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U.S. Securities and Exchange Commission

Before the

Securities Exchange Act of 1934
Release No. 34-55561 / March 30, 2007

Administrative Proceeding File No. 3-11317

In the Matter of

Putnam Investment Management, LLC




Notice is hereby given, pursuant to Rule 1103 of the Securities and Exchange Commission's ("Commission") Rules on Fair Fund and Disgorgement Plans, 17 C.F.R. 201.1103, that the Independent Distribution Consultant appointed in this matter has submitted to the Commission a proposed plan ("Distribution Plan") for the distribution of monies placed into a Fair Fund in the above-captioned matter. On April 8, 2004, in the above-captioned matter, the Commission entered an Order Making Findings and Imposing Supplemental Remedial Sanctions Pursuant To Section 203(e) of the Investment Advisers Act of 1940 and Section 9(b) of the Investment Company Act of 1940, Release No. IA-2226, IC-26312. On September 29, 2005, the Commission issued an Order Creating a Fair Fund. Among other things, the Commission's Orders authorized and established a Fair Fund comprised of disgorgement, penalties and additional amounts paid by Putnam Investment Management LLC ("Putnam"), for distribution to investors for losses attributable to excessive short-term trading and market timing trading activity by Putnam employees pursuant to a distribution plan developed by an Independent Distribution Consultant.


Pursuant to this Notice, all interested parties are advised that they may print a copy of the proposed Distribution Plan from the Commission's public website, www.sec.gov/litigation/admin/2007 and Putnam's public website, https://www-uat.putnam.com/individual/. Interested parties may also obtain a written copy of the proposed Distribution Plan by submitting a written request to Ian D. Roffman, United States Securities and Exchange Commission, 33 Arch Street, Boston, Massachusetts 02110. All persons who desire to comment on the Distribution Plan may submit their comments, in writing, no later than April 30, 2007:

  1. to the Office of the Secretary, United States Securities and Exchange Commission, 100 F Street, N.E., Washington, DC 20549-1090;
  2. by using the Commission's Internet comment form (http://www.sec.gov/litigation/admin.shtml); or
  3. by sending an e-mail to rule-comments@sec.gov.

Comments submitted electronically should include Administrative Proceeding File Number 3-11317 on the subject line.

Comments received will be publicly available. Persons should submit only information that they wish to make publicly available.


The Distribution Plan provides that Putnam will distribute the Fair Fund consisting of $97.9 million plus interest, together with an additional $55.6 million paid in a related action brought by the Commonwealth of Massachusetts, to shareholders harmed by the improper trading alleged in the actions. The plan provides that the amount owed to shareholders will be calculated per fund-quarter and distributed based on shareholders' average daily holdings per quarter. Where possible, Putnam will aggregate money owed to a shareholder in connection with both actions into a single payment, including money owed across all funds and accounts, for the purposes of maximizing payments made to shareholders and reducing administrative costs. Shareholders eligible to receive distributions may have held shares directly as Putnam retail customers or through one of many different intermediaries, including brokerage firm "omnibus accounts," qualified and non-qualified retirement plans, 529 plans, trusts or foreign distribution agents. Retail shareholders will be sent a check directly from the Fair Fund. The plan provides omnibus accounts, other than retirement plans, that are receiving distributions of $1,000 or more the options of (1) distributing the funds to beneficial shareholders themselves in accordance with the plan; (2) providing data to the Fair Fund to permit the Fair Fund to distribute the funds to beneficial shareholders in accordance with the plan; or (3) providing data to the Fair Fund to permit the Fair Fund to calculate the distributions to beneficial shareholders, but thereafter make the actual distributions to beneficial shareholders on their own. The plan instructs that retirement plan distributions will be handled by retirement plans in accordance with their fiduciary and contractual obligations. Eligible shareholders would not need to go through a claims process.

By the Commission.

Nancy M. Morris

See also Proposed Distribution Plan


Modified: 03/30/2007