWTH AND INCOME 197 04- 811- 33-
FUND 3251560 7237 56339
PUTNAM INVESTMENT GRADE 215 04- 11/18/9 811- 1- 33-
MUNICIPAL TRUST III 6743450 3 07099 1125 50455
3
PUTNAM CONVERTIBLE 224 04- 6/26/95 811- 1- 33-
OPPORTUNITIES AND INCOME 6777185 07253 1143 57901
TRUST 3
PUTNAM ASSET ALLOCATION 250 04- 1/10/94 811- 33-
FUNDS: GROWTH PORTFOLIO 6746612 7121 51017
PUTNAM ASSET ALLOCATION 259 04- 1/10/94 811- 33-
FUNDS: BALANCED 6746615 7121 51017
PORTFOLIO
PUTNAM ASSET ALLOCATION 264 04- 1/10/94 811- 33-
FUNDS: CONSERVATIVE 6746611 7121 51017
PORTFOLIO
NEW VALUE FUND 274 04- 12/28/9 811- 33-
3251564 5 7237 56339
PUTNAM INVESTMENT FUNDS: 318 04- 12/23/9 811- 33-
BALANCED FUND 3251562 4 7237 56339
PUTNAM VOYAGER FUND II 377 04- 4/13/93 811- 33-
6661046 6203 37527
PUTNAM INTERMEDIATE U.S. 398 04- 2/1/93 811- 33-
GOVERNMENT INCOME FUND 6661044 6257 37991
PUTNAM CAPITAL 433 04- 8/2/93 811- 33-
APPRECIATION FUND 6733578 7061 49583
PUTNAM DIVERSIFIED EQUITY 522 04- 6/15/94 811- 33-
TRUST 6755894 7615 53135
INTERNATIONAL NEW 539 04- 811- 33-
OPPORTUNITIES FUND 3251556 7237 56339
PUTNAM MUNICIPAL 582 04- 5/21/93 811- 1- 33-
OPPORTUNITIES TRUST 3187549 7626 1189 60790
2
PUTNAM MANAGED HIGH YIELD 590 04- 6/18/93 811- 1- 33-
TRUST 6733967 7658 1191 61388
0
PUTNAM VT ASIA PACIFIC 713 04- 5/1/95 811- 33-
GROWTH FUND 6779870 5346 17486
PUTNAM UTILITIES GROWTH 840 04- 11/16/9 811- 33-
AND INCOME FUND 6660195 0 5889 37011
PUTNAM INTERNATIONAL 841 04- 2/25/91 811- 33-
GROWTH FUND 6661045 6190 37214
PUTNAM ASIA PACIFIC 844 04- 2/20/91 811- 33-
GROWTH FUND 6661084 6202 37528
PUTNAM MASSACHUSETTS TAX 845 04- 10/3/86 811- 33-
EXEMPT INCOME FUND 6626127 4518 5416
PUTNAM MICHIGAN TAX 846 04- 10/3/86 811- 33-
EXEMPT INCOME FUND 6626130 4529 8923
PUTNAM MINNESOTA TAX 847 04- 10/3/86 811- 33-
EXEMPT INCOME FUND 6626128 4527 8916
PUTNAM OHIO TAX EXEMPT 848 04- 10/3/86 811- 33-
INCOME FUND 6626129 4528 8924
PUTNAM NEW OPPORTUNITIES 852 04- 8/29/90 811- 33-
FUND 3091455 6128 35576
PUTNAM NEW YORK TAX 854 04- 10/30/9 811- 33-
EXEMPT OPPORTUNITIES FUND 3101849 0 6176 37001
PUTNAM ARIZONA TAX EXEMPT 855 04- 1/25/91 811- 33-
INCOME FUND 6665534 6258 37992
PUTNAM STRATEGIC INCOME 896 04- 2/19/96 811- 33-
FUND 3251553 07221 55791
PUTNAM GROWTH & INCOME 949 04- 12/30/9 811- 33-
FUND II 3246687 4 07223 55979
PUTNAM VT DIVERSIFIED 961 04- 9/1/93 811- 33-
INCOME FUND 6737822 5346 17486
PUTNAM INVESTMENT FUNDS: 2AP 04- 811- 33-
GROWTH OPPORTUNITIES 3287244 7237 56339
RESEARCH FUND 2AQ 04- 10/2/95 811- 33-
3287245 7237 56339
JAPAN FUND 2AW 04- 12/28/9 811- 33-
3296119 5 7237 56339
INTERNATIONAL FUND 2AX 04- 12/28/9 811- 33-
3296118 5 7237 56339
EMERGING MARKETS FUND 2AY 04- 12/28/9 811- 33-
3296116 5 7237 56339
INTERNATIONAL VOYAGER 2AZ 04- 12/28/9 811- 33-
FUND 3296117 5 7237 56339
PUTNAM INTERNATIONAL 2CE 04- 8/1/96 811- 33-3315
GROWTH AND INCOME 3299786 07513
PUTNAM EQUITY FUND 97 2DC 04- 1/1/97 811- 33-
6817886 07513 3315
PUTNAM HIGH YIELD TOTAL 2DG 04- 1/1/97 811- 33-
RETURN BOND FUND 3336389 07513 3315
PUTNAM VT INTERNATIONAL 2DN 04- 1/1/97 811- 33-
GROWTH & INCOME FUND 3338261 5346 17486
PUTNAM VT INTERNATIONAL 2DO 04- 1/1/97 811- 33-
GROWTH FUND 3338260 5346 17486
PUTNAM VT INTERNATIONAL 2DP 04- 1/1/97 811- 33-
NEW OPPORTUNITIES FUND 3338264 5346 17486
PUTNAM VT VISTA FUND 2DQ 04- 1/1/97 811- 33-
3338265 5346 17486
PUTNAM VT NEW VALUE FUND 2DR 04- 1/1/97 811- 33-
3338264 5346 17486
PUTNAM HIGH YIELD TRUST 2HB 04- 1/6/98 811- 333-515
II 6852657 7513
PUTNAM EQUITY FUND 98 2HF 04- 1/6/98 811- 333-515
3399647 7513
PUTNAM INVESTMENT FUND 98 2HW 04- 1/22/96 811- 333-515
6857012 7513
PUTNAM LATIN AMERICA FUND 2IA 04- 3/23/98 811- 333-515
3406201 7513
PUTNAM ASIA PACIFIC FUND 2IB 04- 3/23/98 811- 333-515
II 3406199 7513
PUTNAM GROWTH FUND 2IE 04- 5/1/98 811- 333-515
3413786 7513
PUTNAM US CORE FUND 2IF 04- 5/1/98 811- 333-515
3413792 7513
PUTNAM VALUE FUND 2IG 04- 5/1/98 811- 333-515
3413789 7513
PUTNAM GLOBAL EQUITY FUND 2IH 04- 5/598 811- 33-
6862432 7237 56339
PUTNAM GROWTH 2II 04- 5/1/98 811- 33-
OPPORTUNITIES FUND 3414992 7237 56339
PUTNAM VT INVESTORS FUND 2IO 04- 4/29/98 811- 33-
6862434 5346 17486
PUTNAM VT OTC & EMERGING 2IP 04- 4/29/98 811- 33-
GROWTH AND INCOME FUND 6862434 5346 17486
PUTNAM VT THE GEORGE 2IS 04- 4/29/98 811- 33-
PUTNAM FUND OF BOSTON 3412097 5346 17486
PUTNAM VT HEALTH SCIENCES 2IW 04- 4/29/98 811- 33-
FUND 3412095 5346 17486
PUTNAM VT RESEARCH FUND 2LA 04- 9/30/98 811- 33-
3428472 5346 17486
PUTNAM SMALL CAP VALUE 2MF 04- 4/99 811- 33-
FUND 3453122 7237 56339
PUTNAM US CORE TAX 2MI 04- 4/99 822- 333-
MANAGED FUND 6888512 09289 76335
PUTNAM VT SMALL CAP VALUE 2MJ 04- 4/99 811- 33-
FUND 6888382 5346 17486
PUTNAM MID CAP VALUE 2OV 04- 811- 33-
FUND 6897774 7237 56339
PUTNAM VT GROWTH 2PU 04- 01/00 811- 33-
OPPORTUNITIES 3492539 5346 17486
PUTNAM VT AMERICAN 2PX 04- 01/00 811- 33-
GOVERNMENT 3492542 5346 17486
2
Report of Independent Accountants
To the Board of Trustees of
The Putnam Funds and the Board
of Directors of Putnam Fiduciary Trust Company
We have examined management's assertion, included in the
accompanying Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940, about
The Putnam Funds' (the "Funds'") compliance with the requirements
of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of March 26, 1999. Management
is responsible for the Funds' compliance with those requirements.
Our responsibility is to express an opinion on management's
assertion about the Funds' compliance based on our examination.
Our examination was conducted in accordance with attestation
standards established by the American Institute of Certified
Public Accountants and, accordingly, included examining, on a
test basis, evidence about the Funds' compliance with those
requirements and performing such other procedures as we
considered necessary in the circumstances. Included among our
procedures were the following tests performed as of March 26,
1999 and with respect to agreement of security purchases and
sales, for the period from October 30, 1998 (the date of our last
examination), through March 26, 1999:
- - Obtained confirmation of all securities record-kept at banks
with whom the custodian and the Funds have contracted to provide
sub-custodian services including The Boston Company, Bankers
Trust Company, Brown Brother Harriman & Co., United Missouri
Bank, and Chase Manhattan Bank;
- - Reconciled all such securities to the books and records of
the Funds and the Custodian;
- - Confirmed with brokers or inspected documentation for
selected securities purchased but not received; and
- - Agreed selected securities purchased and securities sold or
matured since our last report from the books and records of the
Funds to broker confirmations.
We believe that our examination provides a reasonable basis for
our opinion. Our examination does not provide a legal
determination on the Funds' compliance with specified
requirements.
In our opinion, management's assertion 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,
1999 with respect to securities reflected in the investment
accounts of the Funds is fairly stated, in all material respects.
This report is intended solely for the information and use of the
Board of Trustees of The Putnam Funds, the Board of Directors and
management of Putnam Fiduciary Trust Company and the Securities
and Exchange Commission and is not intended to be and should not
be used by anyone other than these specified parties.
March 10, 2000
2
Report of Independent Accountants
To the Board of Trustees of
The Putnam Funds and the Board of Directors
of Putnam Fiduciary Trust Company
We have examined management's assertion, included in the
accompanying Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940, about
The Putnam Funds' (the "Funds'") compliance with the requirements
of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of June 25, 1999. Management
is responsible for the Funds' compliance with those requirements.
Our responsibility is to express an opinion on management's
assertion about the Funds' compliance based on our examination.
Our examination was conducted in accordance with attestation
standards established by the American Institute of Certified
Public Accountants and, accordingly, included examining, on a
test basis, evidence about the Funds' compliance with those
requirements and performing such other procedures as we
considered necessary in the circumstances. Included among our
procedures were the following tests performed as of June 25, 1999
and with respect to agreement of security purchases and sales,
for the period from March 26, 1999 (the date of our last
examination), through June 25, 1999:
- - Without prior notice to management, obtained confirmation of
all securities record-kept at banks with whom the custodian and
the Funds have contracted to provide sub-custodian services
including The Boston Company, Bankers Trust Company, Brown
Brother Harriman & Co., United Missouri Bank, and Chase Manhattan
Bank;
- - Reconciled all such securities to the books and records of
the Funds and the Custodian;
- - Confirmed with brokers or inspected documentation for
selected securities purchased but not received; and
- - Agreed selected securities purchased and securities sold or
matured since our last report from the books and records of the
Funds to broker confirmations.
We believe that our examination provides a reasonable basis for
our opinion. Our examination does not provide a legal
determination on the Funds' compliance with specified
requirements.
In our opinion, management's assertion 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 June 25,
1999 with respect to securities reflected in the investment
accounts of the Funds is fairly stated, in all material respects.
This report is intended solely for the information and use of the
Board of Trustees of The Putnam Funds, the Board of Directors and
management of Putnam Fiduciary Trust Company and the Securities
and Exchange Commission and is not intended to be and should not
be used by anyone other than these specified parties.
March 10, 2000
2
Report of Independent Accountants
To the Board of Trustees of
The Putnam Funds and the Board
of Directors of Putnam Fiduciary Trust Company
We have examined management's assertion, included in the
accompanying Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940, about
The Putnam Funds' (the "Funds'") compliance with the requirements
of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of August 27, 1999.
Management is responsible for the Funds' compliance with those
requirements. Our responsibility is to express an opinion on
management's assertion about the Funds' compliance based on our
examination.
Our examination was conducted in accordance with attestation
standards established by the American Institute of Certified
Public Accountants and, accordingly, included examining, on a
test basis, evidence about the Funds' compliance with those
requirements and performing such other procedures as we
considered necessary in the circumstances. Included among our
procedures were the following tests performed as of August 27,
1999 and with respect to agreement of security purchases and
sales, for the period from June 25, 1999 (the date of our last
examination), through August 27, 1999:
- - Without prior notice to management, obtained confirmation of
all securities record-kept at banks with whom the custodian and
the Funds have contracted to provide sub-custodian services
including The Boston Company, Bankers Trust Company, Brown
Brother Harriman & Co., United Missouri Bank, and Chase Manhattan
Bank;
- - Reconciled all such securities to the books and records of
the Funds and the Custodian;
- - Confirmed with brokers or inspected documentation for
selected securities purchased but not received; and
- - Agreed selected securities purchased and securities sold or
matured since our last report from the books and records of the
Funds to broker confirmations.
We believe that our examination provides a reasonable basis for
our opinion. Our examination does not provide a legal
determination on the Funds' compliance with specified
requirements.
In our opinion, management's assertion 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 August 27,
1999 with respect to securities reflected in the investment
accounts of the Funds is fairly stated, in all material respects.
This report is intended solely for the information and use of the
Board of Trustees of The Putnam Funds, the Board of Directors and
management of Putnam Fiduciary Trust Company and the Securities
and Exchange Commission and is not intended to be and should not
be used by anyone other than these specified parties.
March 10, 2000
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 controls 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, 1999, and from October 30, 1998 through March 26, 1999.
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,
1999, and from October 30, 1998 through March 26, 1999, with
respect to securities reflected in the investment accounts of the
Funds.
Putnam Fiduciary Trust Company
By:
George Crane
Senior Vice President
March 10, 2000
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 controls 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
August 27, 1999 and from June 25, 1999 through August 27, 1999.
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 August 27,
1999 and from June 25, 1999 through August 27, 1999, with respect
to securities reflected in the investment accounts of the Funds.
Putnam Fiduciary Trust Company
By:
George Crane
Senior Vice President
March 10, 2000
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 controls 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 June
25, 1999, and from March 26, 1999 through June 25, 1999.
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 June 25,
1999, and from March 26, 1999, through June 25, 1999, with
respect to securities reflected in the investment accounts of the
Funds.
Putnam Fiduciary Trust Company
By:
George Crane
Senior Vice President
March 10, 2000
