The Putnam Advisory Company LLC

Item 5: Fees and Compensation
Putnam’s management fees are set forth in the client’s investment management agreement. Putnam generally
charges management fees to its discretionary account clients in accordance with its standard fee schedules when
the management agreement is signed. Management fees are negotiated with some clients, so fees vary from the
standard schedules. Putnam is required to deliver this brochure only to “qualified purchasers” as defined in section
2(a)(51)(A) of the Investment Company Act of 1940. As a result, SEC rules do not require us to include our
standard fee schedules in this brochure. Other investment advisers may charge higher or lower fees for
comparable services than Putnam charges.

Generally, management fees are billed to the client and are payable quarterly in arrears. Putnam does not
require prepayment of management fees.

Putnam must comply with SEC rules about “custody” of client assets (which can include automatic billing
arrangements). Clients other than registered investment companies who prefer that Putnam deduct fees
directly from their account will be required to make specific arrangements with a qualified custodian and to
provide Putnam with additional information (including confirmation that the custodian provides the client with
required account statements).

Fees, minimum account sizes, and fee breakpoints may be negotiated or modified in Putnam’s discretion based
on factors such as asset class, pre-existing fee schedules, account size and overall size of the client relationship,
the client’s status as a “founder” or early investor in a given strategy or pooled vehicle, portfolio complexity
and customization requests (such as specific investment restrictions requested by the client that cause the
account to differ from similar accounts managed at Putnam), service requirements (such as non-standard
reporting and information requests), the country or market in which a client is located, affiliate status, or other
factors. Putnam sometimes also chooses to waive all or a portion of negotiated fees for a period.

While we act as a fiduciary in managing client assets, not all our business decisions are fiduciary decisions.
Subject to applicable law and any contractual commitments, we may choose to charge different fees or
otherwise offer different levels of service to different clients for the same fee, depending on our own business
needs and market demands.

UMA and other Wrap Program and Model Portfolio Fees

PAC receives fees quarterly in arrears based on a percentage of the aggregate or average asset value of all UMA
program assets managed by the sponsor in accordance with PAC’s model portfolios. This fee is negotiated with
and paid by the sponsor. Advisory fees paid by the client to the sponsor in order to participate in these programs
are established by the sponsor; PAC does not negotiate advisory fees with a UMA client. Each client should
evaluate whether a particular UMA program is suitable for his or her needs, including the fees charged and services
provided. Please see the sponsor’s wrap fee program brochure or similar disclosure document for additional fee
information and disclosures.

Performance Fees

Some Putnam clients, including some investment funds, pay performance-based fees. For more information on
these fees, please read Item 6 of this brochure.

Separate account Termination

The terms and conditions of PAC’s services are specified in the investment management agreement between PAC
and the separate account client. The management agreement generally allows either the client or PAC to terminate
it at any time upon written notice (typically, of less than 60 days).

       7    The Putnam Advisory Company, LLC

Investment Funds

In addition to separate accounts, PAC manages or subadvises pooled investment funds of various kinds. Each
fund’s offering and subscription documents describe the fees that apply. Normally, the Putnam management fees
that a fund investor pays are similar to the fees for a similar Putnam separate account. However, investors should
note that the fees for fund investments differ from the fees for separate accounts in several ways.

First, a separate account client arranges for custody, recordkeeping and other service providers for its portfolio
on its own (and pays for these services separately). In contrast, Putnam-managed funds hire their own service
providers, and pay the related operating costs. Depending on the fund and account documentation, in some cases,
Putnam bears some or all of these expenses. For details, please refer to the specific fund’s offering documents.

In addition, the management fees on a fund may also differ from the fees for similar separate accounts depending,
for example, on the specific services provided and Putnam’s related costs. Interested qualified investors can request
a fund’s offering documents from Putnam.

From time to time, where permitted by law, Putnam may agree to rebate a portion of advisory fees or other
fund expenses to certain investors in our pooled funds. These rebates may be made by purchasing additional
shares of the fund, or as a refund payment to the investor.

PAC also sub-advises some of the Putnam Funds, which are registered investment companies. More information
about this relationship, including fees, is disclosed in the prospectus and statement of additional information for
each Putnam Fund; however, these sub-advisory fees are paid by PIM or another relevant affiliate, not by the
Putnam Funds.

Other Third-Party Fees and Expenses
In addition to the fees described above, clients of the Putnam Advisers typically bear other costs associated with their
accounts or portfolio investments. Depending on the type of investment account, vehicle or product that a client
is invested in these costs and expenses may include, but are not limited to: (i) custodial charges, brokerage
...

Item 7: Types of Clients
PAC provides investment advice to a wide variety of clients, such as U.S. and non-U.S. pension and profit-sharing
plans; charities, endowments and foundations; U.S. and non-U.S. investment funds; state, local and non-U.S.
governments, their agencies and instrumentalities; and corporations. PAC also sub-advises some Putnam Funds and
other portfolios managed by other Putnam companies and provides investment advice as a non-discretionary
portfolio manager in UMA or other "wrap fee" programs. PAC generally requires a separate account, at or shortly
after commencement, to have, depending on the product, minimum assets ranging from $25 million to $100 million.
Exceptions to account minimums may be made in some cases.

Use and Provision of Client Information and Confidentiality Clauses in Investment Management Agreements

A Putnam Adviser will at times include a separate account client’s name in a representative or sample client list
prepared by the Putnam Adviser with the client’s consent.

The Putnam Advisers are not generally required to provide notice to, or obtain the consent of, any client for use or
disclosure of account information to third parties, provided such use does not disclose the client’s name or other
personal information. This may include information relating to the Putnam Advisers’ investment experience with
respect to an account or an account’s performance, composite and representative account performance
presentations, marketing materials, attribution and research analyses, statistical and data compilations, or similar
materials.

In various circumstances, a Putnam Adviser will disclose information to third parties that include a client’s name,
account number or other account information (including non-public information), including, but not limited to: (i)
in connection with the performance of the adviser’s services under the respective investment management
agreement (including, but not limited to, providing trading and other account information to brokers, third-party
administrators, consultants, auditors and other counterparties, and the preparation and printing of client account
statements and reports by third parties), (ii) if required by law or regulatory authority, including, but not limited
to, any subpoena, administrative, regulatory or judicial demand or court order, or (iii) in connection with the bylaws
or equivalent governing documents of any issuer in which the account is invested. While the Putnam Advisers are
not generally required to provide notice or obtain consent in these situations, certain clients may have provisions
in their investment management agreements that require the Advisers to provide notice of certain types of
disclosures or disclosure requests. However, any such notice will be limited to the extent permitted by applicable
law, court order or regulation.