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 October 28, 2005, and from September 30, 2005 through October 28, 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 October 28, 2005, and from September 30, 2005 through October 28, 2005, with respect to securities reflected in the investment accounts of the Funds. Putnam Fiduciary Trust Company By: /s/ Paul Bucuvalas Managing Director - Custody Services March 29, 2006 Date