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

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
February 25, 2005, and from September 24, 2004 through February
25, 2005.

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 February
25, 2005, and from September 24, 2004 through February 25, 2005,
with respect to securities reflected in the investment accounts
of the Funds.


Putnam Fiduciary Trust Company




/s/Paul Bucuvalas
Managing Director - Custody
Services


March 29, 2006

Date