N-CSR

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number: (811-05498)
Exact name of registrant as specified in charter:	Putnam Master Intermediate Income Trust
Address of principal executive offices: One Post Office Square, Boston, Massachusetts 02109
Name and address of agent for service:	Beth S. Mazor, Vice President
	One Post Office Square
	Boston, Massachusetts 02109
Copy to:	John W. Gerstmayr, Esq.
	Ropes & Gray LLP
	One International Place
	Boston, Massachusetts 02110
Registrant’s telephone number, including area code:		(617) 292-1000
Date of fiscal year end: September 30, 2009
Date of reporting period: October 1, 2008 - September 30, 2009

Item 1. Report to Stockholders:
The following is a copy of the report transmitted to stockholders pursuant to Rule 30e-1 under the Investment Company Act of 1940:

A BALANCED APPROACH

Since 1937, when George Putnam created a diverse mix of stocks and bonds in a single, professionally managed portfolio, Putnam has championed the balanced approach.

A WORLD OF INVESTING

Today, we offer investors a world of equity, fixed-income, multi-asset, and absolute-return portfolios to suit a range of financial goals.

A COMMITMENT TO EXCELLENCE

Our portfolio managers seek superior results over time, backed by original, fundamental research on a global scale. We believe in the value of experienced financial advice, in providing exemplary service, and in putting clients first in all we do.

Putnam Master
Intermediate
Income Trust

Annual report
9|30|09

Message from the Trustees	1
About the fund	2
Performance and portfolio snapshots	4
Interview with your fund’s portfolio manager	5
Your fund’s performance	8
Terms and definitions	9
Trustee approval of management contract	10
Other information for shareholders	13
Financial statements	14
Federal tax information	57
Compliance certifications	57
Shareholder meeting results	57
About the Trustees	58
Officers	62

Message from the Trustees

Dear Fellow Shareholder:

The nearly 60% advance in the S&P 500 Index from March through September ranks as the most concentrated period of growth in the stock market since just after the Great Depression. Aggressive stimulus efforts by governments worldwide appear to have saved the financial system from collapse and helped foster this historic market rebound.

Investors, however, should prepare for the possibility of this rapid ascent leveling off in coming quarters. The U.S. economy is improving, but headwinds remain. High public and private debt levels, as well as consumer spending held back by high unemployment and still-low housing prices, may result in a slower economic rebound.

We are pleased to report that many Putnam mutual funds have delivered significantly better results over the past year. This reflects the intense efforts of an investment team infused with new talent, new leadership, and a determination to excel. Leading that team is industry veteran Walter C. Donovan, who joined Putnam in April of this year and oversees an investment organization strengthened by the arrival of several senior portfolio managers, research analysts, and traders.

In another development, after several years of steady leadership, Charles E. “Ed” Haldeman, Jr. has stepped down as President of the Putnam Funds and as a member of the Board of Trustees of the Funds. Effective July 2009, Robert L. Reynolds, President and Chief Executive Officer of Putnam Investments and a Trustee of the Putnam Funds, replaced Mr. Haldeman as President of the Putnam Funds.

We would like to take this opportunity to welcome new shareholders to the fund and to thank all our investors for your continued confidence in Putnam.

Respectfully yours,

About the fund

Seeking broad diversification across bond markets

When Putnam Master Intermediate Income Trust was launched in 1988, its three-pronged focus on U.S. investment-grade bonds, high-yield corporate bonds, and non-U.S. bonds was considered innovative. Lower-rated, higher-yielding corporate bonds were relatively new, having just been established in the late 1970s. Additionally, at the time of the fund’s launch, few investors were venturing outside the United States for fixed-income opportunities.

The bond investment landscape has undergone a transformation in the two decades since. New sectors like mortgage- and asset-backed securities now make up a sizable portion of the U.S. investment-grade market. The high-yield corporate bond sector has also grown significantly. Outside the United States, the popularity of the euro has resulted in a large market of European government bonds. There are also growing opportunities to invest in the debt of emerging-market countries.

The fund’s investment perspective has been broadened to keep pace with the market expansion over time. To respond to the market’s increasing complexity, Putnam’s fixed-income group aligns teams of specialists with varied investment opportunities. Each team identifies compelling strategies within its area of expertise. The fund’s managers select from among these strategies, striving to systematically build a diversified portfolio that carefully balances risk and return.

We believe the fund’s multi-strategy approach is well suited to the expanding opportunities of today’s global bond marketplace. As different factors drive the performance of the various fixed-income sectors, the fund’s diversified strategy seeks to take advantage of changing market leadership in pursuit of high current income and relative stability of net asset value.

Consider these risks before investing: International investing involves certain risks, such as currency fluctuations, economic instability, and political developments. Additional risks may be associated with emerging-market securities, including illiquidity and volatility. Lower-rated bonds may offer higher yields in return for more risk. Funds that invest in government securities are not guaranteed. Mortgage-backed securities are subject to prepayment risk. Funds that invest in bonds are subject to certain risks, including interest-rate risk, credit risk, and inflation risk. As interest rates rise, the prices of bonds fall. Long-term bonds are more exposed to interest-rate risk than short-term bonds. Unlike bonds, bond funds have ongoing fees and expenses. The use of derivatives involves special risks and may result in losses. The fund’s shares trade on a stock exchange at market prices, which may be low er than the fund’s net asset value.

How do closed-end funds differ from open-end funds?

More assets at work While open-end funds need to maintain a cash position to meet redemptions, closed-end funds are not subject to redemptions and can keep more of their assets invested in the market.

Traded like stocks Closed-end fund shares are traded on stock exchanges, and their market prices fluctuate in response to supply and demand, among other factors.

Net asset value vs. market price Like an open-end fund’s net asset value (NAV) per share, the NAV of a closed-end fund share is equal to the current value of the fund’s assets, minus its liabilities, divided by the number of shares outstanding. However, when buying or selling closed-end fund shares, the price you pay or receive is the market price. Market price reflects current market supply and demand and may be higher or lower than the NAV.

Putnam Master Intermediate Income Trust

Putnam believes that building a diversified portfolio with multiple income-generating strategies is the best way to pursue your fund’s objectives. The fund’s portfolio is composed of a broad spectrum of government, credit, and securitized debt instruments.

Weightings are shown as a percentage of the fund’s total investment portfolio. Allocations and holdings in each sector will vary over time. For more information on current fund holdings, see pages 16–47.

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Performance and
portfolio snapshots

Average annual total return (%) comparison as of 9/30/09

Data is historical. Past performance does not guarantee future results. More recent returns may be less or more than those shown. Investment return and net asset value will fluctuate, and you may have a gain or a loss when you sell your shares. Performance assumes reinvestment of distributions and does not account for taxes. Fund returns in the bar chart are at NAV. See pages 5 and 8 for additional performance information, including fund returns at market price. Index and Lipper results should be compared to fund performance at NAV. Lipper calculates performance differently than the closed-end funds it ranks, due to varying methods for determining a fund’s monthly reinvestment NAV.

“Liquidity has improved substantially throughout
the credit markets.”

D. William Kohli, Portfolio Manager, Putnam Master Intermediate Income Trust

Credit qualities are shown as a percentage of portfolio value as of 9/30/09. A bond rated Baa or higher (Prime-3 or higher, for short-term debt) is considered investment grade. The chart reflects Moody’s ratings; percentages may include bonds not rated by Moody’s but considered by Putnam Management to be of comparable quality. Ratings will vary over time.

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Interview with your
fund’s portfolio manager

D. William Kohli

Bill, how did Master Intermediate Income Trust perform during its most recent annual period?

The fund posted a solid return and displayed strong performance for the past six months, overcoming the market turmoil of 2008. For the 12-month period ended September 30, 2009, the fund returned 13.32% at net asset value, versus a return of 11.46% for the more narrowly focused Barclays Capital Government/Credit Bond Index and a 13.39% return for the fund’s Lipper peer group. For the past six months ended September 30, the fund posted a 44.70% return.

A year ago, the credit markets were in turmoil. What factors turned the markets around from their low point in late 2008?

During the financial crisis last year, yield “spreads,” or differences in yield between credit instruments and safe-haven Treasuries, widened dramatically, as prices of many credit instruments plummeted.

Following a wave of bad news concerning the U.S. housing market, the collapse of Bear Stearns, and the Lehman Brothers bankruptcy in 2008, the credit markets essentially seized up for a time, reducing credit access for businesses and individuals. This wave of events plunged the United States and all major European countries into severe recession.

In response, the U.S. government took a number of actions to ease the crisis and restore global credit flows: The Fed [the Federal Reserve Board] lowered short-term rates in an effort to restart the economy. The Fed and U.S. Treasury also created a number of credit facilities designed to generate lending. In February, Congress approved a large stimulus package, and other federal initiatives, such as TALF [Term Asset-Backed Securities Loan Facility] and PPIP [Public-Private Investment Program] as well as the “cash for clunkers” automobile program, have worked to increase liquidity in credit markets and boost consumer spending to jumpstart the economy. The U.S. economy has begun to show signs of a turnaround, but unemployment continues to hover around 10%, and analysts have expressed concern over how the economy will fare once the government’s massive interventions are removed.

What has been your portfolio strategy over the past 12 months?

Over the past year — and particularly in 2009 — the fund has responded extremely well as we engaged in a wide variety

Broad market index and fund performance

This comparison shows your fund’s performance in the context of broad market indexes for the 12 months ended 9/30/09. See the previous page and page 8 for additional fund performance information. Index descriptions can be found on page 9.

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of strategies while looking forward to a gradual turnaround in fixed-income markets. Because strategies among major central banks around the world on how best to deal with the downturn have diverged somewhat over the past 12 months, the fund has strongly benefited from our decision regarding the term structure of interest rates, or the overall level of rates and/or the shape of the yield curve. Government policy intervention, net borrowing levels, quantitative easing, and artificially low central bank rates have opened up significant opportunities in term structure strategies, an area that has been relatively dormant for years.

IN THE NEWS

It is an interest rate for the record books. The Federal Reserve Board, which is responsible for implementing U.S. monetary policy, sets short-term interest rates through changes to the federal funds rate, the interest rate at which banks loan funds to other banks, usually on an overnight basis. Since December 2008, the federal funds rate has been resting at an all-time low of near 0% as the government works to restore liquidity to the credit market. The federal funds rate began at 1.13% in 1954 and hit a high of 22.36% in 1981. The Federal Reserve Bank of New York began experimenting in October with reverse repurchase agreements, which would, in effect, raise rates, but stressed that “no inference should be drawn about the timing of monetary policy tightening.”

The fund also profited from our prior decision to position the portfolio for yield-curve steepening — a strategy based on our view that the yield curve will in fact continue to steepen, with longer-term yields rising as central banks keep short-term rates low and concern grows over government budget deficits and longer-term inflation.

We also have an ongoing strategy of focusing on high-quality credit instruments that we believe carry minimal fundamental credit risk. Over the past two years, we have identified compelling opportunities among what we believed were severely undervalued securitized debt. These included commercial and residential mortgage-backed securities and collateralized mortgage obligations markets — particularly interest-only securities. While interest-only securities are highly sensitive to non-credit-related risks, including the risk of prepayment, we believed these risks were more than offset by the potential opportunities. At various points during the past two years, we have purchased large amounts of these securities, and these purchases have contributed substantially to performance.

Master Intermediate Income Trust has the mandate to invest both in the United States and around the world, and across a broad spectrum of fixed-income securities, including Treasuries, as well as in securitized, investment-grade, and high-yield bonds. This ability to target the global bond marketplace

Top holdings

HOLDING (percent of fund’s net assets)	COUPON (%) and MATURITY DATE
Securitized sector
Federal National Mortgage Association Pass-Through Certificates TBA (2.9%)	4.5%, 2039
Credit Suisse Mortgage Capital Certificates Ser. 07-C5, Class A3 (2.0%)	5.694%, 2040
Government National Mortgage Association Pass-Through Certificates TBA (1.9%)	4.5%, 2039
Government sector
Argentina (Republic of) sr. unsec. unsub. bonds FRB (1.1%)	0.943%, 2012
Russia (Federation of) 144A unsec. unsub. bonds (0.6%)	5%, 2030
Venezuela (Republic of) unsec. notes (0.5%)	10.75%, 2013
Credit sector
RSHB Capital SA for OJSC Russian Agricultural Bank sub. bonds FRB (Russia) (0.9%)	6.97%, 2016
VTB Capital SA 144A sec. notes (Russia) (0.5%)	6.609%, 2012
VTB Capital SA 144A notes (Russia) (0.5%)	7.5%, 2011

This table shows the fund’s top holdings and the percentage of the fund’s net assets that each represented as of 9/30/09. Holdings will vary over time.

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benefited the fund during the period. For example, the fund’s emerging-market investments in countries such as Argentina, Brazil, and Russia have contributed to returns as those countries have bounced back strongly from the severe downturn.

With the rapid swings in the market over the past year, what have you done to dampen volatility and risk in the portfolio?

In terms of portfolio positioning, we have increased exposure to collateralized mortgage obligations, which are benefiting from slow prepayment rates. In addition, we are holding more short-dated residential mortgage-backed securities, whose prices are more depressed than can be justified by mortgage market fundamentals, including foreclosure rates. In general, we have reduced risk by shortening duration, or interest-rate exposure, and diversifying exposures across much of the portfolio.

With the intent of decreasing the fund’s price volatility, we have also reduced the overall level of commercial mortgage assets in the fund, shifting to short-duration commercial and residential mortgages. In the residential mortgage area, we have emphasized hybrid adjustable-rate mortgages. These are securities that combine features of both fixed-rate and adjustable-rate mortgages. We have also acquired Alt-A —considered riskier than securities backed by prime mortgages but higher quality than securities backed by subprime mortgages — at what we feel are very depressed prices.

What’s your outlook?

We believe that the U.S. economy’s recovery from this severe recession will be muted, with economic progress curtailed by U.S. debt levels, lingering high unemployment rates, and weak housing prices. In contrast, the credit markets have rebounded from the depths of the crisis. For most credit issues, prices remain appealing, even if we factor in worst-case assumptions regarding mortgage defaults and the pace of economic recovery. Although bank lending remains weak, the markets for securitized debt such as commercial mortgage-backed securities have stabilized. Moreover, liquidity has improved substantially throughout the credit markets.

In early October, Master Intermediate Income Trust increased its monthly dividend payment. What factors drove the increase?

After the close of the period, on October 8, 2009, the Trustees of the Putnam Funds approved an $0.008 increase in the dividend of Master Intermediate Income Trust, from $0.045 to $0.053. This represents an 18% increase in the fund’s dividend and will boost the fund’s yield at NAV to roughly 10.55% (based on the October 8 NAV of $6.03 per share). The increase will be reflected in the next dividend, which has a record date of October 15 and a payable date of October 21. The committee approved raising the dividend because the fund significantly over-earned its distribution rate due to increased yield from asset-backed and commercial mortgage-backed securities.

Putnam is currently estimating Master Intermediate Income Trust will pay an extra taxable income distribution of between 30 and 40 cents per share in December 2009 in addition to the dividend increase.

Thank you, Bill, for your time and insights.

Portfolio Manager D. William Kohli is Team Leader of Portfolio Construction at Putnam. He has an M.B.A. from the Haas School of Business at the University of California, Berkeley, and a B.A. from the University of California, San Diego. Bill joined Putnam in 1994 and has been in the investment industry since 1987.

In addition to Bill, your fund’s portfolio managers are Michael Atkin, Rob Bloemker, Kevin Murphy, and Paul Scanlon.

This chart shows how the fund’s top weightings have changed over the past six months. Weightings are shown as a percentage of net assets. Holdings will vary over time.

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Your fund’s performance

This section shows your fund’s performance for periods ended September 30, 2009, the end of its most recent fiscal year. Performance should always be considered in light of a fund’s investment strategy. Data represents past performance. Past performance does not guarantee future results. More recent returns may be less or more than those shown. Investment return, net asset value, and market price will fluctuate, and you may have a gain or a loss when you sell your shares.

Fund performance Total return for periods ended 9/30/09

	NAV	Market price
Annual average	7.03%	6.71%
Life of fund (since 4/29/88)
10 years	74.43	106.84
Annual average	5.72	7.54
5 years	20.75	29.01
Annual average	3.84	5.23
3 years	7.73	25.07
Annual average	2.51	7.74
1 year	13.32	24.66

Performance assumes reinvestment of distributions and does not account for taxes.

Comparative index returns For periods ended 9/30/09

	Barclays Capital			Lipper Flexible Income
	Government/Credit	Citigroup Non-U.S. World	JPMorgan Global	Funds (closed-end)
	Bond Index	Government Bond Index	High Yield Index	category average*
Annual average (life of fund)	7.41%	7.08%	—†	6.79%
10 years	84.60	90.52	90.43%	63.56
Annual average	6.32	6.66	6.65	4.99
5 years	27.13	40.64	35.01	22.89
Annual average	4.92	7.06	6.19	4.20
3 years	19.94	33.65	17.47	11.42
Annual average	6.25	10.15	5.51	3.65
1 year	11.46	16.07	20.35	13.39

Index and Lipper results should be compared to fund performance at net asset value. Lipper calculates performance differently than the closed-end funds it ranks, due to varying methods for determining a fund’s monthly reinvestment NAV.

* Over the 1-year, 3-year, 5-year, 10-year, and life-of-fund periods ended 9/30/09, there were 5, 5, 5, 4, and 2 funds, respectively, in this Lipper category.

† The inception date of the JPMorgan Global High Yield Index was 12/31/93.

Fund price and distribution information For the 12-month period ended 9/30/09

Distributions
Number	12
Income	$0.540
Capital gains	—
Total	$0.540
Share value	NAV	Market price
9/30/08	$5.88	$5.39
9/30/09	5.94	5.99
Current yield (end of period)
Current dividend rate*	9.09%	9.02%

The classification of distributions, if any, is an estimate. Final distribution information will appear on your year-end tax forms.

* Most recent distribution, excluding capital gains, annualized and divided by NAV or market price at end of period.

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Terms and definitions

Important terms

Total return shows how the value of the fund’s shares changed over time, assuming you held the shares through the entire period and reinvested all distributions in the fund.

Net asset value (NAV) is the value of all your fund’s assets, minus any liabilities, divided by the number of outstanding shares.

Market price is the current trading price of one share of the fund. Market prices are set by transactions between buyers and sellers on exchanges such as the New York Stock Exchange.

Current yield is the annual rate of return earned from dividends or interest of an investment. Current yield is expressed as a percentage of the price of a security, fund share, or principal investment.

Comparative indexes

Barclays Capital Aggregate Bond Index is an unmanaged index of U.S. investment-grade fixed-income securities.

Barclays Capital Government/Credit Bond Index is an unmanaged index of U.S. Treasuries, agency securities, and investment-grade corporate bonds.

BoA Merrill Lynch U.S. 3-Month Treasury Bill Index is an unmanaged index that seeks to measure the performance of U.S. Treasury bills available in the marketplace.

Citigroup Non-U.S. World Government Bond Index is an unmanaged index generally considered to be representative of the world bond market excluding the United States.

JPMorgan Global High Yield Index is an unmanaged index of global high-yield fixed-income securities.

S&P 500 Index is an unmanaged index of common stock performance.

Indexes assume reinvestment of all distributions and do not account for fees. Securities and performance of a fund and an index will differ. You cannot invest directly in an index.

Lipper is a third-party industry-ranking entity that ranks mutual funds. Its rankings do not reflect sales charges. Lipper rankings are based on total return at net asset value relative to other funds that have similar current investment styles or objectives as determined by Lipper. Lipper may change a fund’s category assignment at its discretion. Lipper category averages reflect performance trends for funds within a category.

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Trustee approval of management contract

General conclusions

The Board of Trustees of the Putnam funds oversees the management of each fund and, as required by law, determines annually whether to approve the continuance of your fund’s management contract with Putnam Investment Management (“Putnam Management”) and the sub-management contract, with respect to your fund, between Putnam Management and its affiliate, Putnam Investments Limited (“PIL”).

In this regard, the Board of Trustees, with the assistance of its Contract Committee consisting solely of Trustees who are not “interested persons” (as such term is defined in the Investment Company Act of 1940, as amended) of the Putnam funds (the “Independent Trustees”), requests and evaluates all information it deems reasonably necessary under the circumstances. Over the course of several months ending in June 2009, the Contract Committee met several times to consider the information provided by Putnam Management and other information developed with the assistance of the Board’s independent counsel and independent staff. The Contract Committee reviewed and discussed key aspects of this information with all of the Independent Trustees. At the Trustees’ June 12, 2009 meeting, the Contract Committee recommended, and the Independent Trustees approved, the continuance of your fund’s management and sub-management contrac ts, effective July 1, 2009. (Because PIL is an affiliate of Putnam Management and Putnam Management remains fully responsible for all services provided by PIL, the Trustees have not evaluated PIL as a separate entity, and all subsequent references to Putnam Management below should be deemed to include reference to PIL as necessary or appropriate in the context.)

The Independent Trustees’ approval was based on the following conclusions:

• That the fee schedule in effect for your fund represented reasonable compensation in light of the nature and quality of the services being provided to the fund, the fees paid by competitive funds and the costs incurred by Putnam Management in providing such services, and

• That such fee schedule represented an appropriate sharing between fund shareholders and Putnam Management of such economies of scale as may exist in the management of the fund at current asset levels.

These conclusions were based on a comprehensive consideration of all information provided to the Trustees and were not the result of any single factor. Some of the factors that figured particularly in the Trustees’ deliberations and how the Trustees considered these factors are described below, although individual Trustees may have evaluated the information presented differently, giving different weights to various factors. It is also important to recognize that the fee arrangements for your fund and the other Putnam funds are the result of many years of review and discussion between the Independent Trustees and Putnam Management, that certain aspects of the arrangements may receive greater scrutiny in some years than others, and that the Trustees’ conclusions may be based, in part, on their consideration of these same arrangements in prior years.

Management fee schedules and categories; total expenses

The Trustees reviewed the management fee schedules in effect for all Putnam funds, including fee levels and breakpoints, and the assignment of funds to particular fee categories. The general fee structure has been carefully developed over the years and re-examined on many occasions and adjusted where appropriate. In this regard, the Trustees noted that shareholders of all funds voted by overwhelming majorities in 2007 to approve new management contracts containing identical fee schedules.

In reviewing fees and expenses, the Trustees generally focused their attention on material changes in circumstances — for example, changes in a fund’s size or investment style, changes in Putnam Management’s operating costs, or changes in competitive practices in the mutual fund industry — that suggest that consideration of fee changes might be warranted. The Trustees concluded that the circumstances did not warrant changes to the management fee structure of your fund. The Trustees focused on two areas of particular interest, as discussed further below:

• Competitiveness. The Trustees reviewed comparative fee and expense information for competitive funds, which indicated that, in a custom peer group of competitive funds selected by Lipper Inc., your fund ranked in the 67th percentile in management fees and in the 33rd percentile in total expenses as of December 31, 2008 (the first percentile being the least expensive funds and the 100th percentile being the most expensive funds).

The Trustees noted that expense ratios for a number of Putnam funds, which show the percentage of fund assets used to pay for management and administrative services, distribution (12b-1) fees (as applicable) and other expenses, had been increasing recently as a result of declining net assets and the natural operation of fee breakpoints. The Trustees expressed their intention to monitor the funds’ percentile rankings in management fees and in total expenses to ensure that fees and expenses of the funds continue to meet evolving competitive standards.

Economies of scale. Your fund currently has the benefit of breakpoints in its management fee that provide shareholders with significant economies of scale, which means that the effective management fee rate of the fund (as a percentage of fund assets) declines as the fund grows in size and crosses specified asset thresholds. Conversely, as the fund shrinks in size — as has been the case for many Putnam funds in recent years — these breakpoints result in increasing fee levels. In recent years, the Trustees have examined the operation of the existing breakpoint structure during periods of both growth and decline in asset levels. The Trustees concluded that the fee schedule in effect for your fund represented

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an appropriate sharing of economies of scale at that time.

In connection with their review of the management fees and total expenses of the Putnam funds, the Trustees also reviewed the costs of the services provided and profits realized by Putnam Management and its affiliates from their contractual relationships with the funds. This information included trends in revenues, expenses and profitability of Putnam Management and its affiliates relating to the investment management and distribution services provided to the funds. In this regard, the Trustees also reviewed an analysis of Putnam Management’s revenues, expenses and profitability with respect to the funds’ management contracts, allocated on a fund-by-fund basis.

Investment performance

The quality of the investment process provided by Putnam Management represented a major factor in the Trustees’ evaluation of the quality of services provided by Putnam Management under your fund’s management contract. The Trustees were assisted in their review of the Putnam funds’ investment process and performance by the work of the Investment Oversight Coordinating Committee of the Trustees and the Investment Oversight Committees of the Trustees, which had met on a regular monthly basis with the funds’ portfolio teams throughout the year. The Trustees concluded that Putnam Management generally provides a high-quality investment process — as measured by the experience and skills of the individuals assigned to the management of fund portfolios, the resources made available to such personnel, and in general the ability of Putnam Management to attract and retain high-quality personnel — but also recognized that this does no t guarantee favorable investment results for every fund in every time period. The Trustees considered the investment performance of each fund over multiple time periods and considered information comparing each fund’s performance with various benchmarks and with the performance of competitive funds.

The Trustees noted the disappointing investment performance of many of the funds for periods ended March 31, 2009. They discussed with senior management of Putnam Management the factors contributing to such underperformance and the actions being taken to improve performance. The Trustees recognized that, in recent years, Putnam Management has taken steps to strengthen its investment personnel and processes to address areas of underperformance, including Putnam Management’s continuing efforts to strengthen the equity research function, recent changes in portfolio managers including increased accountability of individual managers rather than teams, recent changes in Putnam Management’s approach to incentive compensation, including emphasis on top quartile performance over a rolling three-year period, and the recent arrival of a new chief investment officer. The Trustees also recognized the substantial improvement in performance of many funds si nce the implementation of those changes. The Trustees indicated their intention to continue to monitor performance trends to assess the effectiveness of these efforts and to evaluate whether additional changes to address areas of underperformance are warranted.

In the case of your fund, the Trustees considered that your fund’s common share cumulative total return performance at net asset value was in the following percentiles of its Lipper Inc. peer group (Lipper Flexible Income Funds (closed-end)) for the one-year, three-year and five-year periods ended March 31, 2009 (the first percentile being the best-performing funds and the 100th percentile being the worst-performing funds):

One-year period	86th
Three-year period	86th
Five-year period	86th

Over the one-year, three-year and five-year periods ended March 31, 2009, there were 6, 6 and 6 funds, respectively, in your fund’s Lipper peer group. Past performance is no guarantee of future results.

The Trustees noted the disappointing performance for certain funds, as well as certain circumstances that may have contributed to that performance and the actions taken by Putnam Management to address these funds’ performance. The Trustees also considered the four broad initiatives that Putnam Management has implemented to improve its investment approach, to reduce the likelihood of fourth quartile results, and to deliver on its long-term investment goals. Specifically, Putnam Management has:

1. Increased accountability and reduced complexity in the portfolio management process for the Putnam equity funds by replacing a team management structure with a decision-making process that vests full authority and responsibility with individual portfolio managers;

2. Clarified Putnam Management’s investment process by affirming a fundamental-driven approach to investing, with quantitative analysis providing additional input for investment decisions;

3. Strengthened Putnam Management’s large-cap equity research capability by adding multiple new investment personnel to the team and by bringing U.S. and international research under common leadership; and

4. Realigned compensation structure for portfolio managers and research analysts so that only those who achieve top-quartile returns over a rolling three-year basis are eligible for full bonuses.

The Trustees noted the disappointing performance for your fund for the one-year, three-year and five-year periods ended March 31, 2009. The Trustees considered Putnam Management’s belief that significant volatility and illiquidity in the markets contributed to the fund’s relative underperformance during these periods. In addition, the Trustees considered Putnam Management’s decision to implement initiative 4 described above. The Trustees also considered Putnam Management’s continued belief that the fund’s investment strategy and process are designed to produce attractive relative performance over longer periods, and noted improvements in the fund’s recent year-to-date performance as

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of March 31, 2009 as the markets began to show signs of stabilizing.

As a general matter, the Trustees believe that cooperative efforts between the Trustees and Putnam Management represent the most effective way to address investment performance problems. The Trustees noted that investors in the Putnam funds have, in effect, placed their trust in the Putnam organization, under the oversight of the funds’ Trustees, to make appropriate decisions regarding the management of the funds. Based on the responsiveness of Putnam Management in the recent past to Trustee concerns about investment performance, the Trustees concluded that it is preferable to seek change within Putnam Management to address performance shortcomings. In the Trustees’ view, the alternative of engaging a new investment adviser for an underperforming fund would entail significant disruptions and would not provide any greater assurance of improved investment performance.

Brokerage and soft-dollar allocations; other benefits

The Trustees considered various potential benefits that Putnam Management may receive in connection with the services it provides under the management contract with your fund. These include benefits related to brokerage and soft-dollar allocations, whereby a portion of the commissions paid by a fund for brokerage may be used to acquire research services that may be useful to Putnam Management in managing the assets of the fund and of other clients. The Trustees considered a change made, at Putnam Management’s request, to the Putnam funds’ brokerage allocation policy commencing in 2009, which increased the permitted soft dollar allocation to third-party services over what had been authorized in previous years. The Trustees noted that a portion of available soft dollars continue to be allocated to the payment of fund expenses, although the amount allocated for this purpose has declined in recent years. The Tr ustees indicated their continued intent to monitor regulatory developments in this area with the assistance of their Brokerage Committee and also indicated their continued intent to monitor the potential benefits associated with the allocation of fund brokerage and trends in industry practice to ensure that the principle of seeking best price and execution remains paramount in the portfolio trading process.

The Trustees’ annual review of your fund’s management contract also included the review of the investor servicing agreement with Putnam Fiduciary Trust Company, which agreement provides benefits to an affiliate of Putnam Management.

Comparison of retail and institutional fee schedules

The information examined by the Trustees as part of their annual contract review has included for many years information regarding fees charged by Putnam Management and its affiliates to institutional clients such as defined benefit pension plans, college endowments, etc. This information included comparisons of such fees with fees charged to the funds, as well as a detailed assessment of the differences in the services provided to these two types of clients. The Trustees observed, in this regard, that the differences in fee rates between institutional clients and mutual funds are by no means uniform when examined by individual asset sectors, suggesting that differences in the pricing of investment management services to these types of clients reflect to a substantial degree historical competitive forces operating in separate market places. The Trustees considered the fact that fee rates across different asset classes are typically higher on average fo r mutual funds than for institutional clients, as well as the differences between the services that Putnam Management provides to the Putnam funds and those that it provides to institutional clients of the firm, but did not rely on such comparisons to any significant extent in concluding that the management fees paid by your fund are reasonable.

12

Other information for shareholders

Important notice regarding share repurchase program

In September 2009, the Trustees of your fund approved the renewal of a share repurchase program that had been in effect since 2005. This renewal will allow your fund to repurchase, in the 12 months beginning October 8, 2009, up to 10% of the fund’s common shares outstanding as of October 7, 2009.

Putnam’s policy on confidentiality

In order to conduct business with our shareholders, we must obtain certain personal information such as account holders’ addresses, telephone numbers, Social Security numbers, and the names of their financial representatives. We use this information to assign an account number and to help us maintain accurate records of transactions and account balances. It is our policy to protect the confidentiality of your information, whether or not you currently own shares of our funds, and, in particular, not to sell information about you or your accounts to outside marketing firms. We have safeguards in place designed to prevent unauthorized access to our computer systems and procedures to protect personal information from unauthorized use. Under certain circumstances, we share this information with outside vendors who provide services to us, such as mailing and proxy solicitation. In those cases, the service providers en ter into confidentiality agreements with us, and we provide only the information necessary to process transactions and perform other services related to your account. We may also share this information with our Putnam affiliates to service your account or provide you with information about other Putnam products or services. It is also our policy to share account information with your financial representative, if you’ve listed one on your Putnam account. If you would like clarification about our confidentiality policies or have any questions or concerns, please don’t hesitate to contact us at 1-800-225-1581, Monday through Friday, 8:30 a.m. to 8:00 p.m., or Saturdays from 9:00 a.m. to 5:00 p.m. Eastern Time.

Proxy voting

Putnam is committed to managing our mutual funds in the best interests of our shareholders. The Putnam funds’ proxy voting guidelines and procedures, as well as information regarding how your fund voted proxies relating to portfolio securities during the 12-month period ended June 30, 2009, are available in the Individual Investors section at putnam.com, and on the SEC’s Web site, www.sec.gov. If you have questions about finding forms on the SEC’s Web site, you may call the SEC at 1-800-SEC-0330.

You may also obtain the Putnam funds’ proxy voting guidelines and procedures at no charge by calling Putnam’s Shareholder Services at 1-800-225-1581.

Fund portfolio holdings

The fund will file a complete schedule of its portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-Q. Shareholders may obtain the fund’s Forms N-Q on the SEC’s Web site at www.sec.gov. In addition, the fund’s Forms N-Q may be reviewed and copied at the SEC’s Public Reference Room in Washington, D.C. You may call the SEC at 1-800-SEC-0330 for information about the SEC’s Web site or the operation of the Public Reference Room.

Trustee and employee fund ownership

Putnam employees and members of the Board of Trustees place their faith, confidence, and, most importantly, investment dollars in Putnam mutual funds. As of September 30, 2009, Putnam employees had approximately $308,000,000 and the Trustees had approximately $40,000,000 invested in Putnam mutual funds. These amounts include investments by the Trustees’ and employees’ immediate family members as well as investments through retirement and deferred compensation plans.

13

Financial statements

These sections of the report, as well as the accompanying Notes, preceded by the Report of Independent Registered Public Accounting Firm, constitute the fund’s financial statements.

The fund’s portfolio lists all the fund’s investments and their values as of the last day of the reporting period. Holdings are organized by asset type and industry sector, country, or state to show areas of concentration and diversification.

Statement of assets and liabilities shows how the fund’s net assets and share price are determined. All investment and noninvest-ment assets are added together. Any unpaid expenses and other liabilities are subtracted from this total. The result is divided by the number of shares to determine the net asset value per share. (For funds with preferred shares, the amount subtracted from total assets includes the liquidation preference of preferred shares.)

Statement of operations shows the fund’s net investment gain or loss. This is done by first adding up all the fund’s earnings —from dividends and interest income — and subtracting its operating expenses to determine net investment income (or loss). Then, any net gain or loss the fund realized on the sales of its holdings — as well as any unrealized gains or losses over the period — is added to or subtracted from the net investment result to determine the fund’s net gain or loss for the fiscal year.

Statement of changes in net assets shows how the fund’s net assets were affected by the fund’s net investment gain or loss, by distributions to shareholders, and by changes in the number of the fund’s shares. It lists distributions and their sources (net investment income or realized capital gains) over the current reporting period and the most recent fiscal year-end. The distributions listed here may not match the sources listed in the Statement of operations because the distributions are determined on a tax basis and may be paid in a different period from the one in which they were earned.

Financial highlights provide an overview of the fund’s investment results, per-share distributions, expense ratios, net investment income ratios, and portfolio turnover in one summary table, reflecting the five most recent reporting periods. In a semian-nual report, the highlight table also includes the current reporting period.

14

Report of Independent Registered Public Accounting Firm

The Board of Trustees and Shareholders
Putnam Master Intermediate Income Trust:

We have audited the accompanying statement of assets and liabilities of Putnam Master Intermediate Income Trust (the “fund”), including the fund’s portfolio, as of September 30, 2009, and the related statement of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended and the financial highlights for each of the five years in the period then ended. These financial statements and financial highlights are the responsibility of the fund’s management. Our responsibility is to express an opinion on these financial statements and financial highlights based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform our audit to obtain reasonable assurance about whether the financial statements and financial highlights are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of September 30, 2009 by correspondence with the custodian and brokers or by other appropriate auditing procedures. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, the financial statements and financial highlights referred to above present fairly, in all material respects, the financial position of Putnam Master Intermediate Income Trust as of September 30, 2009, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended, in conformity with U.S. generally accepted accounting principles.

Boston, Massachusetts
November 16, 2009

15

The fund’s portfolio 9/30/09

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Banc of America Alternative Loan
Trust Ser. 06-7, Class A2, 5.707s, 2036	$4,010,000	$3,007,500
Banc of America Commercial
Mortgage, Inc.
FRB Ser. 07-3, Class A3, 5.837s, 2049	168,000	160,250
Ser. 07-2, Class A2, 5.634s, 2049	513,000	507,593
Ser. 07-1, Class A4, 5.451s, 2049	888,000	785,223
Ser. 05-6, Class A2, 5.165s, 2047	1,131,000	1,135,697
Ser. 07-5, Class XW, IO, 0.606s, 2051	112,594,871	1,902,853
Banc of America Commercial
Mortgage, Inc. 144A
Ser. 01-1, Class J, 6 1/8s, 2036	163,000	65,151
Ser. 01-1, Class K, 6 1/8s, 2036	367,000	184,367
Banc of America Funding Corp. FRB
Ser. 06-D, Class 6A1, 5.885s, 2036	2,740,765	1,617,051
Banc of America Large Loan 144A FRB
Ser. 05-MIB1, Class K, 2.243s, 2022	645,000	327,030
Bayview Commercial Asset Trust 144A
Ser. 07-5A, IO, 3.047s, 2037	965,799	72,049
Ser. 07-1, Class S, IO, 2.477s, 2037	3,667,055	222,224
Bear Stearns Alternate Trust
FRB Ser. 06-5, Class 2A2, 6 1/4s, 2036	2,009,993	953,335
FRB Ser. 05-10, Class 25A1, 5.862s,
2036	1,379,675	724,330
FRB Ser. 06-6, Class 2A1, 5.82s, 2036	963,538	513,944
FRB Ser. 07-1, Class 21A1, 5.619s,
2047	1,386,542	721,002
Bear Stearns Alternate Trust II FRB
Ser. 07-1, Class 1A1, 6.029s, 2047	4,627,174	2,596,821
Bear Stearns Commercial Mortgage
Securities, Inc. FRB Ser. 00-WF2,
Class F, 8.452s, 2032	410,000	249,470
Bear Stearns Commercial Mortgage
Securities, Inc. 144A Ser. 07-PW18,
Class X1, IO, 0.095s, 2050	62,396,111	508,578
Citigroup Mortgage Loan Trust, Inc.
FRB Ser. 06-AR5, Class 2A5A, 6.182s,
2036	1,252,389	653,152
FRB Ser. 05-10, Class 1A5A, 5.837s,
2035	358,988	229,753
FRB Ser. 05-10, Class 1A4A, 5.728s,
2035	1,329,794	744,684
FRB Ser. 06-AR7, Class 2A2A, 5.607s,
2036	783,295	493,476
Citigroup/Deutsche Bank Commercial
Mortgage Trust 144A Ser. 07-CD5,
Class XS, IO, 0.077s, 2044	36,485,300	180,997
Commercial Mortgage Pass-Through
Certificates 144A FRB Ser. 05-F10A,
Class A1, 0.343s, 2017	230,053	228,450
Countrywide Alternative Loan Trust
Ser. 06-45T1, Class 2A2, 6s, 2037	2,822,233	1,848,563
Ser. 06-J8, Class A4, 6s, 2037	2,125,624	1,211,606
Ser. 05-80CB, Class 2A1, 6s, 2036	1,797,990	1,325,456
FRB Ser. 07-HY4, Class 3A1,
5.812s, 2047	868,802	495,217
Ser. 07-HY5R, Class 2A1A, 5.544s, 2047	1,560,491	1,258,877
Ser. 07-8CB, Class A1, 5 1/2s, 2037	953,965	690,432
FRB Ser. 06-23CBC, Class 2A5,
0.646s, 2036	2,916,437	1,312,397
FRB Ser. 06-OC10, Class 2A2A,
0.426s, 2036	1,885,000	921,369
FRB Ser. 07-HY7C, Class A1,
0.386s, 2037	1,920,819	921,993

MORTGAGE-BACKED		Principal
SECURITIES (47.3%)* cont.		amount	Value
Countrywide Home Loans
FRB Ser. 05-HYB7, Class 6A1,
5.661s, 2035		$43,337	$30,336
FRB Ser. 06-HYB1, Class 1A1,
5.309s, 2036		271,640	134,197
FRB Ser. 05-HYB4, Class 2A1,
4.864s, 2035		4,201,577	2,520,946
Countrywide Home Loans 144A
IFB Ser. 05-R1, Class 1AS, IO,
5.626s, 2035		2,833,852	286,928
Ser. 06-R1, Class AS, IO, 5.61s, 2036		1,875,643	185,220
Ser. 05-R3, Class AS, IO, 5.557s, 2035		589,383	58,570
FRB Ser. 06-R2, Class AS, IO,
5.452s, 2036		2,685,849	260,192
Credit Suisse Mortgage
Capital Certificates
FRB Ser. 06-C3, Class A3, 6.02s, 2038		3,576,000	2,982,926
FRB Ser. 07-C4, Class A2, 6.003s, 2039		814,000	821,599
Ser. 07-1, Class 1A1A, 5.942s, 2037		532,273	320,056
Ser. 07-3, Class 1A1A, 5.837s, 2037		1,028,985	596,811
Ser. 07-C5, Class A3, 5.694s, 2040		8,400,000	7,611,374
Ser. 06-C4, Class A3, 5.467s, 2039		1,316,000	1,139,788
CRESI Finance Limited Partnership
144A FRB Ser. 06-A, Class C, 0.846s, 2017		251,000	138,050
CS First Boston Mortgage
Securities Corp. 144A
Ser. 98-C1, Class F, 6s, 2040		966,000	869,400
Ser. 02-CP5, Class M, 5 1/4s, 2035		354,000	27,355
FRB Ser. 05-TFLA, Class L,
2.093s, 2020		699,000	454,350
CWCapital Cobalt Ser. 06-C1,
Class A2, 5.174s, 2048		1,374,000	1,372,144
Deutsche Alternative Securities, Inc.
FRB Ser. 06-AR3, Class A1,
0.436s, 2036		1,494,782	650,464
Deutsche Mortgage & Asset
Receiving Corp. Ser. 98-C1, Class X,
IO, 0.765s, 2031		2,617,032	56,307
DLJ Commercial Mortgage Corp.
Ser. 98-CF2, Class B4, 6.04s, 2031		286,492	229,194
European Loan Conduit 144A FRB
Ser. 22A, Class D, 1.764s, 2014
(United Kingdom) F	GBP	507,000	121,756
European Prime Real Estate PLC 144A
FRB Ser. 1-A, Class D, 1.764s, 2014
(United Kingdom) F	GBP	270,567	21,656
Fannie Mae
IFB Ser. 06-62, Class PS,
38.423s, 2036		$570,222	851,780
IFB Ser. 05-74, Class CP,
23.847s, 2035		395,598	527,957
IFB Ser. 05-99, Class SA,
23.664s, 2035		457,159	600,470
IFB Ser. 05-95, Class OP,
19.595s, 2035		305,931	381,175
IFB Ser. 05-83, Class QP,
16.754s, 2034		165,020	196,578
IFB Ser. 03-44, Class SI, IO,
7.754s, 2033		1,604,655	265,832
IFB Ser. 06-90, Class SE, IO,
7.554s, 2036		1,964,295	345,582
IFB Ser. 08-7, Class SA, IO,
7.304s, 2038		4,052,315	597,352
IFB Ser. 05-113, Class AI, IO,
6.984s, 2036		616,479	97,176

16

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Fannie Mae
IFB Ser. 06-125, Class SM, IO,
6.954s, 2037	$908,712	$113,780
IFB Ser. 06-43, Class SU, IO,
6.954s, 2036	328,187	42,559
IFB Ser. 06-24, Class QS, IO,
6.954s, 2036	844,420	131,822
IFB Ser. 06-79, Class DI, IO,
6.904s, 2036	1,583,072	207,559
IFB Ser. 06-60, Class SI, IO,
6.904s, 2036	2,963,918	405,019
IFB Ser. 06-60, Class UI, IO,
6.904s, 2036	498,947	72,470
IFB Ser. 04-24, Class CS, IO,
6.904s, 2034	316,119	45,349
IFB Ser. 03-130, Class BS, IO,
6.804s, 2033	1,957,952	252,944
IFB Ser. 03-34, Class WS, IO,
6.754s, 2029	1,835,210	196,698
IFB Ser. 08-20, Class SA, IO,
6.744s, 2038	516,996	65,484
IFB Ser. 08-41, Class S, IO,
6.554s, 2036	1,914,500	209,040
IFB Ser. 05-48, Class SM, IO,
6.554s, 2034	803,567	94,741
IFB Ser. 07-54, Class CI, IO,
6.514s, 2037	964,511	132,496
IFB Ser. 08-34, Class SM, IO,
6.504s, 2038	1,694,841	187,904
IFB Ser. 07-28, Class SE, IO,
6.504s, 2037	191,719	26,006
IFB Ser. 07-22, Class S, IO,
6.504s, 2037	13,688,063	1,661,868
IFB Ser. 07-24, Class SD, IO,
6.504s, 2037	773,248	89,635
IFB Ser. 06-79, Class SI, IO,
6.504s, 2036	530,495	61,175
IFB Ser. 05-90, Class GS, IO,
6.504s, 2035	133,754	17,915
IFB Ser. 05-90, Class SP, IO,
6.504s, 2035	534,147	57,706
IFB Ser. 05-12, Class SC, IO,
6.504s, 2035	654,467	80,580
IFB Ser. 05-18, Class SK, IO,
6.504s, 2035	134,688	12,732
IFB Ser. 07-30, Class IE, IO,
6.494s, 2037	2,455,536	374,690
IFB Ser. 06-123, Class CI, IO,
6.494s, 2037	1,890,058	233,328
IFB Ser. 05-45, Class EW, IO,
6.474s, 2035	513,333	62,298
IFB Ser. 06-126, Class CS, IO,
6.454s, 2037	1,335,180	175,353
IFB Ser. 06-31, Class SX, IO,
6.454s, 2036	1,973,682	292,596
IFB Ser. 06-33, Class JS, IO,
6.454s, 2036	585,437	71,565
IFB Ser. 06-36, Class SP, IO,
6.454s, 2036	886,016	100,539
IFB Ser. 06-22, Class QM, IO,
6.454s, 2036	121,659	17,888
IFB Ser. 06-23, Class SP, IO,
6.454s, 2036	935,294	120,728
IFB Ser. 06-16, Class SM, IO,
6.454s, 2036	1,854,823	280,006
IFB Ser. 05-95, Class CI, IO,
6.454s, 2035	1,080,194	149,121

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Fannie Mae
IFB Ser. 05-84, Class SG, IO,
6.454s, 2035	$1,716,224	$227,091
IFB Ser. 05-57, Class NI, IO,
6.454s, 2035	434,452	57,958
IFB Ser. 06-3, Class SB, IO,
6.454s, 2035	4,962,239	689,602
IFB Ser. 05-29, Class SX, IO,
6.454s, 2035	714,984	87,355
IFB Ser. 05-57, Class DI, IO,
6.454s, 2035	765,811	84,774
IFB Ser. 04-92, Class S, IO,
6.454s, 2034	2,443,231	283,073
IFB Ser. 06-104, Class EI, IO,
6.444s, 2036	977,048	125,320
IFB Ser. 05-83, Class QI, IO,
6.444s, 2035	300,297	51,277
IFB Ser. 06-128, Class GS, IO,
6.434s, 2037	1,049,838	141,079
IFB Ser. 05-73, Class SD, IO,
6.434s, 2035	135,880	23,220
IFB Ser. 06-114, Class IS, IO,
6.404s, 2036	921,206	118,114
IFB Ser. 04-92, Class SQ, IO,
6.404s, 2034	1,052,181	140,073
IFB Ser. 06-115, Class IE, IO,
6.394s, 2036	733,228	92,897
IFB Ser. 06-117, Class SA, IO,
6.394s, 2036	1,106,491	141,636
IFB Ser. 06-109, Class SG, IO,
6.384s, 2036	277,715	29,456
IFB Ser. 06-109, Class SH, IO,
6.374s, 2036	922,135	140,567
IFB Ser. 06-111, Class SA, IO,
6.374s, 2036	6,000,827	751,664
IFB Ser. 06-103, Class SB, IO,
6.354s, 2036	337,005	40,566
IFB Ser. 06-43, Class SI, IO,
6.354s, 2036	1,947,400	231,468
IFB Ser. 06-48, Class QB, IO,
6.354s, 2036	1,276,417	140,878
IFB Ser. 06-50, Class IP, IO,
6.354s, 2036	5,315,802	741,209
IFB Ser. 06-8, Class JH, IO,
6.354s, 2036	3,664,832	470,784
IFB Ser. 05-122, Class SG, IO,
6.354s, 2035	857,000	108,728
IFB Ser. 05-122, Class SW, IO,
6.354s, 2035	1,052,330	127,837
IFB Ser. 06-101, Class SA, IO,
6.334s, 2036	2,340,071	269,927
IFB Ser. 06-92, Class LI, IO,
6.334s, 2036	1,089,963	143,593
IFB Ser. 06-99, Class AS, IO,
6.334s, 2036	311,530	36,761
IFB Ser. 06-17, Class SI, IO,
6.334s, 2036	858,823	99,976
IFB Ser. 06-98, Class SQ, IO,
6.324s, 2036	9,857,160	1,151,021
IFB Ser. 06-60, Class YI, IO,
6.324s, 2036	2,690,441	396,759
IFB Ser. 06-98, Class SB, IO,
6.304s, 2036	779,589	84,080
IFB Ser. 06-86, Class SB, IO,
6.304s, 2036	588,482	79,822
IFB Ser. 07-91, Class SA, IO,
6.264s, 2037	1,741,524	181,937

17

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Fannie Mae
IFB Ser. 07-15, Class NI, IO,
6.254s, 2022	$1,640,224	$173,459
IFB Ser. 07-109, Class XI, IO,
6.204s, 2037	754,643	119,452
IFB Ser. 06-79, Class SH, IO,
6.204s, 2036	1,757,108	258,092
IFB Ser. 07-30, Class LI, IO,
6.194s, 2037	2,066,387	238,606
IFB Ser. 07-89, Class SA, IO,
6.184s, 2037	1,952,941	220,096
IFB Ser. 07-54, Class IA, IO,
6.164s, 2037	1,058,215	133,755
IFB Ser. 07-54, Class IB, IO,
6.164s, 2037	1,058,215	133,755
IFB Ser. 07-54, Class IC, IO,
6.164s, 2037	1,058,215	133,755
IFB Ser. 07-54, Class ID, IO,
6.164s, 2037	1,058,215	133,755
IFB Ser. 07-54, Class IE, IO,
6.164s, 2037	1,058,215	133,755
IFB Ser. 07-54, Class IF, IO,
6.164s, 2037	1,688,123	193,898
IFB Ser. 07-54, Class UI, IO,
6.164s, 2037	1,585,103	207,553
IFB Ser. 07-15, Class CI, IO,
6.134s, 2037	3,547,218	407,895
IFB Ser. 06-115, Class JI, IO,
6.134s, 2036	2,502,652	290,808
IFB Ser. 08-12, Class SG, IO,
6.104s, 2038	298,484	28,962
IFB Ser. 09-43, Class SB, IO,
6.084s, 2039	154,606	22,039
IFB Ser. 06-123, Class LI, IO,
6.074s, 2037	1,701,604	189,729
IFB Ser. 07-81, Class IS, IO,
6.054s, 2037	1,426,019	155,850
IFB Ser. 08-11, Class SC, IO,
6.034s, 2038	151,401	17,641
IFB Ser. 07-39, Class AI, IO,
5.874s, 2037	1,947,915	200,090
IFB Ser. 07-32, Class SD, IO,
5.864s, 2037	1,256,497	138,362
IFB Ser. 07-30, Class UI, IO,
5.854s, 2037	1,037,517	111,550
IFB Ser. 07-32, Class SC, IO,
5.854s, 2037	1,781,533	212,663
IFB Ser. 07-32, Class SG, IO,
5.854s, 2037	155,395	16,927
IFB Ser. 07-1, Class CI, IO,
5.854s, 2037	1,167,161	143,301
IFB Ser. 04-46, Class PJ, IO,
5.754s, 2034	893,675	102,388
IFB Ser. 07-75, Class ID, IO,
5.624s, 2037	1,213,290	140,799
Ser. 383, Class 18, IO,
5 1/2s, 2038	601,631	85,299
Ser. 383, Class 19, IO,
5 1/2s, 2038	547,564	77,726
Ser. 383, Class 6, IO,
5 1/2s, 2037	464,903	69,517
Ser. 383, Class 7, IO,
5 1/2s, 2037	459,354	64,097
Ser. 383, Class 20, IO,
5 1/2s, 2037	347,099	51,795
Ser. 367, Class 2, IO,
5 1/2s, 2036	1,176,058	209,115

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Fannie Mae
Ser. 364, Class 12, IO,
5 1/2s, 2035	$269,822	$41,772
Ser. 346, Class 2, IO,
5 1/2s, 2033	1,582,630	281,408
Ser. 338, Class 2, IO,
5 1/2s, 2033	2,372,493	427,419
Ser. 333, Class 2, IO,
5 1/2s, 2033	2,400,411	439,575
IFB Ser. 09-3, Class SE, IO,
5.254s, 2037	1,359,741	121,792
Ser. 359, Class 7, IO,
5s, 2036	78,849	12,378
Ser. 360, Class 2, IO,
5s, 2035	831,987	150,016
Ser. 356, Class 5, IO,
5s, 2035	79,264	13,175
Ser. 03-W17, Class 12, IO,
1.143s, 2033	1,825,969	51,237
Ser. 06-26, Class NB, 1s, 2036	203,438	189,312
Ser. 03-W10, Class 3A, IO,
0.601s, 2043	2,942,211	47,350
Ser. 03-W10, Class 1A, IO,
0.515s, 2043	2,494,655	34,398
Ser. 02-T18, IO, 0.513s, 2042	4,997,992	67,539
Ser. 06-56, Class XF,
zero %, 2036	75,040	62,589
Ser. 06-47, Class VO, PO,
zero %, 2036	92,552	79,221
Ser. 06-37, Class ON, PO,
zero %, 2036	191,151	174,178
Ser. 05-117, Class MO, PO,
zero %, 2036	41,919	40,711
Ser. 05-110, Class KO, PO,
zero %, 2035	61,827	55,014
Ser. 05-103, Class OA, PO,
zero %, 2035	207,000	184,416
Ser. 05-63, PO, zero %, 2035	12,101	11,636
Ser. 08-37, Class DO, PO,
zero %, 2033	239,253	188,945
Ser. 06-59, Class QC, PO,
zero %, 2033	141,978	136,449
Ser. 04-61, Class JO, PO,
zero %, 2032	184,241	164,319
Ser. 326, Class 1, PO,
zero %, 2032	170,393	149,802
Ser. 318, Class 1, PO,
zero %, 2032	64,190	56,897
Ser. 314, Class 1, PO,
zero %, 2031	307,458	275,818
Ser. 99-51, Class N, PO,
zero %, 2029	48,332	37,712
FRB Ser. 06-14, Class DF,
zero %, 2036	45,408	44,793
FRB Ser. 05-91, Class EF,
zero %, 2035	32,620	31,827
FRB Ser. 06-54, Class CF,
zero %, 2035	60,405	59,189
FRB Ser. 05-51, Class FV,
zero %, 2035	66,854	63,812
FRB Ser. 05-77, Class HF,
zero %, 2034	31,116	30,739
IFB Ser. 06-48, Class FG,
zero %, 2036	100,000	93,435

18

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Federal Home Loan Mortgage Corp.
Structured Pass-Through Securities
IFB Ser. T-56, Class 2ASI, IO,
7.854s, 2043	$619,416	$100,655
Ser. T-57, Class 1AX, IO,
0.44s, 2043	1,671,758	15,634
FFCA Secured Lending Corp. 144A
Ser. 00-1, Class X, IO, 1.232s, 2020	3,803,711	112,628
First Chicago Lennar Trust 144A
Ser. 97-CHL1, Class E, 7.744s, 2039	52,209	51,687
Freddie Mac
IFB Ser. 3182, Class SP,
27.626s, 2032	395,996	515,361
IFB Ser. 3211, Class SI, IO,
26.642s, 2036	285,974	158,767
IFB Ser. 3408, Class EK,
24.814s, 2037	307,210	396,184
IFB Ser. 3077, Class ST, IO,
23.674s, 2035	365,574	187,242
IFB Ser. 2979, Class AS,
23.381s, 2034	168,491	212,463
IFB Ser. 3105, Class SI, IO,
18.993s, 2036	223,367	96,240
IFB Ser. 3489, Class SD, IO,
7.557s, 2032	889,325	117,938
IFB Ser. 2684, Class SP, IO,
7.257s, 2033	1,215,000	213,810
IFB Ser. 3184, Class SP, IO,
7.107s, 2033	1,440,489	170,630
IFB Ser. 3110, Class SP, IO,
7.057s, 2035	1,598,434	253,879
IFB Ser. 3156, Class PS, IO,
7.007s, 2036	1,636,126	245,059
IFB Ser. 3149, Class LS, IO,
6.957s, 2036	3,169,961	531,032
IFB Ser. 3119, Class PI, IO,
6.957s, 2036	2,263,634	375,673
IFB Ser. 2882, Class NS, IO,
6.957s, 2034	1,408,309	167,786
IFB Ser. 2882, Class LS, IO,
6.957s, 2034	669,495	92,864
IFB Ser. 3200, Class SB, IO,
6.907s, 2036	1,025,566	126,237
IFB Ser. 3149, Class SE, IO,
6.907s, 2036	884,951	135,203
IFB Ser. 3203, Class SH, IO,
6.897s, 2036	852,898	129,850
IFB Ser. 3208, Class PS, IO,
6.857s, 2036	7,524,912	1,073,770
IFB Ser. 2594, Class SE, IO,
6.807s, 2030	265,721	21,081
IFB Ser. 2828, Class TI, IO,
6.807s, 2030	518,786	58,919
IFB Ser. 3397, Class GS, IO,
6.757s, 2037	689,922	89,323
IFB Ser. 3287, Class SD, IO,
6.507s, 2037	1,135,566	151,963
IFB Ser. 3281, Class BI, IO,
6.507s, 2037	595,294	75,094
IFB Ser. 3281, Class CI, IO,
6.507s, 2037	644,685	79,275
IFB Ser. 3249, Class SI, IO,
6.507s, 2036	556,437	74,704
IFB Ser. 3028, Class ES, IO,
6.507s, 2035	1,736,276	247,112
IFB Ser. 3042, Class SP, IO,
6.507s, 2035	881,032	120,154

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Freddie Mac
IFB Ser. 2981, Class AS, IO,
6.477s, 2035	$975,140	$113,594
IFB Ser. 3287, Class SE, IO,
6.457s, 2037	2,145,436	284,957
IFB Ser. 3136, Class NS, IO,
6.457s, 2036	655,258	84,758
IFB Ser. 3122, Class DS, IO,
6.457s, 2036	1,038,392	153,832
IFB Ser. 3123, Class LI, IO,
6.457s, 2036	634,579	92,902
IFB Ser. 3108, Class SV, IO,
6.457s, 2036	430,188	53,752
IFB Ser. 3117, Class SC, IO,
6.457s, 2036	271,984	34,757
IFB Ser. 3139, Class SE, IO,
6.457s, 2036	414,195	46,779
IFB Ser. 3107, Class DC, IO,
6.457s, 2035	698,086	102,306
IFB Ser. 3001, Class IH, IO,
6.457s, 2035	1,822,483	233,934
IFB Ser. 2950, Class SM, IO,
6.457s, 2016	431,131	45,903
IFB Ser. 3256, Class S, IO,
6.447s, 2036	1,569,585	184,453
IFB Ser. 3031, Class BI, IO,
6.447s, 2035	592,165	101,163
IFB Ser. 3244, Class SB, IO,
6.417s, 2036	828,175	96,027
IFB Ser. 3249, Class SM, IO,
6.407s, 2036	380,754	47,564
IFB Ser. 3236, Class IS, IO,
6.407s, 2036	1,635,295	225,878
IFB Ser. 3240, Class SM, IO,
6.407s, 2036	379,668	45,357
IFB Ser. 3147, Class SD, IO,
6.407s, 2036	2,798,945	321,769
IFB Ser. 3398, Class SI, IO,
6.407s, 2036	2,782,384	320,225
IFB Ser. 3067, Class SI, IO,
6.407s, 2035	1,206,199	171,165
IFB Ser. 3033, Class SG, IO,
6.407s, 2035	676,024	80,765
IFB Ser. 3114, Class TS, IO,
6.407s, 2030	3,203,590	386,994
IFB Ser. 3128, Class JI, IO,
6.387s, 2036	307,791	36,658
IFB Ser. 3240, Class S, IO,
6.377s, 2036	2,802,718	328,787
IFB Ser. 3229, Class BI, IO,
6.377s, 2036	99,315	11,109
IFB Ser. 3065, Class DI, IO,
6.377s, 2035	452,215	59,961
IFB Ser. 3210, Class S, IO,
6.357s, 2036	242,728	24,826
IFB Ser. 3145, Class GI, IO,
6.357s, 2036	259,526	33,858
IFB Ser. 3114, Class IP, IO,
6.357s, 2036	2,790,711	318,643
IFB Ser. 3510, Class IB, IO,
6.357s, 2036	1,116,528	166,687
IFB Ser. 3218, Class AS, IO,
6.337s, 2036	907,292	110,778
IFB Ser. 3221, Class SI, IO,
6.337s, 2036	1,270,882	157,106
IFB Ser. 3153, Class UI, IO,
6.327s, 2036	959,681	171,749

19

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Freddie Mac
IFB Ser. 3424, Class XI, IO,
6.327s, 2036	$1,663,127	$211,721
IFB Ser. 3485, Class SI, IO,
6.307s, 2036	607,143	81,740
IFB Ser. 3346, Class SC, IO,
6.307s, 2033	1,517,272	187,247
IFB Ser. 3346, Class SB, IO,
6.307s, 2033	1,903,491	234,034
IFB Ser. 3201, Class SG, IO,
6.257s, 2036	1,737,355	201,047
IFB Ser. 3203, Class SE, IO,
6.257s, 2036	1,488,716	164,473
IFB Ser. 3238, Class LI, IO,
6.247s, 2036	779,460	87,845
IFB Ser. 3171, Class PS, IO,
6.242s, 2036	1,170,446	137,519
IFB Ser. 3171, Class ST, IO,
6.242s, 2036	1,135,384	133,408
IFB Ser. 3449, Class SL, IO,
6.237s, 2037	104,812	11,423
IFB Ser. 3152, Class SY, IO,
6.237s, 2036	2,751,598	353,690
IFB Ser. 3510, Class DI, IO,
6.237s, 2035	1,746,767	211,691
IFB Ser. 3181, Class PS, IO,
6.227s, 2036	775,537	103,464
IFB Ser. 3361, Class SI, IO,
6.207s, 2037	115,334	13,025
IFB Ser. 3284, Class BI, IO,
6.207s, 2037	970,966	117,328
IFB Ser. 3199, Class S, IO,
6.207s, 2036	2,275,181	264,012
IFB Ser. 3200, Class PI, IO,
6.207s, 2036	324,616	39,324
IFB Ser. 3284, Class LI, IO,
6.197s, 2037	2,654,038	302,295
IFB Ser. 3281, Class AI, IO,
6.187s, 2037	493,348	58,141
IFB Ser. 3261, Class SA, IO,
6.187s, 2037	795,442	91,889
IFB Ser. 3311, Class IA, IO,
6.167s, 2037	1,569,156	182,305
IFB Ser. 3311, Class IB, IO,
6.167s, 2037	1,569,156	182,305
IFB Ser. 3311, Class IC, IO,
6.167s, 2037	1,569,156	182,305
IFB Ser. 3311, Class ID, IO,
6.167s, 2037	1,569,156	182,305
IFB Ser. 3311, Class IE, IO,
6.167s, 2037	2,368,410	275,162
IFB Ser. 3311, Class PI, IO,
6.167s, 2037	1,146,066	132,192
IFB Ser. 3265, Class SC, IO,
6.167s, 2037	555,763	61,484
IFB Ser. 3240, Class GS, IO,
6.137s, 2036	1,749,722	195,164
IFB Ser. 3331, Class SP, IO,
6.107s, 2037	372,904	43,484
IFB Ser. 3257, Class SI, IO,
6.077s, 2036	749,121	88,167
IFB Ser. 3225, Class EY, IO,
6.047s, 2036	7,372,778	736,983
IFB Ser. 3225, Class JY, IO,
6.047s, 2036	3,257,123	352,551
IFB Ser. 3502, Class DS, IO,
5.907s, 2039	629,252	46,904

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Freddie Mac
IFB Ser. 3339, Class TI, IO,
5.897s, 2037	$1,821,765	$193,508
IFB Ser. 3284, Class CI, IO,
5.877s, 2037	4,485,457	477,881
IFB Ser. 3309, Class SG, IO,
5.827s, 2037	1,879,065	195,611
IFB Ser. 3530, Class CS, IO,
5.807s, 2039	16,789,975	1,796,192
IFB Ser. 2965, Class SA, IO,
5.807s, 2032	1,025,651	105,160
IFB Ser. 3397, Class SQ, IO,
5.727s, 2037	2,509,073	250,631
IFB Ser. 3424, Class UI, IO,
5.517s, 2037	1,155,289	118,366
FRB Ser. 3069, Class FO,
0.643s, 2035	61,682	61,423
FRB Ser. 3006, Class FA,
0.643s, 2034	108,647	107,700
FRB Ser. 3232, Class FG,
0.543s, 2036	86,290	85,762
Ser. 3331, Class GO, PO,
zero %, 2037	78,917	72,600
Ser. 3292, Class DO, PO,
zero %, 2037	71,398	63,068
Ser. 3226, Class YI, IO,
zero %, 2036	1,109,785	3,494
Ser. 3142, PO,
zero %, 2036	27,059	26,401
Ser. 3124, Class DO, PO,
zero %, 2036	59,944	55,512
Ser. 3106, PO,
zero %, 2036	40,476	40,089
Ser. 3084, Class ON, PO,
zero %, 2035	46,420	43,886
Ser. 3078, PO,
zero %, 2035	443,714	401,943
Ser. 2989, Class WO, PO,
zero %, 2035	35,833	33,510
Ser. 2971, Class KO, PO,
zero %, 2035	97,972	89,744
Ser. 2975, Class QO, PO,
zero %, 2035	11,720	10,710
Ser. 2980, PO,
zero %, 2035	23,889	22,922
Ser. 2981, Class CO, PO,
zero %, 2035	63,455	57,474
Ser. 2951, Class JO, PO,
zero %, 2035	27,807	25,675
Ser. 2985, Class CO, PO,
zero %, 2035	42,628	36,370
Ser. 2858, Class MO, PO,
zero %, 2034	18,956	18,261
Ser. 201, PO,
zero %, 2029	189,021	164,098
FRB Ser. 3343, Class QF,
zero %, 2037	55,722	51,570
FRB Ser. 3345, Class TY,
zero %, 2037	149,147	116,881
FRB Ser. 3299, Class FD,
zero %, 2037	196,960	192,510
FRB Ser. 3304, Class UF,
zero %, 2037	107,000	103,937
FRB Ser. 3289, Class SF,
zero %, 2037	292,610	292,698
FRB Ser. 3326, Class XF,
zero %, 2037	47,034	46,023

20

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Freddie Mac
FRB Ser. 3273, Class HF,
zero %, 2037	$42,324	$40,916
FRB Ser. 3235, Class TP,
zero %, 2036	25,171	24,408
FRB Ser. 3283, Class KF,
zero %, 2036	20,740	19,710
FRB Ser. 3226, Class YW,
zero %, 2036	103,417	100,217
FRB Ser. 3332, Class UA,
zero %, 2036	28,171	27,212
FRB Ser. 3168, Class AT,
zero %, 2036	21,917	21,896
FRB Ser. 3251, Class TC,
zero %, 2036	341,160	335,258
FRB Ser. 3140, Class KF,
zero %, 2036	42,319	41,703
FRB Ser. 3130, Class JF,
zero %, 2036	109,203	108,300
FRB Ser. 3072, Class TJ,
zero %, 2035	56,292	47,829
FRB Ser. 3047, Class BD,
zero %, 2035	88,184	82,455
FRB Ser. 3052, Class TJ,
zero %, 2035	38,373	32,929
FRB Ser. 3326, Class WF,
zero %, 2035	116,722	111,638
FRB Ser. 3030, Class EF,
zero %, 2035	63,861	58,931
FRB Ser. 3033, Class YF,
zero %, 2035	122,631	119,449
FRB Ser. 3251, Class TP,
zero %, 2035	103,784	94,915
FRB Ser. 3263, Class AE,
zero %, 2035	157,163	156,857
FRB Ser. 3273, Class TJ,
zero %, 2035	76,804	73,412
FRB Ser. 3412, Class UF,
zero %, 2035	221,845	208,194
FRB Ser. 2980, Class TY,
zero %, 2035	18,963	18,469
FRB Ser. 2958, Class TP,
zero %, 2035	38,117	36,057
FRB Ser. 2963, Class TW,
zero %, 2035	82,418	78,588
FRB Ser. 2958, Class FB,
zero %, 2035	54,492	51,253
FRB Ser. 3137, Class TF,
zero %, 2034	18,513	18,334
FRB Ser. 2947, Class GF,
zero %, 2034	80,062	76,585
FRB Ser. 3006, Class TE,
zero %, 2034	24,894	24,702
GE Capital Commercial
Mortgage Corp. 144A
FRB Ser. 00-1, Class F, 7.789s, 2033	170,000	148,362
Ser. 00-1, Class G, 6.131s, 2033	596,000	166,178
GMAC Commercial Mortgage
Securities, Inc. 144A Ser. 99-C3,
Class G, 6.974s, 2036	451,995	348,036
Government National
Mortgage Association
IFB Ser. 07-41, Class SA,
38.723s, 2037	87,021	124,689
Ser. 07-17, Class CI, IO,
7 1/2s, 2037	478,151	85,901

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Government National
Mortgage Association
IFB Ser. 08-47, Class S, IO,
7.459s, 2038	$1,761,547	$225,476
IFB Ser. 08-42, Class AI, IO,
7.449s, 2038	6,829,858	1,070,922
IFB Ser. 05-68, Class PU, IO,
7.054s, 2032	801,812	111,309
IFB Ser. 04-59, Class SC, IO,
6.959s, 2034	585,848	83,910
IFB Ser. 04-26, Class IS, IO,
6.959s, 2034	505,189	42,006
IFB Ser. 05-68, Class SN, IO,
6.958s, 2034	255,041	28,218
IFB Ser. 04-27, Class S, IO,
6.954s, 2032	412,039	31,624
IFB Ser. 07-47, Class SA, IO,
6.859s, 2036	1,011,010	125,922
IFB Ser. 04-47, Class SY, IO,
6.819s, 2034	136,792	16,273
IFB Ser. 04-96, Class KS, IO,
6.754s, 2034	117,850	16,499
IFB Ser. 06-16, Class GS, IO,
6.744s, 2036	87,542	9,806
IFB Ser. 04-5, Class PS, IO,
6.704s, 2033	1,293,000	208,690
IFB Ser. 07-35, Class NY, IO,
6.659s, 2035	1,712,117	175,766
IFB Ser. 04-70, Class SP, IO,
6.654s, 2034	82,755	10,965
IFB Ser. 04-70, Class SH, IO,
6.604s, 2034	2,804,561	385,206
IFB Ser. 07-18, Class S, IO,
6.559s, 2037	8,178,328	1,234,110
IFB Ser. 07-22, Class S, IO,
6.554s, 2037	960,607	110,777
IFB Ser. 07-11, Class SA, IO,
6.554s, 2037	478,971	47,490
IFB Ser. 07-14, Class SB, IO,
6.554s, 2037	1,098,306	109,907
IFB Ser. 07-8, Class SH, IO,
6.554s, 2037	619,871	79,653
IFB Ser. 05-84, Class AS, IO,
6.554s, 2035	2,455,711	291,040
IFB Ser. 05-18, Class S, IO,
6.554s, 2035	150,624	19,804
IFB Ser. 05-77, Class CS, IO,
6.554s, 2032	124,745	11,208
IFB Ser. 04-106, Class SI, IO,
6.509s, 2034	109,644	16,875
IFB Ser. 07-51, Class SJ, IO,
6.504s, 2037	1,014,931	104,416
IFB Ser. 04-104, Class IS, IO,
6.504s, 2034	136,795	15,958
IFB Ser. 04-86, Class SW, IO,
6.504s, 2034	374,112	41,018
IFB Ser. 07-53, Class SY, IO,
6.489s, 2037	1,787,735	184,369
IFB Ser. 07-58, Class PS, IO,
6.454s, 2037	882,806	80,206
IFB Ser. 07-41, Class SM, IO,
6.454s, 2037	300,307	35,466
IFB Ser. 07-41, Class SN, IO,
6.454s, 2037	305,994	36,138
IFB Ser. 04-88, Class S, IO,
6.454s, 2032	1,265,810	79,566
IFB Ser. 07-37, Class SU, IO,
6.449s, 2037	184,924	24,072

21

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Government National
Mortgage Association
IFB Ser. 07-37, Class YS, IO,
6.429s, 2037	$175,345	$20,180
IFB Ser. 07-59, Class PS, IO,
6.424s, 2037	767,925	62,771
IFB Ser. 07-59, Class SP, IO,
6.424s, 2037	171,713	14,300
IFB Ser. 07-48, Class SB, IO,
6.409s, 2037	509,285	42,194
IFB Ser. 06-29, Class SN, IO,
6.404s, 2036	83,548	8,378
IFB Ser. 06-36, Class SN, IO,
6.364s, 2036	540,070	50,113
IFB Ser. 08-6, Class TI, IO,
6.359s, 2032	231,023	16,393
IFB Ser. 03-110, Class SP, IO,
6.359s, 2030	311,478	27,737
IFB Ser. 04-22, Class SE, IO,
6.354s, 2034	1,199,330	117,534
IFB Ser. 07-17, Class AI, IO,
6.309s, 2037	3,630,978	513,856
IFB Ser. 07-78, Class SA, IO,
6.289s, 2037	5,152,904	534,469
IFB Ser. 08-2, Class SM, IO,
6.259s, 2038	1,957,622	197,162
IFB Ser. 07-9, Class AI, IO,
6.259s, 2037	1,818,013	190,510
IFB Ser. 06-26, Class S, IO,
6.254s, 2036	4,113,528	421,505
IFB Ser. 08-9, Class SK, IO,
6.234s, 2038	2,278,891	225,656
IFB Ser. 07-37, Class SM, IO,
6.229s, 2037	1,092,490	118,083
IFB Ser. 09-35, Class SP, IO,
6.159s, 2037	2,661,681	307,983
IFB Ser. 05-71, Class SA, IO,
6.119s, 2035	2,978,436	349,433
IFB Ser. 05-65, Class SI, IO,
6.104s, 2035	1,112,089	116,158
IFB Ser. 06-7, Class SB, IO,
6.074s, 2036	240,402	22,325
IFB Ser. 06-16, Class SX, IO,
6.044s, 2036	1,388,816	135,548
IFB Ser. 07-17, Class IB, IO,
6.004s, 2037	693,579	92,260
IFB Ser. 06-14, Class S, IO,
6.004s, 2036	1,020,612	97,343
IFB Ser. 05-57, Class PS, IO,
6.004s, 2035	1,225,674	125,900
IFB Ser. 06-11, Class ST, IO,
5.994s, 2036	627,395	59,044
IFB Ser. 07-25, Class KS, IO,
5.959s, 2037	1,807,699	166,471
IFB Ser. 07-21, Class S, IO,
5.959s, 2037	60,988	5,607
IFB Ser. 07-19, Class SJ, IO,
5.954s, 2037	719,714	59,182
IFB Ser. 07-7, Class EI, IO,
5.954s, 2037	865,664	69,833
IFB Ser. 07-7, Class JI, IO,
5.954s, 2037	1,912,907	199,841
IFB Ser. 07-1, Class S, IO,
5.954s, 2037	970,964	78,454
IFB Ser. 07-3, Class SA, IO,
5.954s, 2037	921,105	74,775

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
Government National
Mortgage Association
IFB Ser. 07-17, Class SI, IO,
5.947s, 2037	$224,926	$24,240
IFB Ser. 07-31, Class AI, IO,
5.939s, 2037	1,022,091	135,571
IFB Ser. 05-17, Class S, IO,
5.934s, 2035	779,222	87,429
IFB Ser. 07-62, Class S, IO,
5.909s, 2037	859,532	80,796
IFB Ser. 07-43, Class SC, IO,
5.859s, 2037	1,122,493	110,985
IFB Ser. 06-16, Class SJ, IO,
5.854s, 2036	207,912	18,731
IFB Ser. 05-27, Class SP, IO,
5.854s, 2035	217,117	22,975
IFB Ser. 05-3, Class SN, IO,
5.854s, 2035	3,556,939	377,854
IFB Ser. 04-87, Class SD, IO,
5.854s, 2034	190,648	21,253
IFB Ser. 04-83, Class CS, IO,
5.834s, 2034	324,605	35,200
IFB Ser. 07-28, Class SB, IO,
5.804s, 2037	133,047	14,059
IFB Ser. 04-89, Class HS, IO,
5.754s, 2034	962,423	100,968
IFB Ser. 04-41, Class SG, IO,
5.754s, 2034	1,732,155	93,282
Ser. 06-36, Class OD, PO,
zero %, 2036	33,099	27,805
FRB Ser. 07-49, Class CF,
zero %, 2037	10,509	10,477
FRB Ser. 07-35, Class VF,
zero %, 2037	126,261	121,223
FRB Ser. 07-16, Class WF,
zero %, 2037	303,894	300,350
FRB Ser. 06-56, Class YF,
zero %, 2036	38,353	38,217
FRB Ser. 98-2, Class EA, PO,
zero %, 2028	48,081	39,345
Greenwich Capital Commercial
Funding Corp.
FRB Ser. 06-GG7, Class A2,
6.032s, 2038	1,145,000	1,160,931
Ser. 05-GG5, Class A2, 5.117s, 2037	1,727,000	1,722,780
GS Mortgage Securities Corp. II FRB
Ser. 07-GG10, Class A3, 5.999s, 2045	334,000	322,563
GS Mortgage Securities Corp. II 144A
Ser. 05-GG4, Class XC, IO,
0.296s, 2039	78,736,412	1,289,756
GSMPS Mortgage Loan Trust 144A
Ser. 06-RP2, Class 1AS1, IO,
5.69s, 2036	6,759,145	692,812
HASCO NIM Trust 144A Ser. 05-OP1A,
Class A, 6 1/4s, 2035 (In default) †	84,852	1,527
HSI Asset Loan Obligation FRB
Ser. 07-AR1, Class 2A1, 6.051s, 2037	3,090,193	1,823,214
IMPAC Secured Assets Corp. FRB
Ser. 07-2, Class 1A1A, 0.356s, 2037 F	1,739,211	878,301
IndyMac Indx Mortgage Loan Trust
FRB Ser. 06-AR25, Class 5A1,
5.957s, 2036	733,960	418,464
FRB Ser. 07-AR15, Class 1A1,
5.939s, 2037	917,460	513,778
FRB Ser. 07-AR9, Class 2A1,
5.89s, 2037	944,046	500,345

22

MORTGAGE-BACKED	Principal
SECURITIES (47.3%)* cont.	amount	Value
IndyMac Indx Mortgage Loan Trust
FRB Ser. 05-AR31, Class 3A1,
5.512s, 2036	$2,512,861	$1,457,459
FRB Ser. 07-AR11, Class 1A1,
5.126s, 2037	1,165,491	617,710
JPMorgan Alternative Loan Trust
FRB Ser. 06-A1, Class 5A1,
5.93s, 2036	656,625	407,107
FRB Ser. 06-A6, Class 1A1,
0.406s, 2036	1,067,604	509,989
JPMorgan Chase Commercial Mortgage
Securities Corp.
FRB Ser. 07-LD12, Class AM,
6.26s, 2051	299,000	205,549
FRB Ser. 07-LD12, Class A3,
6.188s, 2051	2,365,000	2,207,383
FRB Ser. 07-LD11, Class A3,
6.006s, 2049	417,000	396,600
Ser. 07-CB20, Class A3, 5.863s, 2051	834,000	797,895
Ser. 07-LD12, Class A2, 5.827s, 2051	2,626,000	2,633,253
Ser. 07-CB20, Class A4, 5.794s, 2051	1,386,000	1,201,608
Ser. 06-CB17, Class A4, 5.429s, 2043	1,168,000	1,096,129
Ser. 06-LDP9, Class A3, 5.336s, 2047	3,036,000	2,601,463
Ser. 08-C2, Class X, IO, 0.643s, 2051	30,015,879	401,573
JPMorgan Chase Commercial Mortgage
Securities Corp. 144A Ser. 07-CB20,
Class X1, IO, 0.112s, 2051	63,528,110	510,722
LB Commercial Conduit Mortgage Trust
144A Ser. 99-C1, Class G, 6.41s, 2031	253,101	141,214
LB-UBS Commercial Mortgage Trust
Ser. 07-C2, Class A3, 5.43s, 2040	3,587,000	2,910,729
Ser. 07-C1, Class A4, 5.424s, 2040	4,697,000	3,939,038
Ser. 07-C2, Class A2, 5.303s, 2040	2,057,000	2,050,775
Mach One Commercial
Mortgage Trust 144A
Ser. 04-1A, Class J, 5.45s, 2040	594,000	47,520
Ser. 04-1A, Class K, 5.45s, 2040	212,000	14,840
Ser. 04-1A, Class L, 5.45s, 2040	96,000	5,760
MASTR Alternative Loans Trust
Ser. 06-3, Class 1A1, 6 1/4s, 2036	513,007	346,921
Merrill Lynch Capital Funding Corp.
Ser. 06-4, Class XC, IO, 0.148s, 2049	56,369,213	633,246
Merrill Lynch Mortgage
Investors, Inc. Ser. 96-C2,
Class JS, IO, 2.261s, 2028	1,163,708	40,730
Merrill Lynch Mortgage Trust FRB
Ser. 07-C1, Class A3, 6.022s, 2050	222,000	192,472
Merrill Lynch/Countrywide
Commercial Mortgage Trust
FRB Ser. 07-8, Class A2, 6.119s, 2049	270,000	262,170
Ser. 07-7, Class A2, 5.693s, 2050	802,000	797,518
Ser. 06-3, Class A4, 5.414s, 2046	871,000	818,158
Ser. 06-4, Class A2, 5.112s, 2049	1,062,000	1,055,917
Mezz Cap Commercial Mortgage Trust
Ser. 07-C5, Class X, 4.85s, 2017	2,470,210	148,213
Mezz Cap Commercial Mortgage Trust
144A Ser. 04-C1, Class X, IO,
8.006s, 2037	934,122	93,412
Morgan Stanley Capital I
Ser. 98-CF1, Class E, 7.35s, 2032	1,252,000	763,037
FRB Ser. 08-T29, Class A3,
6.458s, 2043	712,000	693,018
FRB Ser. 07-IQ15, Class A2,
6.036s, 2049	1,632,000	1,641,049

MORTGAGE-BACKED		Principal
SECURITIES (47.3%)* cont.		amount	Value
Morgan Stanley Capital I
Ser. 07-HQ13, Class A2,
5.649s, 2044		$1,144,000	$1,132,539
Ser. 07-IQ13, Class A3,
5.331s, 2044		1,967,000	1,766,846
Morgan Stanley Capital I 144A FRB
Ser. 04-RR, Class F7, 6s, 2039		1,730,000	121,100
Morgan Stanley Mortgage Loan Trust
FRB Ser. 07-11AR, Class 2A1,
6.343s, 2037		2,765,699	1,341,364
FRB Ser. 07-14AR, Class 6A1,
6.233s, 2037		773,770	456,524
Ser. 06-6AR, Class 2A, 5.411s, 2036		2,456,175	1,498,267
Ser. 05-5AR, Class 2A1, 3.991s, 2035		1,002,030	581,177
Mortgage Capital Funding, Inc.
FRB Ser. 98-MC2, Class E, 7.183s, 2030		327,112	232,250
Ser. 97-MC2, Class X, IO, 1.988s, 2012		2,415	61
PNC Mortgage Acceptance Corp. 144A
Ser. 00-C1, Class J, 6 5/8s, 2010		123,000	76,260
Residential Asset Securitization
Trust Ser. 07-A5, Class 2A3, 6s, 2037		767,534	483,547
STRIPS 144A
Ser. 03-1A, Class M, 5s, 2018		162,000	89,100
Ser. 03-1A, Class N, 5s, 2018		193,000	98,430
Ser. 04-1A, Class M, 5s, 2018		174,000	85,260
Ser. 04-1A, Class N, 5s, 2018		167,000	68,470
Structured Adjustable Rate
Mortgage Loan Trust
FRB Ser. 07-10, Class 1A1, 6s, 2037		416,912	241,255
FRB Ser. 06-9, Class 1A1, 5.653s, 2036		866,971	459,146
FRB Ser. 06-12, Class 1A1,
0.406s, 2037		4,168,413	2,292,627
Structured Asset Securities Corp.
IFB Ser. 07-4, Class 1A3, IO,
6.004s, 2037		3,081,631	331,275
Ser. 07-4, Class 1A4, IO, 1s, 2037		3,362,995	100,150
Structured Asset Securities Corp. 144A
Ser. 06-RF1, IO, 5.778s, 2036		23,842,986	2,473,710
Ser. 07-RF1, Class 1A, IO,
5.371s, 2037		4,219,628	406,139
Titan Europe PLC 144A
FRB Ser. 05-CT2A, Class E, 7.095s,
2014 (United Kingdom)	GBP	226,682	240,539
FRB Ser. 05-CT1A, Class D, 7.095s,
2014 (United Kingdom)	GBP	444,023	230,964
Ursus EPC 144A FRB Ser. 1-A, Class D,
6.938s, 2012 (Ireland) F	GBP	239,170	76,572
Wachovia Bank
Commercial Mortgage Trust
FRB Ser. 07-C33, Class A3, 6.1s, 2051		$2,350,000	2,262,583
Ser. 07-C31, Class A3, 5.483s, 2047		396,000	368,040
Ser. 07-C31, Class A2, 5.421s, 2047		2,269,000	2,222,731
Ser. 07-C30, Class A3, 5.246s, 2043		5,030,000	4,817,017
Ser. 07-C34, IO, 0.52s, 2046		16,889,324	243,624
Wachovia Bank Commercial Mortgage
Trust 144A FRB Ser. 05-WL5A,
Class L, 3.543s, 2018		477,000	143,100
Wells Fargo Alternative Loan Trust
FRB Ser. 07-PA6, Class A1,
6.558s, 2037		5,971,355	3,391,555
Total mortgage-backed securities
(cost $161,144,518)			$181,195,990

23

CORPORATE BONDS		Principal
AND NOTES (22.6%)*		amount	Value
Basic materials (1.6%)
Beverage Packaging Holdings
Luxembourg II SA company
guaranty sr. notes Ser. REGS, 8s,
2016 (Luxembourg)	EUR	154,000	$227,773
Builders FirstSource, Inc. company
guaranty sr. notes FRN 4.69s, 2012		$270,000	233,550
Clondalkin Acquisition BV 144A
company guaranty sr. notes FRN
2.299s, 2013 (Netherlands)		215,000	175,225
Cognis GmbH sr. sec. notes FRN
Ser. REGS, 2.773s, 2013
(Netherlands)	EUR	156,000	199,130
Dow Chemical Co. (The) sr. unsec.
notes 7.6s, 2014		$131,000	144,919
Freeport-McMoRan Copper & Gold, Inc.
sr. unsec. notes 8 3/8s, 2017		1,046,000	1,111,375
Freeport-McMoRan Copper & Gold, Inc.
sr. unsec. notes 8 1/4s, 2015		44,000	46,750
Georgia-Pacific Corp. notes
8 1/8s, 2011		55,000	57,063
Georgia-Pacific Corp. sr. unsec.
unsub. notes 9 1/2s, 2011		43,000	45,795
Grief, Inc. 144A sr. notes 7 3/4s, 2019		60,000	61,800
Hanson PLC, Ltd. company
guaranty sr. unsec.
unsub. notes 7 7/8s, 2010
(United Kingdom)		100,000	102,875
Hexion U.S. Finance Corp./Hexion Nova
Scotia Finance, ULC company
guaranty 9 3/4s, 2014		64,000	55,040
International Paper Co. sr. unsec.
notes 9 3/8s, 2019		100,000	116,500
Lecta S.A. company guaranty sr. sec.
notes FRN Ser. REGS, 3.498s, 2014
(Luxembourg)	EUR	190,000	224,445
Mosaic Co. (The) 144A sr. unsec.
unsub. notes 7 5/8s, 2016		$224,000	238,944
Nalco Co. 144A sr. notes 8 1/4s, 2017		28,000	29,400
NewPage Holding Corp. sr. unsec.
unsub. notes FRN 8.579s, 2013 ‡‡		87,171	16,127
Novelis, Inc. company
guaranty 7 1/4s, 2015		113,000	97,745
Novelis, Inc. 144A sr. unsec.
notes 11 1/2s, 2015		75,000	75,750
PE Paper Escrow GmbH
sr. notes Ser. REGS, 11 3/4s,
2014 (Austria)	EUR	60,000	93,098
PE Paper Escrow GmbH 144A
sr. notes 12s, 2014 (Austria)		$100,000	108,000
Rhodia SA sr. unsec. FRN Ser. REGS,
3.746s, 2013 (France)	EUR	305,000	396,953
Rockwood Specialties Group, Inc.
company guaranty 7 5/8s, 2014	EUR	50,000	73,220
SGL Carbon SE company
guaranty sr. sub. notes FRN
Ser. EMTN, 2.123s, 2015 (Germany)	EUR	152,000	195,878
Smurfit Kappa Funding PLC sr. unsec.
sub. notes 7 3/4s, 2015 (Ireland)		$280,000	246,400
Smurfit-Stone Container Corp.
sr. unsec. unsub. notes 8 3/8s,
2012 (In default) †		240,000	171,300

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont..		amount	Value
Basic materials cont.
Steel Dynamics, Inc. company
guaranty sr. unsec.
unsub. notes 6 3/4s, 2015		$95,000	$90,963
Steel Dynamics, Inc. 144A
sr. notes 7 3/4s, 2016		269,000	270,345
Teck Resources, Ltd.
sr. notes 10 3/4s, 2019 (Canada)		168,000	195,300
Teck Resources, Ltd.
sr. notes 10 1/4s, 2016 (Canada)		291,000	328,830
Teck Resources, Ltd.
sr. notes 9 3/4s, 2014 (Canada)		358,000	393,800
Verso Paper Holdings, LLC/Verso
Paper, Inc. company
guaranty sr. sub. notes Ser. B,
9 1/8s, 2014		118,000	87,320
Verso Paper Holdings, LLC/Verso
Paper, Inc. 144A sr. sec.
notes 11 1/2s, 2014		194,000	198,850
Weyerhaeuser Co. sr. unsec.
notes 7 3/8s, 2019		105,000	104,385
			6,214,848
Capital goods (1.1%)
Alliant Techsystems, Inc.
sr. sub. notes 6 3/4s, 2016		104,000	100,360
Ardagh Glass Finance B.V. company
guaranty sr. notes Ser. REGS,
8 7/8s, 2013 (Netherlands)	EUR	121,000	181,622
Ball Corp. company
guaranty sr. unsec. notes
7 3/8s, 2019		$26,000	26,390
Ball Corp. company
guaranty sr. unsec. notes
7 1/8s, 2016		39,000	39,780
BBC Holding Corp. sr. notes
8 7/8s, 2014		350,000	333,375
Belden CDT, Inc. 144A company
guaranty sr. sub. notes 9 1/4s, 2019		86,000	89,440
Berry Plastics Holding Corp. company
guaranty sr. unsec.
sub. notes 10 1/4s, 2016		65,000	55,250
Bombardier, Inc. 144A sr. unsec.
notes FRN 3.998s, 2013 (Canada)	EUR	100,000	138,849
Crown Americas, LLC/Crown Americas
Capital Corp. sr. notes 7 5/8s, 2013		$516,000	521,160
General Cable Corp. company
guaranty sr. unsec. notes FRN
2.972s, 2015		87,000	76,343
Graham Packaging Co., Inc. company
guaranty sr. unsec. notes
8 1/2s, 2012		86,000	86,860
Impress Holdings BV company
guaranty sr. sec. bond FRB
Ser. REGS, 4.121s, 2013
(Netherlands)	EUR	136,000	187,209
L-3 Communications Corp. company
guaranty sr. unsec.
sub. notes 6 1/8s, 2014		$607,000	611,553
L-3 Communications Corp. company
guaranty sr. unsec.
sub. notes 5 7/8s, 2015		574,000	571,130
RBS Global, Inc. / Rexnord Corp.
company guaranty 9 1/2s, 2014		317,000	307,490

24

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont.		amount	Value
Capital goods cont.
Ryerson Tull, Inc. company
guaranty sr. sec. notes
12 1/4s, 2015		$409,000	$388,550
Spirit Aerosystems Inc. 144A company
guaranty sr. notes 7 1/2s, 2017		55,000	54,725
TD Funding Corp. company
guaranty 7 3/4s, 2014		310,000	307,675
TD Funding Corp. 144A
sr. sub. notes 7 3/4s, 2014 D		70,000	67,988
Titan International, Inc. company
guaranty 8s, 2012		116,000	112,230
			4,257,979
Communication services (2.8%)
American Tower Corp. sr. unsec.
notes 7s, 2017		280,000	287,000
Cablecom SCA sr. notes Ser. REGS, 8s,
2016 (Netherlands)	EUR	77,000	107,121
CCH I Holdings, LLC company
guaranty sr. unsec.
unsub. notes 12 1/8s,
2015 (In default) †		$8,000	80
CCH II, LLC sr. unsec. notes 10 1/4s,
2010 (In default) †		59,000	66,375
CCH II, LLC sr. unsec. notes Ser. B,
10 1/4s, 2010 (In default) †		560,000	627,200
Centennial Cellular
Operating Co., LLC company
guaranty 10 1/8s, 2013		175,000	180,250
Centennial Communications Corp.
sr. unsec. notes FRN 6.346s, 2013		45,000	43,875
Cincinnati Bell, Inc. company
guaranty 7s, 2015		578,000	560,660
Cricket Communications, Inc. company
guaranty 9 3/8s, 2014		435,000	441,525
Cricket Communications, Inc. company
guaranty sr. unsec.
unsub. notes 10s, 2015 ###		354,000	363,735
CSC Holdings, Inc. sr. notes
6 3/4s, 2012		633,000	651,990
Digicel Group, Ltd. 144A sr. unsec.
notes 8 7/8s, 2015 (Jamaica)		245,000	227,850
Frontier Communications Corp.
sr. unsec. notes 8 1/8s, 2018		343,000	347,288
Global Crossing UK Finance PLC
company guaranty 11 3/4s, 2014
(United Kingdom)	GBP	152,000	240,843
Global Crossing, Ltd. 144A sr. sec.
notes 12s, 2015 (United Kingdom)		$25,000	26,250
iesy Hessen GmbH & Co. company
guaranty FRN Ser. REGS, 3.778s,
2013 (Germany)	EUR	270,000	378,256
Inmarsat Finance PLC company
guaranty 10 3/8s, 2012
(United Kingdom)		$768,000	794,880
Intelsat Subsidiary Holding Co., Ltd.
company guaranty sr. unsec.
notes Ser. *, 8 7/8s, 2015 (Bermuda)		128,000	130,240
iPCS, Inc. company
guaranty sr. notes FRN 2.608s, 2013		140,000	118,300
Level 3 Financing, Inc. company
guaranty 9 1/4s, 2014		340,000	299,625

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont.		amount	Value
Communication services cont.
MetroPCS Wireless, Inc. company
guaranty sr. unsec. notes
9 1/4s, 2014		$90,000	$92,025
NII Capital Corp. 144A company
guaranty sr. notes 10s, 2016		70,000	72,800
Nordic Telephone Co. Holdings ApS
sec. notes Ser. REGS, 8 1/4s, 2016
(Denmark)	EUR	214,000	330,618
PAETEC Holding Corp. company
guaranty sr. unsec.
unsub. notes 9 1/2s, 2015		$150,000	136,125
Qwest Communications
International, Inc. company
guaranty 7 1/2s, 2014		353,000	348,588
Qwest Corp. sr. unsec. notes
7 1/2s, 2014		75,000	75,750
Qwest Corp. sr. unsec.
unsub. notes 8 7/8s, 2012		1,501,000	1,579,803
Rainbow National Services, LLC 144A
sr. notes 8 3/4s, 2012		383,000	390,660
SBA Telecommunications, Inc. 144A
company guaranty sr. notes
8 1/4s, 2019		105,000	108,150
SBA Telecommunications, Inc. 144A
company guaranty sr. notes 8s, 2016		180,000	184,050
Sprint Nextel Corp. sr. notes
8 3/8s, 2017		1,100,000	1,094,500
UPC Holdings BV sr. notes Ser. REGS,
8 5/8s, 2014 (Netherlands)	EUR	57,000	84,306
West Corp. company guaranty
9 1/2s, 2014		$189,000	185,220
Wind Acquisition Finance SA
sr. notes Ser. REGS, 11 3/4s, 2017
(Netherlands)	EUR	195,000	318,397
			10,894,335
Consumer cyclicals (4.7%)
Affinia Group, Inc. 144A
sr. notes 10 3/4s, 2016		25,000	26,875
Affinion Group, Inc. company
guaranty 11 1/2s, 2015		250,000	256,875
Affinion Group, Inc. company
guaranty 10 1/8s, 2013		285,000	292,838
Affinity Group, Inc.
sr. sub. notes 9s, 2012		482,000	336,195
Allison Transmission, Inc. 144A
company guaranty sr. unsec.
notes 11 1/4s, 2015 ‡‡		212,000	197,160
AMC Entertainment, Inc. company
guaranty 11s, 2016		251,000	267,315
AMC Entertainment, Inc.
sr. sub. notes 8s, 2014		205,000	197,825
American Casino & Entertainment
Properties LLC 144A sr. notes
11s, 2014		190,000	169,100
Bon-Ton Stores, Inc. (The) company
guaranty 10 1/4s, 2014		160,000	116,800
Boyd Gaming Corp.
sr. sub. notes 6 3/4s, 2014		134,000	119,930
Building Materials Corp. company
guaranty notes 7 3/4s, 2014		265,000	255,063

25

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont..		amount	Value
Consumer cyclicals cont.
CanWest Media, Inc. company
guaranty 8s, 2012
(Canada) (In default) †		$337,021	$264,561
Cenveo Corp. 144A company
guaranty sr. unsec. notes
10 1/2s, 2016		235,000	220,900
Cirsa Capital Luxembourg SA company
guaranty Ser. REGS, 7 7/8s, 2012
(Luxembourg)	EUR	77,000	108,812
Clear Channel Communications, Inc.
company guaranty unsec.
unsub. notes 10 3/4s, 2016		$200,000	109,000
Clear Channel Communications, Inc.
sr. unsec. notes 7.65s, 2010		185,000	155,400
Codere Finance Luxembourg SA sr. sec.
notes Ser. REGS, 8 1/4s, 2015
(Luxembourg)	EUR	227,000	299,177
D.R. Horton, Inc. sr. notes
7 7/8s, 2011		$765,000	803,250
DIRECTV Holdings, LLC company
guaranty sr. unsec. notes
7 5/8s, 2016		117,000	125,190
DIRECTV Holdings, LLC company
guaranty sr. unsec. notes
6 3/8s, 2015		938,000	949,725
Echostar DBS Corp. company
guaranty 6 5/8s, 2014		1,369,000	1,331,353
Europcar Groupe SA company
guaranty sr. sub. bond FRB
Ser. REGS, 4.373s, 2013 (France)	EUR	127,000	163,661
Fiat Finance Lux, Ltd. SA company
guaranty Ser. EMTN, 7 5/8s, 2014
(Italy)	EUR	228,000	344,621
Ford Motor Credit Co., LLC
sr. notes 9 7/8s, 2011		$661,000	675,873
Ford Motor Credit Co., LLC sr. unsec.
notes 9 3/4s, 2010		889,000	913,448
Goodyear Tire & Rubber Co. (The)
sr. unsec. notes 10 1/2s, 2016		416,000	451,360
Grupo Televisa SA sr. unsec.
notes 6s, 2018 (Mexico)		460,000	462,143
Hanesbrands, Inc. company
guaranty sr. unsec. notes FRN
Ser. B, 4.593s, 2014		60,000	52,650
Harrah’s Operating Co., Inc. 144A
sr. sec. notes 11 1/4s, 2017		185,000	186,850
Host Marriott LP sr. notes Ser. M,
7s, 2012 R		725,000	731,344
Interpublic Group of Companies, Inc.
(The) 144A sr. unsec. notes
10s, 2017		170,000	183,600
ISS Holdings A/S
sr. sub. notes Ser. REGS, 8 7/8s,
2016 (Denmark)	EUR	296,000	390,116
Jarden Corp. company guaranty
7 1/2s, 2017		$165,000	160,463
Lamar Media Corp. company
guaranty 7 1/4s, 2013		190,000	186,913
Lamar Media Corp. company
guaranty sr. notes 9 3/4s, 2014		100,000	108,250

CORPORATE BONDS	Principal
AND NOTES (22.6%)* cont..	amount	Value
Consumer cyclicals cont.
Lender Processing Services, Inc.
company guaranty sr. unsec.
unsub. notes 8 1/8s, 2016	$795,000	$826,800
Levi Strauss & Co. sr. unsec.
notes 8 7/8s, 2016	70,000	70,875
Levi Strauss & Co. sr. unsec.
unsub. notes 9 3/4s, 2015	651,000	677,040
Liberty Media, LLC sr. notes
5.7s, 2013	138,000	130,755
Masco Corp. sr. unsec.
unsub. notes 6 1/8s, 2016	265,000	251,191
Mashantucket Western Pequot Tribe
144A bonds 8 1/2s, 2015	340,000	123,250
Meritage Homes Corp. company
guaranty 6 1/4s, 2015	140,000	128,800
Meritage Homes Corp. sr. notes
7s, 2014	45,000	42,188
MGM Mirage, Inc. company
guaranty 8 1/2s, 2010	49,000	48,633
MGM Mirage, Inc. company
guaranty 6 3/4s, 2013	132,000	110,385
Nielsen Finance LLC/Nielsen
Finance Co. company guaranty
10s, 2014	251,000	252,255
Nielsen Finance LLC/Nielsen
Finance Co. company
guaranty sr. unsec. sub. disc.
notes stepped-coupon zero %
(12 1/2s, 8/1/11), 2016 ††	360,000	283,500
Owens Corning, Inc. company
guaranty unsec. unsub. notes
9s, 2019	493,000	532,440
Penn National Gaming, Inc. 144A
sr. unsec. sub. notes 8 3/4s, 2019	50,000	50,125
Pinnacle Entertainment, Inc. company
guaranty sr. unsec.
sub. notes 7 1/2s, 2015	320,000	283,200
Pinnacle Entertainment, Inc.
sr. sub. notes 8 1/4s, 2012	337,000	337,000
Pinnacle Entertainment, Inc. 144A
sr. notes 8 5/8s, 2017	55,000	55,275
Sealy Mattress Co.
sr. sub. notes 8 1/4s, 2014	75,000	69,375
Sirius XM Radio, Inc. 144A
sr. notes 9 3/4s, 2015	264,000	269,280
Standard Pacific Corp. company
guaranty sr. unsec. unsub. notes
7s, 2015	124,000	108,500
Station Casinos, Inc. sr. notes 6s,
2012 (In default) †	318,000	93,810
Tenneco Automotive, Inc. sec.
notes Ser. B, 10 1/4s, 2013	156,000	162,240
THL Buildco, Inc. (Nortek Holdings,
Inc.) sr. sec. notes 10s, 2013	115,000	117,300
THL Buildco, Inc. (Nortek
Holdings, Inc.)
sr. sub. notes 8 1/2s,
2014 (In default) †	255,000	175,950
Travelport LLC company
guaranty 9 7/8s, 2014	166,000	160,605

26

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont.		amount	Value
Consumer cyclicals cont.
Trump Entertainment Resorts, Inc.
sec. notes 8 1/2s,
2015 (In default) †		$220,000	$26,400
TUI AG sr. unsec. notes 7 3/8s, 2011
(Germany)	EUR	34,000	47,051
TVN Finance Corp. PLC notes 9 1/2s,
2013 (United Kingdom)	EUR	90,000	115,980
Univision Communications, Inc. 144A
company guaranty unsec. notes
9 3/4s, 2015 ‡‡		$352,587	271,492
Vertis, Inc. company
guaranty sr. notes 13 1/2s, 2014 ‡‡		231,104	18,488
Visant Corp. Company guaranty
sr. unsec. sub. notes company
guaranty 7 5/8s, 2012		600,000	600,750
Yonkers Racing Corp. 144A
sr. notes 11 3/8s, 2016		75,000	78,000
Young Broadcasting, Inc. company
guaranty sr. sub. notes 8 3/4s,
2014 (In default) †		83,000	156
Young Broadcasting, Inc. company
guaranty sr. unsec. sub. notes 10s,
2011 (In default) †		239,000	299
			18,134,024
Consumer staples (0.3%)
Archibald Candy Corp. company
guaranty 10s, 2009 (In default) F †		88,274	1,363
Avis Budget Car Rental, LLC company
guaranty sr. unsec.
unsub. notes 7 3/4s, 2016		285,000	247,950
Constellation Brands, Inc. company
guaranty sr. unsec. notes
7 1/4s, 2017		23,000	22,885
Constellation Brands, Inc. company
guaranty sr. unsec.
unsub. notes 7 1/4s, 2016		111,000	110,445
Great Atlantic & Pacific Tea Co. 144A
sr. notes 11 3/8s, 2015		100,000	101,250
Prestige Brands, Inc.
sr. sub. notes 9 1/4s, 2012		321,000	327,420
Rite Aid Corp. company
guaranty 9 1/2s, 2017		277,000	224,370
Rite Aid Corp. sec. notes 7 1/2s, 2017		315,000	277,200
			1,312,883
Energy (4.3%)
Arch Western Finance, LLC company
guaranty sr. notes 6 3/4s, 2013		1,347,000	1,325,111
Chaparral Energy, Inc. company
guaranty sr. unsec. notes
8 7/8s, 2017		320,000	257,600
Chesapeake Energy Corp.
sr. notes 7 1/2s, 2013		1,031,000	1,024,556
Complete Production Services, Inc.
company guaranty 8s, 2016		515,000	468,650
Comstock Resources, Inc.
sr. notes 6 7/8s, 2012		510,000	506,175
Connacher Oil and Gas, Ltd. 144A sec.
notes 10 1/4s, 2015 (Canada)		210,000	171,150
Connacher Oil and Gas, Ltd. 144A
sr. sec. notes 11 3/4s, 2014
(Canada)		15,000	15,975
Denbury Resources, Inc.
sr. sub. notes 7 1/2s, 2015		345,000	342,413

CORPORATE BONDS	Principal
AND NOTES (22.6%)* cont.	amount	Value
Energy cont.
Empresa Nacional del Petroleo 144A
sr. unsec. notes 6 1/4s, 2019
(Chile)	$600,000	$640,624
Ferrellgas LP/Finance
sr. notes 6 3/4s, 2014	520,000	494,650
Forest Oil Corp. sr. notes 8s, 2011	540,000	548,100
Gaz Capital SA 144A company
guaranty sr. unsec. bond 8.146s,
2018 (Russia)	176,000	185,685
Gaz Capital SA 144A sr. sec. bond
9 1/4s, 2019 (Russia)	935,000	1,042,908
Harvest Operations Corp.
sr. notes 7 7/8s, 2011	584,000	563,560
Helix Energy Solutions Group, Inc.
144A sr. unsec. notes 9 1/2s, 2016	455,000	455,000
Hornbeck Offshore Services, Inc.
sr. notes Ser. B, 6 1/8s, 2014	517,000	479,518
Key Energy Services, Inc. company
guaranty sr. unsec.
unsub. notes 8 3/8s, 2014	180,000	171,000
Newfield Exploration Co. sr. unsec.
sub. notes 6 5/8s, 2014	348,000	341,910
Oslo Seismic Services, Inc. 1st mtge.
8.28s, 2011	232,897	236,084
Peabody Energy Corp. company
guaranty 7 3/8s, 2016	455,000	459,550
Petrobras International Finance Co.
company guaranty sr. unsec.
notes 7 7/8s, 2019 (Brazil)	865,000	994,750
PetroHawk Energy Corp. company
guaranty 9 1/8s, 2013	169,000	173,648
Petroleos de Venezuela SA company
guaranty sr. unsec. notes 5 1/4s,
2017 (Venezuela)	2,065,000	1,264,813
Petroleos de Venezuela SA sr. unsec.
bonds zero %, 2011 (Venezuela)	585,000	441,675
Petroleum Co. of Trinidad & Tobago
Ltd. 144A sr. unsec. notes 9 3/4s,
2019 (Trinidad)	545,000	617,213
Petroleum Development Corp. company
guaranty sr. unsec. notes 12s, 2018	240,000	236,400
Plains Exploration & Production Co.
company guaranty 7 3/4s, 2015	70,000	69,475
Plains Exploration & Production Co.
company guaranty 7s, 2017	80,000	76,200
Plains Exploration & Production Co.
company guaranty sr. unsec.
notes 10s, 2016	270,000	290,925
Power Sector Assets & Liabilites
Management Corp. 144A govt.
guaranty sr. unsec. notes 7 1/4s,
2019 (Philippines)	425,000	452,625
Pride International, Inc. sr. unsec.
notes 7 3/8s, 2014	451,000	462,275
Range Resources Corp. company
guaranty sr. unsec.
sub. notes 7 1/2s, 2017	232,000	230,840
SandRidge Energy, Inc. 144A company
guaranty sr. unsec. unsub. notes
8s, 2018	365,000	351,313

27

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont.		amount	Value
Energy cont.
Targa Resources, Inc. company
guaranty sr. unsec. notes
8 1/2s, 2013		$40,000	$37,600
Williams Cos., Inc. (The) sr. unsec.
notes 8 1/8s, 2012		150,000	163,046
Williams Cos., Inc. (The) sr. unsec.
notes 7 5/8s, 2019		665,000	717,967
			16,310,984
Financials (4.1%)
Banco Do Brasil 144A sr. unsec.
5.113s, 2017 (Brazil)	BRL	536,000	297,983
Bosphorus Financial Services, Ltd.
144A sr. notes FRN 2.24s, 2012		$903,125	795,765
GMAC, LLC 144A company
guaranty sr. unsec. unsub. notes
7s, 2012		25,000	23,250
GMAC, LLC 144A company
guaranty sr. unsec.
unsub. notes 6 7/8s, 2012		403,000	370,760
GMAC, LLC 144A company
guaranty sr. unsec.
unsub. notes 6 7/8s, 2011		53,000	50,085
GMAC, LLC 144A company
guaranty sr. unsec.
unsub. notes 6 5/8s, 2012		512,000	471,040
GMAC, LLC 144A company
guaranty sr. unsec. unsub. notes FRN
2.561s, 2014		39,000	30,225
HUB International Holdings, Inc. 144A
sr. sub. notes 10 1/4s, 2015		95,000	88,469
HUB International Holdings, Inc. 144A
sr. unsec. unsub. notes 9s, 2014		65,000	62,725
JPMorgan Chase & Co. 144A sr. unsec.
notes FRN zero%, 2017		1,000,000	679,300
JPMorgan Chase & Co. 144A sr. unsec.
unsub. notes FRN 10.82s, 2011	RUB	22,000,000	693,768
JPMorgan Chase & Co. 144A unsec.
unsub. notes 0.163s, 2012	INR	19,000,000	425,920
Leucadia National Corp. sr. unsec.
notes 8 1/8s, 2015		$100,000	102,000
Leucadia National Corp. sr. unsec.
notes 7 1/8s, 2017		252,000	241,920
Merrill Lynch & Co., Inc. notes FRN
Ser. MTN, 0.704s, 2011		365,000	355,231
RSHB Capital SA for OJSC Russian
Agricultural Bank sub. bonds FRB
6.97s, 2016 (Russia)		3,455,000	3,292,373
RSHB Capital SA for OJSC Russian
Agricultural Bank 144A notes 9s,
2014 (Russia)		1,425,000	1,561,515
Shinhan Bank 144A sr. unsec. bond 6s,
2012 (South Korea)		137,000	143,891
UBS Luxembourg SA for Sberbank
sub. bonds stepped-coupon 6.23s
(7.429s, 2/11/10), 2015 (Russia) ††		1,290,000	1,289,162
USI Holdings Corp. 144A company
guaranty sr. unsec. notes FRN
4.315s, 2014		60,000	49,875
VTB Capital SA 144A notes 7 1/2s,
2011 (Russia)		1,925,000	1,985,156

CORPORATE BONDS	Principal
AND NOTES (22.6%)* cont..	amount	Value
Financials cont.
VTB Capital SA 144A notes 6 7/8s,
2018 (Russia)	$750,000	$738,750
VTB Capital SA 144A sec.
notes 6.609s, 2012 (Russia)	2,025,000	2,013,255
		15,762,418
Health care (1.5%)
Community Health Systems, Inc.
company guaranty 8 7/8s, 2015	197,000	201,925
DaVita, Inc. company guaranty
6 5/8s, 2013	153,000	151,470
Elan Finance PLC/Elan Finance Corp.
company guaranty 7 3/4s, 2011
(Ireland)	205,000	209,100
HCA, Inc. company
guaranty sr. notes 9 5/8s, 2016 ‡‡	299,000	310,960
HCA, Inc. sr. sec. notes 9 1/4s, 2016	346,000	357,678
HCA, Inc. sr. sec. notes 9 1/8s, 2014	282,000	291,165
Omnicare, Inc. company
guaranty 6 3/4s, 2013	195,000	188,663
Omnicare, Inc. sr. sub. notes
6 1/8s, 2013	545,000	524,563
Select Medical Corp. company
guaranty 7 5/8s, 2015	547,000	512,129
Stewart Enterprises, Inc.
sr. notes 6 1/4s, 2013	724,000	704,090
Sun Healthcare Group, Inc. company
guaranty sr. unsec.
unsub. notes 9 1/8s, 2015	70,000	69,650
Surgical Care Affiliates, Inc. 144A
sr. sub. notes 10s, 2017	310,000	248,000
Surgical Care Affiliates, Inc. 144A
sr. unsec. notes 8 7/8s, 2015 ‡‡	115,293	91,658
Tenet Healthcare Corp. 144A company
guaranty sr. sec. notes 10s, 2018	119,000	131,198
Tenet Healthcare Corp. 144A company
guaranty sr. sec. notes 9s, 2015	471,000	492,195
Vanguard Health Holding Co. II, LLC
sr. sub. notes 9s, 2014	491,000	500,820
Ventas Realty LP/Capital Corp.
company guaranty 9s, 2012 R	305,000	320,250
Ventas Realty LP/Capital Corp.
company guaranty sr. unsec.
notes 7 1/8s, 2015 R	50,000	49,625
Ventas Realty LP/Capital Corp.
sr. notes 6 5/8s, 2014 R	173,000	167,378
		5,522,517
Technology (0.9%)
Advanced Micro Devices, Inc.
sr. notes 7 3/4s, 2012	334,000	300,600
Avago Technologies Finance company
guaranty sr. unsec. notes 10 1/8s,
2013 (Singapore)	80,000	84,200
Ceridian Corp. sr. unsec.
notes 11 1/4s, 2015	305,000	273,356
Compucom Systems, Inc. 144A
sr. sub. notes 12 1/2s, 2015	155,000	144,538
First Data Corp. company guaranty
sr. unsec. notes 9 7/8s, 2015	103,000	95,146
First Data Corp. company guaranty
sr. unsec. notes zero %, 2015 ‡‡	162,000	137,700
First Data Corp. company guaranty
sr. unsec. sub. notes 11 1/4s, 2016	161,000	138,460

28

CORPORATE BONDS		Principal
AND NOTES (22.6%)* cont.		amount	Value
Technology cont.
Freescale Semiconductor, Inc. company
guaranty sr. unsec. notes 8 7/8s, 2014		$609,000	$465,885
Freescale Semiconductor, Inc. company
guaranty sr. unsec.
sub. notes 10 1/8s, 2016		14,000	9,310
Iron Mountain, Inc. company
guaranty sr. unsec. sub. notes
8s, 2020		470,000	474,700
New ASAT Finance, Ltd. company
guaranty 9 1/4s, 2011
(Cayman Islands) (In default) †		13,000	16
Sanmina Corp. sr. unsec.
sub. notes 8 1/8s, 2016		136,000	127,160
SunGard Data Systems, Inc. company
guaranty 10 1/4s, 2015		310,000	316,200
SunGard Data Systems, Inc. company
guaranty 9 1/8s, 2013		620,000	626,200
Unisys Corp. 144A company guaranty
sr. sub. notes 14 1/4s, 2015		320,000	331,200
			3,524,671
Transportation (0.2%)
British Airways PLC sr. unsec.
8 3/4s, 2016 (United Kingdom)	GBP	157,000	226,987
Offshore Logistics, Inc. company
guaranty 6 1/8s, 2013		$295,000	282,094
RailAmerica, Inc. 144A company
guaranty sr. notes 9 1/4s, 2017		170,000	178,075
			687,156
Utilities and power (1.1%)
AES Corp. (The) sr. unsec.
unsub. notes 8s, 2017		130,000	130,813
AES Corp. (The) 144A sec.
notes 8 3/4s, 2013		380,000	387,125
Allegheny Energy Supply 144A
sr. unsec. bond 8 1/4s, 2012		146,000	160,831
CMS Energy Corp. sr. unsec.
unsub. notes 6.3s, 2012		45,000	45,839
Dynegy-Roseton Danskamme sec.
bonds 7.27s, 2010		137,786	137,442
Edison Mission Energy sr. unsec.
notes 7 3/4s, 2016		151,000	132,125
Edison Mission Energy sr. unsec.
notes 7 1/2s, 2013		69,000	64,688
Edison Mission Energy sr. unsec.
notes 7.2s, 2019		147,000	119,070
Edison Mission Energy sr. unsec.
notes 7s, 2017		23,000	19,205
El Paso Corp. sr. unsec. notes
12s, 2013		516,000	589,530
Ipalco Enterprises, Inc. 144A
sr. sec. notes 7 1/4s, 2016		115,000	115,288
Majapahit Holding BV 144A company
guaranty sr. unsec. notes 8s, 2019
(Indonesia)		400,000	427,000
Mirant Americas Generation, Inc.
sr. unsec. notes 8.3s, 2011		100,000	101,500
NRG Energy, Inc. sr. notes
7 3/8s, 2016		235,000	227,363
Orion Power Holdings, Inc. sr. unsec.
notes 12s, 2010		655,000	677,925
Sierra Pacific Resources sr. unsec.
notes 8 5/8s, 2014		257,000	264,389

CORPORATE BONDS	Principal
AND NOTES (22.6%)* cont.	amount	Value
Utilities and power cont.
Teco Finance, Inc. company
guaranty sr. unsec.
unsub. notes Ser. *, 7.2s, 2011	$185,000	$193,380
Teco Finance, Inc. company
guaranty sr. unsec.
unsub. notes Ser. *, 7s, 2012	280,000	299,126
Utilicorp United, Inc. sr. unsec.
notes 7.95s, 2011	18,000	18,915
		4,111,554
Total corporate bonds and notes
(cost $87,052,854)		$86,733,369
	Principal
ASSET-BACKED SECURITIES (11.9%)*	amount	Value
Accredited Mortgage Loan Trust
FRB Ser. 05-1, Class M2, 0.936s, 2035	$74,142	$29,658
FRB Ser. 05-4, Class A2C, 0.456s, 2035	25,148	22,171
Ace Securities Corp.
FRB Ser. 06-OP2, Class A2C,
0.396s, 2036	107,000	28,712
FRB Ser. 06-HE3, Class A2C,
0.396s, 2036	115,000	33,133
Ameriquest Mortgage Securities, Inc.
FRB Ser. 03-8, Class M2, 1.996s, 2033	199,684	42,219
Arcap REIT, Inc. 144A
Ser. 03-1A, Class E, 7.11s, 2038 F	383,000	68,940
Ser. 04-1A, Class E, 6.42s, 2039 F	361,000	64,980
Argent Securities, Inc.
FRB Ser. 03-W3, Class M3, 2.516s, 2033	24,453	3,767
FRB Ser. 06-W4, Class A2C,
0.406s, 2036	204,000	62,568
Asset Backed Funding Certificates
FRB Ser. 04-OPT2, Class M2, 1.246s,
2033	154,064	101,798
FRB Ser. 05-WMC1, Class M1, 0.686s,
2035	31,000	18,600
Asset Backed Securities Corp. Home
Equity Loan Trust
FRB Ser. 06-HE2, Class A3,
0.436s, 2036	30,265	15,696
FRB Ser. 06-HE4, Class A5,
0.406s, 2036	112,818	70,619
Aviation Capital Group Trust 144A FRB
Ser. 03-2A, Class G1, 0.946s, 2033	228,044	109,461
Bear Stearns Asset
Backed Securities, Inc.
FRB Ser. 04-FR3, Class M6,
5.121s, 2034	54,804	7,510
FRB Ser. 05-HE1, Class M3,
1.176s, 2035	223,000	43,953
Bombardier Capital Mortgage
Securitization Corp.
Ser. 00-A, Class A4, 8.29s, 2030	474,538	270,487
Ser. 00-A, Class A2, 7.575s, 2030	1,261,826	694,619
Ser. 99-B, Class A4, 7.3s, 2016	621,037	321,239
Ser. 99-B, Class A3, 7.18s, 2015	1,045,145	549,221
FRB Ser. 00-A, Class A1, 0.403s, 2030	136,499	22,706
Capital Auto Receivables Asset Trust
144A Ser. 06-1, Class D, 7.16s, 2013	500,000	500,170

29

		Principal
ASSET-BACKED SECURITIES(11.9%)* cont.		amount	Value
Citigroup Mortgage Loan Trust, Inc.
FRB Ser. 05-OPT1, Class M1,
0.666s, 2035		$47,073	$26,412
FRB Ser. 07-OPX1, Class A1A,
0.316s, 2037		847,703	508,622
Conseco Finance Securitizations Corp.
Ser. 00-2, Class A5, 8.85s, 2030		1,273,086	987,048
Ser. 00-4, Class A6, 8.31s, 2032		3,046,489	2,320,443
Ser. 00-5, Class A7, 8.2s, 2032		476,000	384,650
Ser. 00-1, Class A5, 8.06s, 2031		865,954	619,155
Ser. 00-4, Class A5, 7.97s, 2032		172,788	128,380
Ser. 00-5, Class A6, 7.96s, 2032		559,995	445,501
Ser. 02-1, Class M1F, 7.954s, 2033		44,000	31,771
Ser. 01-3, Class M2, 7.44s, 2033		31,182	1,343
Ser. 01-4, Class A4, 7.36s, 2033		172,708	158,649
Ser. 00-6, Class A5, 7.27s, 2031		418,391	377,481
Ser. 01-1, Class A5, 6.99s, 2032		3,823,937	3,396,444
Ser. 01-3, Class A4, 6.91s, 2033		2,502,766	2,229,955
Ser. 02-1, Class A, 6.681s, 2033		656,581	624,269
FRB Ser. 02-1, Class M1A, 2.311s, 2033		2,249,000	1,004,777
FRB Ser. 01-4, Class M1, 2.011s, 2033		295,000	110,367
Countrywide Asset Backed Certificates
FRB Ser. 05-BC3, Class M1,
0.766s, 2035		47,000	32,910
FRB Ser. 05-14, Class 3A2,
0.486s, 2036		20,560	17,028
Countrywide Asset-Backed Certificates
FRB Ser. 06-4, Class 2A2, 0.426s, 2036		1,051,164	732,241
Credit-Based Asset Servicing and
Securitization FRB Ser. 07-CB1,
Class AF1A, 0.316s, 2037		882,257	433,364
Crest, Ltd. 144A Ser. 03-2A,
Class E2, 8s, 2038		431,000	142,230
Equifirst Mortgage Loan Trust FRB
Ser. 05-1, Class M5, 0.916s, 2035		73,605	7,043
First Franklin Mortgage Loan Asset
Backed Certificates FRB Ser. 06-FF7,
Class 2A3, 0.396s, 2036		173,000	62,867
Fremont Home Loan Trust
FRB Ser. 05-E, Class 2A4, 0.576s, 2036		244,000	98,994
FRB Ser. 06-2, Class 2A3, 0.416s, 2036		353,000	144,061
Gears Auto Owner Trust 144A
Ser. 05-AA, Class E1, 8.22s, 2012		687,000	687,824
Granite Mortgages PLC
FRB Ser. 03-2, Class 3C,
7.589s, 2043 F	GBP	688,016	195,934
FRB Ser. 03-2, Class 2C1,
5.2s, 2043 F	EUR	1,430,000	407,236
Green Tree Financial Corp.
Ser. 94-6, Class B2, 9s, 2020		$835,002	730,627
Ser. 94-4, Class B2, 8.6s, 2019		351,873	185,725
Ser. 93-1, Class B, 8.45s, 2018		287,050	249,463
Ser. 99-5, Class A5, 7.86s, 2030		3,645,658	3,023,450
Ser. 96-8, Class M1, 7.85s, 2027		387,000	313,795
Ser. 95-8, Class B1, 7.3s, 2026		362,579	256,597
Ser. 95-4, Class B1, 7.3s, 2025		371,800	299,629
Ser. 96-10, Class M1, 7.24s, 2028		41,000	35,260
Ser. 97-6, Class M1, 7.21s, 2029		1,087,000	745,666
Ser. 98-2, Class A6, 6.81s, 2027		343,815	322,153
Ser. 99-3, Class A7, 6.74s, 2031		608,421	498,906
FRN Ser. 98-4, Class A6, 6.53s, 2030		161,939	149,561
Ser. 99-2, Class A7, 6.44s, 2030		40,832	33,403
Ser. 99-1, Class A6, 6.37s, 2025		18,000	17,091
Ser. 98-4, Class A5, 6.18s, 2030		408,619	373,573
Ser. 99-1, Class A5, 6.11s, 2023		57,324	57,262

	Principal
ASSET-BACKED SECURITIES(11.9%)* cont.	amount	Value
Greenpoint Manufactured Housing
Ser. 00-3, Class IA, 8.45s, 2031	$1,522,615	$1,096,283
Ser. 99-5, Class M1A, 8.3s, 2026	157,000	124,532
Ser. 99-5, Class A4, 7.59s, 2028	30,211	29,176
GS Auto Loan Trust 144A Ser. 04-1,
Class D, 5s, 2011 F	26,388	26,124
GSAA Home Equity Trust FRB
Ser. 06-19, Class A1, 0.336s, 2036	2,608,478	1,343,366
GSAMP Trust
FRB Ser. 06-HE5, Class A2C,
0.396s, 2036	526,000	144,481
FRB Ser. 07-HE2, Class A2A,
0.366s, 2047	1,134,953	858,592
Guggenheim Structured Real
Estate Funding, Ltd. 144A
FRB Ser. 05-2A, Class E, 2.246s, 2030	381,221	19,061
FRB Ser. 05-1A, Class E, 2.046s, 2030	83,828	4,191
Home Equity Asset Trust FRB
Ser. 06-1, Class 2A4, 0.576s, 2036	122,000	46,817
JPMorgan Mortgage Acquisition Corp.
FRB Ser. 06-FRE1, Class A4,
0.536s, 2035	103,000	52,181
Lehman ABS Manufactured Housing
Contract Ser. 01-B, Class A4,
5.27s, 2018	1,014,992	849,553
Lehman XS Trust Ser. 07-6, Class 3A6,
6 1/2s, 2037	1,038,099	627,389
LNR CDO, Ltd. 144A FRB Ser. 02-1A,
Class FFL, 2.996s, 2037	1,260,000	189,000
Local Insight Media Finance, LLC
Ser. 07-1W, Class A1, 5.53s, 2012 F	1,671,674	802,403
Long Beach Mortgage Loan Trust
FRB Ser. 05-2, Class M4, 0.866s, 2035	255,000	86,903
FRB Ser. 06-4, Class 2A4, 0.506s, 2036	117,000	40,378
FRB Ser. 06-1, Class 2A3, 0.436s, 2036	122,002	56,360
Madison Avenue Manufactured Housing
Contract FRB Ser. 02-A, Class B1,
3.496s, 2032	1,046,356	841,658
MASTR Asset Backed Securities Trust
FRB Ser. 06-FRE2, Class A4,
0.396s, 2036	61,000	26,607
Mid-State Trust Ser. 11, Class B,
8.221s, 2038	106,336	87,200
Morgan Stanley ABS Capital I
FRB Ser. 04-HE8, Class B3,
3.446s, 2034	68,909	5,856
FRB Ser. 05-HE2, Class M5,
0.926s, 2035	147,818	91,603
FRB Ser. 05-HE1, Class M3,
0.766s, 2034	160,000	114,508
FRB Ser. 06-NC4, Class M2,
0.546s, 2036	223,000	903
Navistar Financial Corp. Owner Trust
Ser. 05-A, Class C, 4.84s, 2014	32,033	30,416
New Century Home Equity Loan Trust
FRB Ser. 03-4, Class M3, 3.321s, 2033	12,217	5,342
Novastar Home Equity Loan
FRB Ser. 06-1, Class A2C, 0.406s, 2036	146,000	79,731
FRB Ser. 06-2, Class A2C, 0.396s, 2036	146,000	74,816
Oakwood Mortgage Investors, Inc.
Ser. 96-C, Class B1, 7.96s, 2027	968,213	484,107
Ser. 99-D, Class A1, 7.84s, 2029	804,575	695,448
Ser. 00-A, Class A2, 7.765s, 2017	117,293	67,975
Ser. 95-B, Class B1, 7.55s, 2021	281,592	156,985

30

	Principal
ASSET-BACKED SECURITIES(11.9%)* cont.	amount	Value
Oakwood Mortgage Investors, Inc.
Ser. 00-D, Class A4, 7.4s, 2030	$1,022,000	$693,990
Ser. 02-B, Class A4, 7.09s, 2032	335,885	262,339
Ser. 99-B, Class A4, 6.99s, 2026	824,686	674,346
Ser. 00-D, Class A3, 6.99s, 2022	145,085	142,199
Ser. 02-A, Class A4, 6.97s, 2032	48,964	33,540
Ser. 01-D, Class A4, 6.93s, 2031	636,555	457,956
Ser. 01-E, Class A4, 6.81s, 2031	841,572	563,853
Ser. 99-B, Class A3, 6.45s, 2017	196,466	165,081
Ser. 01-C, Class A2, 5.92s, 2017	861,479	363,565
Ser. 02-C, Class A1, 5.41s, 2032	1,018,281	748,437
Ser. 01-D, Class A2, 5.26s, 2019	127,239	83,778
Ser. 01-E, Class A2, 5.05s, 2019	893,308	544,918
Ser. 02-A, Class A2, 5.01s, 2020	215,184	112,102
Oakwood Mortgage Investors, Inc. 144A
Ser. 01-B, Class A4, 7.21s, 2030	152,867	133,389
FRB Ser. 01-B, Class A2, 0.618s, 2018	41,271	29,425
Park Place Securities, Inc. FRB
Ser. 05-WCH1, Class M4, 1.076s, 2036	104,000	17,041
People’s Financial Realty Mortgage
Securities Trust FRB Ser. 06-1,
Class 1A2, 0.376s, 2036	217,285	72,736
Residential Asset Mortgage
Products, Inc.
FRB Ser. 06-NC3, Class A2,
0.436s, 2036	116,334	66,200
FRB Ser. 07-RZ1, Class A2,
0.406s, 2037	176,000	94,822
Residential Asset Securities Corp.
FRB Ser. 05-EMX1, Class M2,
0.976s, 2035	326,293	241,964
Ser. 01-KS3, Class AII, 0.706s, 2031	1,297,477	846,105
Securitized Asset Backed
Receivables, LLC
FRB Ser. 05-HE1, Class M2,
0.896s, 2035	160,000	798
Securitized Asset Backed
Receivables, LLC
FRB Ser. 07-NC2, Class A2B,
0.386s, 2037	165,000	55,961
FRB Ser. 07-BR5, Class A2A,
0.376s, 2037	389,077	258,736
FRB Ser. 07-BR4, Class A2A,
0.336s, 2037	346,014	214,529
FRB Ser. 07-BR3, Class A2A,
0.316s, 2037	2,518,194	1,687,190
SG Mortgage Securities Trust FRB
Ser. 06-OPT2, Class A3D, PO,
0.456s, 2036	246,000	86,265
Soundview Home Equity
Loan Trust
FRB Ser. 06-OPT3, Class 2A3,
0.416s, 2036	117,000	75,020
FRB Ser. 06-3, Class A3, 0.406s, 2036	529,000	282,512
South Coast Funding 144A FRB Ser. 3A,
Class A2, 1.664s, 2038	140,000	1,400
Structured Asset Investment Loan
Trust FRB Ser. 06-BNC2, Class A6,
0.506s, 2036	117,000	10,193
TIAA Real Estate CDO, Ltd.
Ser. 03-1A, Class E, 8s, 2038	467,000	28,020
TIAA Real Estate CDO, Ltd. 144A
Ser. 02-1A, Class IV, 6.84s, 2037	390,000	29,250
WAMU Asset-Backed Certificates FRB
Ser. 07-HE2, Class 2A1, 0.356s, 2037	769,827	477,293

		Principal
ASSET-BACKED SECURITIES(11.9%)* cont.		amount	Value
Whinstone Capital Management, Ltd.
144A FRB Ser. 1A, Class B3, 1.404s,
2044 (United Kingdom)		$256,909	$30,829
Total asset-backed securities (cost $61,122,172)			$45,437,114
		Principal
U.S. TREASURY OBLIGATIONS (0.1%)*		amount	Value
U.S. Treasury Bonds 8.125%,
August 15, 2019 i		$153,000	$216,904
Total U.S. treasury obligations (cost $216,904)			$216,904
U.S. GOVERNMENT AND AGENCY		Principal
MORTGAGE OBLIGATIONS (8.0%)*		amount	Value
U.S. Government Guaranteed Mortgage Obligations (2.4%)
Government National Mortgage Association
Pass-Through Certificates
6 1/2s, TBA, October 1, 2039		$2,000,000	$2,127,500
4 1/2s, TBA, October 1, 2039		7,000,000	7,103,907
			9,231,407
U.S. Government Agency Mortgage Obligations (5.6%)
Federal National Mortgage Association
Pass-Through Certificates
6 1/2s, TBA, October 1, 2039		2,000,000	2,136,875
6s, TBA, October 1, 2024		3,000,000	3,195,000
5 1/2s, TBA, October 1, 2024		1,000,000	1,057,188
5s, March 1, 2039		937,200	969,562
4 1/2s, May 1, 2039		910,052	923,134
4 1/2s, TBA, November 1, 2039		2,000,000	2,018,828
4 1/2s, TBA, October 1, 2039		11,000,000	11,140,938
			21,441,525
Total U.S. government and agency
mortgage obligations (cost $30,456,750)			$30,672,932
FOREIGN GOVERNMENT		Principal
BONDS AND NOTES (6.6%)*		amount	Value
Argentina (Republic of)
bonds Ser. VII, zero %, 2013		$47,000	$37,318
Argentina (Republic of) bonds FRB
zero %, 2013		1,431,000	574,547
Argentina (Republic of) sr. unsec.
unsub. bonds zero %, 2015		2,411,000	1,793,784
Argentina (Republic of) sr. unsec.
unsub. bonds Ser. $V, 10 1/2s, 2012	ARS	2,039,000	397,605
Argentina (Republic of) sr. unsec.
unsub. bonds FRB 0.943s, 2012		$13,711,000	4,125,640
Banco Nacional de
Desenvolvimento Economico e Social
144A notes 6 1/2s, 2019		535,000	568,438
Brazil (Federal Republic of)
notes zero %, 2017		BRL 1,500	763,788
Brazil (Federal Republic of)
sr. notes 5 7/8s, 2019		$795,000	854,625
Brazil (Federal Republic of)
sr. unsec. bonds 6s, 2017		790,000	850,767
Ecuador (Republic of) regs
notes Ser. REGS, 9 3/8s, 2015		125,000	109,100
Indonesia (Republic of) 144A
sr. unsec. unsub. bonds 6 3/4s, 2014		1,590,000	1,702,079
Industrial Bank Of Korea 144A
sr. notes 7 1/8s, 2014		325,000	356,659

31

FOREIGN GOVERNMENT		Principal
BONDS AND NOTES (6.6%)* cont.		amount	Value
Peru (Republic of) sr. unsec.
unsub. notes 7 1/8s, 2019		$942,000	$1,076,235
Republic of Indonesia 144A sr. unsec.
unsub. bonds 6 7/8s, 2018		550,000	591,250
Russia (Federation of) 144A unsec.
unsub. bonds 5s, 2030		2,293,600	2,471,515
South Africa (Republic of) sr. unsec.
unsub. notes 6 7/8s, 2019		430,000	479,450
Spain (Government of)
bonds Ser. REGS, 5.4s, 2011	EUR	1,000,000	1,572,517
Turkey (Republic of) bonds 16s, 2012	TRY	175,000	133,846
Turkey (Republic of) sr. unsec.
notes 7 1/2s, 2019		$810,000	886,270
Turkey (Republic of) sr. unsec.
notes 7 1/2s, 2017		1,505,000	1,643,641
Venezuela (Republic of) bonds
8 1/2s, 2014		450,000	403,128
Venezuela (Republic of) unsec. note
FRN Ser. REGS, 1.505s, 2011		770,000	685,716
Venezuela (Republic of) unsec.
notes 10 3/4s, 2013		1,985,000	1,966,996
Venezuela (Republic of) 144A unsec.
bonds 13 5/8s, 2018		1,285,000	1,316,560
Total foreign government bonds
and notes (cost $23,724,299)			$25,361,474
		Principal
SENIOR LOANS (6.2%)* c		amount	Value
Basic materials (0.3%)
Georgia-Pacific Corp. bank term loan
FRN Ser. C, 3.597s, 2014		$84,123	$83,475
Georgia-Pacific, LLC bank term loan
FRN Ser. B2, 2.369s, 2012		152,767	146,752
Novelis, Inc. bank term loan FRN
Ser. B, 2.422s, 2014		500,678	457,584
Novelis, Inc. bank term loan FRN
Ser. B, 2.27s, 2014		227,574	207,987
Rockwood Specialties Group, Inc. bank
term loan FRN Ser. H, 6s, 2014		70,813	71,521
			967,319
Capital goods (0.5%)
Graham Packaging Co., LP bank term
loan FRN Ser. B, 2.563s, 2011		96,290	93,852
Hawker Beechcraft
Acquisition Co., LLC bank term loan
FRN 2.598s, 2014		38,254	29,073
Hawker Beechcraft
Acquisition Co., LLC bank term loan
FRN Ser. B, 2.372s, 2014		737,925	560,823
Manitowoc Co., Inc. (The) bank term
loan FRN Ser. A, 4.807s, 2013		222,000	205,905
Mueller Water Products, Inc. bank
term loan FRN Ser. B, 6s, 2014		135,825	131,750
Polypore, Inc. bank term loan FRN
Ser. B, 2.52s, 2014		309,734	289,214
Sensata Technologies BV bank term
loan FRN 2.246s, 2013 (Netherlands)		276,114	235,560
Sequa Corp. bank term loan FRN
3.844s, 2014		404,956	349,275
Wesco Aircraft Hardware Corp. bank
term loan FRN 2.52s, 2013		114,000	105,878
			2,001,330

	Principal
SENIOR LOANS (6.2%)* c cont.	amount	Value
Communication services (1.1%)
Cebridge Connections, Inc. bank term
loan FRN 4.788s, 2014	$160,000	$149,600
Charter Communications Operating, LLC
bank term loan FRN 9 1/4s, 2014	227,125	228,488
Charter Communications, Inc. bank
term loan FRN 6 3/4s, 2014	200,000	174,125
Charter Communications, Inc. bank
term loan FRN 6 1/4s, 2014	929,731	885,569
Fairpoint Communications, Inc. bank
term loan FRN Ser. B, 5 1/2s, 2015	232,789	174,243
Insight Midwest, LP bank term loan
FRN Ser. B, 2.26s, 2014	130,326	123,763
Intelsat Corp. bank term loan FRN
Ser. B2, 2.753s, 2011	209,416	198,684
Intelsat Corp. bank term loan FRN
Ser. B2-A, 2.753s, 2013	209,481	198,745
Intelsat Corp. bank term loan FRN
Ser. B2-C, 2.753s, 2013	209,416	198,684
Intelsat, Ltd. bank term loan FRN
3.253s, 2014 (Bermuda)	460,000	412,083
Level 3 Communications, Inc. bank
term loan FRN 2.683s, 2014	108,000	95,256
Level 3 Financing, Inc. bank term
loan FRN Ser. B, 11 1/2s, 2014	95,000	100,463
Mediacom Communications Corp. bank
term loan FRN Ser. C, 1 3/4s, 2015	544,439	501,792
Mediacom Communications Corp. bank
term loan FRN Ser. D2, 2s, 2015	116,700	108,239
MetroPCS Wireless, Inc. bank term
loan FRN 2.683s, 2013	219,205	208,825
PAETEC Holding Corp. bank term loan
FRN Ser. B1, 2.761s, 2013	84,643	80,199
TW Telecom, Inc. bank term loan FRN
Ser. B, 2.02s, 2013	230,457	222,295
West Corp. bank term loan FRN 2.
623s, 2013	112,675	106,156
		4,167,209
Consumer cyclicals (2.5%)
Affinion Group, Inc. bank term loan
FRN Ser. B, 2.761s, 2013	430,536	411,807
Allison Transmission, Inc. bank term
loan FRN Ser. B, 3s, 2014	433,384	377,285
Building Materials Holdings Corp. bank term
loan FRN 3.005s, 2014	153,615	139,704
CCM Merger, Inc. bank term loan FRN
Ser. B, 8 1/2s, 2012	245,683	229,100
Cenveo, Inc. bank term loan FRN
Ser. C, 4.792s, 2014	230,118	222,539
Cenveo, Inc. bank term loan FRN
Ser. DD, 4.792s, 2014	7,668	7,415
Clear Channel Communications, Inc.
bank term loan FRN Ser. B, 3.84s, 2016	210,000	158,375
Cooper-Standard Automotive, Inc. bank
term loan FRN Ser. B, 3 1/8s, 2012	220,103	194,791
Cooper-Standard Automotive, Inc. bank
term loan FRN Ser. C, 3 1/8s, 2012	549,806	486,578
Dex Media West, LLC/Dex Media
Finance Co. bank term loan FRN
Ser. B, 7s, 2014	235,412	200,453
GateHouse Media, Inc. bank term loan
FRN 2 1/2s, 2014	220,000	68,567

32

	Principal
SENIOR LOANS (6.2%)* c cont.	amount	Value
Consumer cyclicals cont.
GateHouse Media, Inc. bank term loan
FRN Ser. B, 2 1/4s, 2014	$513,424	$160,017
GateHouse Media, Inc. bank term loan
FRN Ser. DD, 2 1/4s, 2014	191,576	59,708
Golden Nugget, Inc. bank term loan
FRN Ser. B, 2 1/4s, 2014	101,564	66,016
Golden Nugget, Inc. bank term loan
FRN Ser. DD, 2.269s, 2014	57,964	37,676
Goodman Global Holdings, Inc. bank
term loan FRN Ser. B, 6 1/2s, 2011	898,895	896,198
Harrah’s Operating Co., Inc. bank
term loan FRN Ser. B2, 3.504s, 2015	169,439	136,653
Jarden Corp. bank term loan FRN
Ser. B1, 2.348s, 2012	100,547	97,581
Jarden Corp. bank term loan FRN
Ser. B2, 2.348s, 2012	45,709	44,300
Jarden Corp. bank term loan FRN
Ser. B4, 3.848s, 2015	166,517	163,990
Michaels Stores, Inc. bank term loan
FRN Ser. B, 2.538s, 2013	123,076	109,794
National Bedding Co. bank term loan
FRN 2.255s, 2011	89,621	80,659
Navistar Financial Corp. bank term
loan FRN 2.057s, 2012	218,667	211,013
Navistar International Corp. bank
term loan FRN 3.496s, 2012	601,333	580,287
QVC, Inc. bank term loan FRN
5.746s, 2014	205,000	204,570
R.H. Donnelley, Inc. bank term loan
FRN 6 3/4s, 2011	487,042	413,986
R.H. Donnelley, Inc. bank term loan
FRN Ser. D1, 6 3/4s, 2011	271,841	231,291
Realogy Corp. bank term loan FRN
0.166s, 2013	165,224	140,205
Realogy Corp. bank term loan FRN
Ser. B, 3.254s, 2013	613,690	520,760
Six Flags Theme Parks bank term loan
FRN 2.595s, 2015	375,114	365,361
Thomas Learning bank term loan FRN
Ser. B, 2.76s, 2014	99,746	89,721
Tribune Co. bank term loan FRN
Ser. B, 5 1/4s, 2014 (In default) †	948,000	471,334
TRW Automotive, Inc. bank term loan
FRN Ser. B, 6 1/4s, 2014	350,874	349,832
United Components, Inc. bank term
loan FRN Ser. D, 2.72s, 2012	388,444	358,340
Universal City Development Partners,
Ltd. bank term loan FRN Ser. B,
6s, 2011	969,872	951,687
Univision Communications, Inc. bank
term loan FRN Ser. B, 2.511s, 2014	175,000	147,693
Yankee Candle Co., Inc. bank term
loan FRN 2 1/4s, 2014	117,445	110,046
		9,495,332
Consumer staples (0.4%)
Claire’s Stores, Inc. bank term loan
FRN 3.114s, 2014	79,796	59,348
Dole Food Co., Inc. bank term loan
FRN Ser. B, 7.973s, 2013	35,072	35,450
Dole Food Co., Inc. bank term loan
FRN Ser. C, 7.939s, 2013	132,298	133,723

	Principal
SENIOR LOANS (6.2%)* c cont.	amount	Value
Consumer staples cont.
Dole Food Co., Inc. bank term loan
FRN Ser. C, 0.505s, 2013	$20,311	$20,530
Pinnacle Foods Holding Corp. bank
term loan FRN Ser. B, 3.009s, 2014	499,557	469,375
Revlon Consumer Products bank term
loan FRN Ser. B, 4.337s, 2012	105,000	100,887
Rite-Aid Corp. bank term loan FRN
Ser. B, 2.01s, 2014	98,500	85,982
Spectrum Brands, Inc. bank term loan
FRN 1 1/2s, 2013	30,543	29,054
Spectrum Brands, Inc. bank term loan
FRN Ser. B1, 8.003s, 2013	529,397	503,589
		1,437,938
Energy (0.2%)
EPCO Holding, Inc. bank term loan FRN
Ser. A, 1.246s, 2012	220,000	198,000
Hercules Offshore, Inc. bank term
loan FRN Ser. B, 7.559s, 2013	237,479	231,542
MEG Energy Corp. bank term loan FRN
2.6s, 2013 (Canada)	96,500	91,675
MEG Energy Corp. bank term loan FRN
Ser. DD, 2.6s, 2013 (Canada)	98,375	93,456
Petroleum Geo-Services ASA bank term
loan FRN 2.35s, 2015 (Norway)	143,000	135,731
Targa Resources, Inc. bank term loan
FRN 2.263s, 2012	35,095	34,306
Targa Resources, Inc. bank term loan
FRN Ser. C, 0.473s, 2012	25,645	25,068
		809,778
Financials (—%)
Hub International, Ltd. bank term
loan FRN Ser. B, 2.761s, 2014	139,757	126,305
Hub International, Ltd. bank term
loan FRN Ser. DD, 2.761s, 2014	31,414	28,390
		154,695
Health care (0.7%)
Community Health Systems, Inc. bank
term loan FRN Ser. B, 2.612s, 2014	528,100	495,622
Community Health Systems, Inc. bank
term loan FRN Ser. DD, 2.511s, 2014	27,184	25,513
Health Management Associates, Inc.
bank term loan FRN 2.348s, 2014	1,289,546	1,208,466
IASIS Healthcare Corp. bank term loan
FRN Ser. DD, 2.261s, 2014	120,362	113,140
IASIS Healthcare, LLC/IASIS
Capital Corp. bank term loan FRN
7.62s, 2014	32,503	30,553
IASIS Healthcare, LLC/IASIS
Capital Corp. bank term loan FRN
5.738s, 2014	395,329	337,018
IASIS Healthcare, LLC/IASIS
Capital Corp. bank term loan FRN
Ser. B, 2.261s, 2014	347,799	326,931
Select Medical Corp. bank term loan
FRN Ser. B, 2.413s, 2012	14,961	14,369
Sun Healthcare Group, Inc. bank term
loan FRN 0.498s, 2014	35,012	32,561
Sun Healthcare Group, Inc. bank term
loan FRN Ser. B, 2.683s, 2014	$123,526	$114,879
		2,699,052

33

	Principal
SENIOR LOANS (6.2%)* c cont.	amount	Value
Technology (0.1%)
Compucom Systems, Inc. bank term loan
FRN 3.77s, 2014	$124,099	$116,653
First Data Corp. bank term loan FRN
Ser. B1, 2.998s, 2014	386,633	332,827
Freescale Semiconductor, Inc. bank
term loan FRN 12 1/2s, 2014	110,384	110,660
		560,140
Utilities and power (0.4%)
Dynegy Holdings, Inc. bank term loan
FRN 4.02s, 2013	194,000	186,301
Energy Future Holdings Corp. bank
term loan FRN Ser. B2, 3.754s, 2014	268,686	212,061

	Principal
SENIOR LOANS (6.2%)* c cont.	amount	Value
Utilities and power cont.
Energy Future Holdings Corp. bank
term loan FRN Ser. B3, 3.754s, 2014	$195,442	$153,471
NRG Energy, Inc. bank term loan FRN
2.252s, 2014	319,046	302,329
NRG Energy, Inc. bank term loan FRN
0.498s, 2014	171,715	162,718
Reliant Energy, Inc. bank term loan
FRN 0.241s, 2014	450,000	421,313
		1,438,193
Total senior loans (cost $26,405,334)		$23,730,986

PURCHASED OPTIONS OUTSTANDING (3.3%)*	Expiration date/	Contract
	strike price	amount	Value
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the right to
receive a fixed rate of 5.355% versus the three month USD-LIBOR-BBA
maturing November 12, 2019.	Nov-09/5.355	$18,927,000	$2,998,605
Option on an interest rate swap with Goldman Sachs International for the right to
receive a fixed rate of 5.355% versus the three month USD-LIBOR-BBA
maturing November 12, 2019.	Nov-09/5.355	18,927,000	2,998,605
Option on an interest rate swap with Goldman Sachs International for the right to
pay a fixed rate of 5.355% versus the three month USD-LIBOR-BBA
maturing November 12, 2019.	Nov-09/5.355	18,927,000	189
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the right to
pay a fixed rate of 5.355% versus the three month USD-LIBOR-BBA maturing
November 12, 2019.	Nov-09/5.355	18,927,000	189
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the right to
receive a fixed rate of 4.235% versus the three month USD-LIBOR-BBA maturing
June 11, 2020.	Jun-10/4.235	19,098,000	1,224,393
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the right to
receive a fixed rate of 4.23% versus the three month USD-LIBOR-BBA maturing
June 9, 2020.	Jun-10/4.23	19,098,000	1,217,732
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the right to
receive a fixed rate of 5.03% versus the three month USD-LIBOR-BBA maturing
February 16, 2020.	Feb-10/5.03	32,120,000	3,931,488
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the
right to pay a fixed rate of 5.03% versus the three month USD-LIBOR-BBA
maturing February 16, 2020.	Feb-10/5.03	32,120,000	107,281
Total purchased options outstandings (cost $7,011,266)			$12,478,482

CONVERTIBLE BONDS AND NOTES (0.3%)*		Principal amount	Value
General Cable Corp. cv. company guaranty sr. unsec. notes 1s, 2012		$525,000	$448,875
General Growth Properties, Inc. 144A cv. sr. notes 3.98s, 2027 (In default) † R		395,000	266,625
Steel Dynamics, Inc. cv. sr. notes 5 1/8s, 2014		195,000	229,856
TUI AG cv. sr. unsec. notes 2 3/4s, 2012 (Germany)	EUR	50,000	56,746
Total convertible bonds and notes (cost $1,082,770)			$1,002,102
PREFERRED STOCKS (—%)*		Shares	Value
Preferred Blocker, Inc. 144A 7.00% cum. pfd.		228	$132,589
Total preferred stocks (cost $76,202)			$132,589

34

COMMON STOCKS (—%)*			Shares	Value
AboveNet, Inc. †			614	$29,939
Bohai Bay Litigation, LLC † F			991	3,091
Vertis Holdings, Inc. † F			11,336	11
Total common stocks (cost $0)				$33,041
WARRANTS (—%)* †	Expiration date	Strike price	Warrants	Value
AboveNet, Inc.	9/08/10	$24.00	118	$8,585
New ASAT (Finance), Ltd. (Cayman Islands) F	2/01/11	0.01	3,380	—
Smurfit Kappa Group PLC 144A (Ireland)	10/01/13	EUR .001	508	20,796
Vertis Holdings, Inc. F	10/18/15	$0.01	752	—
Total warrants (cost $19,322)				$29,381
CONVERTIBLE PREFERRED STOCKS (—%)*			Shares	Value
Emmis Communications Corp. Ser. A, $3.125 cum. cv. pfd. (acquired various dates
from 12/2/04 to 12/22/04, cost $109,821) ‡			2,393	$22,255
Lehman Brothers Holdings, Inc. Ser. P, 7.25% cv. pfd. (In default) †			667	4,202
Total convertible preferred stocks (cost $738,520)				$26,457
SHORT-TERM INVESTMENTS (9.5%)*		Principal amount/shares		Value
Putnam Money Market Liquidity Fund e			17,319,935	$17,319,935
SSgA Prime Money Market Fund i			$5,750,000	5,750,000
U.S. Treasury Bills for an effective yield of zero%, maturity date December 17, 2009 i			605,000	604,879
U.S. Treasury Cash Management Bills for an effective yield of 0.40%, maturity date
June 10, 2010 ##			1,310,000	1,306,497
U.S. Treasury Cash Management Bills with yields ranging from 0.30% to 0.47%, maturity date
April 1, 2010 # ##			11,388,000	11,365,319
Total short-term investments (cost $36,347,343)				$36,346,630
TOTAL INVESTMENTS
Total investments (cost $435,398,254)				$443,397,451

Key to holding’s currency abbreviations

ARS Argentine Peso
AUD Australian Dollar
BRL Brazilian Real
CAD Canadian Dollar
EUR Euro
GBP British Pound
HUF Hungarian Forint
INR Indian Rupee
JPY Japanese Yen
MXN Mexican Peso
PLN Polish Zloty
RUB Russian Ruble
SEK Swedish Krona
TRY Turkish Lira
ZAR South African Rand

Key to holding’s abbreviations

EMTN Euro Medium Term Notes
FRB Floating Rate Bonds
FRN Floating Rate Notes
IFB Inverse Floating Rate Bonds
IO Interest Only
MTN Medium Term Notes
PO Principal Only
TBA To Be Announced Commitments

35

* Percentages indicated are based on net assets of $383,388,420.

† Non-income-producing security.

†† The interest rate and date shown parenthetically represent the new interest rate to be paid and the date the fund will begin accruing interest at this rate.

‡ Restricted, excluding 144A securities, as to public resale. The total market value of restricted securities held at September 30, 2009 was $22,255, or less than 0.1% of net assets.

‡‡ Income may be received in cash or additional securities at the discretion of the issuer.

# This security, in part or in entirety, was pledged and segregated with the broker to cover margin requirements for futures contracts at September 30, 2009.

## These securities, in part or in entirety, were pledged and segregated with the custodian for collateral on certain derivative contracts at September 30, 2009.

▲ Forward commitments, in part or in entirety (Note 1).

^c Senior loans are exempt from registration under the Securities Act of 1933, as amended, but contain certain restrictions on resale and cannot be sold publicly. These loans pay interest at rates which adjust periodically. The interest rates shown for senior loans are the current interest rates at September 30, 2009. Senior loans are also subject to mandatory and/or optional prepayment which cannot be predicted. As a result, the remaining maturity may be substantially less than the stated maturity shown (Notes 1 and 7).

^e See Note 6 to the financial statements regarding investments in Putnam Money Market Liquidity Fund.

^F Is valued at fair value following procedures approved by the Trustees. Securities may be classified as a Level 2 or Level 3 for Accounting Standards Codification ASC 820 Fair Value Measurements and Disclosures (“ASC 820”) disclosures based on the securities valuation inputs.

ⁱ Securities purchased with cash or received, that were pledged to the fund for collateral on certain derivative contracts (Note 1).

^R Real Estate Investment Trust.

At September 30, 2009 liquid assets totaling $177,094,749 have been segregated to cover open forward commitments, swap contracts and futures contracts.

Debt obligations are considered secured unless otherwise indicated.

144A after the name of an issuer represents securities exempt from registration under Rule 144A under the Securities Act of 1933, as amended. These securities may be resold in transactions exempt from registration, normally to qualified institutional buyers.

See Note 1 to the financial statements regarding TBA’s.

The rates shown on FRB and FRN are the current interest rates at September 30, 2009.

The dates shown on debt obligations are the original maturity dates.

IFB are securities that pay interest rates that vary inversely to changes in the market interest rates. As interest rates rise, inverse floaters produce less current income. The interest rates shown are the current interest rates at September 30, 2009.

DIVERSIFICATION BY COUNTRY
Distribution of investments by country of risk at September 30, 2009 (as a percentage of Portfolio Value):
United States	89.2%	Brazil	1.0%	United Kingdom	0.5%
Russia	3.3	Indonesia	0.6	Other	1.8
Argentina	1.6	Turkey	0.6	Total	100.0%
Venezuela	1.4

FORWARD CURRENCY CONTRACTS TO BUY at 9/30/09		Aggregate	Delivery	Unrealized appreciation/
(aggregate face value $65,574,323)	Value	face value	date	(depreciation)
Australian Dollar	$12,243,839	$11,558,857	10/21/09	$684,982
Canadian Dollar	3,771,036	3,755,473	10/21/09	15,563
Danish Krone	264,816	263,383	10/21/09	1,433
Euro	6,884,027	6,883,316	10/21/09	711
Hungarian Forint	1,185,564	1,168,990	10/21/09	16,574
Japanese Yen	19,165,159	18,590,461	10/21/09	574,698
Malaysian Ringgit	162,861	161,192	10/21/09	1,669
Mexican Peso	47,798	48,500	10/21/09	(702)
New Zealand Dollar	6,138	5,907	10/21/09	231
Norwegian Krone	9,773,428	9,331,268	10/21/09	442,160
Polish Zloty	4,728,486	4,800,430	10/21/09	(71,944)
South African Rand	1,319,023	1,309,837	10/21/09	9,186
Swedish Krona	4,785,812	4,623,858	10/21/09	161,954
Swiss Franc	3,104,182	3,072,851	10/21/09	31,331
Total				$1,867,846

36

FORWARD CURRENCY CONTRACTS TO SELL at 9/30/09		Aggregate	Delivery	Unrealized appreciation/
(aggregate face value $39,958,446)	Value	face value	date	(depreciation)
Australian Dollar	$1,919,981	$1,898,324	10/21/09	$(21,657)
Brazilian Real	1,395,319	1,349,826	10/21/09	(45,493)
British Pound	5,779,776	5,879,259	10/21/09	99,483
Canadian Dollar	3,658,730	3,625,590	10/21/09	(33,140)
Czech Koruna	1,749,819	1,725,602	10/21/09	(24,217)
Euro	4,753,508	4,707,698	10/21/09	(45,810)
Hungarian Forint	1,201,645	1,181,499	10/21/09	(20,146)
Japanese Yen	1,085,175	1,083,876	10/21/09	(1,299)
Norwegian Krone	2,304,296	2,225,952	10/21/09	(78,344)
Polish Zloty	2,935,179	2,981,933	10/21/09	46,754
South African Rand	1,288,038	1,281,763	10/21/09	(6,275)
Swedish Krona	2,376,051	2,286,447	10/21/09	(89,604)
Swiss Franc	9,693,348	9,601,890	10/21/09	(91,458)
Turkish Lira	129,602	128,787	10/21/09	(815)
Total				$(312,021)
FUTURES CONTRACTS OUTSTANDING at 9/30/09				Unrealized
	Number of		Expiration	appreciation/
	contracts	Value	date	(depreciation)
Australian Government Treasury Bond 10 yr (Long)	2	$1,252,012	Dec-09	$(1,067)
Canadian Government Bond 10 yr (Long)	5	568,112	Dec-09	7,647
Euro-Bobl 5 yr (Long)	80	13,536,914	Dec-09	14,590
Euro-Bund 10 yr (Long)	3	535,443	Dec-09	2,185
Euro-Schatz 2 yr (Short)	471	74,601,456	Dec-09	(158,621)
Japanese Government Bond 10 yr (Short)	7	10,883,508	Dec-09	(50,024)
Japanese Government Bond 10 yr Mini (Short)	1	155,456	Dec-09	(1,015)
U.K. Gilt 10 yr (Short)	61	11,575,072	Dec-09	(53,510)
U.S. Treasury Bond 20 yr (Long)	948	115,063,500	Dec-09	2,164,737
U.S. Treasury Note 2 yr (Short)	3	650,906	Dec-09	(3,789)
U.S. Treasury Note 5 yr (Short)	501	58,162,969	Dec-09	(882,003)
U.S. Treasury Note 10 yr (Short)	3	354,984	Dec-09	(3,992)
Total				$1,035,138

WRITTEN OPTIONS OUTSTANDING at 9/30/09 (premiums received $26,542,096)	Contract	Expiration date/
	amount	strike price	Value
Option on an interest rate swap with Citibank, N.A. for the obligation to pay a
fixed rate of 4.49% versus the three month USD-LIBOR-BBA maturing August 17, 2021.	$11,060,000	Aug-11/4.49	$835,362
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to pay a
fixed rate of 4.525% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	20,362,000	Jul-11/4.525	1,567,704
Option on an interest rate swap with Bank of America, N.A. for the obligation to pay a
fixed rate of 4.475% versus the three month USD-LIBOR-BBA maturing August 19, 2021.	7,124,000	Aug-11/4.475	532,519
Option on an interest rate swap with Bank of America, N.A. for the obligation to receive a
fixed rate of 4.475% versus the three month USD-LIBOR-BBA maturing August 19, 2021.	7,124,000	Aug-11/4.475	352,211
Option on an interest rate swap with Citibank, N.A. for the obligation to receive a
fixed rate of 4.49% versus the three month USD-LIBOR-BBA maturing August 17, 2021.	11,060,000	Aug-11/4.49	540,834
Option on an interest rate swap with Bank of America, N.A. for the obligation to pay a
fixed rate of 4.55% versus the three month USD-LIBOR-BBA maturing August 17, 2021.	5,530,000	Aug-11/4.55	434,824
Option on an interest rate swap with Bank of America, N.A. for the obligation to receive a
fixed rate of 4.55% versus the three month USD-LIBOR-BBA maturing August 17, 2021.	5,530,000	Aug-11/4.55	261,016
Option on an interest rate swap with Bank of America, N.A. for the obligation to pay a
fixed rate of 4.765% versus the three month USD-LIBOR-BBA maturing August 16, 2021.	10,823,000	Aug-11/4.765	976,235
Option on an interest rate swap with Bank of America, N.A. for the obligation to receive a
fixed rate of 4.765% versus the three month USD-LIBOR-BBA maturing August 16, 2021.	10,823,000	Aug-11/4.765	449,046
Option on an interest rate swap with Bank of America, N.A. for the obligation to pay a
fixed rate of 4.70% versus the three month USD-LIBOR-BBA maturing August 8, 2021.	11,515,000	Aug-11/4.70	998,466

37

WRITTEN OPTIONS OUTSTANDING at 9/30/09 (premiums received $26,542,096) cont.	Contract	Expiration date/
	amount	strike price	Value
Option on an interest rate swap with Bank of America, N.A. for the obligation to receive a
fixed rate of 4.70% versus the three month USD-LIBOR-BBA maturing August 8, 2021.	$11,515,000	Aug-11/4.70	$492,151
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to pay a
fixed rate of 4.745% versus the three month USD-LIBOR-BBA maturing July 27, 2021.	30,543,000	Jul-11/4.745	2,714,982
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 4.745% versus the three month USD-LIBOR-BBA maturing July 27, 2021.	30,543,000	Jul-11/4.745	1,245,551
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to pay a
fixed rate of 4.46% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	20,362,000	Jul-11/4.46	1,499,287
Option on an interest rate swap with Citibank, N.A. for the obligation to pay a
fixed rate of 4.52% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	19,096,000	Jul-11/4.52	1,475,166
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 4.46% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	20,362,000	Jul-11/4.46	984,513
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 4.525% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	20,362,000	Jul-11/4.525	946,654
Option on an interest rate swap with Citibank, N.A. for the obligation to receive a
fixed rate of 4.52% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	19,096,000	Jul-11/4.52	892,165
Option on an interest rate swap with Citibank, N.A. for the obligation to pay a
fixed rate of 4.5475% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	9,548,000	Jul-11/4.5475	751,332
Option on an interest rate swap with Citibank, N.A. for the obligation to receive a
fixed rate of 4.5475% versus the three month USD-LIBOR-BBA maturing July 26, 2021.	9,548,000	Jul-11/4.5475	438,826
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to pay a
fixed rate of 4.4% versus the three month USD-LIBOR-BBA maturing November 9, 2019.	50,458,000	Nov-09/4.40	3,903,431
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 5.235% versus the three month USD-LIBOR-BBA maturing June 11, 2020.	19,098,000	Jun-10/5.235	165,007
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to pay a
fixed rate of 4.82% versus the three month USD-LIBOR-BBA maturing September 12, 2018.	1,469,000	Sep-13/4.82	77,969
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to pay a
fixed rate of 5.51% versus the three month USD-LIBOR-BBA maturing May 14, 2022.	25,011,500	May-12/5.51	3,206,305
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 5.23% versus the three month USD-LIBOR-BBA maturing June 9, 2020.	19,098,000	Jun-10/5.23	163,670
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 4.4% versus the three month USD-LIBOR-BBA maturing November 9, 2019.	50,458,000	Nov-09/4.40	28,761
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 4.82% versus the three month USD-LIBOR-BBA maturing September 12, 2018.	1,469,000	Sep-13/4.82	49,579
Option on an interest rate swap with JPMorgan Chase Bank, N.A. for the obligation to receive a
fixed rate of 5.51% versus the three month USD-LIBOR-BBA maturing May 14, 2022.	25,011,500	May-12/5.51	865,021
Total			$26,848,587

TBA SALE COMMITMENTS OUTSTANDING at 9/30/09 (proceeds receivable $2,023,281)	Principal	Settlement
Agency	amount	date	Value
FNMA, 4 1/2s, October 1, 2039	$2,000,000	10/14/08	$2,025,625
Total			$2,025,625

INTEREST RATE SWAP CONTRACTS OUTSTANDING at 9/30/09
		Upfront	Termi-			Unrealized
Swap	Notional	premium	nation	Payments made by	Payments received by	appreciation/
counterparty	amount	received (paid)	date	fund per annum	fund per annum	(depreciation)
Bank of America, N.A.	$32,178,000	$—	5/23/10	3 month USD-LIBOR-BBA	3.155%	$904,053
	23,500,000	—	7/18/13	4.14688%	3 month USD-LIBOR-	(1,803,258)
					BBA
	7,133,000	—	9/18/38	4.36125%	3 month USD-LIBOR-	(558,011)
					BBA
	28,409,000	25,825	10/20/10	3 month USD-LIBOR-BBA	3.00%	1,076,177
	219,700,000	(78,194)	11/26/10	3 month USD-LIBOR-BBA	2.35%	5,718,118
	550,228,000	—	12/22/10	3 month USD-LIBOR-BBA	1.515%	7,292,670
	54,651,000	—	10/26/12	4.6165%	3 month USD-LIBOR-	(5,439,677)
					BBA
	18,938,000	—	5/19/10	3.2925%	3 month USD-LIBOR-	(561,462)
					BBA
	23,910,000	—	7/22/10	3 month USD-LIBOR-BBA	3.5375%	722,661
	11,889,000	—	5/8/28	4.95%	3 month USD-LIBOR-	(2,003,317)
					BBA

38

INTEREST RATE SWAP CONTRACTS OUTSTANDING at 9/30/09 cont.
				Upfront	Termi-			Unrealized
Swap		Notional		premium	nation	Payments made by	Payments received by	appreciation/
counterparty		amount		received (paid)	date	fund per annum	fund per annum	(depreciation)
Barclays Bank PLC		$76,136,000		$—	12/9/10	3 month USD-LIBOR-BBA	2.005%	$1,598,026
		28,963,000		—	12/9/20	3 month USD-LIBOR-BBA	2.91875%	(1,476,479)
Citibank, N.A.	JPY	1,134,000,000		—	9/11/16	1.8675%	6 month JPY-LIBOR-	(687,902)
							BBA
		$7,876,000		—	7/17/19	3.8675%	3 month USD-LIBOR-	(340,679)
							BBA
		17,993,000		—	7/28/19	3.895%	3 month USD-LIBOR-	(799,970)
							BBA
		15,000,000		—	8/6/19	3.8425%	3 month USD-LIBOR-	(584,976)
							BBA
		17,500,000		—	8/12/14	3 month USD-LIBOR-BBA	3.1925%	533,893
		18,950,000		—	8/14/11	1.61125%	3 month USD-LIBOR-	(165,888)
							BBA
		11,450,000		—	8/14/14	3 month USD-LIBOR-BBA	3.10%	296,871
	MXN	33,510,000		—	7/18/13	1 month MXN-TIIE-BANXICO	9.175%	162,540
	MXN	10,055,000		—	7/22/13	1 month MXN-TIIE-BANXICO	9.21%	50,572
		$95,602,000		—	9/17/13	3 month USD-LIBOR-BBA	3.4975%	4,433,643
		6,895,000		—	9/18/38	4.45155%	3 month USD-LIBOR-	(648,903)
							BBA
		302,431,000		—	9/18/10	3 month USD-LIBOR-BBA	2.92486%	7,101,321
		8,078,000		—	2/24/16	2.77%	3 month USD-LIBOR-	85,890
							BBA
		113,713,000		(270,689)	8/27/14	3 month USD-LIBOR-BBA	2.97%	1,848,416
		4,608,000		—	8/27/19	3 month USD-LIBOR-BBA	3.6875%	108,303
	EUR	43,720,000	E	—	8/28/24	6 month EUR-EURIBOR-	4.835%	(151,736)
						REUTERS
		$36,571,000		—	9/22/11	1.3675%	3 month USD-LIBOR-	(72,393)
							BBA
	EUR	15,360,000		—	9/29/19	3.501%	6 month EUR-EURIBOR-	(85,637)
							REUTERS
		$23,704,000		—	9/30/19	3 month USD-LIBOR-BBA	3.425%	(60,272)
		30,650,000		—	3/27/14	3 month USD-LIBOR-BBA	2.335%	(204,099)
		102,606,000		—	3/30/11	3 month USD-LIBOR-BBA	1.535%	898,294
	MXN	12,400,000		—	3/28/13	1 month MXN-TIIE-BANXICO	6.9425%	(6,245)
		$10,396,000		—	4/6/39	3.295%	3 month USD-LIBOR-	1,009,849
							BBA
		12,349,000		—	5/11/39	3.8425%	3 month USD-LIBOR-	8,773
							BBA
Citibank, N.A., London	JPY	1,300,000,000		—	2/10/16	6 month JPY-LIBOR-BBA	1.755%	691,326
Credit Suisse		$11,827,400		—	9/16/10	3.143%	3 month USD-LIBOR-	(302,979)
International							BBA
		4,042,000		—	9/18/38	4.41338%	3 month USD-LIBOR-	(353,304)
							BBA
		124,287,000		—	9/18/10	3 month USD-LIBOR-BBA	2.91916%	2,911,888
		13,961,000		—	9/23/10	3 month USD-LIBOR-BBA	3.32%	379,927
		18,000,000		—	12/5/20	3 month USD-LIBOR-BBA	3.01%	(751,175)
		18,900,000		—	7/30/19	3 month USD-LIBOR-BBA	3.87%	795,649
		5,750,000		—	8/5/19	3 month USD-LIBOR-BBA	3.903%	255,037
		14,832,000		—	8/25/19	3.8475%	3 month USD-LIBOR-	(556,251)
							BBA
	GBP	11,600,000		—	8/25/11	1.98%	6 month GBP-LIBOR-	(83,875)
							BBA
		$14,199,000		—	8/28/19	3 month USD-LIBOR-BBA	3.6825%	327,775
		14,255,000		—	2/5/14	2.475%	3 month USD-LIBOR-	(53,925)
							BBA
		6,455,000		—	2/5/29	3 month USD-LIBOR-BBA	3.35%	(428,780)
	EUR	71,710,000		—	9/18/11	1.6875%	6 month EUR-EURIBOR-	(70)
							REUTERS

39

INTEREST RATE SWAP CONTRACTS OUTSTANDING at 9/30/09 cont.
				Upfront	Termi-			Unrealized
Swap		Notional		premium	nation	Payments made by	Payments received by	appreciation/
counterparty		amount		received (paid)	date	fund per annum	fund per annum	(depreciation)
Credit Suisse	EUR	18,900,000		$—	9/18/14	6 month EUR-EURIBOR-	2.755%	$93,045
International cont.						REUTERS
		$26,736,000		—	9/24/24	3.975%	3 month USD-LIBOR-	(684,104)
							BBA
		4,180,000		—	4/28/39	3.50375%	3 month USD-LIBOR-	255,002
							BBA
	SEK	79,760,000	E	—	6/8/11	2.11%	3 month SEK-STIBOR-	(18,227)
							SIDE
	SEK	79,760,000	E	—	6/8/12	3 month SEK-STIBOR-SIDE	3.275%	(12,839)
		$11,675,000		—	6/5/39	4.29417%	3 month USD-LIBOR-	(921,694)
							BBA
	SEK	26,590,000	E	—	6/8/11	2.22%	3 month SEK-STIBOR-	(10,166)
							SIDE
	SEK	26,590,000	E	—	6/8/12	3 month SEK-STIBOR-SIDE	3.37%	(841)
		$9,000,000		—	6/23/19	3 month USD-LIBOR-BBA	4.054%	571,154
Deutsche Bank AG		45,054,000		—	4/21/14	2.51%	3 month USD-LIBOR-	(437,837)
							BBA
		273,775,000		—	5/12/11	1.43%	3 month USD-LIBOR-	(3,029,111)
							BBA
		3,000,000		—	6/9/19	3 month USD-LIBOR-BBA	4.195%	231,787
		19,578,000		—	7/27/19	3.755%	3 month USD-LIBOR-	(634,367)
							BBA
		6,298,000		—	7/28/19	3.895%	3 month USD-LIBOR-	(280,010)
							BBA
		13,500,000		—	8/11/19	4.18%	3 month USD-LIBOR-	(913,844)
							BBA
		9,268,000		—	9/23/38	4.75%	3 month USD-LIBOR-	(1,353,325)
							BBA
		125,936,000		—	10/24/10	3 month USD-LIBOR-BBA	2.604%	3,899,532
		97,260,000		—	11/25/13	3 month USD-LIBOR-BBA	2.95409%	3,152,508
	ZAR	12,120,000		—	7/6/11	3 month ZAR-JIBAR-SAFEX	9.16%	47,317
		$70,018,000		—	11/28/13	3 month USD-LIBOR-BBA	2.8725%	2,013,939
		79,355,000		—	12/5/13	2.590625%	3 month USD-LIBOR-	(1,268,626)
							BBA
		28,551,000		—	12/9/13	3 month USD-LIBOR-BBA	2.5225%	360,859
		20,515,000		—	12/16/28	3 month USD-LIBOR-BBA	2.845%	(2,705,005)
		332,987,000		—	12/19/10	3 month USD-LIBOR-BBA	1.53429%	4,547,296
		4,000,000		—	12/22/13	2.008%	3 month USD-LIBOR-	43,601
							BBA
		23,757,000		—	12/24/13	2.165%	3 month USD-LIBOR-	100,779
							BBA
		49,838,000		—	12/30/13	2.15633%	3 month USD-LIBOR-	256,024
							BBA
		34,300,000		—	1/8/29	3 month USD-LIBOR-BBA	3.19625%	(2,937,626)
		109,800,000		—	1/8/14	2.375%	3 month USD-LIBOR-	(218,667)
							BBA
		12,754,000		—	1/28/29	3 month USD-LIBOR-BBA	3.1785%	(1,146,633)
		14,015,000		—	8/26/19	3 month USD-LIBOR-BBA	3.73%	381,902
		208,867,000		—	2/3/14	2.44%	3 month USD-LIBOR-	(509,492)
							BBA
		89,668,000		—	2/3/24	3 month USD-LIBOR-BBA	3.27%	(4,385,076)
		20,377,000		—	2/5/29	3 month USD-LIBOR-BBA	3.324%	(1,428,152)
		41,011,000		—	2/5/14	2.44661%	3 month USD-LIBOR-	(104,935)
							BBA
		285,446,000		—	2/6/14	2.5529%	3 month USD-LIBOR-	(2,011,873)
							BBA
		48,326,000		—	2/6/29	3 month USD-LIBOR-BBA	3.42575%	(2,699,892)

40

INTEREST RATE SWAP CONTRACTS OUTSTANDING at 9/30/09 cont.
				Upfront	Termi-			Unrealized
Swap		Notional		premium	nation	Payments made by	Payments received by	appreciation/
counterparty		amount		received (paid)	date	fund per annum	fund per annum	(depreciation)
Deutsche Bank AG cont.		$9,000,000		$—	2/6/14	2.5675%	3 month USD-LIBOR-	$(69,124)
							BBA
		5,000,000		—	2/9/14	2.525%	3 month USD-LIBOR-	(27,382)
							BBA
		4,000,000		—	2/10/14	2.55%	3 month USD-LIBOR-	(26,207)
							BBA
		65,000,000		—	2/17/14	2.55%	3 month USD-LIBOR-	(383,283)
							BBA
		25,000,000		—	2/17/39	3.31%	3 month USD-LIBOR-	2,638,611
							BBA
		21,612,000		—	2/25/14	2.4675%	3 month USD-LIBOR-	(37,031)
							BBA
		106,000,000		—	3/4/14	2.54%	3 month USD-LIBOR-	(459,775)
							BBA
		41,000,000		—	3/4/39	3.37174%	3 month USD-LIBOR-	3,924,467
							BBA
		2,000,000		—	3/10/16	3 month USD-LIBOR-BBA	2.845%	(14,853)
		1,000,000		—	3/11/16	3 month USD-LIBOR-BBA	2.892%	(4,699)
		1,100,000		—	3/11/16	3 month USD-LIBOR-BBA	2.938%	(2,138)
		202,712,000		—	3/20/11	3 month USD-LIBOR-BBA	1.43%	1,537,803
		3,000,000		—	3/24/14	2.297%	3 month USD-LIBOR-	23,847
							BBA
		84,000,000		—	3/30/14	2.36%	3 month USD-LIBOR-	496,633
							BBA
		38,000,000		—	3/30/21	3 month USD-LIBOR-BBA	3.125%	(1,642,020)
		7,314,200		—	9/22/19	3.6875%	3 month USD-LIBOR-	(153,083)
							BBA
		93,246,000		(251,041)	10/2/39	3.91%	3 month USD-LIBOR-	—
							BBA
		115,031,000		181,194	10/2/29	3 month USD-LIBOR-BBA	3.85%	—
		74,773,000		26,058	10/2/19	3 month USD-LIBOR-BBA	3.45%	—
		129,396,000		(28,106)	10/2/11	1.29%	3 month USD-LIBOR-	—
							BBA
Goldman Sachs	JPY	743,800,000		—	6/10/16	1.953%	6 month JPY-LIBOR-	(520,509)
International							BBA
	GBP	23,150,000		—	8/20/11	2.0225%	6 month GBP-LIBOR-	(205,161)
							BBA
	GBP	83,130,000		—	8/24/11	2.035%	6 month GBP-LIBOR-	(751,961)
							BBA
	GBP	29,790,000		—	8/24/14	6 month GBP-LIBOR-BBA	3.4825%	678,871
	GBP	6,070,000		—	8/24/29	6 month GBP-LIBOR-BBA	4.29%	244,388
	AUD	15,162,500	E	—	2/14/12	3 month AUD-BBR-BBSW	4.39%	(188,850)
	EUR	49,190,000		—	9/22/11	6 month EUR-EURIBOR-	1.718%	38,252
						REUTERS
		$22,856,900		—	9/22/14	2.83%	3 month USD-LIBOR-	(220,230)
							BBA
	EUR	55,340,000		—	9/25/11	6 month EUR-EURIBOR-	1.718%	34,462
						REUTERS
	GBP	50,070,000		—	9/23/11	1.9475%	6 month GBP-LIBOR-	(223,726)
							BBA
		$27,831,100		—	9/29/14	3 month USD-LIBOR-BBA	2.6925%	68,016

41

INTEREST RATE SWAP CONTRACTS OUTSTANDING at 9/30/09 cont.
				Upfront	Termi-			Unrealized
Swap		Notional		premium	nation	Payments made by	Payments received by	appreciation/
counterparty		amount		received (paid)	date	fund per annum	fund per annum	(depreciation)
JPMorgan Chase Bank,		$15,289,000		$—	3/11/38	5.0025%	3 month USD-LIBOR-	$(2,913,215)
N.A.							BBA
		35,403,000		—	3/20/13	3 month USD-LIBOR-BBA	3.145%	1,295,379
		69,999,000		—	3/26/10	3 month USD-LIBOR-BBA	2.33375%	690,252
		26,533,000		—	4/8/13	3 month USD-LIBOR-BBA	3.58406%	1,762,197
		53,631,000		—	5/23/10	3 month USD-LIBOR-BBA	3.16%	1,509,859
		21,496,000		—	5/22/19	3 month USD-LIBOR-BBA	3.3225%	62,255
		66,969,000		—	5/28/11	3 month USD-LIBOR-BBA	1.3375%	571,820
		13,885,000	E	—	6/9/20	4.73%	3 month USD-LIBOR-	(1,123,435)
							BBA
		4,000,000		—	6/9/19	3 month USD-LIBOR-BBA	4.207%	313,239
		41,204,000		—	6/9/11	3 month USD-LIBOR-BBA	1.7675%	687,703
		69,867,000		—	6/10/11	3 month USD-LIBOR-BBA	1.81%	1,222,305
		6,423,000		—	7/16/10	3 month USD-LIBOR-BBA	3.384%	184,870
		19,148,000		—	7/22/10	3 month USD-LIBOR-BBA	3.565%	583,955
		49,717,000		—	7/28/10	3 month USD-LIBOR-BBA	3.5141%	1,485,718
	CAD	16,680,000		—	6/9/12	6 month CAD-BA-CDOR	1.95%	111,164
	CAD	5,330,000		—	6/9/14	2.725%	6 month CAD-BA-CDOR	(68,904)
		$13,885,000	E	—	6/11/20	4.735%	3 month USD-LIBOR-	(1,126,351)
							BBA
	CAD	26,600,000		—	6/9/10	0.57%	1 month CAD-BA-CDOR	(22,444)
		$35,465,000		—	6/16/19	4.09%	3 month USD-LIBOR-	(2,388,789)
							BBA
		12,266,000		—	6/19/19	3 month USD-LIBOR-BBA	3.8725%	590,252
	AUD	6,090,000		—	6/26/19	6 month AUD-BBR-BBSW	6.05%	35,749
	CAD	6,090,000		—	6/25/19	3.626%	6 month CAD-BA-CDOR	(168,623)
	JPY	8,737,320,000		—	9/18/15	6 month JPY-LIBOR-BBA	1.19%	1,350,303
	JPY	32,620,000		—	9/18/38	2.17%	6 month JPY-LIBOR-	(3,860)
							BBA
		$17,560,000		—	9/23/38	4.70763%	3 month USD-LIBOR-	(2,433,321)
							BBA
		3,445,000		—	10/22/10	3 month USD-LIBOR-BBA	2.78%	115,863
		17,025,000		—	10/23/13	3 month USD-LIBOR-BBA	3.535%	1,033,356
	JPY	358,600,000	E	—	7/28/29	6 month JPY-LIBOR-BBA	2.67%	(21,807)
	JPY	482,100,000	E	—	7/28/39	2.40%	6 month JPY-LIBOR-	30,447
							BBA
		$52,300,000		—	7/30/11	1.46%	3 month USD-LIBOR-	(344,354)
							BBA
		20,609,000		—	8/3/14	3 month USD-LIBOR-BBA	3.061%	516,870
		71,000,000		—	11/24/10	3 month USD-LIBOR-BBA	2.0075%	1,502,431
	EUR	22,020,000		—	12/11/13	6 month EUR-EURIBOR-	3.536%	1,992,176
						REUTERS
	PLN	9,400,000		—	1/26/11	6 month PLN-WIBOR-WIBO	4.177%	$39,618
		$22,300,000		—	8/4/14	3 month USD-LIBOR-BBA	2.89%	376,502
	HUF	349,000,000		—	8/6/14	6 month HUF-BUBOR-REUTERS	7.08%	(6,603)
		$17,000,000		—	8/7/19	4.015%	3 month USD-LIBOR-	(915,234)
							BBA
		14,000,000		—	8/10/19	4.02%	3 month USD-LIBOR-	(755,079)
							BBA
	HUF	91,700,000		—	8/27/14	6 month HUF-BUBOR-REUTERS	6.94%	(3,279)
	JPY	7,460,000,000		—	6/6/13	1.83%	6 month JPY-LIBOR-	(3,638,667)
							BBA
		$6,970,000		—	1/27/24	3.1%	3 month USD-LIBOR-	472,792
							BBA
	AUD	12,130,000	E	—	1/27/12	3 month AUD-BBR-BBSW	4.21%	(163,637)
		$3,485,000		—	2/3/24	3 month USD-LIBOR-BBA	3.2825%	(165,410)

42

INTEREST RATE SWAP CONTRACTS OUTSTANDING at 9/30/09 cont.
				Upfront	Termi-			Unrealized
Swap		Notional		premium	nation	Payments made by	Payments received by	appreciation/
counterparty		amount		received (paid)	date	fund per annum	fund per annum	(depreciation)
JPMorgan Chase Bank,		$80,000,000		$—	2/5/11	1.625%	3 month USD-LIBOR-	$(952,851)
N.A. cont.							BBA
		195,522,000		—	2/6/11	1.6966%	3 month USD-LIBOR-	(2,531,998)
							BBA
		20,767,000		—	2/6/29	3 month USD-LIBOR-BBA	3.4546%	(1,075,818)
		22,859,000		—	3/3/11	3 month USD-LIBOR-BBA	1.68283%	275,423
		4,658,000		—	3/6/39	3.48%	3 month USD-LIBOR-	357,769
							BBA
		12,980,600		—	9/10/19	3.66%	3 month USD-LIBOR-	(257,521)
							BBA
	EUR	7,270,000	E	—	9/17/29	6 month EUR-EURIBOR-	4.944%	65,474
						REUTERS
		$12,000,000		—	9/14/19	3 month USD-LIBOR-BBA	3.505%	71,803
		5,521,000		(32,641)	9/16/39	4.00%	3 month USD-LIBOR-	(112,882)
							BBA
	EUR	56,970,000		—	9/18/11	1.662%	6 month EUR-EURIBOR-	37,878
							REUTERS
	EUR	15,010,000		—	9/18/14	6 month EUR-EURIBOR-	2.72%	38,007
						REUTERS
		$8,500,000		—	9/21/19	3 month USD-LIBOR-BBA	3.575%	96,067
	EUR	19,200,000		—	9/22/19	6 month EUR-EURIBOR-	3.549%	236,165
						REUTERS
		$27,550,000		—	9/22/19	3.645%	3 month USD-LIBOR-	(475,483)
							BBA
		36,571,000		—	9/22/11	1.335%	3 month USD-LIBOR-	(49,057)
							BBA
	GBP	910,000		—	9/24/29	6 month GBP-LIBOR-BBA	4.1975%	15,293
	GBP	7,260,000		—	9/28/19	3.9225%	6 month GBP-LIBOR-	(44,739)
							BBA
	EUR	9,600,000		—	10/1/19	3.481%	6 month EUR-EURIBOR-	(26,711)
							REUTERS
	CAD	7,690,000		—	3/16/11	0.98%	3 month CAD-BA-CDOR	(1,316)
	CAD	1,690,000		—	3/16/19	3 month CAD-BA-CDOR	2.7%	(82,287)
	CAD	7,940,000		—	3/17/13	1.56%	3 month CAD-BA-CDOR	155,805
	CAD	2,520,000		—	3/17/24	3 month CAD-BA-CDOR	3.46%	(107,302)
		$41,000,000		—	3/20/19	3.20875%	3 month USD-LIBOR-	636,720
							BBA
		120,000,000		—	3/24/11	3 month USD-LIBOR-BBA	1.4625%	953,860
		63,500,000		—	4/3/11	3 month USD-LIBOR-BBA	1.365%	718,846
		20,810,000		—	4/3/13	1.963%	3 month USD-LIBOR-	(74,710)
							BBA
		116,130,000		—	4/3/14	2.203%	3 month USD-LIBOR-	400,200
							BBA
		158,590,000		—	4/3/10	3 month USD-LIBOR-BBA	1.168%	1,337,923
		57,988,000		—	4/9/11	3 month USD-LIBOR-BBA	1.5025%	806,291
		55,000,000		—	5/11/19	3 month USD-LIBOR-BBA	3.4%	584,583
		18,600,000		—	5/13/19	3 month USD-LIBOR-BBA	3.2825%	4,175
Merrill Lynch Capital	JPY	743,800,000		—	6/10/16	1.99625%	6 month JPY-LIBOR-	(544,972)
Services, Inc.							BBA
Merrill Lynch	JPY	371,900,000		—	6/11/17	2.05625%	6 month JPY-LIBOR-	(291,536)
Derivative Products							BBA
AG
Morgan Stanley		$2,100,000		—	7/30/19	3 month USD-LIBOR-BBA	3.87%	88,405
Capital Services, Inc.
Total								$16,553,697

^E See Note 1 to the financial statements regarding extended effective dates.

43

TOTAL RETURN SWAP CONTRACTS OUTSTANDING at 9/30/09
			Upfront	Termi-			Unrealized
Swap		Notional	premium	nation	Fixed payments received (paid)	Total return received by	appreciation/
counterparty		amount	received (paid)	date	by fund per annum	or paid by fund	(depreciation)
Deutsche Bank AG
	EUR	5,760,000	$—	3/27/14	1.785%	Eurostat Eurozone HICP	$42,175
						excluding tobacco
Goldman Sachs
International
	EUR	9,600,000	—	4/30/13	2.375%	French Consumer Price	583,979
						Index excluding tobacco
	EUR	9,600,000	—	4/30/13	(2.41%)	Eurostat Eurozone HICP	(606,754)
						excluding tobacco
	EUR	9,600,000	—	5/6/13	2.34%	French Consumer Price	564,298
						Index excluding tobacco
	EUR	9,600,000	—	5/6/13	(2.385%)	Eurostat Eurozone HICP	(591,571)
						excluding tobacco
		$6,400,000	—	7/9/14	(1.70%)	USA Non Revised	37,952
						Consumer Price Index —
						Urban (CPI-U)
	GBP	5,920,000	—	8/21/12	(2.66%)	GBP Non-revised UK	12,981
						Retail Price Index
		$5,120,000	—	7/13/14	(1.60%)	USA Non Revised	54,989
						Consumer Price Index —
						Urban (CPI-U)
	EUR	5,320,000	—	4/23/14	1.67%	Eurostat Eurozone HICP	(52,665)
						excluding tobacco
	EUR	5,760,000	—	4/14/14	1.835%	Eurostat Eurozone HICP	9,278
						excluding tobacco
		$18,950,000	—	5/18/10	(0.25%)	USA Non Revised	322,719
						Consumer Price Index —
						Urban (CPI-U)
Total							$377,381

CREDIT DEFAULT CONTRACTS OUTSTANDING at 9/30/09
					Fixed payments	Unrealized
Swap counterparty /		Upfront premium	Notional	Termination	received (paid) by	appreciation/
Referenced debt*	Rating***	received (paid)**	amount	date	fund per annum	(depreciation)
Bank of America, N.A.
Financial Security Assurance Holdings,	Baa1	$—	$555,000	12/20/12	95 bp	$(85,262)
Ltd, 6.4%, 12/15/66
Nalco Co., 7.75%, 11/15/11	Ba2	—	80,000	9/20/12	350 bp	434
Barclays Bank PLC
DJ ABX HE PEN AAA Series 6	A+	278,302	1,531,250	7/25/45	18 bp	98,732
Version 1 Index
DJ ABX HE PEN AAA Series 6	A+	220,207	1,148,438	7/25/45	18 bp	85,529
Version 1 Index
DJ ABX HE PEN AAA Series 6	A+	208,985	990,387	7/25/45	18 bp	92,843
Version 1 Index
DJ ABX HE PEN AAA Series 6	A+	210,906	995,408	7/25/45	18 bp	94,174
Version 1 Index
DJ ABX HE PEN AAA Series 7	BB–	898,208	1,524,000	8/25/37	9 bp	(44,364)
Version 1 Index
DJ CDX NA IG Series 12 Version 1 Index	—	(1,130,107)	29,966,000	6/20/14	(100 bp)	(1,006,880)

44

CREDIT DEFAULT CONTRACTS OUTSTANDING at 9/30/09 cont.
						Fixed payments	Unrealized
Swap counterparty /		Upfront premium		Notional	Termination	received (paid) by	appreciation/
Referenced debt*	Rating***	received (paid)**		amount	date	fund per annum	(depreciation)
Citibank, N.A.
DJ ABX HE AAA Index	BBB–	$717,663		$3,469,012	5/25/46	11 bp	$(262,269)
DJ ABX HE PEN AAA Index	BBB–	611,503		3,954,273	5/25/46	11 bp	(505,506)
DJ ABX HE PEN AAA Series 6	BBB–	171,737		807,698	5/25/46	11 bp	(56,423)
Version 1 Index
DJ ABX HE PEN AAA Series 6	A+	163,880		805,078	7/25/45	18 bp	69,469
Version 1 Index
DJ ABX HE PEN AAA Series 6	BBB–	686,668		3,740,116	5/25/46	11 bp	(369,847)
Version 2 Index
Lighthouse International Co., SA,	B3	—	EUR	495,000	3/20/13	815 bp	(123,847)
8%, 4/30/14
Republic of Argentina, 8.28%, 12/31/33	—	—		$330,000	9/20/13	(1,170 bp)	(6,052)
Republic of Argentina, 8.28%, 12/31/33	B–	—		330,000	9/20/13	(945 bp)	16,653
Credit Suisse First Boston International
Ukraine (Government of), 7.65%,	B2	—		1,105,000	10/20/11	194 bp	(216,881)
6/11/13
Credit Suisse International
DJ ABX HE PEN AAA Series 6	A+	861,696		4,200,896	7/25/45	18 bp	369,057
Version 1 Index
DJ ABX HE PEN AAA Series 6	BBB–	1,991,129		4,355,315	5/25/46	11 bp	760,833
Version 2 Index
DJ ABX HE PEN AAA Series 7	BB–	1,146,531		1,931,000	8/25/37	9 bp	(45,832)
Version 1 Index
DJ CMB NA CMBX AAA Index	AA+	8,988		54,000	12/13/49	8 bp	(1,136)
DJ CMBX NA AAA Series 4	AA+	1,523,481		3,688,000	2/17/51	35 bp	782,777
Version 1 Index
Deutsche Bank AG
DJ ABX HE PEN AAA Index	BBB–	608,711		3,954,273	5/25/46	11 bp	(508,299)
DJ ABX HE PEN AAA Series 6	A+	113,424		520,061	7/25/45	18 bp	52,437
Version 1 Index
DJ ABX HE PEN AAA Series 6	BBB–	655,834		1,741,324	5/25/46	11 bp	163,417
Version 2 Index
DJ iTraxx Europe Series 8 Version 1	—	(54,791)	EUR	571,200	12/20/12	(375 bp)	2,135
DJ iTraxx Europe Series 9 Version 1	—	158,373	EUR	2,318,400	6/20/13	(650 bp)	104,225
Federal Republic of Brazil,	Baa3	—		$775,000	10/20/17	105 bp	(18,272)
12 1/4%, 3/6/30
General Electric Capital Corp.,	Aa2	—		300,000	9/20/13	109 bp	(9,214)
6%, 6/15/12
India Government Bond, 5 7/8%, 1/2/10	Ba2	—		5,800,000	1/11/10	170 bp	50,901
Korea Monetary STAB Bond,	A2	—		1,365,000	2/19/10	115 bp	5,067
5.15%, 2/12/10
Korea Monetary STAB Bond, 5.45%,	A	—		870,000	2/1/10	101 bp	3,278
1/23/10
Nalco Co., 7.75%, 11/15/11	Ba2	—		70,000	12/20/12	363 bp	586
Republic of Argentina, 8.28%, 12/31/33	—	—		660,000	8/20/12	(380 bp)	107,482
Smurfit Kappa Funding, 7 3/4%, 4/1/15	B2	—	EUR	425,000	9/20/13	715 bp	21,105
Thomson SA, 5 3/4%, 9/25/49	—	—	EUR	11,900	12/20/12	(375 bp)	3,597
Thomson SA, 5 3/4%, 9/25/49	—	—	EUR	48,300	6/20/13	(650 bp)	12,653
United Mexican States, 7.5%, 4/8/33	Baa1	—		$1,495,000	3/20/14	56 bp	(59,866)
Virgin Media Finance PLC, 8 3/4%,	B2	—	EUR	400,000	9/20/13	477 bp	6,454
4/15/14
Virgin Media Finance PLC, 8 3/4%,	B2	—	EUR	400,000	9/20/13	535 bp	18,199
4/15/14

45

CREDIT DEFAULT CONTRACTS OUTSTANDING at 9/30/09 cont.
							Fixed payments	Unrealized
Swap counterparty /		Upfront premium		Notional		Termination	received (paid) by	appreciation/
Referenced debt*	Rating***	received (paid)**		amount		date	fund per annum	(depreciation)
Goldman Sachs International
DJ ABX HE PEN AAA Series 6 Version 2	BBB–	$809,979		$1,876,876		5/25/46	11 bp	$279,796
Index
DJ CDX NA CMBX AAA Index	AAA	56,692		1,550,000		3/15/49	7 bp	(133,168)
DJ CDX NA IG Series 12 Version 1 Index	—	(1,177,535)		27,089,000		6/20/14	(100 bp)	(1,066,139)
DJ CDX NA IG Series 12 Version 1 Index	—	(127,138)		2,893,000		6/20/14	(100 bp)	(115,242)
Lighthouse International Co, SA, 8%,	B3	—	EUR	420,000		3/20/13	680 bp	(106,077)
4/30/14
Smurfit Kappa Funding, 7 3/4%, 4/1/15	B2	—	EUR	390,000		9/20/13	720 bp	18,073
JPMorgan Chase Bank, N.A.
Claire’s Stores, 9 5/8%, 6/1/15	Caa1	—		$70,000		6/20/12	230 bp	(19,394)
DJ ABX HE PEN AAA Series 6 Version 1	A+	77,693		362,249		7/25/45	18 bp	35,201
Index
DJ ABX HE PEN AAA Series 6 Version 2	BBB–	189,164		866,250		5/25/46	11 bp	(55,536)
Index
DJ ABX HE PEN AAA Series 6 Version 2	BBB–	659,822		1,726,886		5/25/46	11 bp	172,009
Index
DJ CDX NA EM Series 10 Index	Ba2	28,017		485,000		12/20/13	335 bp	36,460
DJ iTraxx Europe Crossover Series 8	—	(153,928)	EUR	1,152,000		12/20/12	(375 bp)	(39,118)
Version 1
Freeport-McMoRan Copper & Gold, Inc.,	Ba2	—		$1,194,100		3/20/12	(85 bp)	(7,566)
bank term loan
Republic of Argentina, 8.28%, 12/31/33	B–	—		705,000		6/20/14	235 bp	(205,307)
Republic of Hungary, 4 3/4%, 2/3/15	—	—		600,000		4/20/13	(171.5 bp)	1,942
Russian Federation, 7 1/2%, 3/31/30	Baa1	—		1,605,000		5/20/17	60 bp	(160,178)
Sanmina-Sci Corp., 8 1/8%, 3/1/16	B3	—		215,000		6/20/13	595 bp	(9,604)
Thomson SA, 5 3/4%, 9/25/49	—	—	EUR	24,000		12/20/12	(375 bp)	7,255
Merrill Lynch Capital Services, Inc.
D.R. Horton Inc., 7 7/8%, 8/15/11	—	—		$735,000		9/20/11	(426 bp)	(40,729)
Morgan Stanley Capital Services, Inc.
DJ ABX CMBX BBB Index	—	50		68,790		10/12/52	(134 bp)	49,972
DJ CDX NA IG Series 12 Version 1 Index	—	(256,363)		6,310,000		6/20/14	(100 bp)	(230,415)
DJ CMB NA CMBX AAA Index	AA+	273,852		2,523,500		2/17/51	35 bp	(232,996)
Dominican Republic, 8 5/8%, 4/20/27	—	—		1,190,000		11/20/11	(170 bp)	92,399
Freeport-McMoRan Copper & Gold, Inc.,	Baa3	—		1,191,200		3/20/12	44 bp	(12,091)
T/L Bank Loan
Nalco Co., 7.75%, 11/15/11	Ba2	—		80,000		9/20/12	330 bp	(113)
Nalco Co., 7.75%, 11/15/11	Ba2	—		115,000		3/20/13	460 bp	4,289
Republic of Venezuela, 9 1/4%, 9/15/27	B2	—		510,000		10/12/12	339 bp	(59,146)
UBS, AG
Meritage Homes Corp., 7%, 5/1/14	—	—		67,000	F	9/20/13	(760 bp)	(8,429)
Total								$(2,201,765)

^* Payments related to the referenced debt are made upon a credit default event.

^** Upfront premium is based on the difference between the original spread on issue and the market spread on day of execution.

^*** Ratings are presented for credit default contracts in which the fund has sold protection on the underlying referenced debt. Ratings for an underlying index represent the average of the ratings of all the securities included in that index. The Moody’s, Standard & Poor’s or Fitch ratings are believed to be the most recent ratings available at September 30, 2009.

^F Is valued at fair value following procedures approved by the Trustees. Securities may be classified as a Level 2 or Level 3 for ASC 820 disclosures based on securities valuation inputs.

46

In September 2006, Accounting Standards Codification ASC 820 Fair Value Measurements and Disclosures (“ASC 820”) was issued. ASC 820 is effective for financial statements issued for fiscal years beginning after November 15, 2007 and interim periods within those fiscal years. While the adoption of ASC 820 does not have a material effect on the fund’s net asset value, it does require additional disclosures about fair value measurements. ASC 820 establishes a three-level hierarchy for disclosure of fair value measurements. The valuation hierarchy is based upon the transparency of inputs to the valuation of the fund’s investments. The three levels are defined as follows:

Level 1 — Valuations based on quoted prices for identical securities in active markets.

Level 2 — Valuations based on quoted prices in markets that are not active or for which all significant inputs are observable, either directly or indirectly.

Level 3 — Valuations based on inputs that are unobservable and significant to the fair value measurement.

The following is a summary of the inputs used to value the fund’s net assets as of September 30, 2009:

		Valuation inputs
Investments in securities:	Level 1	Level 2	Level 3
Asset-backed securities	$—	$44,031,541	$1,405,573
Common stocks:
Communication services	29,939	—	—
Conglomerates	—	—	3,091
Consumer cyclicals	—	—	11
Total Common stocks	29,939	—	3,102
Convertible bonds and notes	—	1,002,102	—
Convertible preferred stocks	—	26,457	—
Corporate bonds and notes	—	86,732,006	1,363
Foreign government bonds and notes	—	25,361,474	—
Mortgage-backed securities	—	181,195,990	—
Preferred stocks	—	132,589	—
Purchased options outstanding	—	12,478,482	—
Senior loans	—	23,730,986	—
U.S. government and agency mortgage obligations	—	30,672,932	—
U.S treasury obligations	—	216,904	—
Warrants	8,585	20,796	—
Short-term investments	23,069,935	13,276,695	—
Totals by level	$23,108,459	$418,878,954	$1,410,038
	Level 1	Level 2	Level 3
Other financial instruments:	$1,035,138	$(22,593,113)	$(163,825)

Other financial instruments include futures, written options, TBA sale commitments, swaps, forward currency contracts and receivable purchase agreements.

The following is a reconciliation of Level 3 assets as of September 30, 2009:

				Change in net
	Balance as of	Accrued		unrealized		Net transfers in	Balance as of
	September 30,	discounts/	Realized gain/	appreciation/	Net purchases/	and/or out of	September 30,
Investments in securities:	2008	premiums	(loss)	(depreciation) †	sales	Level 3	2009
Asset-backed securities	$4,153,299	$—	$(410,549)	$(360,235)	$(1,362,890)	$(614,052)	$1,405,573
Common stocks:
Conglomerates	$33,627	—	(522,593)	574,932	(82,875)	—	3,091
Consumer cyclicals	$—	—	—	11	—	—	11
Total Common stocks	$33,627	—	(522,593)	574,943	(82,875)	—	$3,102
Corporate bonds and notes	$13	—	(11)	3,239	(1,878)	—	$1,363
Mortgage-backed securities	$1,042,398	—	—	—	—	(1,042,398)	$—
Warrants	$1,847	—	(19,265)	17,418	—	—	$—
Totals:	$5,231,184	$—	$(952,418)	$235,365	$(1,447,643)	$(1,656,450)	$1,410,038

† Includes $(516,614) related to Level 3 securities still held at period end. Total change in unrealized appreciation/(depreciation) for securities (including Level 1 and Level 2) can be found in the Statement of operations.

				Change in net
	Balance as of	Accrued		unrealized		Net transfers in	Balance as of
	September 30,	discounts/	Realized gain/	appreciation/	Net purchases/	and/or out of	September 30,
	2008	premiums	(loss)	(depreciation)†	sales	Level 3	2009 ††
Other financial instruments:	$(169,014)	$—	$—	$5,189	$—	$—	$(163,825)

†† Includes amount payable under receivable purchase agreement.

† Includes $5,189 related to Level 3 securities still held at period end. Total change in unrealized appreciation/(depreciation) for securities (including Level 1 and Level 2) can be found in the Statement of operations.

The accompanying notes are an integral part of these financial statements.

47

Statement of assets and liabilities 9/30/09
ASSETS
Investment in securities, at value, (Note 1):
Unaffiliated issuers (identified cost $418,078,319)	$426,077,516
Affiliated issuers (identified cost $17,319,935) (Note 6)		17,319,935
Cash		1,668,015
Foreign currency (cost $529) (Note 1)		417
Dividends, interest and other receivables		4,572,740
Receivable for investments sold		63,971,589
Receivable for sales of delayed delivery securities (Note 1)		2,026,531
Unrealized appreciation on swap contracts (Note 1)		95,517,333
Unrealized appreciation on forward currency contracts (Note 1)		2,139,224
Premium paid on swap contracts (Note 1)		3,560,533
Total assets		616,853,833
LIABILITIES
Payable for variation margin (Note 1)		323,198
Distributions payable to shareholders		2,898,810
Payable for investments purchased		69,860,068
Payable for purchases of delayed delivery securities (Note 1)		28,699,007
Payable for compensation of Manager (Note 2)		687,095
Payable for investor servicing fees (Note 2)		15,674
Payable for custodian fees (Note 2)		72,014
Payable for Trustee compensation and expenses (Note 2)		125,242
Payable for administrative services (Note 2)		1,215
Unrealized depreciation on forward currency contracts (Note 1)		583,399
Interest payable (Note 2)		110,551
Written options outstanding, at value (premiums
received $26,542,096) (Notes 1 and 3)		26,848,587
Payable for receivable purchase agreement (Note 2)		163,825
Premium received on swap contracts (Note 1)		13,564,572
Unrealized depreciation on swap contracts (Note 1)		80,788,020
TBA sales commitments, at value
(proceeds receivable $2,023,281) (Note 1)		2,025,625
Collateral on certain derivative contracts, at value (Note 1)		6,571,783
Other accrued expenses		126,728
Total liabilities		233,465,413
Net assets	$383,388,420

REPRESENTED BY
Paid-in capital (Unlimited shares authorized) (Notes 1 and 4)	$551,166,870
Undistributed net investment income (Note 1)	23,598,627
Accumulated net realized loss on investments
and foreign currency transactions (Note 1)	(216,587,033)
Net unrealized appreciation of investments and
assets and liabilities in foreign currencies	25,209,956
Total — Representing net assets applicable to
capital shares outstanding	$383,388,420
COMPUTATION OF NET ASSET VALUE AND OFFERING PRICE
Net asset value per share
($383,388,420 divided by 64,565,117 shares)	$5.94

The accompanying notes are an integral part of these financial statements.

48

Statement of operations Year ended 9/30/09
INVESTMENT INCOME
Interest (net of foreign tax of $16,129 ) (including
interest income of $25,038 from investments in
affiliated issuers) (Note 6)	$25,198,190
Dividends	10,348
Securities lending	2,656
Total investment income	25,211,194
EXPENSES
Compensation of Manager (Note 2)	2,341,735
Investor servicing fees (Note 2)	156,343
Custodian fees (Note 2)	97,625
Trustee compensation and expenses (Note 2)	36,202
Administrative services (Note 2)	23,622
Interest expense (Note 2)	110,551
Other	413,679
Total expenses	3,179,757
Expense reduction (Note 2)	(3,683)
Net expenses	3,176,074
Net investment income	22,035,120
Net realized loss on investments (Notes 1 and 3)	(23,592,519)
Net realized loss on swap contracts (Note 1)	(50,963,760)
Net realized loss on futures contracts (Note 1)	(27,690,473)
Net realized loss on foreign currency transactions (Note 1)	(40,525)
Net realized gain on written options (Notes 1 and 3)	234,919
Net unrealized appreciation of assets and liabilities
in foreign currencies during the year	3,395,199
Net unrealized appreciation of investments, futures contracts,
swap contracts, written options, and TBA sale commitments
during the year	112,973,602
Net gain on investments	14,316,443
Net increase in net assets resulting from operations	$36,351,563

Statement of changes in net assets
DECREASE IN NET ASSETS
	Year ended	Year ended
	9/30/09	9/30/08
Operations:
Net investment income	$22,035,120	$37,047,440
Net realized loss on investments and
foreign currency transactions	(102,052,358)	(357,169)
Net unrealized appreciation (depreciation)
of investments and assets and liabilities in
foreign currencies	116,368,801	(94,081,603)
Net increase (decrease) in net assets
resulting from operations	36,351,563	(57,391,332)
Distributions to shareholders (Note 1):
From ordinary income
Net investment income	(34,859,749)	(36,112,991)
Increase in capital share transactions from
reinvestment of distributions	634,849	—
Decrease from shares repurchased
(Note 4)	(10,711,596)	(93,333,036)
Total decrease in net assets	(8,584,933)	(186,837,359)
NET ASSETS
Beginning of year	391,973,353	578,810,712
End of year (including undistributed net
investment income of $23,598,627 and
$32,192,969, respectively)	$383,388,420	$391,973,353
NUMBER OF FUND SHARES
Shares outstanding at beginning of year	66,640,509	81,137,030
Shares issued in connection with reinvestment
of distributions	136,964	—
Shares repurchased (Note 4)	(2,212,356)	(14,496,521)
Shares outstanding at end of year	64,565,117	66,640,509

The accompanying notes are an integral part of these financial statements.

49

Financial highlights (For a common share outstanding throughout the period)
PER-SHARE OPERATING PERFORMANCE	Year ended
	9/30/09	9/30/08	9/30/07	9/30/06	9/30/05
Net asset value, beginning of period	$5.88	$7.13	$7.08	$7.07	$7.13
Investment operations:
Net investment income a	.34	.49 f	.36 f	.34 f	.32 f
Net realized and unrealized gain (loss) on investments	.24	(1.28)	.01	(.04)	.04
Total from investment operations	.58	(.79)	.37	.30	.36
Less distributions:
From net investment income	(.54)	(.49)	(.36)	(.35)	(.42)
Total distributions	(.54)	(.49)	(.36)	(.35)	(.42)
Increase from shares repurchased	.02	.03	.04	.06	—
Net asset value, end of period	$5.94	$5.88	$7.13	$7.08	$7.07
Market value, end of period	$5.99	$5.39	$6.41	$6.15	$6.25
Total return at market value (%) b	24.66	(8.92)	10.15	4.17	(0.98)
RATIOS AND SUPPLEMENTAL DATA
Net assets, end of period (in thousands)	$383,388	$391,973	$578,811	$664,410	$709,266
Ratio of expenses to average net assets (%) c	1.02 d	.96 f	.90 f	.89 f	.87 f
Ratio of expenses to average net assets excluding
interest expenses c	.98	.96 f	.90 f	.89 f	.87 f
Ratio of net investment income to average net assets (%)	7.05 d	7.29 f	5.01 f	4.84 f	4.43 f
Portfolio turnover (%)	223.19 e	158.75 e	77.78 e	113.12 e	165.33 e

^a Per share net investment income has been determined on the basis of weighted average number of shares outstanding during the period.

^b Total return assumes dividend reinvestment.

^c Includes amounts paid through expense offset arrangements (Note 2).

^d Includes interest accrued in connection with certain terminated derivative contracts, which amounted to 0.04% of average net assets as of September 30, 2009 (Note 2).

^e Portfolio turnover excludes dollar roll transactions.

^f Reflects waivers of certain fund expenses in connection with investments in Putnam Prime Money Market Fund during the period. As a result of such waivers, the expenses of the fund reflect a reduction of the following amounts:

	Percentage of average net assets
September 30, 2008	0.01%
September 30, 2007	0.02
September 30, 2006	0.02
September 30, 2005	0.02

The accompanying notes are an integral part of these financial statements.

50

Notes to financial statements 9/30/09

Note 1: Significant accounting policies

Putnam Master Intermediate Income Trust (the “fund”), a Massachusetts business trust, is registered under the Investment Company Act of 1940, as amended, as a diversified, closed-end management investment company and is authorized to issue an unlimited number of shares. The fund’s investment objective is to seek, with equal emphasis, high current income and relative stability of net asset value, by allocating its investments among the U.S. investment grade sector, high-yield sector and international sector. The fund invests in higher yielding, lower rated bonds that have a higher rate of default. The fund may invest a significant portion of its assets in securitized debt instruments, including mortgage-backed and asset-backed investments. The yields and values of these investments are sensitive to changes in interest rates, the rate of principal payments on the underlying assets and the market’s perception of the issuers. The market for these investments may be volatile and limited, which may make them difficult to buy or sell.

In the normal course of business, the fund enters into contracts that may include agreements to indemnify another party under given circumstances. The fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be, but have not yet been, made against the fund. However, the fund’s management team expects the risk of material loss to be remote.

The following is a summary of significant accounting policies consistently followed by the fund in the preparation of its financial statements. The preparation of financial statements is in conformity with accounting principles generally accepted in the United States of America and requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities in the financial statements and the reported amounts of increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates. Subsequent events after the balance sheet date through the date that the financial statements were issued, November 16, 2009, have been evaluated in the preparation of the financial statements.

A) Security valuation Investments for which market quotations are readily available are valued at the last reported sales price on their principal exchange, or official closing price for certain markets. If no sales are reported — as in the case of some securities traded over-the-counter — a security is valued at its last reported bid price. Market quotations are not considered to be readily available for certain debt obligations; such investments are valued on the basis of valuations furnished by an independent pricing service approved by the Trustees or dealers selected by Putnam Investment Management, LLC (“Putnam Management”), the fund’s manager, an indirect wholly-owned subsidiary of Putnam Investments, LLC. Such services or dealers determine valuations for normal institutional-size trading units of such securities using methods based on market transactions for comparable securiti es and various relationships, generally recognized by institutional traders, between securities (which considers such factors as security prices, yields, maturities and ratings) . Many securities markets and exchanges outside the U.S. close prior to the close of the New York Stock Exchange and therefore the closing prices for securities in such markets or on such exchanges may not fully reflect events that occur after such close but before the close of the New York Stock Exchange. Accordingly, on certain days, the fund will fair value foreign equity securities taking into account multiple factors, including movements in the U.S. securities markets. The number of days on which fair value prices will be used will depend on market activity and it is possible that fair value prices will be used by the fund to a significant extent. Securities quoted in foreign currencies, if any, are translated into U.S. dollars at the current exchange rate. To the extent a pricing service or dealer is unable to value a security or provides a valuation that Putnam Management does not believe accurately reflects the security’s fair value, the security will be valued at fair value by Putnam Management. Certain investments, including certain restricted and illiquid securities and derivatives, are also valued at fair value following procedures approved by the Trustees. Such valuations and procedures are reviewed periodically by the Trustees. Certain securities may be valued on the basis of a price provided by a single source. The fair value of securities is generally determined as the amount that the fund could reasonably expect to realize from an orderly disposition of such securities over a reasonable period of time. By its nature, a fair value price is a good faith estimate of the value of a security in a current sale and does not reflect an actual market price, which may be different by a material amount.

B) Joint trading account Pursuant to an exemptive order from the Securities and Exchange Commission (the “SEC”), the fund may transfer uninvested cash balances, including cash collateral received under security lending arrangements, into a joint trading account along with the cash of other registered investment companies and certain other accounts managed by Putnam Management. These balances may be invested in issues of short-term investments having maturities of up to 397 days for collateral received under security lending arrangements and up to 90 days for other cash investments.

C) Repurchase agreements The fund, or any joint trading account, through its custodian, receives delivery of the underlying securities, the market value of which at the time of purchase is required to be in an amount at least equal to the resale price, including accrued interest. Collateral for certain tri-party repurchase agreements is held at the counterparty’s custodian in a segregated account for the benefit of the fund and the counterparty. Putnam Management is responsible for determining that the value of these underlying securities is at all times at least equal to the resale price, including accrued interest.

D) Security transactions and related investment income Security transactions are recorded on the trade date (the date the order to buy or sell is executed). Gains or losses on securities sold are determined on the identified cost basis. Interest income is recorded on the accrual basis. Dividend income, net of applicable withholding taxes, is recognized on the ex-dividend date except that certain dividends from foreign securities, if any, are recognized as soon as the fund is informed of the ex-dividend date. Non-cash dividends, if any, are recorded at the fair market value of the securities received. Dividends representing a return of capital or capital gains, if any, are reflected as a reduction of cost and/or as a realized gain. All premiums/discounts are amortized/accreted on a yield-to-maturity basis.

Securities purchased or sold on a forward commitment or delayed delivery basis may be settled a month or more after the trade date; interest income is accrued based on the terms of the securities. Losses may arise due to changes in the market value of the underlying securities or if the counterparty does not perform under the contract.

The fund earned certain fees in connection with its senior loan purchasing activities. These fees are treated as market discount and are recorded as income in the Statement of operations.

E) Stripped securities The fund may invest in stripped securities which represent a participation in securities that may be structured in classes with rights to receive different portions of the interest and principal. Interest-only securities receive all of the interest and principal-only securities receive all of the principal. If the interest-only securities experience greater than anticipated prepayments of principal, the fund may fail to recoup fully its initial investment in these securities. Conversely, principal-only securities increase in value if prepayments are greater than anticipated and decline if prepayments are slower than anticipated. The market value of these securities is highly sensitive to changes in interest rates.

F) Foreign currency translation The accounting records of the fund are maintained in U.S. dollars. The market value of foreign securities, currency holdings, and other assets and liabilities is recorded in the books and records of the fund after translation to U.S. dollars based on the exchange rates on that day. The cost of each security is determined using historical exchange rates. Income and withholding taxes are translated at prevailing exchange

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rates when earned or incurred. The fund does not isolate that portion of realized or unrealized gains or losses resulting from changes in the foreign exchange rate on investments from fluctuations arising from changes in the market prices of the securities. Such gains and losses are included with the net realized and unrealized gain or loss on investments. Net realized gains and losses on foreign currency transactions represent net realized exchange gains or losses on closed forward currency contracts, disposition of foreign currencies, currency gains and losses realized between the trade and settlement dates on securities transactions and the difference between the amount of investment income and foreign withholding taxes recorded on the fund’s books and the U.S. dollar equivalent amounts actually received or paid. Net unrealized appreciation and depreciation of assets and liabilities in foreign currencies arise from changes in the value of open forward currency contracts and assets and liabilities other than investments at the period end, resulting from changes in the exchange rate. Investments in foreign securities involve certain risks, including those related to economic instability, unfavorable political developments, and currency fluctuations, not present with domestic investments.

G) Futures and options contracts The fund may use futures and options contracts to hedge against changes in the values of securities the fund owns, owned or expects to purchase, or for other investment purposes. The fund may also write options on swaps or securities it owns or in which it may invest to increase its current returns.

The potential risk to the fund is that the change in value of futures and options contracts may not correspond to the change in value of the hedged instruments. In addition, losses may arise from changes in the value of the underlying instruments, if there is an illiquid secondary market for the contracts, interest or exchange rates moving unexpectedly or if the counterparty to the contract is unable to perform. With futures, there is minimal counterparty credit risk to the fund since futures are exchange traded and the exchange’s clearinghouse, as counterparty to all exchange traded futures, guarantees the futures against default. Risks may exceed amounts recognized on the Statement of assets and liabilities. When the contract is closed, the fund records a realized gain or loss equal to the difference between the value of the contract at the time it was opened and the value at the time it was closed. Realized gains and losses on purchased options are included in realized gains and losses on investment securities. If a written call option is exercised, the premium originally received is recorded as an addition to sales proceeds. If a written put option is exercised, the premium originally received is recorded as a reduction to the cost of investments.

Futures contracts are valued at the quoted daily settlement prices established by the exchange on which they trade. The fund and the broker agree to exchange an amount of cash equal to the daily fluctuation in the value of the futures contract. Such receipts or payments are known as “variation margin.” Exchange traded options are valued at the last sale price or, if no sales are reported, the last bid price for purchased options and the last ask price for written options. Options traded over-the-counter are valued using prices supplied by dealers. Futures and written option contracts outstanding at period end, if any, are listed after the fund’s portfolio.

The fund had an average contract amount of approximately 3,000 on Futures contracts for the year ended September 30, 2009.

Outstanding contracts on Purchased options contracts at the year ended September 30, 2009 are indicative of the volume of activity during the period.

See Note 3 for the volume of Written options contracts activity for the year ended September 30, 2009.

H) Forward currency contracts The fund may buy and sell forward currency contracts, which are agreements between two parties to buy and sell currencies at a set price on a future date. These contracts are used to protect against a decline in value relative to the U.S. dollar of the currencies in which its portfolio securities are denominated or quoted (or an increase in the value of a currency in which securities a fund intends to buy are denominated, when a fund holds cash reserves and short term investments), or for other investment purposes. The U.S. dollar value of forward currency contracts is determined using current forward currency exchange rates supplied by a quotation service. The market value of the contract will fluctuate with changes in currency exchange rates. The contract is marked to market daily and the change in market value is recorded as an unrealized gai n or loss. When the contract is closed, the fund records a realized gain or loss equal to the difference between the value of the contract at the time it was opened and the value at the time it was closed. The fund could be exposed to risk if the value of the currency changes unfavorably, if the counterparties to the contracts are unable to meet the terms of their contracts or if the fund is unable to enter into a closing position. Risks may exceed amounts recognized on the Statement of assets and liabilities. Forward currency contracts outstanding at period end, if any, are listed after the fund’s portfolio. Outstanding contracts on Forward currency contracts at the year ended September 30, 2009 are indicative of the volume of activity during the period.

I) Total return swap contracts The fund may enter into total return swap contracts, which are arrangements to exchange a market linked return for a periodic payment, both based on a notional principal amount to help enhance the funds return and manage the fund’s exposure to credit risk. To the extent that the total return of the security, index or other financial measure underlying the transaction exceeds or falls short of the offsetting interest rate obligation, the fund will receive a payment from or make a payment to the counterparty. Total return swap contracts are marked to market daily based upon quotations from market makers and the change, if any, is recorded as an unrealized gain or loss. Payments received or made are recorded as realized gains or losses. Certain total return swap contracts may include extended effective dates. Payments related to these swap contracts are accrued based on the ter ms of the contract. The fund could be exposed to credit or market risk due to unfavorable changes in the fluctuation of interest rates or in the price of the underlying security or index, the possibility that there is no liquid market for these agreements or that the counterparty may default on its obligation to perform. The fund’s maximum risk of loss from counterparty risk, is the fair value of the contract. This risk may be mitigated by having a master netting arrangement between the fund and the counterparty. Risk of loss may exceed amounts recognized on the Statement of assets and liabilities. Total return swap contracts outstanding at period end, if any, are listed after the fund’s portfolio. The fund had an average notional amount of approximately $203,500,000 on Total return swap contracts for the year ended September 30, 2009.

J) Interest rate swap contracts The fund may enter into interest rate swap contracts, which are arrangements between two parties to exchange cash flows based on a notional principal amount, to manage the fund’s exposure to interest rates. An interest rate swap can be purchased or sold with an upfront premium. An upfront payment received by the fund is recorded as a liability on the fund’s books. An upfront payment made by the fund is recorded as an asset on the fund’s books. Interest rate swap contracts are marked to market daily based upon quotations from an independent pricing service or market makers and the change, if any, is recorded as an unrealized gain or loss. Payments received or made are recorded as realized gains or losses. Certain interest rate swap contracts may include extended effective dates. Payments related to these swap contracts are accrued based on the terms of the contract . The fund could be exposed to credit or market risk due to unfavorable changes in the fluctuation of interest rates or if the counterparty defaults on its obligation to perform. The fund’s maximum risk of loss from counterparty risk , is the fair value of the contract. This risk may be mitigated by having a master netting arrangement between the fund and the counterparty. Risk of loss may exceed amounts recognized on the Statement of assets and liabilities. Interest rate swap contracts outstanding at period end, if any, are listed after the fund’s portfolio. The fund had an

52

average notional amount of approximately $6,946,900,000 on Interest rate swap contracts for the year ended September 30, 2009.

K) Credit default contracts The fund may enter into credit default contracts to provide a measure of protection against risk of loss following a default, or other credit event in respect of issuers within an underlying index or a single issuer, or to gain credit exposure to an underlying index or issuer. In a credit default contract, the protection buyer typically makes an up front payment and a periodic stream of payments to a counterparty, the protection seller, in exchange for the right to receive a contingent payment upon the occurrence of a credit event on the reference obligation or all other equally ranked obligations of the reference entity. Credit events are contract specific but may include bankruptcy, failure to pay, restructuring and obligation acceleration. An upfront payment received by the fund, as the protection seller, is recorded as a liability on the fund’s books. An upfront payment mad e by the fund, as the protection buyer, is recorded as an asset on the fund’s books. Periodic payments received or paid by the fund are recorded as realized gains or losses. The credit default contracts are marked to market daily based upon quotations from an independent pricing service or market makers and the change, if any, is recorded as an unrealized gain or loss. Upon the occurrence of a credit event, the difference between the par value and market value of the reference obligation, net of any proportional amount of the upfront payment, is recorded as a realized gain or loss.

In addition to bearing the risk that the credit event will occur, the fund could be exposed to market risk due to unfavorable changes in interest rates or in the price of the underlying security or index or the possibility that the fund may be unable to close out its position at the same time or at the same price as if it had purchased the underlying reference obligations. In certain circumstances, the fund may enter into offsetting credit default contracts which would mitigate its risk of loss. Risks of loss may exceed amounts recognized on the Statement of assets and liabilities. The fund’s maximum risk of loss from counterparty risk, either as the protection seller or as the protection buyer, is the fair value of the contract. This risk may be mitigated by having a master netting arrangement between the fund and the counterparty. Where the fund is a seller of protection, the maximum potential amount of future payments the fund may be required t o make is equal to the notional amount of the relevant credit default contract. Credit default contracts outstanding, including their respective notional amounts at period end, if any, are listed after the fund’s portfolio. The fund had an average notional amount of approximately $240,000,000 on Credit default swap contracts for the year ended September 30, 2009.

L) Master agreements The fund is a party to ISDA (International Swap and Derivatives Association, Inc.) Master Agreements (“Master Agreements”) with certain counterparties that govern over the counter derivative and foreign exchange contracts entered into from time to time. The Master Agreements may contain provisions regarding, among other things, the parties’ general obligations, representations, agreements, collateral requirements, events of default and early termination. With respect to certain counterparties, in accordance with the terms of the Master Agreements, collateral posted to the fund is held in a segregated account by the fund’s custodian and with respect to those amounts which can be sold or repledged, are presented in the fund’s portfolio. Collateral posted to the fund which can not be sold or repledged totaled $1,624,697 at September 30, 2009. Collateral pledged b y the fund is segregated by the fund’s custodian and identified in the fund’s portfolio. Collateral can be in the form of cash or debt securities issued by the U.S. Government or related agencies or other securities as agreed to by the fund and the applicable counterparty. Collateral requirements are determined based on the fund’s net position with each counterparty. Termination events applicable to the fund may occur upon a decline in the fund’s net assets below a specified threshold over a certain period of time. Termination events applicable to counterparties may occur upon a decline in the counterparty’s long-term and short-term credit ratings below a specified level. In each case, upon occurrence, the other party may elect to terminate early and cause settlement of all derivative and foreign exchange contracts outstanding, including the payment of any losses and costs resulting from such early termination, as reasonably determined by the termi nating party. Any decision by one or more of the fund’s counterparties to elect early termination could impact the fund’s future derivative activity.

At September 30, 2009, the fund had net liability position of $16,978,202 on derivative contracts subject to the Master Agreements. Collateral posted by the fund totaled $6,324,706.

M) TBA purchase commitments The fund may enter into “TBA” (to be announced) commitments to purchase securities for a fixed unit price at a future date beyond customary settlement time. Although the unit price has been established, the principal value has not been finalized. However, it is anticipated that the amount of the commitments will not significantly differ from the principal amount. The fund holds, and maintains until settlement date, cash or high-grade debt obligations in an amount sufficient to meet the purchase price, or the fund may enter into offsetting contracts for the forward sale of other securities it owns. Income on the securities will not be earned until settlement date. TBA purchase commitments may be considered securities themselves, and involve a risk of loss if the value of the security to be purchased declines prior to the settlement date, which risk is in addition to the ris k of decline in the value of the fund’s other assets. Unsettled TBA purchase commitments are valued at fair value of the underlying securities, according to the procedures described under “Security valuation” above. The contract is marked to market daily and the change in market value is recorded by the fund as an unrealized gain or loss.

Although the fund will generally enter into TBA purchase commitments with the intention of acquiring securities for its portfolio or for delivery pursuant to options contracts it has entered into, the fund may dispose of a commitment prior to settlement if Putnam Management deems it appropriate to do so.

N) TBA sale commitments The fund may enter into TBA sale commitments to hedge its portfolio positions or to sell mortgage-backed securities it owns under delayed delivery arrangements. Proceeds of TBA sale commitments are not received until the contractual settlement date. During the time a TBA sale commitment is outstanding, equivalent deliverable securities or an offsetting TBA purchase commitment deliverable on or before the sale commitment date, are held as “cover” for the transaction.

Unsettled TBA sale commitments are valued at the fair value of the underlying securities, generally according to the procedures described under “Security valuation” above. The contract is marked to market daily and the change in market value is recorded by the fund as an unrealized gain or loss. If the TBA sale commitment is closed through the acquisition of an offsetting TBA purchase commitment, the fund realizes a gain or loss. If the fund delivers securities under the commitment, the fund realizes a gain or a loss from the sale of the securities based upon the unit price established at the date the commitment was entered into. TBA sale commitments outstanding at period end, if any, are listed after the fund’s portfolio.

O) Dollar rolls: To enhance returns, the fund may enter into dollar rolls (principally using TBAs) in which the fund sells securities for delivery in the current month and simultaneously contracts to purchase similar securities on a specified future date. During the period between the sale and subsequent purchase, the fund will not be entitled to receive income and principal payments on the securities sold. The fund will, however, retain the difference between the initial sales price and the forward price for the future purchase. The fund will also be able to earn interest on the cash proceeds that are received from the initial sale, on settlement date. The fund may be exposed to market or credit risk if the price of the security changes unfavorably or the counterparty fails to perform under the terms of the agreement.

P) Securities lending The fund may lend securities, through its agents, to qualified borrowers in order to earn additional income. The loans are

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collateralized by cash and/or securities in an amount at least equal to the market value of the securities loaned. The market value of securities loaned is determined daily and any additional required collateral is allocated to the fund on the next business day. The risk of borrower default will be borne by the fund’s agents; the fund will bear the risk of loss with respect to the investment of the cash collateral. Income from securities lending is included in investment income on the Statement of operations. At September 30, 2009, the fund had no securities out on loan.

Q) Federal taxes It is the policy of the fund to distribute all of its taxable income within the prescribed time and otherwise comply with the provisions of the Internal Revenue Code of 1986, as amended (the “Code”), applicable to regulated investment companies. It is also the intention of the fund to distribute an amount sufficient to avoid imposition of any excise tax under Section 4982 of the Code. The fund is subject to the provisions of ASC 740 Income Taxes (“ASC 740”). ASC 740 sets forth a minimum threshold for financial statement recognition of the benefit of a tax position taken or expected to be taken in a tax return. The fund did not have any unrecognized tax benefits in the accompanying financial statements. No provision has been made for federal taxes on income, capital gains or unrealized appreciatio n on securities held nor for excise tax on income and capital gains. Each of the fund’s federal tax returns for the prior three fiscal years remains subject to examination by the Internal Revenue Service and state departments of revenue.

At September 30, 2009, the fund had a capital loss carryover of $122,894,194 available to the extent allowed by the Code to offset future net capital gain, if any. The amounts of the carryovers and the expiration dates are:

Loss Carryover	Expiration
$27,431,170	September 30, 2010
47,564,236	September 30, 2011
7,342,291	September 30, 2015
11,586,218	September 30, 2016
28,970,279	September 30, 2017

Pursuant to federal income tax regulations applicable to regulated investment companies, the fund has elected to defer to its fiscal year ending September 30, 2010 $87,176,440 of losses recognized during the period November 1, 2008 to September 30, 2009.

R) Distributions to shareholders Distributions to shareholders from net investment income are recorded by the fund on the ex-dividend date. Distributions from capital gains, if any, are recorded on the ex-dividend date and paid at least annually. The amount and character of income and gains to be distributed are determined in accordance with income tax regulations, which may differ from generally accepted accounting principles. These differences include temporary and/or permanent differences of post-October loss deferrals, the expiration of a capital loss carryover, dividends payable, realized and unrealized gains and losses on certain futures contracts, income on swap contracts, and interest only securities. Reclassifications are made to the fund’s capital accounts to reflect income and gains available for distribution (or available capital loss carryovers) under income tax regulations. For the year ende d September 30, 2009, the fund reclassified $4,230,287 to increase undistributed net investment income and $24,608,806 to decrease paid-in-capital, with a decrease to accumulated net realized losses of $20,378,519.

The tax basis components of distributable earnings and the federal tax cost as of September 30, 2009 were as follows:

Unrealized appreciation	$45,942,859
Unrealized depreciation	(43,441,168)
Net unrealized appreciation	2,501,691
Undistributed ordinary income	34,544,182
Capital loss carryforward	(122,894,194)
Post-October loss	(87,176,440)
Cost for federal income tax purposes	$440,895,760

Note 2: Management fee, administrative services and other transactions

The fund pays Putnam Management for management and investment advisory services quarterly based on the average net assets (including assets, but excluding liabilities, attributable to leverage for investment purposes) of the fund. The fee is based on the following annual rates: 0.75% of the first $500 million of average weekly assets, 0.65% of the next $500 million, 0.60% of the next $500 million and 0.55% of the next $5 billion, with additional breakpoints at higher asset levels.

Putnam Investments Limited (“PIL”), an affiliate of Putnam Management, is authorized by the Trustees to manage a separate portion of the assets of the fund as determined by Putnam Management from time to time. Putnam Management pays a quarterly sub-management fee to PIL for its services at an annual rate of 0.40% of the average net assets (including assets, but excluding liabilities, attributable to leverage for investment purposes) of the portion of the fund managed by PIL.

On September 15, 2008, the fund terminated its outstanding derivatives contracts with Lehman Brothers Special Financing, Inc. (“LBSF”) in connection with the bankruptcy filing of LBSF’s parent company, Lehman Brothers Holdings, Inc. On September 26, 2008, the fund entered into a receivable purchase agreement (“Agreement”) with another registered investment company (the “Seller”) managed by Putnam Management. Under the Agreement, the Seller sold to the fund the right to receive, in the aggregate, $655,823 in net payments from LBSF in connection with certain terminated derivatives transactions (the “Receivable”), in exchange for an initial payment plus (or minus) additional amounts based on the fund’s ultimate realized gain (or loss) with respect to the Receivable. The Receivable will be offset against the fund’s net payable to LBSF and is included in the Statement of assets and liabilities in Payabl e for investments purchased. Future payments under the Agreement are valued at fair value following procedures approved by the Trustees and are included in the Statement of assets and liabilities. All remaining payments under the Agreement will be recorded as realized gain or loss. The fund’s net payable to LBSF was calculated in accordance with the fund’s master contract with LBSF. The fund has accrued interest on the net payable, which is included in the Statement of operations in Interest expense. Putnam Management currently is in discussions with LBSF regarding resolution of amounts payable to LBSF. Amounts recorded are estimates and final payments may differ from these estimates by a material amount.

The fund reimburses Putnam Management an allocated amount for the compensation and related expenses of certain officers of the fund and their staff who provide administrative services to the fund. The aggregate amount of all such reimbursements is determined annually by the Trustees.

Custodial functions for the fund’s assets are provided by State Street Bank and Trust Company (“State Street”). Custody fees are based on the fund’s asset level, the number of its security holdings and transaction volumes.

Putnam Investor Services, a division of Putnam Fiduciary Trust Company (“PFTC”), which is an affiliate of Putnam Management, provided investor servicing agent functions to the fund. Putnam Investor Services was paid a monthly fee for investor servicing at an annual rate of 0.05% of the fund’s average net assets. The amounts incurred for investor servicing agent functions provided by PFTC during the year ended September 30, 2009 are included in Investor servicing fees in the Statement of operations.

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The fund has entered into expense offset arrangements with PFTC and State Street whereby PFTC’s and State Street’s fees are reduced by credits allowed on cash balances. For the year ended September 30, 2009, the fund’s expenses were reduced by $3,683 under the expense offset arrangements.

Each independent Trustee of the fund receives an annual Trustee fee, of which $281, as a quarterly retainer, has been allocated to the fund, and an additional fee for each Trustees meeting attended. Trustees receive additional fees for attendance at certain committee meetings and industry seminars and for certain compliance-related matters. Trustees also are reimbursed for expenses they incur relating to their services as Trustees.

The fund has adopted a Trustee Fee Deferral Plan (the “Deferral Plan”) which allows the Trustees to defer the receipt of all or a portion of Trustees fees payable on or after July 1, 1995. The deferred fees remain invested in certain Putnam funds until distribution in accordance with the Deferral Plan.

The fund has adopted an unfunded noncontributory defined benefit pension plan (the “Pension Plan”) covering all Trustees of the fund who have served as a Trustee for at least five years and were first elected prior to 2004. Benefits under the Pension Plan are equal to 50% of the Trustee’s average annual attendance and retainer fees for the three years ended December 31, 2005. The retirement benefit is payable during a Trustee’s lifetime, beginning the year following retirement, for the number of years of service through December 31, 2006. Pension expense for the fund is included in Trustee compensation and expenses in the Statement of operations. Accrued pension liability is included in Payable for Trustee compensation and expenses in the Statement of assets and liabilities. The Trustees have terminated the Pension Plan with respect to any Trustee first elected after 2003.

Note 3: Purchases and sales of securities

During the year ended September 30, 2009, cost of purchases and proceeds from sales of investment securities other than short-term investments aggregated $703,110,312 and $753,864,209, respectively. There were no purchases or sales of U.S. government securities.

Written option transactions during the year ended September 30, 2009 are summarized as follows:

		Contract	Premiums
		Amounts	Received
Written options outstanding
at beginning of year	EUR	—	—
	USD	55,081,000	$2,141,204
Options opened	EUR	29,182,000	1,265,518
	USD	431,038,000	24,464,228
Options expired	EUR	—	—
	USD	2,120,000	63,336
Options closed	EUR	29,182,000	1,265,518
	USD	—	—
Written options outstanding
at end of year	EUR	—	—
	USD	483,999,000	$26,542,096

Note 4: Share repurchase program

In September 2009, the Trustees approved the renewal of the repurchase program to allow the fund to repurchase up to 10% of its outstanding common shares over the 12 month period ending October 7, 2010 (based on shares outstanding as of October 7, 2009). Prior to this renewal, the Trustees had approved a repurchase program to allow the fund to repurchase up to 10% of its outstanding common shares over the 12 month period ending October 7, 2009 (based on shares outstanding as of October 7, 2008) and prior to that, to allow the fund to repurchase up to 10% of its outstanding common shares over the 12 month period ending October 7, 2008 (based on shares outstanding as of October 5, 2007). Repurchases are made when the fund’s shares are trading at less than net asset value and in accordance with procedures approved by the fund’s Trustees.

For the year ended September 30, 2009, the fund repurchased 2,212,356 common shares for an aggregate purchase price of $10,711,596, which reflects a weighted-average discount from net asset value per share of 8.41%.

Note 5: Summary of derivative activity

The following is a summary of the market values of derivative instruments as of September 30, 2009:

	Asset derivatives		Liability derivatives
Derivatives not accounted for
as hedging instruments under	Statement of assets and		Statement of assets and
ASC 815	liabilities location	Market value	liabilities location	Market value
Credit contracts	Receivables	$872,935	Payables	$13,506,333
Foreign exchange contracts	Receivables	2,139,224	Payables	583,399
Interest rate contracts	Receivables	107,167,746	Payables	103,144,041
Total		$110,179,905		$117,233,773

The following is a summary of realized and unrealized gains or losses of derivative instruments on the Statement of operations for the year ended September 30, 2009 (see Note 1):

Change in Unrealized Appreciation or (Depreciation) on Derivatives Recognized in Income

Derivatives not accounted
for as hedging instruments			Forward currency
under ASC 815	Options	Futures	contracts	Swaps	Total
Credit contracts	$—	$—	$—	$(720,116)	$(720,116)
Foreign exchange contracts	—	—	3,263,306	—	3,263,306
Interest rate contracts	5,281,268	7,184,616	—	58,911,930	71,377,814
Total	$5,281,268	$7,184,616	$3,263,306	$58,191,814	$73,921,004

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Amount of Realized Gain (Loss) on Derivatives Recognized in Income

Derivatives not accounted
for as hedging instruments			Forward currency
under ASC 815	Options	Futures	contracts	Swaps	Total
Credit contracts	$—	$—	$—	$(32,325,288)	$(32,325,288)
Foreign exchange contracts	—	—	134,117	—	134,117
Interest rate contracts	(945,519)	(27,690,473)	—	(18,638,472)	(47,274,464)
Total	$(945,519)	$(27,690,473)	$134,117	$(50,963,760)	$(79,465,636)

Note 6: Investment in Putnam Money Market Liquidity Fund

The fund invested in Putnam Money Market Liquidity Fund, an open-end management investment company managed by Putnam Management. Investments in Putnam Money Market Liquidity Fund are valued at its closing net asset value each business day. Income distributions earned by the fund are recorded as interest income in the Statement of operations and totaled $25,038 for the year ended September 30, 2009. During the year ended September 30, 2009, cost of purchases and proceeds of sales of investments in Putnam Money Market Liquidity Fund aggregated $181,933,658 and $164,613,723, respectively. Management fees charged to Putnam Money Market Liquidity Fund have been waived by Putnam Management.

Note 7: Senior loan commitments

Senior loans are purchased or sold on a when-issued or delayed delivery basis and may be settled a month or more after the trade date, which from time to time can delay the actual investment of available cash balances; interest income is accrued based on the terms of the securities. Senior loans can be acquired through an agent, by assignment from another holder of the loan, or as a participation interest in another holder’s portion of the loan. When the fund invests in a loan or participation, the fund is subject to the risk that an intermediate participant between the fund and the borrower will fail to meet its obligations to the fund, in addition to the risk that the borrower under the loan may default on its obligations.

Note 8: Regulatory matters and litigation

In late 2003 and 2004, Putnam Management settled charges brought by the Securities and Exchange Commission (the “SEC”) and the Massachusetts Securities Division in connection with excessive short-term trading in Putnam funds. Distribution of payments from Putnam Management to certain open-end Putnam funds and their shareholders is expected to be completed in the next several months. These allegations and related matters have served as the general basis for certain lawsuits, including purported class action lawsuits against Putnam Management and, in a limited number of cases, some Putnam funds. Putnam Management believes that these lawsuits will have no material adverse effect on the funds or on Putnam Management’s ability to provide investment management services. In addition, Putnam Management has agreed to bear any costs incurred by the Putnam funds as a result of these matters.

Note 9: Market and credit risk

In the normal course of business, the fund trades financial instruments and enters into financial transactions where risk of potential loss exists due to changes in the market (market risk) or failure of the contracting party to the transaction to perform (credit risk). The fund may be exposed to additional credit risk that an institution or other entity with which the fund has unsettled or open transactions will default.

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Federal tax information (unaudited)

The fund designated 0.03% of ordinary income distributions as qualifying for the dividends received deduction for corporations.

For its tax year ended September 30, 2009, the fund hereby designates 0.03%, or the maximum amount allowable, of its taxable ordinary income distributions as qualified dividends taxed at the individual net capital gain rates.

For the tax year ended September  30, 2009, pursuant to §871(k) of the Internal Revenue Code, the fund hereby designates $24,948,245 of distributions paid as qualifying to be taxed as interest-related dividends.

The Form 1099 you receive in January 2010 will show the tax status of all distributions paid to your account in calendar 2009.

Compliance certifications (unaudited)

On February 27, 2009, your fund submitted a CEO annual certification to the New York Stock Exchange (“NYSE”) on which the fund’s principal executive officer certified that he was not aware, as of that date, of any violation by the fund of the NYSE’s Corporate Governance listing standards. In addition, as required by Section 302 of the Sarbanes-Oxley Act of 2002 and related SEC rules, the fund’s principal executive and principal financial officers have made quarterly certifications, included in filings with the SEC on Forms N-CSR and N-Q, relating to, among other things, the fund’s disclosure controls and procedures and internal control over financial reporting.

Shareholder meeting results (unaudited)

January 29, 2009 annual meeting

At the meeting, each of the nominees for Trustees was elected, as follows:

	Votes for	Votes withheld
Jameson A. Baxter	52,770,644	5,428,717
Charles B. Curtis	52,783,549	5,415,812
Robert J, Darretta	52,751,878	5,447,483
Myra R. Drucker	52,772,846	5,426,515
Charles E. Haldeman, Jr.	52,730,313	5,469,048
John A. Hill	52,770,297	5,429,064
Paul L. Joskow	52,751,987	5,447,374
Elizabeth T. Kennan	52,747,239	5,452,122
Kenneth R. Leibler	52,735,929	5,463,432
Robert E. Patterson	52,753,000	5,446,361
George Putnam, III	52,666,563	5,532,798
Robert L. Reynolds	52,643,403	5,555,958
Richard B. Worley	52,779,617	5,419,744

All tabulations are rounded to the nearest whole number.

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About the Trustees

Ravi Akhoury

Born 1947, Trustee since 2009

Mr. Akhoury serves as Advisor to New York Life Insurance Company. He is also a Director of Jacob Ballas Capital India (a non-banking finance company focused on private equity advisory services) and is a member of its Compensation Committee. He also serves as a Trustee of American India Foundation and of the Rubin Museum.

Previously, Mr. Akhoury was a Director and on the Compensation Committee of MaxIndia/New York Life Insurance Company in India. He was also Vice President and Investment Policy Committee Member of Fischer, Francis, Trees and Watts (a fixed-income portfolio management firm). He has also served on the Board of Bharti Telecom (an Indian telecommunications company), serving as a member of its Audit and Compensation committees, and as a member of the Audit Committee on the Board of Thompson Press (a publishing company). From 1992 to 2007, he was Chairman and CEO of MacKay Shields, a multi-product investment management firm with over $40 billion in assets under management.

Mr. Akhoury graduated from the Indian Institute of Technology with a B.S. in Engineering and obtained an M.S. in Quantitative Methods from SUNY at Stony Brook.

Jameson A. Baxter

Born 1943, Trustee since 1994 and Vice Chairman since 2005

Ms. Baxter is the President of Baxter Associates, Inc., a private investment firm.

Ms. Baxter serves as a Director of ASHTA Chemicals, Inc., and the Mutual Fund Directors Forum. Until 2007, she was a Director of Banta Corporation (a printing and supply chain management company), Ryerson, Inc. (a metals service corporation), and Advocate Health Care. Until 2004, she was a Director of BoardSource (formerly the National Center for Nonprofit Boards), and until 2002, she was a Director of Intermatic Corporation (a manufacturer of energy control products). She is Chairman Emeritus of the Board of Trustees of Mount Holyoke College, having served as Chairman for five years.

Ms. Baxter has held various positions in investment banking and corporate finance, including Vice President of and Consultant to First Boston Corporation and Vice President and Principal of the Regency Group. She is a graduate of Mount Holyoke College.

Charles B. Curtis

Born 1940, Trustee since 2001

Mr. Curtis is President and Chief Operating Officer of the Nuclear Threat Initiative (a private foundation dealing with national security issues), and serves as Senior Advisor to the United Nations Foundation.

Mr. Curtis is a member of the Council on Foreign Relations and the National Petroleum Council. He also serves as Director of Edison International and Southern California Edison. Until 2006, Mr. Curtis served as a member of the Trustee Advisory Council of the Applied Physics Laboratory, Johns Hopkins University.

From August 1997 to December 1999, Mr. Curtis was a Partner at Hogan & Hartson LLP, an international law firm headquartered in Washington, D.C. Prior to May 1997, Mr. Curtis was Deputy Secretary of Energy and Under Secretary of the U.S. Department of Energy. He was a founding member of the law firm of Van Ness Feldman. Mr. Curtis served as Chairman of the Federal Energy Regulatory Commission from 1977 to 1981 and has held positions on the staff of the U.S. House of Representatives, the U.S. Treasury Department, and the Securities and Exchange Commission.

Robert J. Darretta

Born 1946, Trustee since 2007

Mr. Darretta serves as Director of United-Health Group, a diversified health-care company.

Until April 2007, Mr. Darretta was Vice Chairman of the Board of Directors of Johnson & Johnson, one of the world’s largest and most broadly based health-care companies. Prior to 2007, he had responsibility for Johnson & Johnson’s finance, investor relations, information technology, and procurement function. He served as Johnson & Johnson Chief Financial Officer for a decade, prior to which he spent two years as Treasurer of the corporation and over ten years leading various Johnson & Johnson operating companies.

Mr. Darretta received a B.S. in Economics from Villanova University.

Myra R. Drucker

Born 1948, Trustee since 2004

Ms. Drucker is Chair of the Board of Trustees of Commonfund (a not-for-profit firm managing assets for educational endowments and foundations), Vice Chair of the Board of Trustees of Sarah Lawrence College, and a member of the Investment Committee of the Kresge Foundation (a charitable trust). She is also a Director of Interactive Data Corporation (a provider of financial market data and analytics to financial institutions and investors).

Ms. Drucker is an ex-officio member of the New York Stock Exchange Pension Managers Advisory Committee, having served as Chair for seven years. She serves as an advisor to RCM Capital Management (an investment management firm) and to the Employee Benefits Investment Committee of The Boeing Company (an aerospace firm).

From November 2001 until August 2004, Ms. Drucker was Managing Director and a member of the Board of Directors of General Motors Asset Management and Chief Investment Officer of General Motors Trust Bank. From December 1992 to November 2001, Ms. Drucker served as Chief Investment Officer of Xerox Corporation (a document company).

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Prior to December 1992, Ms. Drucker was Staff Vice President and Director of Trust Investments for International Paper (a paper and packaging company).

Ms. Drucker received a B.A. in Literature and Psychology from Sarah Lawrence College and pursued graduate studies in economics, statistics, and portfolio theory at Temple University.

John A. Hill

Born 1942, Trustee since 1985 and Chairman since 2000

Mr. Hill is founder and Vice-Chairman of First Reserve Corporation, the leading private equity buyout firm specializing in the worldwide energy industry, with offices in Greenwich, Connecticut; Houston, Texas; London, England; and Shanghai, China. The firm’s investments on behalf of some of the nation’s largest pension and endowment funds are currently concentrated in 31 companies with annual revenues in excess of $15 billion, which employ over 100,000 people in 23 countries.

Mr. Hill is a Director of Devon Energy Corporation and various private companies owned by First Reserve, and serves as a Trustee of Sarah Lawrence College where he serves as Chairman and also chairs the Investment Committee. He is also a member of the Advisory Board of the Millstein Center for Corporate Governance and Performance at the Yale School of Management.

Prior to forming First Reserve in 1983, Mr. Hill served as President of F. Eberstadt and Company, an investment banking and investment management firm. Between 1969 and 1976, Mr. Hill held various senior positions in Washington, D.C. with the federal government, including Deputy Associate Director of the Office of Management and Budget and Deputy Administrator of the Federal Energy Administration during the Ford Administration.

Born and raised in Midland, Texas, he received his B.A. in Economics from Southern Methodist University and pursued graduate studies as a Woodrow Wilson Fellow.

Paul L. Joskow

Born 1947, Trustee since 1997

Dr. Joskow is an economist and President of the Alfred P. Sloan Foundation (a philanthropic institution focused primarily on research and education on issues related to science, technology, and economic performance). He is on leave from his position as the Elizabeth and James Killian Professor of Economics and Management at the Massachusetts Institute of Technology (MIT), where he has been on the faculty since 1972. Dr. Joskow was the Director of the Center for Energy and Environmental Policy Research at MIT from 1999 through 2007.

Dr. Joskow serves as a Trustee of Yale University, as a Director of TransCanada Corporation (an energy company focused on natural gas transmission and power services) and of Exelon Corporation (an energy company focused on power services), and as a member of the Board of Overseers of the Boston Symphony Orchestra. Prior to August 2007, he served as a Director of National Grid (a UK-based holding company with interests in electric and gas transmission and distribution and telecommunications infrastructure). Prior to July 2006, he served as President of the Yale University Council. Prior to February 2005, he served on the board of the White-head Institute for Biomedical Research (a non-profit research institution). Prior to February 2002, he was a Director of State Farm Indemnity Company (an automobile insurance company), and prior to March 2000, he was a Director of New England Electric System (a public utility holding company).

Dr. Joskow has published six books and numerous articles on industrial organization, government regulation of industry, and competition policy. He is active in industry restructuring, environmental, energy, competition, and privatization policies —serving as an advisor to governments and corporations worldwide. Dr. Joskow holds a Ph.D. and M.Phil. from Yale University and a B.A. from Cornell University.

Elizabeth T. Kennan

Born 1938, Trustee since 1992

Dr. Kennan is a Partner of Cambus-Kenneth Farm (thoroughbred horse and cattle breeding). She is President Emeritus of Mount Holyoke College.

Dr. Kennan served as Chairman and is now Lead Director of Northeast Utilities. She is a Trustee of the National Trust for Historic Preservation and of Centre College. Until 2006, she was a member of The Trustees of Reservations. Prior to 2001, Dr. Kennan served on the oversight committee of the Folger Shakespeare Library. Prior to June 2005, she was a Director of Talbots, Inc., and she has served as Director on a number of other boards, including Bell Atlantic, Chastain Real Estate, Shawmut Bank, Berkshire Life Insurance, and Kentucky Home Life Insurance. Dr. Kennan has also served as President of Five Colleges Incorporated and as a Trustee of the University of Notre Dame, and is active in various educational and civic associations.

As a member of the faculty of Catholic University for twelve years, until 1978, Dr. Kennan directed the post-doctoral program in Patristic and Medieval Studies, taught history, and published numerous articles and two books. Dr. Kennan holds a Ph.D. from the University of Washington in Seattle, an M.A. from Oxford University, and an A.B. from Mount Holyoke College. She holds several honorary doctorates.

Kenneth R. Leibler

Born 1949, Trustee since 2006

Mr. Leibler is a founder and former Chairman of the Boston Options Exchange, an electronic marketplace for the trading of derivative securities.

Mr. Leibler currently serves as a Trustee of Beth Israel Deaconess Hospital in Boston. He is also Lead Director of Ruder Finn Group, a global communications and advertising firm, and a Director of Northeast Utilities, which operates New

59

England’s largest energy delivery system. Prior to December 2006, he served as a Director of the Optimum Funds group. Prior to October 2006, he served as a Director of ISO New England, the organization responsible for the operation of the electric generation system in the New England states. Prior to 2000, Mr. Leibler was a Director of the Investment Company Institute in Washington, D.C.

Prior to January 2005, Mr. Leibler served as Chairman and Chief Executive Officer of the Boston Stock Exchange. Prior to January 2000, he served as President and Chief Executive Officer of Liberty Financial Companies, a publicly traded diversified asset management organization. Prior to June 1990, Mr. Leibler served as President and Chief Operating Officer of the American Stock Exchange (AMEX), and at the time was the youngest person in AMEX history to hold the title of President. Prior to serving as AMEX President, he held the position of Chief Financial Officer, and headed its management and marketing operations. Mr. Leibler graduated with a degree in Economics from Syracuse University.

Robert E. Patterson

Born 1945, Trustee since 1984

Mr. Patterson is Senior Partner of Cabot Properties, LP and Chairman of Cabot Properties, Inc. (a private equity firm investing in commercial real estate).

Mr. Patterson serves as Chairman Emeritus and Trustee of the Joslin Diabetes Center. Prior to June 2003, he was a Trustee of the Sea Education Association. Prior to December 2001, Mr. Patterson was President and Trustee of Cabot Industrial Trust (a publicly traded real estate investment trust). Prior to February 1998, he was Executive Vice President and Director of Acquisitions of Cabot Partners Limited Partnership (a registered investment adviser involved in institutional real estate investments). Prior to 1990, he served as Executive Vice President of Cabot, Cabot & Forbes Realty Advisors, Inc. (the predecessor company of Cabot Partners).

Mr. Patterson practiced law and held various positions in state government, and was the founding Executive Director of the Massachusetts Industrial Finance Agency. Mr. Patterson is a graduate of Harvard College and Harvard Law School.

George Putnam, III

Born 1951, Trustee since 1984

Mr. Putnam is Chairman of New Generation Research, Inc. (a publisher of financial advisory and other research services), and President of New Generation Advisors, LLC (a registered investment adviser to private funds). Mr. Putnam founded the New Generation companies in 1986.

Mr. Putnam is a Director of The Boston Family Office, LLC (a registered investment adviser). He is a Trustee of St. Mark’s School, a Trustee of Epiphany School, and a Trustee of the Marine Biological Laboratory in Woods Hole, Massachusetts. Until 2006, he was a Trustee of Shore Country Day School, and until 2002, was a Trustee of the Sea Education Association.

Mr. Putnam previously worked as an attorney with the law firm of Dechert LLP (formerly known as Dechert Price & Rhoads) in Philadelphia. He is a graduate of Harvard College, Harvard Business School, and Harvard Law School.

Robert L. Reynolds*

Born 1952, Trustee since 2008 and President of the Putnam Funds since July 2009

Mr. Reynolds is President and Chief Executive Officer of Putnam Investments, a member of Putnam Investments’ Executive Board of Directors, and President of the Putnam Funds. He has more than 30 years of investment and financial services experience.

Prior to joining Putnam Investments in 2008, Mr. Reynolds was Vice Chairman and Chief Operating Officer of Fidelity Investments from 2000 to 2007. During this time, he served on the Board of Directors for FMR Corporation, Fidelity Investments Insurance Ltd., Fidelity Investments Canada Ltd., and Fidelity Management Trust Company. He was also a Trustee of the Fidelity Family of Funds. From 1984 to 2000, Mr. Reynolds served in a number of increasingly responsible leadership roles at Fidelity.

Mr. Reynolds serves on several not-for-profit boards, including those of the West Virginia University Foundation, Concord Museum, Dana-Farber Cancer Institute, Lahey Clinic, and Initiative for a Competitive Inner City in Boston. He is a member of the Chief Executives Club of Boston, the National Innovation Initiative, and the Council on Competitiveness.

Mr. Reynolds received a B.S. in Business Administration/Finance from West Virginia University.

W. Thomas Stephens

Born 1942, Trustee since 2009

Mr. Stephens retired as Chairman and Chief Executive Officer of Boise Cascade, L.L.C. (a paper, forest products and timberland assets company) in December 2008.

Mr. Stephens is a Director of TransCanada Pipelines, Ltd. (an energy infrastructure company). From 1997 to 2008, Mr. Stephens served as a Trustee on the Board of the Putnam Funds, which he rejoined as a Trustee in 2009. Until 2004, Mr. Stephens was a Director of Xcel Energy Incorporated (a public utility company), Qwest Communications and Norske Canada, Inc. (a paper manufacturer). Until 2003, Mr. Stephens was a Director of Mail-Well, Inc. (a diversified printing company). He served as Chairman of Mail-Well until 2001 and as CEO of MacMillan-Bloedel, Ltd. (a forest products company) until 1999.

Prior to 1996, Mr. Stephens was Chairman and Chief Executive Officer of Johns Manville Corporation. He holds B.S. and M.S. degrees from the University of Arkansas.

Richard B. Worley

Born 1945, Trustee since 2004

Mr. Worley is Managing Partner of Permit Capital LLC, an investment management firm.

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Mr. Worley serves as a Trustee of the University of Pennsylvania Medical Center, The Robert Wood Johnson Foundation (a philanthropic organization devoted to health-care issues), and the National Constitution Center. He is also a Director of The Colonial Williamsburg Foundation (a historical preservation organization), and the Philadelphia Orchestra Association. Mr. Worley also serves on the investment committees of Mount Holyoke College and World Wildlife Fund (a wildlife conservation organization).

Prior to joining Permit Capital LLC in 2002, Mr. Worley served as President, Chief Executive Officer, and Chief Investment Officer of Morgan Stanley Dean Witter Investment Management and as a Managing Director of Morgan Stanley, a financial services firm. Mr. Worley also was the Chairman of Miller Anderson & Sherrerd, an investment management firm that was acquired by Morgan Stanley in 1996.

Mr. Worley holds a B.S. degree from the University of Tennessee and pursued graduate studies in economics at the University of Texas.

The address of each Trustee is One Post Office Square, Boston, MA 02109.

As of September 30, 2009, there were over 100 Putnam funds. All Trustees serve as Trustees of all Putnam funds.

Each Trustee serves for an indefinite term, until his or her resignation, retirement at age 72, death, or removal.

* Trustee who is an “interested person” (as defined in the Investment Company Act of 1940) of the fund, Putnam Management, and/or Putnam Retail Management. Mr. Reynolds is President and Chief Executive Officer of Putnam Investments, as well as the President of your fund and each of the other Putnam funds.

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Officers

In addition to Robert L. Reynolds, the other officers of the fund are shown below:

Charles E. Porter (Born 1938)	James P. Pappas (Born 1953)	Wanda M. McManus (Born 1947)
Executive Vice President, Principal	Vice President	Vice President, Senior Associate
Executive Officer, Associate Treasurer,	Since 2004	Treasurer and Assistant Clerk
and Compliance Liaison	Managing Director, Putnam Investments	Since 2005
Since 1989	and Putnam Management
		Nancy E. Florek (Born 1957)
Jonathan S. Horwitz (Born 1955)	Francis J. McNamara, III (Born 1955)	Vice President, Assistant Clerk,
Senior Vice President and Treasurer	Vice President and Chief Legal Officer	Assistant Treasurer and Proxy Manager
Since 2004	Since 2004	Since 2005
	Senior Managing Director, Putnam
Steven D. Krichmar (Born 1958)	Investments, Putnam Management and
Vice President and	Putnam Retail Management
Principal Financial Officer
Since 2002	Robert R. Leveille (Born 1969)
Senior Managing Director,	Vice President and
Putnam Investments	Chief Compliance Officer
	Since 2007
Janet C. Smith (Born 1965)	Managing Director, Putnam Investments,
Vice President, Principal Accounting	Putnam Management, and Putnam
Officer and Assistant Treasurer	Retail Management
Since 2007
Managing Director, Putnam Investments	Mark C. Trenchard (Born 1962)
and Putnam Management	Vice President and
	BSA Compliance Officer
Susan G. Malloy (Born 1957)	Since 2002
Vice President and Assistant Treasurer	Managing Director, Putnam Investments
Since 2007
Managing Director, Putnam Investments	Judith Cohen (Born 1945)
	Vice President,
Beth S. Mazor (Born 1958)	Clerk and Assistant Treasurer
Vice President	Since 1993
Since 2002
Managing Director, Putnam Investments

The principal occupations of the officers for the past five years have been with the employers as shown above although in some cases, they have held different positions with such employers. The address of each Officer is One Post Office Square, Boston, MA 02109.

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Fund information

Founded over 70 years ago, Putnam Investments was built around the concept that a balance between risk and reward is the hallmark of a well-rounded financial program. We manage over 100 funds across income, value, blend, growth, asset allocation, absolute return, and global sector categories.

Investment Manager	Kenneth R. Leibler	Francis J. McNamara, III
Putnam Investment	Robert E. Patterson	Vice President and Chief Legal Officer
Management, LLC	George Putnam, III
One Post Office Square	Robert L. Reynolds	Robert R. Leveille
Boston, MA 02109	W. Thomas Stephens	Vice President and Chief
	Richard B. Worley	Compliance Officer
Investment Sub-Manager
Putnam Investments Limited	Officers	Mark C. Trenchard
57–59 St James’s Street	Robert L. Reynolds	Vice President and BSA Compliance Officer
London, England SW1A 1LD	President
		Judith Cohen
Marketing Services	Charles E. Porter	Vice President, Clerk and
Putnam Retail Management	Executive Vice President, Principal	Assistant Treasurer
One Post Office Square	Executive Officer, Associate Treasurer and
Boston, MA 02109	Compliance Liaison	Wanda M. McManus
		Vice President, Senior Associate Treasurer
Custodian	Jonathan S. Horwitz	and Assistant Clerk
State Street Bank and Trust Company	Senior Vice President and Treasurer
		Nancy E. Florek
Legal Counsel	Steven D. Krichmar	Vice President, Assistant Clerk, Assistant
Ropes & Gray LLP	Vice President and Principal	Treasurer and Proxy Manager
	Financial Officer
Independent Registered Public
KPMG LLP	Janet C. Smith
	Vice President, Principal Accounting
Trustees	Officer and Assistant Treasurer
John A. Hill, Chairman
Jameson A. Baxter, Vice Chairman	Susan G. Malloy
Ravi Akhoury	Vice President and Assistant Treasurer
Charles B. Curtis
Robert J. Darretta	Beth S. Mazor
Myra R. Drucker	Vice President
Paul L. Joskow
Elizabeth T. Kennan	James P. Pappas
	Vice President

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Call 1-800-225-1581 weekdays between 8:30 a.m. and 8:00 p.m. or on Saturday between 9:00 a.m. and 5:00 p.m. Eastern Time, or visit our Web site (putnam.com) anytime for up-to-date information about the fund’s NAV.

Item 2. Code of Ethics:

(a) The Fund’s principal executive, financial and accounting officers are employees of Putnam Investment Management, LLC, the Fund's investment manager. As such they are subject to a comprehensive Code of Ethics adopted and administered by Putnam Investments which is designed to protect the interests of the firm and its clients. The Fund has adopted a Code of Ethics which incorporates the Code of Ethics of Putnam Investments with respect to all of its officers and Trustees who are employees of Putnam Investment Management, LLC. For this reason, the Fund has not adopted a separate code of ethics governing its principal executive, financial and accounting officers.

(c) In May 2008, the Code of Ethics of Putnam Investment Management, LLC was updated in its entirety to include the amendments adopted in August 2007 as well as a several additional technical, administrative and non-substantive changes. In May of 2009, the Code of Ethics of Putnam Investment Management, LLC was amended to reflect that all employees will now be subject to a 90-day blackout restriction on holding Putnam open-end funds, except for portfolio managers and their supervisors (and each of their immediate family members), who will be subject to a one-year blackout restriction on the funds that they manage or supervise.

Item 3. Audit Committee Financial Expert:

The Funds' Audit and Compliance Committee is comprised solely of Trustees who are "independent" (as such term has been defined by the Securities and Exchange Commission ("SEC") in regulations implementing Section 407 of the Sarbanes-Oxley Act (the "Regulations")). The Trustees believe that each of the members of the Audit and Compliance Committee also possess a combination of knowledge and experience with respect to financial accounting matters, as well as other attributes, that qualify them for service on the Committee. In addition, the Trustees have determined that each of Mr. Patterson, Mr. Leibler, Mr. Hill, Mr. Darretta and Mr. Stephens qualifies as an "audit committee financial expert" (as such term has been defined by the Regulations) based on their review of his pertinent experience and education. The SEC has stated that the designation or identification of a person as an audit committee financial expert pursuant to this Item 3 of Form N-CSR do es not impose on such person any duties, obligations or liability that are greater than the duties, obligations and liability imposed on such person as a member of the Audit and Compliance Committee and the Board of Trustees in the absence of such designation or identification.

Item 4. Principal Accountant Fees and Services:

The following table presents fees billed in each of the last two fiscal years for services rendered to the fund by the fund’s independent auditor:

Fiscal		Audit-
year	Audit	Related	Tax	All Other
ended	Fees	Fees	Fees	Fees
September 30, 2009	$87,993	$--	$5,800	$-
September 30, 2008	$89,000	$--	$6,000	$-

For the fiscal years ended September 30, 2009 and September 30, 2008, the fund’s independent auditor billed aggregate non-audit fees in the amounts of $5,800 and $74,733 respectively, to the fund, Putnam Management and any entity controlling, controlled by or under common control with Putnam Management that provides ongoing services to the fund.

Audit Fees represent fees billed for the fund's last two fiscal years relating to the audit and review of the financial statements included in annual reports and registration statements, and other services that are normally provided in connection with statutory and regulatory filings or engagements.

Audit-Related Fees represent fees billed in the fund’s last two fiscal years for services traditionally performed by the fund’s auditor, including accounting consultation for proposed transactions or concerning financial accounting and reporting standards and other audit or attest services not required by statute or regulation.

Tax Fees represent fees billed in the fund’s last two fiscal years for tax compliance, tax planning and tax advice services. Tax planning and tax advice services include assistance with tax audits, employee benefit plans and requests for rulings or technical advice from taxing authorities.

Pre-Approval Policies of the Audit and Compliance Committee. The Audit and Compliance Committee of the Putnam funds has determined that, as a matter of policy, all work performed for the funds by the funds’ independent auditors will be pre-approved by the Committee itself and thus will generally not be subject to pre-approval procedures.

The Audit and Compliance Committee also has adopted a policy to pre-approve the engagement by Putnam Management and certain of its affiliates of the funds’ independent auditors, even in circumstances where pre-approval is not required by applicable law. Any such requests by Putnam Management or certain of its affiliates are typically submitted in writing to the Committee and explain, among other things, the nature of the proposed engagement, the estimated fees, and why this work should be performed by that particular audit firm as opposed to another one. In reviewing such requests, the Committee considers, among other things, whether the provision of such services by the audit firm are compatible with the independence of the audit firm.

The following table presents fees billed by the fund’s independent auditor for services required to be approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X.

Fiscal	Audit-		All	Total
year	Related	Tax	Other	Non-Audit
ended	Fees	Fees	Fees	Fees
September 30, 2009	$ -	$ -	$ -	$ -
September 30, 2008	$ -	$ -	$ -	$ -

Item 5. Audit Committee of Listed Registrants

(a) The fund has a separately-designated Audit and Compliance Committee established in accordance with Section 3(a)(58)(A) of the Securities Exchange Act of 1934, as amended. The Audit and Compliance Committee of the fund's Board of Trustees is composed of the following persons:

Robert E. Patterson (Chairperson)
Robert J. Darretta
Myra R. Drucker
John A. Hill
Kenneth R. Leibler
W. Thomas Stephens

(b) Not applicable

Item 6. Schedule of Investments:

The registrant’s schedule of investments in unaffiliated issuers is included in the report to shareholders in Item 1 above.

Item 7. Disclosure of Proxy Voting Policies and Procedures For Closed-End Management Investment Companies:

Proxy voting guidelines of the Putnam funds 

The proxy voting guidelines below summarize the funds’ positions on various issues of concern to investors, and give a general indication of how fund portfolio securities will be voted on proposals dealing with particular issues. The funds’ proxy voting service is instructed to vote all proxies relating to fund portfolio securities in accordance with these guidelines, except as otherwise instructed by the Proxy Manager, a member of the Office of the Trustees who is appointed to assist in the coordination and voting of the funds’ proxies.

The proxy voting guidelines are just that – guidelines. The guidelines are not exhaustive and do not address all potential voting issues. Because the circumstances of individual companies are so varied, there may be instances when the funds do not vote in strict adherence to these guidelines. For example, the proxy voting service is expected to bring to the Proxy Manager’s attention proxy questions that are company-specific and of a non-routine nature and that, even if covered by the guidelines, may be more appropriately handled on a case-by-case basis.

Similarly, Putnam Management’s investment professionals, as part of their ongoing review and analysis of all fund portfolio holdings, are responsible for monitoring significant corporate developments, including proxy proposals submitted to shareholders, and notifying the Proxy Manager of circumstances where the interests of fund shareholders may warrant a vote contrary to these guidelines. In such instances, the investment professionals submit a written recommendation to the Proxy Manager and the person or persons designated by Putnam Management’s Legal and Compliance Department to assist in processing referral items under the funds’ “Proxy Voting Procedures.” The Proxy Manager, in consultation with the funds’ Senior Vice President, Executive Vice President, and/or the Chair of the Board Policy and Nominating Committee, as appropriate, will determine how the funds’ proxies will be voted. When indicated, the Chair of t he Board Policy and Nominating Committee may consult with other members of the Committee or the full Board of Trustees.

The following guidelines are grouped according to the types of proposals generally presented to shareholders. Part I deals with proposals submitted by management and approved and recommended by a company’s board of directors. Part II deals with proposals submitted by shareholders. Part III addresses unique considerations pertaining to non-U.S. issuers.

The Trustees of the Putnam funds are committed to promoting strong corporate governance practices and encouraging corporate actions that enhance shareholder value through the judicious voting of the funds’ proxies. It is the funds’ policy to vote their proxies at all shareholder meetings where it is practicable to do so. In furtherance of this, the funds’ have requested that their securities lending agent recall each domestic issuer’s voting securities that are on loan, in advance of the record date for the issuer’s shareholder meetings, so that the funds may vote at the meetings.

The Putnam funds will disclose their proxy votes not later than August 31 of each year for the most recent 12-month period ended June 30, in accordance with the timetable established by SEC rules.

I. BOARD-APPROVED PROPOSALS

The vast majority of matters presented to shareholders for a vote involve proposals made by a company itself (sometimes referred to as “management proposals”), which have been approved and recommended by its board of directors. In view of the enhanced corporate governance practices currently being implemented in public companies and of the funds’ intent to hold corporate boards accountable for their actions in promoting shareholder interests, the funds’ proxies generally will be voted for the decisions reached by majority independent boards of directors, except as otherwise indicated in these guidelines. Accordingly, the funds’ proxies will be voted for board-approved proposals, except as follows:

Matters relating to the Board of Directors

Uncontested Election of Directors

The funds’ proxies will be voted for the election of a company’s nominees for the board of directors, except as follows:

► The funds will withhold votes from the entire board of directors if

• the board does not have a majority of independent directors,

• the board has not established independent nominating, audit, and compensation committees,

• the board has more than 19 members or fewer than five members, absent special circumstances,

• the board has not acted to implement a policy requested in a shareholder proposal that received the support of a majority of the shares of the company cast at its previous two annual meetings, or

• the board has adopted or renewed a shareholder rights plan (commonly referred to as a “poison pill”) without shareholder approval during the current or prior calendar year.

► The funds will on a case-by-case basis withhold votes from the entire board of directors, or from particular directors as may be appropriate, if the board has approved compensation arrangements for one or more company executives that the funds determine are unreasonably excessive relative to the company’s performance or has otherwise failed to observe good corporate governance practices.

► The funds will withhold votes from any nominee for director:

• who is considered an independent director by the company and who has received compensation within the last three years from the company other than for service as a director (e.g., investment banking, consulting, legal, or financial advisory fees),

• who attends less than 75% of board and committee meetings without valid reasons for the absences (e.g., illness, personal emergency, etc.),

• of a public company (Company A) who is employed as a senior executive of another company (Company B), if a director of Company B serves as a senior executive of Company A (commonly referred to as an “interlocking directorate”), or

• who serves on more than five unaffiliated public company boards (for the purpose of this guideline, boards of affiliated registered investment companies will count as one board).

Commentary:

Board independence: Unless otherwise indicated, for the purposes of determining whether a board has a majority of independent directors and independent nominating, audit, and compensation committees, an “independent director” is a director who (1) meets all requirements to serve as an independent director of a company under the NYSE Corporate Governance Rules (e.g., no material business relationships with the company and no present or recent employment relationship with the company including employment of an immediate family member as an executive officer), and (2) has not within the last three years accepted directly or indirectly any consulting, advisory, or other compensatory fee from the company other than in his or her capacity as a member of the board of directors or any board committee. The funds’ Trustees beli eve that the recent (i.e., within the last three years) receipt of any amount of compensation for services other than service as a director raises significant independence issues.

Board size: The funds’ Trustees believe that the size of the board of directors can have a direct impact on the ability of the board to govern effectively. Boards that have too many members can be unwieldy and ultimately inhibit their ability to oversee management performance. Boards that have too few members can stifle innovation and lead to excessive influence by management.

Time commitment: Being a director of a company requires a significant time commitment to adequately prepare for and attend the company’s board and committee meetings. Directors must be able to commit the time and attention necessary to perform their fiduciary duties in proper fashion, particularly in times of crisis. The funds’ Trustees are concerned about over-committed directors. In some cases, directors may serve on too many boards to make a meaningful contribution. This may be particularly true for senior executives of public companies (or other directors with substantially full-time employment) who serve on more than a few outside boards. The funds may withhold votes from such directors on a case-by-case basis where it appears that they may be unable to discharge their duties properly because of excessive commitments.

Interlocking directorships: The funds’ Trustees believe that interlocking directorships are inconsistent with the degree of independence required for outside directors of public companies.

Corporate governance practices: Board independence depends not only on its members’ individual relationships, but also on the board’s overall attitude toward management. Independent boards are committed to good corporate governance practices and, by providing objective independent judgment, enhancing shareholder value. The funds may withhold votes on a case-by-case basis from some or all directors who, through their lack of independence or otherwise, have failed to observe good corporate governance practices or, through specific corporate action, have demonstrated a disregard for the interests of shareholders. Such instances may include cases where a board of directors has approved compensation arrangements for one or more members of management that, in the judgment of the funds’ Trustees, are excessive by reasonable corporate standards relative to the company’s record of performance.

Contested Elections of Directors

► The funds will vote on a case-by-case basis in contested elections of directors.

Classified Boards

► The funds will vote against proposals to classify a board, absent special circumstances indicating that shareholder interests would be better served by this structure.

Commentary: Under a typical classified board structure, the directors are divided into three classes, with each class serving a three-year term. The classified board structure results in directors serving staggered terms, with usually only a third of the directors up for re-election at any given annual meeting. The funds’ Trustees generally believe that it is appropriate for directors to stand for election each year, but recognize that, in special circumstances, shareholder interests may be better served under a classified board structure.

Other Board-Related Proposals

The funds will generally vote for proposals that have been approved by a majority independent board, and on a case-by-case basis on proposals that have been approved by a board that fails to meet the guidelines’ basic independence standards (i.e., majority of independent directors and independent nominating, audit, and compensation committees).

Executive Compensation

The funds generally favor compensation programs that relate executive compensation to a company’s long-term performance. The funds will vote on a case-by-case basis on board-approved proposals relating to executive compensation, except as follows:

► Except where the funds are otherwise withholding votes for the entire board of directors, the funds will vote for stock option and restricted stock plans that will result in an average annual dilution of 1.67% or less (based on the disclosed term of the plan and including all equity-based plans).

► The funds will vote against stock option and restricted stock plans that will result in an average annual dilution of greater than 1.67% (based on the disclosed term of the plan and including all equity-based plans).

► The funds will vote against any stock option or restricted stock plan where the company’s actual grants of stock options and restricted stock under all equity-based compensation plans during the prior three (3) fiscal years have resulted in an average annual dilution of greater than 1.67%.

► The funds will vote against stock option plans that permit the replacing or repricing of underwater options (and against any proposal to authorize a replacement or repricing of underwater options).

► The funds will vote against stock option plans that permit issuance of options with an exercise price below the stock’s current market price.

► Except where the funds are otherwise withholding votes for the entire board of directors, the funds will vote for an employee stock purchase plan that has the following features: (1) the shares purchased under the plan are acquired for no less than 85% of their market value; (2) the offering period under the plan is 27 months or less; and (3) dilution is 10% or less.

Commentary: Companies should have compensation programs that are reasonable and that align shareholder and management interests over the longer term. Further, disclosure of compensation programs should provide absolute transparency to shareholders regarding the sources and amounts of, and the factors influencing, executive compensation. Appropriately designed equity-based compensation plans can be an effective way to align the interests of long-term shareholders with the interests of management. However, the funds may vote against these

or other executive compensation proposals on a case-by-case basis where compensation is excessive by reasonable corporate standards or where a company fails to provide transparent disclosure of executive compensation. (Examples of excessive executive compensation may include, but are not limited to, equity incentive plans that exceed the dilution criteria noted above, excessive perquisites, performance-based compensation programs that do not properly correlate reward and performance, “golden parachutes” or other severance arrangements that present conflicts between management’s interests and the interests of shareholders, and “golden coffins” or unearned death benefits.) In voting on a proposal relating to executive compensation, the funds will consider whether the proposal has been approved by an independent compensation committee of the board.

Capitalization

Many proxy proposals involve changes in a company’s capitalization, including the authorization of additional stock, the issuance of stock, the repurchase of outstanding stock, or the approval of a stock split. The management of a company’s capital structure involves a number of important issues, including cash flow, financing needs, and market conditions that are unique to the circumstances of the company. As a result, the funds will vote on a case-by-case basis on board-approved proposals involving changes to a company’s capitalization, except that where the funds are not otherwise withholding votes from the entire board of directors:

► The funds will vote for proposals relating to the authorization and issuance of additional common stock (except where such proposals relate to a specific transaction).

► The funds will vote for proposals to effect stock splits (excluding reverse stock splits).

► The funds will vote for proposals authorizing share repurchase programs.

Commentary: A company may decide to authorize additional shares of common stock for reasons relating to executive compensation or for routine business purposes. For the most part, these decisions are best left to the board of directors and senior management. The funds will vote on a case-by-case basis, however, on other proposals to change a company’s capitalization, including the authorization of common stock with special voting rights, the authorization or issuance of common stock in connection with a specific transaction (e.g., an acquisition, merger or reorganization), or the authorization or issuance of preferred stock. Actions such as these involve a number of considerations that may affect a shareholder’s investment and that warrant a case-by-case determination.

Acquisitions, Mergers, Reincorporations, Reorganizations and Other Transactions

Shareholders may be confronted with a number of different types of transactions, including acquisitions, mergers, reorganizations involving business combinations, liquidations, and the sale of all or substantially all of a company’s assets, which may require their consent. Voting on such proposals involves considerations unique to each transaction. As a result, the funds will vote on a case-by-case basis on board-approved proposals to effect these types of transactions, except as follows:

► The funds will vote for mergers and reorganizations involving business combinations designed solely to reincorporate a company in Delaware.

Commentary: A company may reincorporate into another state through a merger or reorganization by setting up a “shell” company in a different state and then merging the company into the new company. While reincorporation into states with extensive and established corporate laws – notably Delaware – provides companies and shareholders with a more well-defined legal

framework, shareholders must carefully consider the reasons for a reincorporation into another jurisdiction, including especially an offshore jurisdiction.

Anti-Takeover Measures

Some proxy proposals involve efforts by management to make it more difficult for an outside party to take control of the company without the approval of the company’s board of directors. These include the adoption of a shareholder rights plan, requiring supermajority voting on particular issues, the adoption of fair price provisions, the issuance of blank check preferred stock, and the creation of a separate class of stock with disparate voting rights. Such proposals may adversely affect shareholder rights, lead to management entrenchment, or create conflicts of interest. As a result, the funds will vote against board-approved proposals to adopt such anti-takeover measures, except as follows:

► The funds will vote on a case-by-case basis on proposals to ratify or approve shareholder rights plans; and

► The funds will vote on a case-by-case basis on proposals to adopt fair price provisions.

Commentary: The funds’ Trustees recognize that poison pills and fair price provisions may enhance or protect shareholder value under certain circumstances. For instance, where a company has incurred significant operating losses, a shareholder rights plan may be appropriately tailored to protect shareholder value by preserving a company’s net operating losses. Thus, the funds will consider proposals to approve such matters on a case-by-case basis.

Other Business Matters

Many proxies involve approval of routine business matters, such as changing a company’s name, ratifying the appointment of auditors, and procedural matters relating to the shareholder meeting. For the most part, these routine matters do not materially affect shareholder interests and are best left to the board of directors and senior management of the company. The funds will vote for board-approved proposals approving such matters, except as follows:

► The funds will vote on a case-by-case basis on proposals to amend a company’s charter or bylaws (except for charter amendments necessary to effect stock splits, to change a company’s name or to authorize additional shares of common stock).

► The funds will vote against authorization to transact other unidentified, substantive business at the meeting.

► The funds will vote on a case-by-case basis on proposals to ratify the selection of independent auditors if there is evidence that the audit firm’s independence or the integrity of an audit is compromised.

► The funds will vote on a case-by-case basis on other business matters where the funds are otherwise withholding votes for the entire board of directors.

Commentary: Charter and bylaw amendments and the transaction of other unidentified, substantive business at a shareholder meeting may directly affect shareholder rights and have a significant impact on shareholder value. As a result, the funds do not view these items as routine business matters. Putnam Management’s investment professionals and the funds’ proxy voting service may also bring to the Proxy Manager’s attention company-specific items that they believe to be non-routine and warranting special consideration. Under these circumstances, the funds will vote on a case-by-case basis.

The fund’s proxy voting service may identify circumstances that call into question an audit firm’s independence or the integrity of an audit. These circumstances may include recent material restatements of financials, unusual audit fees, egregious contractual relationships, and aggressive accounting policies. The funds will consider proposals to ratify the selection of auditors in these circumstances on a case-by-case basis. In all other cases, given the existence of rules that enhance the independence of audit committees and auditors by, for example, prohibiting auditors from performing a range of non-audit services for audit clients, the funds will vote for the ratification of independent auditors.

II. SHAREHOLDER PROPOSALS

SEC regulations permit shareholders to submit proposals for inclusion in a company’s proxy statement. These proposals generally seek to change some aspect of the company’s corporate governance structure or to change some aspect of its business operations. The funds generally will vote in accordance with the recommendation of the company’s board of directors on all shareholder proposals, except as follows:

► The funds will vote for shareholder proposals asking that director nominees receive support from holders of a majority of votes cast or a majority of shares outstanding in order to be (re)elected.

► The funds will vote for shareholder proposals to declassify a board, absent special circumstances which would indicate that shareholder interests are better served by a classified board structure.

► The funds will vote for shareholder proposals to require shareholder approval of shareholder rights plans.

► The funds will vote for shareholder proposals requiring companies to make cash payments under management severance agreements only if both of the following conditions are met:

• the company undergoes a change in control, and

• the change in control results in the termination of employment for the person receiving the severance payment.

► The funds will vote on a case-by-case basis on shareholder proposals requiring companies to accelerate vesting of equity awards under management severance agreements only if both of the following conditions are met:

• the company undergoes a change in control, and

• the change in control results in the termination of employment for the person receiving the severance payment.

► The funds will vote on a case-by-case basis on shareholder proposals to limit a company’s ability to make excise tax gross-up payments under management severance agreements.

► The funds will vote on a case-by-case basis on shareholder proposals requesting that the board adopt a policy to recoup, in the event of a significant restatement of financial results or significant extraordinary write-off, to the fullest extent practicable, for the benefit of the company, all performance-based bonuses or awards that were paid to senior executives based on the company having met or exceeded specific performance targets to the extent that the specific performance targets were not, in fact, met.

► The funds will vote for shareholder proposals requiring a company to report on its executive retirement benefits (e.g., deferred compensation, split-dollar life insurance, SERPs and pension benefits).

► The funds will vote for shareholder proposals requiring a company to disclose its relationships with executive compensation consultants (e.g., whether the company, the board or the compensation committee retained the consultant, the types of services provided by the consultant over the past five years, and a list of the consultant’s clients on which any of the company’s executives serve as a director).

► The funds will vote for shareholder proposals that are consistent with the funds’ proxy voting guidelines for board-approved proposals.

► The funds will vote on a case-by-case basis on other shareholder proposals where the funds are otherwise withholding votes for the entire board of directors.

Commentary: In light of the substantial reforms in corporate governance that are currently underway, the funds’ Trustees believe that effective corporate reforms should be promoted by holding boards of directors – and in particular their independent directors – accountable for their actions, rather than by imposing additional legal restrictions on board governance through piecemeal proposals. Generally speaking, shareholder proposals relating to business operations are often motivated primarily by political or social concerns, rather than the interests of shareholders as investors in an economic enterprise. As stated above, the funds’ Trustees believe that boards of directors and management are responsible for ensuring that their businesses are operating in accordance with high legal and ethical standards and should be held accountable for resulting corporate behavior. Accordingly, the fund s will generally support the recommendations of boards that meet the basic independence and governance standards established in these guidelines. Where boards fail to meet these standards, the funds will generally evaluate shareholder proposals on a case-by-case basis.

However, the funds generally support shareholder proposals to implement majority voting for directors, observing that majority voting is an emerging standard intended to encourage directors to be attentive to shareholders’ interests. The funds also generally support shareholder proposals to declassify a board or to require shareholder approval of shareholder rights plans. The funds’ Trustees believe that these shareholder proposals further the goals of reducing management entrenchment and conflicts of interest, and aligning management’s interests with shareholders’ interests in evaluating proposed acquisitions of the company. The Trustees also believe that shareholder proposals to limit severance payments may further these goals in some instances. In general, the funds favor arrangements in which severance payments are made to an executive only when there is a change in control and the executive loses his or her job as a result. Arr angements in which an executive receives a payment upon a change of control even if the executive retains employment introduce potential conflicts of interest and may distract management focus from the long term success of the company.

In evaluating shareholder proposals that address severance payments, the funds distinguish between cash and equity payments. The funds generally do not favor cash payments to executives upon a change in control transaction if the executive retains employment. However, the funds recognize that accelerated vesting of equity incentives, even without termination of employment, may help to align management and shareholder interests in some instances, and will evaluate shareholder proposals addressing accelerated vesting of equity incentive payments on a case-by-case basis.

When severance payments exceed a certain amount based on the executive’s previous compensation, the payments may be subject to an excise tax. Some compensation arrangements provide for full excise tax gross-ups, which means that the company pays the executive sufficient additional amounts to cover the cost of the excise tax. The funds are

concerned that the benefits of providing full excise tax gross-ups to executives may be outweighed by the cost to the company of the gross-up payments. Accordingly, the funds will vote on a case-by-case basis on shareholder proposals to curtail excise tax gross-up payments. The funds generally favor arrangements in which severance payments do not trigger an excise tax or in which the company’s obligations with respect to gross-up payments are limited in a reasonable manner.

The funds’ Trustees believe that performance-based compensation can be an effective tool for aligning management and shareholder interests. However, to fulfill its purpose, performance compensation should only be paid to executives if the performance targets are actually met. A significant restatement of financial results or a significant extraordinary write-off may reveal that executives who were previously paid performance compensation did not actually deliver the required business performance to earn that compensation. In these circumstances, it may be appropriate for the company to recoup this performance compensation. The funds will consider on a case-by-case basis shareholder proposals requesting that the board adopt a policy to recoup, in the event of a significant restatement of financial results or significant extraordinary write-off, performance-based bonuses or awards paid to senior executives based on the company having met or exceeded specific performance targets to the extent that the specific performance targets were not, in fact, met. The funds do not believe that such a policy should necessarily disadvantage a company in recruiting executives, as executives should understand that they are only entitled to performance compensation based on the actual performance they deliver.

The funds’ Trustees will also consider whether a company’s severance payment and performance-based compensation arrangements, taking all of the pertinent circumstances into account, constitute excessive compensation or otherwise reflect poorly on the corporate governance practices of the company. In addition, as the Trustees evaluate these matters, they will be mindful of evolving practices and legislation relevant to executive compensation and corporate governance.

The funds’ Trustees also believe that shareholder proposals that are intended to increase transparency, particularly with respect to executive compensation, without establishing rigid restrictions upon a company’s ability to attract and motivate talented executives, are generally beneficial to sound corporate governance without imposing undue burdens. The funds will generally support shareholder proposals calling for reasonable disclosure.

III. VOTING SHARES OF NON-U.S. ISSUERS

Many of the Putnam funds invest on a global basis, and, as a result, they may hold, and have an opportunity to vote, shares in non-U.S. issuers – i.e., issuers that are incorporated under the laws of foreign jurisdictions and whose shares are not listed on a U.S. securities exchange or the NASDAQ stock market.

In many non-U.S. markets, shareholders who vote proxies of a non-U.S. issuer are not able to trade in that company’s stock on or around the shareholder meeting date. This practice is known as “share blocking.” In countries where share blocking is practiced, the funds will vote proxies only with direction from Putnam Management’s investment professionals.

In addition, some non-U.S. markets require that a company’s shares be re-registered out of the name of the local custodian or nominee into the name of the shareholder for the shareholder to be able to vote at the meeting. This practice is known as “share re-registration.” As a result, shareholders, including the funds, are not able to trade in that company’s stock until the shares are re-registered back in the name of the local custodian or nominee following the meeting. In countries where share re-registration is practiced, the funds will generally not vote proxies.

Protection for shareholders of non-U.S. issuers may vary significantly from jurisdiction to jurisdiction. Laws governing non-U.S. issuers may, in some cases, provide substantially less

protection for shareholders than do U.S. laws. As a result, the guidelines applicable to U.S. issuers, which are premised on the existence of a sound corporate governance and disclosure framework, may not be appropriate under some circumstances for non-U.S. issuers. However, the funds will vote proxies of non-U.S. issuers in accordance with the guidelines applicable to U.S. issuers, except as follows:

Uncontested Election of Directors

Germany

► For companies subject to “co-determination,” the funds will vote on a case by- case basis for the election of nominees to the supervisory board.

► The funds will withhold votes for the election of a former member of the company’s managerial board to chair of the supervisory board.

Commentary: German corporate governance is characterized by a two-tier board system—a managerial board composed of the company’s executive officers, and a supervisory board. The supervisory board appoints the members of the managerial board. Shareholders elect members of the supervisory board, except that in the case of companies with more than 2,000 employees, company employees are allowed to elect half of the supervisory board members. This “co-determination” practice may increase the chances that the supervisory board of a large German company does not contain a majority of independent members. In this situation, under the Fund’s proxy voting guidelines applicable to U.S. issuers, the funds would vote against all nominees. However, in the case of companies subject to “co-determination,” the Funds will vote for supervisory board members on a case-by-case basis, so that the funds can support independent nominees.

Consistent with the funds’ belief that the interests of shareholders are best protected by boards with strong, independent leadership, the funds will withhold votes for the election of former chairs of the managerial board to chair of the supervisory board.

Japan

► For companies that have established a U.S.-style corporate governance structure, the funds will withhold votes from the entire board of directors if

• the board does not have a majority of outside directors,

• the board has not established nominating and compensation committees composed of a majority of outside directors, or

• the board has not established an audit committee composed of a majority of independent directors.

► The funds will withhold votes for the appointment of members of a company’s board of statutory auditors if a majority of the members of the board of statutory auditors is not independent.

Commentary:

Board structure: Recent amendments to the Japanese Commercial Code give companies the option to adopt a U.S.-style corporate governance structure (i.e., a board of directors and audit, nominating, and compensation committees). The funds will vote for proposals to amend a company’s articles of incorporation to adopt the U.S.-style corporate structure.

Definition of outside director and independent director: Corporate governance principles in Japan focus on the distinction between outside directors and independent directors. Under these principles, an outside director is a director who is not and has never been a director, executive, or employee of the company or its parent company, subsidiaries or affiliates. An outside director is “independent” if that person can make decisions completely independent from the managers of the company, its parent, subsidiaries, or affiliates and does not have a material relationship with the company (i.e., major client, trading partner, or other business relationship; familial relationship with current director or executive; etc.). The guidelines have incorporated these definitions in applying the board independence standards above.

Korea

► The funds will withhold votes from the entire board of directors if

• the board does not have a majority of outside directors,

• the board has not established a nominating committee composed of at least a majority of outside directors, or

• the board has not established an audit committee composed of at least three members and in which at least two-thirds of its members are outside directors.

Commentary: For purposes of these guidelines, an “outside director” is a director that is independent from the management or controlling shareholders of the company, and holds no interests that might impair performing his or her duties impartially from the company, management or controlling shareholder. In determining whether a director is an outside director, the funds will also apply the standards included in Article 415-2(2) of the Korean Commercial Code (i.e., no employment relationship with the company for a period of two years before serving on the committee, no director or employment relationship with the company’s largest shareholder, etc.) and may consider other business relationships that would affect the independence of an outside director.

Russia

► The funds will vote on a case-by-case basis for the election of nominees to the board of directors.

Commentary: In Russia, director elections are typically handled through a cumulative voting process. Cumulative voting allows shareholders to cast all of their votes for a single nominee for the board of directors, or to allocate their votes among nominees in any other way. In contrast, in “regular” voting, shareholders may not give more than one vote per share to any single nominee. Cumulative voting can help to strengthen the ability of minority shareholders to elect a director.

In Russia, as in some other emerging markets, standards of corporate governance are usually behind those in developed markets. Rather than vote against the entire board of directors, as the funds generally would in the case of a company whose board fails to meet the funds’ standards for independence, the funds may, on a case by case basis, cast all of their votes for one or more independent director nominees. The funds believe that it is important to increase the number of independent directors on the boards of Russian companies to mitigate the risks associated with dominant shareholders.

United Kingdom

► The funds will withhold votes from the entire board of directors if

• the board does not have at least a majority of independent non-executive directors,

• the board has not established a nomination committee composed of a majority of independent non-executive directors, or

• the board has not established compensation and audit committees composed of (1) at least three directors (in the case of smaller companies, two directors) and (2) solely independent non-executive directors.

► The funds will withhold votes from any nominee for director who is considered an independent director by the company and who has received compensation within the last three years from the company other than for service as a director, such as investment banking, consulting, legal, or financial advisory fees.

► The funds will vote for proposals to amend a company’s articles of association to authorize boards to approve situations that might be interpreted to present potential conflicts of interest affecting a director.

Commentary:

Application of guidelines: Although the United Kingdom’s Combined Code on Corporate Governance (“Combined Code”) has adopted the “comply and explain” approach to corporate governance, the funds’ Trustees believe that the guidelines discussed above with respect to board independence standards are integral to the protection of investors in U.K. companies. As a result, these guidelines will generally be applied in a prescriptive manner.

Definition of independence: For the purposes of these guidelines, a non-executive director shall be considered independent if the director meets the independence standards in section A.3.1 of the Combined Code (i.e., no material business or employment relationships with the company, no remuneration from the company for non-board services, no close family ties with senior employees or directors of the company, etc.), except that the funds do not view service on the board for more than nine years as affecting a director’s independence.

Smaller companies: A smaller company is one that is below the FTSE 350 throughout the year immediately prior to the reporting year.

Conflicts of interest: The Companies Act 2006 requires a director to avoid a situation in which he or she has, or can have, a direct or indirect interest that conflicts, or possibly may conflict, with the interests of the company. This broadly written requirement could be construed to prevent a director from becoming a trustee or director of another organization. Provided there are reasonable safeguards, such as the exclusion of the relevant director from deliberations, the funds believe that the board may approve this type of potential conflict of interest in its discretion.

Other Matters

► The funds will vote for shareholder proposals calling for a majority of a company’s directors to be independent of management.

► The funds will vote for shareholder proposals seeking to increase the independence of board nominating, audit, and compensation committees.

► The funds will vote for shareholder proposals that implement corporate governance standards similar to those established under U.S. federal law and the listing requirements of

U.S. stock exchanges, and that do not otherwise violate the laws of the jurisdiction under which the company is incorporated.

► The funds will vote on a case-by-case basis on proposals relating to (1) the issuance of common stock in excess of 20% of the company’s outstanding common stock where shareholders do not have preemptive rights, or (2) the issuance of common stock in excess of 100% of the company’s outstanding common stock where shareholders have preemptive rights.

► The funds will vote for proposals permitting companies to deliver reports and other materials electronically (e.g., via website posting).

► The funds will vote for proposals permitting companies to issue regulatory reports in English.

► The funds will vote: against remuneration reports that indicate that awards under a long term incentive plan are not linked to performance targets; and on a case-by-case basis on other remuneration reports, giving consideration to whether the report indicates a correlation between compensation and performance that is consistent with the funds’ high standards for compensation practices.

As adopted March 6, 2009

Proxy Voting Procedures of the Putnam Funds

The proxy voting procedures below explain the role of the funds’ Trustees, the proxy voting service and the Proxy Coordinator, as well as how the process will work when a proxy question needs to be handled on a case-by-case basis, or when there may be a conflict of interest.

The role of the funds’ Trustees

The Trustees of the Putnam funds exercise control of the voting of proxies through their Board Policy and Nominating Committee, which is composed entirely of independent Trustees. The Board Policy and Nominating Committee oversees the proxy voting process and participates, as needed, in the resolution of issues that need to be handled on a case-by-case basis. The Committee annually reviews and recommends, for Trustee approval, guidelines governing the funds’ proxy votes, including how the funds vote on specific proposals and which matters are to be considered on a case-by-case basis. The Trustees are assisted in this process by their independent administrative staff (“Office of the Trustees”), independent legal counsel, and an independent proxy voting service. The Trustees also receive assistance from Putnam Investment Management, LLC (“Putnam Management”), the funds’ investment advisor, on matters involving investment jud gments. In all cases, the ultimate decision on voting proxies rests with the Trustees, acting as fiduciaries on behalf of the shareholders of the funds.

The role of the proxy voting service

The funds have engaged an independent proxy voting service to assist in the voting of proxies. The proxy voting service is responsible for coordinating with the funds’ custodians to ensure that all proxy materials received by the custodians relating to the funds’ portfolio securities are processed in a timely fashion. To the extent applicable, the proxy voting service votes all proxies in accordance with the proxy voting guidelines established by the Trustees. The proxy voting service will refer proxy questions to the Proxy Coordinator (described below) for instructions under circumstances

where: (1) the application of the proxy voting guidelines is unclear; (2) a particular proxy question is not covered by the guidelines; or (3) the guidelines call for specific instructions on a case-by-case basis. The proxy voting service is also requested to call to the Proxy Coordinator’s attention specific proxy questions that, while governed by a guideline, appear to involve unusual or controversial issues. The funds also utilize research services relating to proxy questions provided by the proxy voting service and by other firms.

The role of the Proxy Coordinator

Each year, a member of the Office of the Trustees is appointed Proxy Coordinator to assist in the coordination and voting of the funds’ proxies. The Proxy Coordinator will deal directly with the proxy voting service and, in the case of proxy questions referred by the proxy voting service, will solicit voting recommendations and instructions from the Office of the Trustees, the Chair of the Board Policy and Nominating Committee, and Putnam Management’s investment professionals, as appropriate. The Proxy Coordinator is responsible for ensuring that these questions and referrals are responded to in a timely fashion and for transmitting appropriate voting instructions to the proxy voting service.

Voting procedures for referral items

As discussed above, the proxy voting service will refer proxy questions to the Proxy Coordinator under certain circumstances. When the application of the proxy voting guidelines is unclear or a particular proxy question is not covered by the guidelines (and does not involve investment considerations), the Proxy Coordinator will assist in interpreting the guidelines and, as appropriate, consult with one of more senior staff members of the Office of the Trustees and the Chair of the Board Policy and Nominating Committee on how the funds’ shares will be voted.

For proxy questions that require a case-by-case analysis pursuant to the guidelines or that are not covered by the guidelines but involve investment considerations, the Proxy Coordinator will refer such questions, through a written request, to Putnam Management’s investment professionals for a voting recommendation. Such referrals will be made in cooperation with the person or persons designated by Putnam Management’s Legal and Compliance Department to assist in processing such referral items. In connection with each such referral item, the Legal and Compliance Department will conduct a conflicts of interest review, as described below under “Conflicts of Interest,” and provide a conflicts of interest report (the “Conflicts Report”) to the Proxy Coordinator describing the results of such review. After receiving a referral item from the Proxy Coordinator, Putnam Management’s investment professionals will provide a writt en recommendation to the Proxy Coordinator and the person or persons designated by the Legal and Compliance Department to assist in processing referral items. Such recommendation will set forth (1) how the proxies should be voted; (2) the basis and rationale for such recommendation; and (3) any contacts the investment professionals have had with respect to the referral item with non-investment personnel of Putnam Management or with outside parties (except for routine communications from proxy solicitors). The Proxy Coordinator will then review the investment professionals’ recommendation and the Conflicts Report with one of more senior staff members of the Office of the Trustees in determining how to vote the funds’ proxies. The Proxy Coordinator will maintain a record of all proxy questions that have been referred to Putnam Management’s investment professionals, the voting recommendation, and the Conflicts Report.

In some situations, the Proxy Coordinator and/or one of more senior staff members of the Office of the Trustees may determine that a particular proxy question raises policy issues requiring consultation with the Chair of the Board Policy and Nominating Committee, who, in turn, may decide to bring the particular proxy question to the Committee or the full Board of Trustees for consideration.

Conflicts of interest

Occasions may arise where a person or organization involved in the proxy voting process may have a conflict of interest. A conflict of interest may exist, for example, if Putnam Management has a business relationship with (or is actively soliciting business from) either the company soliciting the proxy or a third party that has a material interest in the outcome of a proxy vote or that is actively lobbying for a particular outcome of a proxy vote. Any individual with knowledge of a personal conflict of interest (e.g., familial relationship with company management) relating to a particular referral item shall disclose that conflict to the Proxy Coordinator and the Legal and Compliance Department and otherwise remove himself or herself from the proxy voting process. The Legal and Compliance Department will review each item referred to Putnam Management’s investment professionals to determine if a conflict of interest exists and will provide the Prox y Coordinator with a Conflicts Report for each referral item that (1) describes any conflict of interest; (2) discusses the procedures used to address such conflict of interest; and (3) discloses any contacts from parties outside Putnam Management (other than routine communications from proxy solicitors) with respect to the referral item not otherwise reported in an investment professional’s recommendation. The Conflicts Report will also include written confirmation that any recommendation from an investment professional provided under circumstances where a conflict of interest exists was made solely on the investment merits and without regard to any other consideration.

As adopted March 11, 2005

Item 8. Portfolio Managers of Closed-End Management Investment Companies

(a)(1) Portfolio Managers. The officers of Putnam Management identified below are primarily responsible for the day-to-day management of the fund’s portfolio .

Portfolio Managers	Joined
	Fund	Employer	Positions Over Past Five Years
William Kohli	1994	Putnam	Team Leader, Portfolio Construction
		Management	Previously, Director
		1994 – Present
Michael Atkin	2007	Putnam	Senior Economist
		Management	Previously, Team Leader Country Analysis
		1997 – Present
Rob Bloemker	2005	Putnam	Head of Fixed Income
		Management	Previously, Deputy Head of Investments
		1999 – Present
Kevin Murphy	2005	Putnam	Team Leader, High Grade Credit
		Management
		1999 – Present
Paul Scanlon	2005	Putnam	Team Leader, U.S. High Yield
		Management	Previously, Portfolio Manager
		1999 – Present

(a)(2) Other Accounts Managed by the Fund’s Portfolio Managers.

The following table shows the number and approximate assets of other investment accounts (or portions of investment accounts) that the fund’s Portfolio Managers managed as of the fund’s

most recent fiscal year-end. Unless noted, none of the other accounts pays a fee based on the account’s performance.

					Other accounts (including
					separate accounts,
					managed account
					programs and single-
	Other SEC-registered open-		Other accounts that pool		sponsor defined
Portfolio Leader	end and closed-end funds		assets from more than one		contribution plan
or Member			client		offerings)
	Number	Assets	Number	Assets	Number	Assets
	of		of		of
	accounts		accounts		accounts
William Kohli	7*	$4,270,500,000	8	$1,793,500,000	8	$2,669,700,000
Rob Bloemker	19**	$9,377,100,000	26	$11,330,200,000	21***	$7,348,400,000
Michael Atkin	5	$3,974,600,000	4	$1,006,200,000	4	$1,329,800,000
Paul Scanlon	16#	$7,165,700,000	21	$1,982,500,000	7	$611,100,000
Kevin Murphy	14##	$7,053,000,000	19	$8,402,300,000	15	$5,117,300,000

* 2 accounts, with total assets of $295,900,000, pay an advisory fee based on account performance.

** 4 accounts, with total assets of $453,000,000, pay an advisory fee based on account performance.

*** 2 accounts, with total assets of $333,500,000, pay an advisory fee based on account performance.

# 2 accounts, with total assets of $295,900,000, pay an advisory fee based on account performance.

## 4 accounts, with total assets of $453,000,000, pay an advisory fee based on account performance.

Potential conflicts of interest in managing multiple accounts. Like other investment professionals with multiple clients, the fund’s Portfolio Managers may face certain potential conflicts of interest in connection with managing both the fund and the other accounts listed under “Other Accounts Managed by the Fund’s Portfolio Managers” at the same time. The paragraphs below describe some of these potential conflicts, which Putnam Management believes are faced by investment professionals at most major financial firms. As described below, Putnam Management and the

Trustees of the Putnam funds have adopted compliance policies and procedures that attempt to address certain of these potential conflicts.

The management of accounts with different advisory fee rates and/or fee structures, including accounts that pay advisory fees based on account performance (“performance fee accounts”), may raise potential conflicts of interest by creating an incentive to favor higher-fee accounts. These potential conflicts may include, among others:

• The most attractive investments could be allocated to higher-fee accounts or performance fee accounts.

• The trading of higher-fee accounts could be favored as to timing and/or execution price. For example, higher-fee accounts could be permitted to sell securities earlier than other accounts when a prompt sale is desirable or to buy securities at an earlier and more opportune time.

• The trading of other accounts could be used to benefit higher-fee accounts (front-running).

• The investment management team could focus their time and efforts primarily on higher-fee accounts due to a personal stake in compensation.

Putnam Management attempts to address these potential conflicts of interest relating to higher-fee accounts through various compliance policies that are generally intended to place all accounts, regardless of fee structure, on the same footing for investment management purposes. For example, under Putnam Management’s policies:

• Performance fee accounts must be included in all standard trading and allocation procedures with all other accounts.

• All accounts must be allocated to a specific category of account and trade in parallel with allocations of similar accounts based on the procedures generally applicable to all accounts in those groups (e.g., based on relative risk budgets of accounts).

• All trading must be effected through Putnam’s trading desks and normal queues and procedures must be followed (i.e., no special treatment is permitted for performance fee accounts or higher-fee accounts based on account fee structure).

• Front running is strictly prohibited.

• The fund’s Portfolio Manager(s) may not be guaranteed or specifically allocated any portion of a performance fee.

As part of these policies, Putnam Management has also implemented trade oversight and review procedures in order to monitor whether particular accounts (including higher-fee accounts or performance fee accounts) are being favored over time.

Potential conflicts of interest may also arise when the Portfolio Manager(s) have personal investments in other accounts that may create an incentive to favor those accounts. As a general matter and subject to limited exceptions, Putnam Management’s investment professionals do not have the opportunity to invest in client accounts, other than the Putnam funds. However, in the ordinary course of business, Putnam Management or related persons may from time to time establish “pilot” or “incubator” funds for the purpose of testing proposed investment strategies and products prior to offering them to clients. These pilot accounts may be in the form of registered investment companies, private funds such as partnerships or separate accounts established by Putnam Management or an affiliate. Putnam Management or an affiliate supplies the funding for these accounts. Putnam employees, including the fund’s Portfolio Manager(s), may als o invest in certain pilot accounts. Putnam Management, and to the extent applicable, the Portfolio Manager(s) will benefit from the favorable investment performance of those funds and accounts. Pilot funds and accounts may, and frequently do, invest in the same securities as the client accounts. Putnam Management’s policy is to treat pilot accounts in the same manner as client accounts for purposes of trading allocation – neither favoring nor disfavoring them except as is

legally required. For example, pilot accounts are normally included in Putnam Management’s daily block trades to the same extent as client accounts (except that pilot accounts do not participate in initial public offerings).

A potential conflict of interest may arise when the fund and other accounts purchase or sell the same securities. On occasions when the Portfolio Manager(s) consider the purchase or sale of a security to be in the best interests of the fund as well as other accounts, Putnam Management’s trading desk may, to the extent permitted by applicable laws and regulations, aggregate the securities to be sold or purchased in order to seek to obtain the best execution and lower brokerage commissions, if any. Aggregation of trades may create the potential for unfairness to the fund or another account if one account is favored over another in allocating the securities purchased or sold – for example, by allocating a disproportionate amount of a security that is likely to increase in value to a favored account. Putnam Management’s trade allocation policies generally provide that each day’s transactions in securities that are purchased or sold by m ultiple accounts are, insofar as possible, averaged as to price and allocated between such accounts (including the fund) in a manner which in Putnam Management’s opinion is equitable to each account and in accordance with the amount being purchased or sold by each account. Certain exceptions exist for specialty, regional or sector accounts. Trade allocations are reviewed on a periodic basis as part of Putnam Management’s trade oversight procedures in an attempt to ensure fairness over time across accounts.

“Cross trades,” in which one Putnam account sells a particular security to another account (potentially saving transaction costs for both accounts), may also pose a potential conflict of interest. Cross trades may be seen to involve a potential conflict of interest if, for example, one account is permitted to sell a security to another account at a higher price than an independent third party would pay. Putnam Management and the fund’s Trustees have adopted compliance procedures that provide that any transactions between the fund and another Putnam-advised account are to be made at an independent current market price, as required by law.

Another potential conflict of interest may arise based on the different investment objectives and strategies of the fund and other accounts. For example, another account may have a shorter-term investment horizon or different investment objectives, policies or restrictions than the fund. Depending on another account’s objectives or other factors, the Portfolio Manager(s) may give advice and make decisions that may differ from advice given, or the timing or nature of decisions made, with respect to the fund. In addition, investment decisions are the product of many factors in addition to basic suitability for the particular account involved. Thus, a particular security may be bought or sold for certain accounts even though it could have been bought or sold for other accounts at the same time. More rarely, a particular security may be bought for one or more accounts managed by the Portfolio Manager(s) when one or more other accounts are selling the security (including short sales). There may be circumstances when purchases or sales of portfolio securities for one or more accounts may have an adverse effect on other accounts. As noted above, Putnam Management has implemented trade oversight and review procedures to monitor whether any account is systematically favored over time.

The fund’s Portfolio Manager(s) may also face other potential conflicts of interest in managing the fund, and the description above is not a complete description of every conflict that could be deemed to exist in managing both the fund and other accounts.

(a)(3) Compensation of portfolio managers. Putnam’s goal for our products and investors is to deliver top quartile or better performance over a rolling 3-year period versus peers on a pre-tax basis. For this fund, the peer group Putnam compares fund performance against is its broad investment category as determined by Lipper Inc. and identified in the shareholder report included in Item 1. Each portfolio manager is assigned an industry competitive incentive compensation target for achieving this goal. The target is based in part on the type and amount of

assets the individual manages. The target increases or decreases depending on whether the portfolio manager’s performance is higher or lower than the top quartile, subject to a maximum increase of 50%, for a portfolio manager who outperforms at least 90% of his or her peer group, and a maximum decrease of 100%, for a portfolio manager who outperforms less than 25% of his or her peer group. For example, the target of a portfolio manager who outperforms 50% of his or her peer group would decrease 50%. Investment performance of a portfolio manager is asset-weighted across the products he or she manages.

Portfolio manager incentive compensation targets are also adjusted for company performance/economics. Actual incentive compensation may be greater or less than a portfolio manager’s target, as it takes into consideration team/group performance and qualitative performance factors. Incentive compensation includes a cash bonus and may also include grants of restricted stock or options. In addition to incentive compensation, portfolio managers receive fixed annual salaries typically based on level of responsibility and experience.

(a)(4) Fund ownership. The following table shows the dollar ranges of shares of the fund owned by the professionals listed above at the end of the fund’s last two fiscal years, including investments by their immediate family members and amounts invested through retirement and deferred compensation plans.

* Assets in the fund

			$1–	$10,001–	$50,001–	$100,001–	$500,001–	$1,000,001
	Year	$0	$10,000	$50,000	$100,000	$500,000	$1,000,000	and over
D. William Kohli	2009	*
Portfolio Leader
Michael Atkin	2009	*
Portfolio Member
Rob Bloemker	2009	*
Portfolio Member
Kevin Murphy	2009	*
Portfolio Member
Paul Scanlon	2009	*
Portfolio Member

(b) Not applicable

Item 9. Purchases of Equity Securities by Closed-End Management Investment Companies and Affiliated Purchasers:

Registrant Purchase of Equity Securities

			Maximum
		Total Number	Number (or
		of Shares	Approximate
		Purchased	Dollar Value)
		as Part	of Shares
		of Publicly	that May Yet Be
Total Number	Average	Announced	Purchased

	of Shares	Price Paid	Plans or	under the Plans
Period	Purchased	per Share	Programs*	or Programs**
October 1 -
October 7, 2008	-	-	-	5,747,748
October 8 -
October 31, 2008	1,990,091	$4.95	1,990,091	4,673,960
November 1 -
November 30, 2008	165,037	$3.86	165,037	4,508,923
December 1 -
December 31, 2008	57,228	$4.04	57,228	4,451,695
January 1 -
January 31, 2009	-	-	-	4,451,695
February 1 -
February 28, 2009	-	-	-	4,451,695
March 1 -
March 31, 2009	-	-	-	4,451,695
April 1 -
April 30, 2009	-	-	-	4,451,695
May 1 -
May 31, 2009	-	-	-	4,451,695
June 1 -
June 30, 2009	-	-	-	4,451,695
July 1 -
July 31, 2009	-	-	-	4,451,695
August 1 -
August 31, 2009	-	-	-	4,451,695
September 1 -
September 30, 2009	-	-	-	4,451,695

* In October 2005, the Board of Trustees of the Putnam Funds initiated the closed-end fund share repurchase program, which, as subsequently amended, authorized the repurchase of up to 10% of the fund's outstanding common shares over the two-years ending October 5, 2007. The Trustees subsequently renewed the program on three occasions, to permit the repurchase of an additional 10% of the fund's outstanding common shares over each of the twelve-month periods beginning on October 8, 2007, October 8, 2008 and October 8, 2009. The October 8, 2008 - October 7, 2009 program, which was announced in September 2008, allowed repurchases up to a total of 6,664,051 shares of the fund. The October 8, 2009 - October 7, 2010 program, which was announced in September 2009, allows repurchases up to a total of 6,456,512 shares of the fund.

** Information prior to October 7, 2008 is based on the total number of shares eligible for repurchase under the program, as amended through September 2007. Information from October 8, 2008 forward is based on the total number of shares eligible for repurchase under the program, as amended through September 2008.

Item 10. Submission of Matters to a Vote of Security Holders:

Not applicable

Item 11. Controls and Procedures:

(a) The registrant's principal executive officer and principal financial officer have concluded, based on their evaluation of the effectiveness of the design and operation of the registrant's disclosure controls and procedures as of a date within 90 days of the filing date of this report, that the design and operation of such procedures are generally effective to provide reasonable assurance that information required to be disclosed by the registrant in this report is recorded, processed, summarized and reported within the time periods specified in the Commission's rules and forms.

(b) Changes in internal control over financial reporting: Not applicable

Item 12. Exhibits:

(a)(1) The Code of Ethics of The Putnam Funds, which incorporates the Code of Ethics of Putnam Investments, is filed herewith.

(a)(2) Separate certifications for the principal executive officer and principal financial officer of the registrant as required by Rule 30a-2(a) under the Investment Company Act of 1940, as amended, are filed herewith.

(b) The certifications required by Rule 30a-2(b) under the Investment Company Act of 1940, as amended, are filed herewith.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Putnam Master Intermediate Income Trust

By (Signature and Title):

/s/Janet C. Smith
Janet C. Smith
Principal Accounting Officer

Date: November 25, 2009

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title):

/s/Charles E. Porter
Charles E. Porter
Principal Executive Officer

Date: November 25, 2009

By (Signature and Title):

/s/Steven D. Krichmar
Steven D. Krichmar
Principal Financial Officer

Date: November 25, 2009

EX-99.CERT

Certifications

I, Charles E. Porter, the Principal Executive Officer of the funds listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on Attachment A:

2. Based on my knowledge, each report does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by each report;

3. Based on my knowledge, the financial statements, and other financial information included in each report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in each report;

4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a) designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which each report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c) evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of each report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant's other certifying officer and I have disclosed to each registrant's auditors and the audit committee of each registrant's board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect each registrant's ability to record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other employees who have a significant role in each registrant's internal control over financial reporting.

Date: November 24, 2009

/s/ Charles E. Porter
_______________________
Charles E. Porter
Principal Executive Officer

Certifications

I, Steven D. Krichmar, the Principal Financial Officer of the funds listed on Attachment A, certify that:

1. I have reviewed each report on Form N-CSR of the funds listed on Attachment A:

2. Based on my knowledge, each report does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by each report;

3. Based on my knowledge, the financial statements, and other financial information included in each report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in each report;

4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

a) designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which each report is being prepared;

b) designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c) evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of each report based on such evaluation; and

d) disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant's other certifying officer and I have disclosed to each registrant's auditors and the audit committee of each registrant's board of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect each registrant's ability to record, process, summarize, and report financial information; and

b) any fraud, whether or not material, that involves management or other employees who have a significant role in each registrant's internal control over financial reporting.

Date: November 24, 2009

/s/ Steven D. Krichmar
_______________________
Steven D. Krichmar
Principal Financial Officer

Attachment A 

N-CSR 

Period (s) ended September 30, 2009 

Putnam Master Intermediate Income Trust 

Putnam California Tax Exempt Income Fund 

Putnam American Government Income Fund 

Putnam Tax Exempt Income Fund 

Putnam International New Opportunities Fund 

Putnam U.S. Government Income Trust 

Putnam Money Market Fund 

Putnam Money Market Liquidity Fund 

Putnam Tax Exempt Money Market Fund 

Putnam Diversified Income Trust 

Putnam Asset Allocation: Balanced Portfolio 

Putnam Asset Allocation: Growth Portfolio 

Putnam Asset Allocation: Conservative Portfolio 

EX-99.906 CERT

Section 906 Certifications

I, Charles E. Porter, the Principal Executive Officer of the Funds listed on Attachment A, certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period ended September 30, 2009 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on Attachment A for the period ended September 30, 2009 fairly presents, in all material respects, the financial condition and results of operations of the Funds listed on Attachment A.

Date: November 24, 2009

/s/ Charles E. Porter
______________________
Charles E. Porter
Principal Executive Officer

Section 906 Certifications

I, Steven D. Krichmar, the Principal Financial Officer of the Funds listed on Attachment A, certify that, to my knowledge:

1. The form N-CSR of the Funds listed on Attachment A for the period ended September 30, 2009 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. The information contained in the Form N-CSR of the Funds listed on Attachment A for the period ended September 30, 2009 fairly presents, in all material respects, the financial condition and results of operations of the Funds listed on Attachment A.

Date: November 24, 2009

/s/ Steven D. Krichmar
______________________
Steven D. Krichmar
Principal Financial Officer

Attachment A

N-CSR

Period (s) ended September 30, 2009

Putnam Master Intermediate Income Trust 

Putnam California Tax Exempt Income Fund 

Putnam American Government Income Fund 

Putnam Tax Exempt Income Fund 

Putnam International New Opportunities Fund 

Putnam U.S. Government Income Trust 

Putnam Money Market Fund 

Putnam Money Market Liquidity Fund 

Putnam Tax Exempt Money Market Fund 

Putnam Diversified Income Trust 

Putnam Asset Allocation: Balanced Portfolio 

Putnam Asset Allocation: Growth Portfolio 

Putnam Asset Allocation: Conservative Portfolio 

EX-99.CODE ETH

   a_nf68stixmod6.htm



 

EX-99.CODE ETH

THE PUTNAM FUNDS 

Code of Ethics

Each of The Putnam Funds (the "Funds") has determined to adopt this Code of Ethics with respect to certain activities by officers and Trustees of the Funds which might be deemed to create possible conflicts of interest and to establish reporting requirements and enforcement procedures with respect to such activities.

I. Rules Applicable to Officers and Trustees Affiliated with Putnam Investments Trust or Its Subsidiaries

A. Incorporation of Adviser's Code of Ethics. The provisions of the Code of Ethics for employees of Putnam Investments Trust and its subsidiaries (the "Putnam Investments Code of Ethics"), which is attached as Appendix A hereto, are hereby incorporated herein as the Funds' Code of Ethics applicable to officers and Trustees of the Funds who are employees of the Funds or officers, directors or employees of Putnam Investments Trust or its subsidiaries. A violation of the Putnam Investments' Code of Ethics shall constitute a violation of the Funds' Code.

B. Reports. Officers and Trustees of each of the Funds who are made subject to the Putnam Investments' Code of Ethics pursuant to the preceding paragraph shall file the reports required by the Putnam Investments' Code of Ethics with the Code of Ethics Officer designated therein. A report filed with the Code of Ethics Officer shall be deemed to be filed with each of the Funds of which the reporting individual is an officer or Trustee.

C. Review and Reporting.

(1) The Code of Ethics Officer shall cause the reported personal securities transactions to be compared with completed and contemplated portfolio transactions of each of the Funds to determine whether a violation of this Code may have occurred. Before making any determination that a violation has been committed by any person, the Code of Ethics Officer shall give such person an opportunity to supply additional explanatory material.

(2) If the Code of Ethics Officer determines that a violation of any provision of this Code has or may have occurred, he shall submit his written determination, together with any additional explanatory material, to the Audit and Compliance Committee of the Funds at its next meeting when Code of Ethics matters are discussed.

D. Sanctions. In addition to reporting violations of this Code to the Audit and Compliance Committee of the Funds as provided in Section I-C(2), the Code of Ethics Officer shall also report to such Committee any sanctions imposed with

respect to such violations. The Committee reserves the right to impose such additional sanctions as it deems appropriate.

II. Rules Applicable to Unaffiliated Trustees

A. Definitions.

(1) "Beneficial ownership" shall be interpreted in the same manner as it would be in determining whether a person is subject to the provisions of Section 16 of the Securities Exchange Act of 1934 and the rules and regulations thereunder.

(2) "Control" means the power to exercise a controlling influence over the management or policies of a company, unless such power is solely the result of an official position with such company.

(3) "Covered Person" means an affiliated person of the Fund, who is not made subject to the Putnam Investments Code of Ethics pursuant to Part I hereof.

(4) "Interested Trustee" means a Trustee of a Fund who is an "interested person" of the Fund within the meaning of the Investment Company Act of 1940, as amended (the "Investment Company Act").

(5) "Purchase or sale of a security" includes, among other things, the writing of an option to purchase or sell a security.

(6) "Security" shall have the same meaning as that set forth in Section 2(a)(36) of the Investment Company Act (in effect, all securities) except that it shall not include securities issued by the Government of the United States or an agency thereof, bankers' acceptances, bank certificates of deposit, commercial paper and high-quality short-term debt investments, including repurchase agreements, and shares of registered open-end investment companies, but shall include any security convertible into or exchangeable for a security.

(7) "Security Held or to be Acquired by a Fund" means: (i) any security, as defined herein, which, within the most recent 15 days: (A) is or has been held by the Fund, or (B) is being or has been considered by the Fund or Putnam Investments for purchase by the Fund, and (ii) any option to purchase or sell, and any security convertible into or exchangeable for, a security described in (i) above.

(8) "Unaffiliated Trustee" means a Trustee who is not made subject to the Putnam Investments Code of Ethics pursuant to Part I hereof.

2 

B. Prohibited Actions. No Covered Person, in connection with the purchase or sale, directly or indirectly, by such Covered Person of a security held or to be acquired by the Fund, shall:

(1) Employ any device, scheme or artifice to defraud the Fund;

(2) Make any untrue statement of a material fact to the Fund or omit to state a material fact necessary in order to make the statements made to the Fund, in light of the circumstances under which they are made, not misleading;

(3) Engage in any act, practice or course of business that operates or would operate as a fraud or deceit on the Fund; or

(4) Engage in any manipulative practice with respect to the Fund.

C. Reporting.

(1) Every Unaffiliated Trustee of a Fund shall file with the Funds' Compliance Liaison a report containing the information described in Section II-C(2) of this Code with respect to purchases or sales of any security in which such Unaffiliated Trustee has, or by reason of such transaction acquires, any direct or indirect beneficial ownership, if such Trustee, at the time of that transaction, knew or, in the ordinary course of fulfilling his official duties as a Trustee of the Fund, should have known that, during the 15-day period immediately preceding or after the date of the transaction by the Trustee:

(a) such security was or is to be purchased or sold by the Fund or

(b) such security was or is being considered for purchase or sale by the Fund;

provided, however, that an Unaffiliated Trustee shall not be required to make a report with respect to transactions effected for any account over which such person does not have any direct or indirect influence or control.

(2) Every report shall be made not later than 10 days after the end of the calendar quarter in which the transaction to which the report relates was effected, and shall contain the following information:

3 

(a) The date of the transaction, the title, the number of shares, the interest rate and maturity date (if applicable) and the principal amount of each security involved;

(b) The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

(c) The price at which the transaction was effected;

(d) The name of the broker, dealer or bank with or through whom the transaction was effected; and

(e) the date that the report is submitted by each Unaffiliated Trustee.

(3) Any such report may contain a statement that the report shall not be construed as an admission by the person making such report that he has any direct or indirect beneficial ownership in the security to which the report relates.

(4) Notwithstanding anything to the contrary contained herein, an Unaffiliated Trustee who is an "interested person" of the Funds shall file the reports required by Rule 17j-1(d)(1) under the Investment Company Act with the Code of Ethics Officer of Putnam Investments. Such reports shall be reviewed by such Officer as provided in Section I-D(1) and any related violations shall be reported by him to the Audit and Compliance Committee as provided in Section I-C(2). The Committee may impose such additional sanctions as it deems appropriate.

D. Review and Reporting.

(1) The Compliance Liaison of the Funds, in consultation with the Code of Ethics Officer of Putnam Investments, shall cause the reported personal securities transactions that he receives pursuant to Section II-C(1) to be compared with completed and contemplated portfolio transactions of the Funds to determine whether any prohibited action listed in Section II-B may have occurred.

(2) Before making any determination that a violation of this Code has occurred, the Compliance Liaison shall give the person involved an opportunity to supply additional information regarding the transaction in question.

E. Sanctions. If the Compliance Liaison determines that a violation of this Code has occurred, he shall so advise the Funds' Audit and Compliance Committee, and provide the Committee with a report of the matter, including any additional information supplied by such person. The Committee may impose such sanctions as it deems appropriate.

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III. Miscellaneous

A. Amendments to the Putnam Investments' Code of Ethics. Any amendment to the Putnam Investments' Code of Ethics shall be deemed an amendment to Section 1-A of this Code effective 30 days after written notice of such amendment shall have been received by the Chairman of the Funds, unless the Trustees of the Funds expressly determine that such amendment shall become effective at an earlier or later date or shall not be adopted.

B. Records. The Funds shall maintain records in the manner and to the extent set forth below, which records may be maintained on microfilm under the conditions described in Rule 31a-2(f)(1) under the Investment Company Act and shall be available for examination by representatives of the Securities and Exchange Commission.

(1) A copy of this Code and any other code which is, or at any time within the past five years has been, in effect shall be preserved in an easily accessible place;

(2) A record of any violation of this Code and of any action taken as a result of such violation shall be preserved in an easily accessible place for a period of not less than five years following the end of the fiscal year in which the violation occurs;

(3) A copy of each report made by an officer or Trustee pursuant to this Code shall be preserved for a period of not less than five years from the end of the fiscal year in which it is made, the first two years in an easily accessible place;

(4) A list of all persons who are, or within the past five years have been, required to make reports pursuant to this Code shall be maintained in an easily accessible place; and

(5) To the extent any record required to be kept by this section is also required to be kept by Putnam Investments pursuant to the Putnam Investments' Code of Ethics, Putnam Investments shall maintain such record on behalf of the Funds as well.

C. Confidentiality. All reports of securities transactions and any other information filed with any Fund pursuant to this Code shall be treated as confidential, but are subject to review as provided herein and by personnel of the Securities and Exchange Commission.

D. Interpretation of Provisions. The Trustees may from time to time adopt such interpretations of this Code as they deem appropriate.

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E. Delegation by Chairman. The Chairman of the Funds may from time to time delegate any or all of his responsibilities under this Code, either generally or as to specific instances, to such officer or Trustee of the Funds as he may designate.

As revised
September 11, 2009

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EX-99.CODE ETH

working@PUTNAM MAY  2008 

Putnam’s
Code of Ethics

Graphic Omitted: Portrait of Justice Samuel Putnam

Dear Putnam Employee,

Putnam’s Code of Ethics is an essential component of the “fiduciary mindset” and of our commitment to the maintenance of the highest professional standards. Taking care of other people’s money is a serious responsibility, and we need to ensure that our clients’ interests come first. Firms with a strong fiduciary culture are attractive to clients who are looking for superior money management, and Putnam’s Code is designed to ensure that Putnam preserves that trust.

The rules reflected in the Code are good business practices and were not created simply to meet regulatory standards. If, from time to time, the rules seem burdensome, I ask you to put yourself in the place of our shareholders and clients, who have entrusted us to manage their assets so that they may pursue the goals of saving for retirement or funding their children’s education.

If you have any questions or concerns at any time, however, I encourage you to contact one of the members of our Code of Ethics staff in the Legal and Compliance Department.

Graphic Omitted: Signature of Ed Haldeman

Ed Haldeman
President and Chief Executive Officer

Table of Contents
Code of Ethics Overview	1
Putnam’s Code of Ethics	4
Definitions	5
Section I — Personal Securities Rules for All Employees	8
A. Pre-clearance	8
Rule 1: Pre-clearance Requirements	8
Rule 2: Personal Trading Assistant (PTA) System and Restricted List	8
Rule 3: Marsh & McLennan (MMC) securities	11
B. Prohibited Transactions	12
Rule 1: Short-Selling Prohibition	12
Rule 2: Initial Public Offerings Prohibition	12
Rule 3: Private Placement Pre-approval Requirements	13
Rule 4: Trading with Material Non-public Information	13
Rule 5: No Personal Trading with Client Portfolios	13
Rule 6: Holding Putnam Mutual Fund Shares	14
Rule 7: Putnam Mutual Fund Employee Restrictions	15
Rule 8: Special Orders	16
Rule 9: Excessive Trading	16
Rule 10: Spread Betting	17
C. Discouraged Transaction	17
Rule 1: Naked Options	17
D. Exempted Transactions	17
Rule 1: Involuntary Transactions	17
Rule 2: Special Exemptions	18
Section II — Additional Special Rules for Personal Securities Transactions	19
A. Access Persons and Certain Investment Professionals	19
Rule 1: 90-Day Short-Term Rule	19
B. Certain Investment Professionals	19
Rule 2: 7-Day Rule	19
Rule 3: Blackout Rule	20
Rule 4: Contra-Trading Rule	21
Rule 5: No Personal Benefit	21
Section III — General Rules for All Employees	23
Rule 1: Compliance with All Laws, Regulations, and Policies	23
Rule 2: Conflicts of Interest	23
Rule 3: Gifts and Entertainment Policy	23
Rule 4: Anti-bribery/Kickback Policy	25
Rule 5: Political Activities, Contributions, Solicitations, and Lobbying Policy	26
Rule 6: Confidentiality of Putnam Business Information	27
Rule 7: Positions Outside Putnam	27
Rule 8: Role as Trustee or Fiduciary Outside of Putnam Investments	28
Rule 9: Investment Clubs	28
Rule 10: Business Negotiations for Putnam Investments	28
Rule 11: Accurate Records	29
Rule 12: Family Members’ Conflict Policy	29
Rule 13: Affiliated Entities	29

Rule 14: Computer Systems and Network Use Policy	30
Rule 15: CFA Institute Code of Ethics and Standards of Professional Conduct	31
Rule 16: Privacy Policy	31
Rule 17: Anti- money Laundering Policy	32
Rule 18: Record Retention	32
Section IV — Reporting Requirements	33
Reporting of Personal Securities Transactions	33
Rule 1: Broker Confirmations and Statements	33
Rule 2: Access Person — Quarterly Transaction Report	34
Rule 3: Access Person — Initial/Annual Holdings Report	34
Rule 4: Certifications	34
Rule 5: Positions Outside Putnam	34
Rule 6: Business Ethics	34
Rule 7: Ombudsman	35
Section V — Education Requirements	36
Rule 1: Distribution of Code	36
Rule 2: Annual Training Requirement	36
Section VI — Compliance and Appeal Procedures	37
Section VII — Sanctions	39
Appendix A — Insider Trading Prohibitions Policy Statement	40
Appendix A — Definitions: Insider Trading	41
Appendix A — Section I: Rules Concerning Inside Information	42
Rule 1: Inside Information	42
Rule 2: Material Non-public Information	42
Rule 3: Reporting of Material Non-public Information	42
Appendix A — Section II: Overview of Insider Trading	44
Appendix B — Policy Statement Regarding Employee Trades in Shares of Putnam Closed-End
Funds	48
Appendix C — Contra- Trading Rule Clearance Form	49
Appendix D — CFA Institute Code of Ethics and Standards of Professional Conduct	50
Appendix E — Inducement Policy for Putnam Investments Limited (PIL) Employees	54

Code of Ethics Overview

This overview of Putnam’s Code of Ethics is not intended to substitute for a careful reading of the complete document. As a condition of continued employment, every Putnam employee is required to read, understand, and comply with all of the provisions of the Code of Ethics. Additionally, employees are expected to comply with the policies and procedures contained within the Putnam Employee Handbook, which is available online via Putnam’s intranet home page at http://intranet .

It is the personal responsibility of every Putnam employee to avoid any conduct that could create a conflict, or even the appearance of a conflict, with our fund shareholders or other clients, or do anything that could damage or erode the trust our clients place in Putnam and its employees. This is the spirit of the Code of Ethics. In accepting employment at Putnam, every employee accepts the absolute obligation to comply with the letter and the spirit of the Code of Ethics. Failure to comply with the spirit of the Code of Ethics is just as much a violation of the Code as failure to comply with the written rules of the Code.

The rules of the Code cover activities, including personal securities transactions, of Putnam employees, certain family members of employees, and entities (such as corporations, trusts, or partnerships) that employees may be deemed to control or influence.

Sanctions will be imposed for violations of the Code of Ethics. Sanctions may include monetary fines, bans on personal trading, reductions in salary increases or bonuses, disgorgement of trading profits, suspension of employment, and termination of employment. The proceeds resulting from monetary sanctions will be given to a charity chosen by the Code of Ethics Officer.

Insider trading

Putnam employees are forbidden to buy or sell any security while either Putnam or the employee is in possession of material non-public information (inside information) concerning the security or the issuer. A violation of Putnam’s insider trading policies may result in criminal and civil penalties, including imprisonment, disgorgement of profits, and substantial fines. An employee aware of or in possession of inside information must report it immediately to the Code of Ethics Officer. (See Appendix A: Insider Trading Prohibitions Policy Statement.)

Conflicts of interest

The Code of Ethics imposes limits on activities of Putnam employees where the activity may conflict with the interests of Putnam or its clients. These include limits on the receipt and solicitation of gifts and on service as a fiduciary for a person or entity outside of Putnam. For example, Putnam employees generally may not accept gifts over $100 in total value in a calendar year from any entity, or any supplier of goods or services to Putnam. In addition, a Putnam employee may not serve as a director of any corporation or other entity without prior approval of the Code of Ethics Officer.

Confidentiality

Information about Putnam clients and Putnam investment activity and research is proprietary and confidential and may not be disclosed or used by any Putnam employee outside Putnam without a valid business purpose.

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Putnam mutual funds

All employees and certain family members are subject to a minimum 90-day holding period for shares in Putnam’s open-end mutual funds. This restriction does not apply to Putnam’s Stable Value or money market funds. Except in limited circumstances, all employees must hold Putnam open-end fund shares in accounts at Putnam.

Portfolio managers and others with access to investment information (“Access Persons”) are subject to a minimum one-year holding period for holding Putnam open-end fund shares.

Personal securities trading

Putnam employees may not buy or sell any security for their own account without clearing the proposed transaction in advance. Clearance is facilitated through the Personal Trading Assistant (PTA), the online pre-clearance system for equity securities, and directly with the Code of Ethics Administrator for fixed-income securities and transactions in Putnam closed-end funds. Certain securities are exempted from this pre-clearance requirement (e.g., shares of open-end (not closed-end) mutual funds).

Putnam employees may not buy any securities in an initial public offering or in a private placement, except in limited circumstances when prior written authorization is obtained.

Clearance must be obtained in advance, between 9:00 a.m. and 4:00 p.m. Eastern Time (ET) on the day of the trade. A clearance is valid only for the day it is obtained. Putnam employees are strongly discouraged from engaging in excessive trading for their personal accounts. Employees are prohibited from making more than 10 trades in individual securities each calendar quarter.

Short selling

Putnam employees are prohibited from short selling any security, whether or not it is held in a Putnam client portfolio, although short selling against broad market indexes and “against the box” is permitted. Note, however, that short selling “against the box” or otherwise hedging an investment in shares of Power Corporation of Canada, Power Financial Corporation, and Great-West Lifeco Inc. stock is prohibited.

Confirmations of trading and periodic account statements

All Putnam employees must have their brokers send copies of confirmations and statements of personal securities transactions to the Code of Ethics Administrator. This also applies to members of the immediate family who share the same household as the employee or for whom the employee has investment discretion. Employees must contact the Code of Ethics Administrator to (a) obtain an authorization [407] letter, (b) provide instructions to the broker in establishing a personal brokerage account, and (c) enter a broker account profile into PTA.

Quarterly and annual reporting

Employees will be notified if the following requirements apply. Upon commencement of employment and thereafter on an annual basis, Access Persons must disclose in the PTA system all personal securities holdings (even those to which pre-clearance may not apply). On a quarterly basis, Access Persons must disclose all their securities transactions in Personal Trading Assistant (PTA) within 15 days after the end of the quarter.

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Personal securities transactions by Access Persons and certain investment professionals

The Code imposes several special restrictions on personal securities transactions by Access Persons and certain investment professionals, which are summarized as follows. (Refer to Section II for details):

• 90-Day Short-Term Rule. No Access Person shall purchase and then sell at a profit, or sell and then repurchase at a lower price, any security or related derivative security, for example, options, within 90 calendar days.

• 7-Day Rule. Before a portfolio manager places an order to buy a security for any portfolio he manages, he must sell from his personal account any such security or related derivative security purchased within the preceding seven calendar days, and disgorge any profit from the sale.

• Blackout Rule. No portfolio manager may sell any security or related derivative security for her personal account until seven calendar days after the most recent purchase of that security or related derivative security for any portfolio she manages. No portfolio manager may buy any security or related derivative security for her personal account until seven calendar days after the most recent sale of that security or related derivative security by any portfolio she manages.

Analysts are also subject to the 7-Day and Blackout rules in connection with a recommendation to buy/outperform or sell/underperform a security.

• Contra-Trading Rule. No portfolio manager may sell out of her personal account any security or related derivative security that is held in any portfolio she manages unless she has received the written approval of an appropriate CIO and the Code of Ethics Officer.

• No portfolio manager may cause a Putnam client to take action for the manager’s personal benefit.

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Putnam’s Code of Ethics

Putnam Investments is required by law to adopt a Code of Ethics. The purposes of the law are to ensure that companies and their employees comply with all applicable laws and to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between the employees of an investment advisor and its clients. By adopting and enforcing a Code of Ethics, we strengthen the trust and confidence reposed in us by demonstrating that at Putnam, client interests come first.

The Code that follows represents a balancing of important interests. On the one hand, as a registered investment advisor, Putnam owes a duty of undivided loyalty to its clients, and must avoid even the appearance of a conflict that might be perceived as abusing the trust they have placed in Putnam. On the other hand, Putnam does not want to prevent conscientious professionals from investing for their own account where conflicts do not exist or that are immaterial to investment decisions affecting Putnam clients.

When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Putnam employees owe a fiduciary duty to Putnam clients. In most cases, this means that the affected employee will be required to forego conflicting personal securities transactions. In some cases, personal investments will be permitted, but only in a manner, which, because of the circumstances and applicable controls, cannot reasonably be perceived as adversely affecting Putnam client portfolios or taking unfair advantage of the relationship Putnam employees have to Putnam clients.

The Code contains specific rules prohibiting defined types of conflicts. Because every potential conflict cannot be anticipated, the Code also contains general provisions prohibiting conflict situations. In view of these general provisions, it is critical that any individual who is in doubt about the applicability of the Code in a given situation seeks a determination from the Code of Ethics Officer about the propriety of the conduct in advance. The procedures for obtaining such a determination are described in Section VI of the Code.

It is critical that the Code be strictly observed. Not only will adherence to the Code ensure that Putnam renders the best possible service to its clients, it will help to ensure that no individual is liable for violations of law.

It should be emphasized that adherence to this policy is a fundamental condition of employment at Putnam. Every employee is expected to adhere to the requirements of this Code of Ethics despite any inconvenience that may be involved. Any employee failing to do so may be subject to disciplinary action, including financial penalties and termination of employment, as determined by the Code of Ethics Officer, the Code of Ethics Oversight Committee, or the Chief Executive Officer of Putnam Investments.

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Definitions

The words below are defined specifically for the purpose of Putnam’s Code of Ethics.

Access Persons

Each employee will be informed if he or she is considered an Access Person. The Code of Ethics Officer maintains a list of all Access Persons, categorized as follows:

• All employees of Putnam’s Investment Management Division

• Employees of the Operations and Administration Division within the following specific groups and departments:

o Fund Administration Group

o Global Operations Strategy Group

o Fund Accounting Oversight Group

o Custody Oversight Group

o Alternative Investments Department (in the Global Client Operations & Services Group)

• All employees in the Market Data Services Group

• Senior Managing Directors and Managing Directors in:

o Mutual Fund Shareholder Services Group

o Fund Accounting Oversight & Control Group

o Global Client Operations, Services & Custody Group

o Global Distribution and Marketing Division

o Corporate Development & Global Distribution Services Division

• All members of Putnam’s Executive Board

• All directors and employees of Putnam Investments Limited (PIL) and those based in Europe

• All directors and officers of a registered investment advisor affiliate, e.g., Putnam Investment Management, LLC (PIM), or The Putnam Advisory Company, LLC (PAC)

• All employees who have access to My Putnam (unless access is limited to the Wall Street Journal via Factiva )

• Employees who have systems access to non-public information about any client’s purchase or sale of securities or to information regarding recommendations with respect to such purchases or sales

• Employees who have access to non-public information regarding the portfolio holdings of any Putnam-advised or sub-advised mutual fund

• Others as defined by the Legal and Compliance Department

Closed-end fund A fund with a fixed number of shares outstanding, and that does not redeem shares the way a typical mutual fund does. Closed-end funds typically trade like stocks on exchange.

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Code of Ethics Administrator The individual designated by the Code of Ethics Officer to assume responsibility for day-to-day, nondiscretionary administration of this Code. The current Code of Ethics Administrator is Laura Rose, who can be reached at extension 11104.

Code of Ethics Officer The Putnam officer who has been assigned the responsibility of enforcing and interpreting this Code. The Code of Ethics Officer shall be the Chief Compliance Officer or such other person as is designated by the Chief Executive Officer of Putnam Investments. If the Code of Ethics Officer is unavailable, the Deputy Code of Ethics Officer shall act in his stead. The Code of Ethics Officer is Bob Leveille. The Deputy Code of Ethics Officer is Kathleen Griffin.

Code of Ethics Oversight Committee Has oversight responsibility for administering the Code of Ethics. Members include the Code of Ethics Officer and other members of Putnam’s senior management approved by the Chief Executive Officer of Putnam.

Discretionary Account An account for which the holder gives his/her broker or investment advisor (but not an immediate family member) complete authority to make management decisions to buy and sell securities (also called controlled account or managed account).

Exchange-Traded Fund (ETF) A fund that tracks an index, but can be traded like a stock. ETFs always bundle together the securities that are in an index. Examples include (but are not limited to): SPDRs, WEBs, QQQQs, iShares, and HLDRs.

NOTE:

Excluded from pre-clearance but not from reporting requirements are: exchange-traded index funds (ETFs) containing a portfolio of securities of 25 or more issuers (e.g., SPDRs, WEBs, QQQQs, iShares, and HLDRs), and any option on a broad-based market index or an exchange-traded futures contract or option. Country funds, as well as other funds that are not tied to an index, are considered closed-end funds and are subject to pre-clearance and reporting requirements. (See Section I.A, Rule 1: Pre-clearance Requirements for more information.)

Immediate family Spouse, domestic partner, minor children, or other relatives living in the same household as the Putnam employee. All pre-clearance and reporting rules apply to “immediate family members.”

Narrow-based derivative A future, swap, put or call option, or similar derivative instrument whose return is determined by reference to fewer than 25 underlying issuers. Single stock futures and ETFs based on less than 25 issuers are included.

Personal Trading Assistant (PTA) The Personal Trading Assistant (PTA) is an Internet application designed for employees to manage personal trading activities, such as pre-clearance, reporting, and certifications, in accordance with regulatory requirements and Putnam’s Code of Ethics.

Policy statements The Insider Trading Prohibitions Policy Statement is attached to the Code as Appendix A and the Policy Statement Regarding Employee Trades in Shares of Putnam Closed-End Funds is attached to the Code as Appendix B.

Private placement Any offering of a security not offered to the public and not requiring registration with the relevant securities authorities.

Purchase or sale of a security Any acquisition or transfer of any interest in the security for direct or indirect consideration; this includes the writing of an option. This definition includes any transfer of a security by an employee as a gift to an individual or a charity.

Putnam Any or all of Putnam Investments, LLC and its subsidiaries, any one of which shall be a Putnam company.

Putnam client Any of the Putnam mutual funds, or any advisor, trust, or other client for whom Putnam manages money.

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Putnam employee (or employee) Any employee of Putnam.

Restricted list The list established in accordance with Rule 1 of Section I.A.

Security The following instruments are defined as “securities” and require pre-clearance:

• Any type or class of equity or debt security, e.g., corporate or municipal bonds

• Any rights relating to a security, such as warrants and convertible securities

• Closed-end funds

• Any narrow-based derivative, e.g., a put or call option on a single security

Pre-clearance and reporting is not required (unless otherwise noted) for:

• Open-end mutual funds

• Currencies, Treasuries (T-bills), and direct and indirect obligations of the U.S. government and its agencies

• Direct and indirect obligations of any member country in the Organization for Economic CoOperation and Development (OECD), commercial paper, certificates of deposit (CDs), repurchase agreements, bankers’ acceptances, and other money market instruments

Short selling The sale of a security that the investor does not own in order to take advantage of an anticipated decline in the price of the security. In order to sell short, the investor must borrow the security from his broker in order to make delivery to the buyer.

Short selling against the box A short sale where the investor owns the security, but does not want to use the shares for delivery, so he borrows them from the brokerage firm.

Transaction for a personal account Securities transactions: (a) for the personal account of any employee; (b) for the account of a member of the immediate family of any employee; (c) for the account of a partnership in which a Putnam employee or immediate family member is a general partner or a partner with investment discretion; (d) for the account of a trust in which a Putnam employee or immediate family member is a trustee with investment discretion; (e) for the account of a closely held corporation in which a Putnam employee or immediate family member holds shares and for which he has investment discretion; and (f ) for any account other than a Putnam client account, which receives investment advice of any sort from the employee or immediate family member, or as to which the employee or immediate family member has investment discretion.

Rule of construction regarding time periods Unless the context indicates otherwise, time periods used in the Code of Ethics shall be measured inclusively, i.e., beginning on the date from which the measurement is made.

EXCEPTIONS

Unless the context indicates otherwise, there will be no exceptions to the rules.

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Section I — Personal Securities Rules for All Employees

A. Pre-clearance

Rule 1: Pre-clearance Requirements

Pre-clearance is required for the following securities:

• Any type or class of equity or debt security, including corporate and municipal bonds

• Stock of Power Corporation of Canada, Power Financial Corporation, and Great-West Lifeco Inc.

• Any rights relating to a security, such as warrants and convertible securities

• Closed-end funds – including Putnam closed-end funds. Country funds, as well as other funds that are not tied to an index, are considered closed-end funds and are subject to pre-clearance and reporting requirements, e.g., India Fund (IFN), Morgan Stanley Asia Pacific Fund (APF), and Central Europe and Russia Fund (CEE). Certain closed-end funds that sometimes are referred to as closed-end ETFs, such as Western Asset Emerging (ESD) or Eaton Vance Muni Trust (EVN), are also subject to pre-clearance and reporting requirements.

• Any narrow-based derivative, e.g., a put or call option on a single security

• Any security donated as a gift to an individual or a charity

• Marsh & McLennan (MMC) securities

Pre-clearance is not required for:

• Open-end mutual funds

• Currencies, Treasuries (T-bills), and direct and indirect obligations of the U.S. government and its agencies

• Direct and indirect obligations of any member of the country of the Organization for Economic Co-Operation and Development (OECD), commercial paper, certificates of deposit (CDs), repurchase agreements, bankers’ acceptances, and other money market instruments

• Application for a loan and/or withdrawals of MMC stock from your 401(k)/Profit Sharing Plan

The following are excluded from pre-clearance but not from reporting requirements:

Exchange-traded funds (ETFs) containing a portfolio of securities of 25 or more issuers (e.g., SPDRs, WEBs, QQQQs, iShares, and HLDRs), and any option on a broad-based market index or an exchange-traded futures contract or option thereon.

Rule 2: Personal Trading Assistant (PTA) System and Restricted List

No Putnam employee shall purchase or sell for his personal account any security requiring pre-clearance under Rule 1 without prior clearance obtained through procedures set forth by the Code of Ethics Officer. Equity securities are pre-cleared through the PTA pre-clearance system (on Putnam’s intranet home page at http://intranet ). Fixed-income securities must be pre-cleared by calling the Code of Ethics Administrator. There are special rules for trading in Putnam closed-end funds. (See Appendix B.) Subject to the limited exceptions below, no clearance will be granted for securities appearing on the Restricted List. Securities will be placed on the Restricted List in the following circumstances:

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(a) When orders to purchase or sell such security have been entered for any Putnam client or the security is being actively considered for purchase for any Putnam client, unless the security is a non-convertible investment-grade (rated at least BBB by S&P or Baa by Moody’s) fixed-income investment;

(b) When such a security is a voting security of a corporation in the banking, savings and loan, insurance, communications, public utilities, or gaming (i.e., casinos) industries, if holdings of Putnam clients in that corporation exceed 7%;

(c) When, in the judgment of the Code of Ethics Officer, other circumstances warrant restricting personal transactions of Putnam employees in a particular security; and

(d) When required under the Policy Statement Concerning Insider Trading Prohibitions. (See Appendix A.)

IMPLEMENTATION

An employee wishing to trade any equity securities for his personal account shall first obtain clearance through the Personal Trading Assistant (PTA) system. The system may be accessed online via Putnam’s intranet home page at http://intranet . Employees may pre-clear securities between 9:00 a.m. and 4:00 p.m. ET. Requests to make personal securities transactions may not be made using the system or presented to the Code of Ethics Administrator before 9:00 a.m. or after 4:00 p.m. ET.

Pre-clearance must be made by calling the Code of Ethics Administrator for a fixed-income investment (municipal and corporate bonds, including non-convertible investment-grade bonds rated BBB by S&P or Baa by Moody’s).

The PTA system will inform the employee whether the security may be traded and whether trading in the security is only eligible up to the limits under the “Large-/Mid-Cap Exemption.” The response of the pre-clearance system as to whether a security appears on the Restricted List and, if so, whether it is eligible for the exceptions set forth after this Rule shall be final, unless the employee appeals to the Code of Ethics Officer, using the procedure described in Section VI, regarding the request to trade a particular security.

A clearance is only valid for trading on the day it is obtained. Trades in any security by employees in Asian or European offices of Putnam or trades by any employee in securities listed on Asian or European stock exchanges, however, may be executed within one business day after pre-clearance is obtained.

If a security is not on the Restricted List, other classes of securities of the same issuer (e.g., preferred or convertible preferred stock) may be on the Restricted List. It is the employee’s responsibility to identify with particularity the class of securities for which permission is being sought for a personal investment.

If the PTA system does not recognize a security, or if an employee is unable to use the system or has any questions with respect to the system or pre-clearance, the employee may consult the Code of Ethics Administrator. The Code of Ethics Administrator shall not have authority to answer any questions about a security other than whether trading is permitted. The response of the Code of Ethics Administrator as to whether a security appears on the Restricted List and, if so, whether it is eligible for any applicable exceptions set forth after this Rule shall be final, unless the employee appeals to the Code of Ethics Officer, using the procedure described in Section VI, regarding the request to trade a particular security.

EXCEPTIONS

A. Large-/Mid-Cap Exemption. If a security appearing on the Restricted List is an equity security for which the issuer has a market capitalization (defined as outstanding shares multiplied by current price per share) of over $2 billion, then upon clearance approval, the Putnam employee may not trade more than 1,000 shares of the security for the day.

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B. Pre-clearing Transactions Effected by Share Subscription. Trades of securities made by subscription rather than on an exchange are limited to issuers having a market capitalization of $2 billion or more and are subject to the 1,000 share limit. The following are procedures to comply with Rules 1 and 2 when effecting a purchase or sale of shares by subscription:

• The Putnam employee must pre-clear the trade on the day he or she submits a subscription to the issuer rather than on the actual day of the trade since the actual day of the trade typically will not be known to the employee who submits the subscription. The employee must contact the Code of Ethics Administrator at the time of pre-clearance and will be told whether the purchase is permitted (in the case of a corporation having a market capitalization of $2 billion or more) or not permitted (in the case of a smaller capitalization issuer).

• The subscription for any purchase or sale of shares must be reported on the Access Person’s quarterly personal securities transaction report, noting the trade was accomplished by subscription.

• Because no brokers are involved in the transaction, the confirmation requirement will be waived for these transactions, although the Putnam employee must provide the Legal and Compliance Department with any transaction summaries or statements sent by the issuer.

C. Trades in Approved Discretionary Brokerage Accounts. A transaction does not need to be pre-cleared if it takes place in an account that the Code of Ethics Officer has approved in writing as exempt from the pre-clearance requirement prior to establishing the account. In the sole discretion of the Code of Ethics Officer, accounts that will be considered for exclusion from the pre-clearance requirement are only those for which an employee’s securities broker or investment advisor has complete discretion (a discretionary account).

Employees wishing to seek such an exemption must send a written request to the Code of Ethics Administrator and meet the following conditions: (i) the employee certifies annually in writing that the employee has no influence over the transactions in the discretionary account and is not aware of the transactions in the discretionary account prior to their execution; (ii) the broker or investment advisor certifies annually in writing that the employee has no influence over the transactions in the discretionary account and is not aware of the transactions in the discretionary account prior to their execution; and (iii) each calendar quarter, the broker or investment advisor sends Putnam’s Code of Ethics Administrator copies of each quarterly statement for the discretionary account.

COMMENTS

• Pre-clearance. Subpart (a) of Rule 2 is designed to avoid the conflict of interest that might occur when an employee trades for his personal account a security that currently is being traded or is likely to be traded for a Putnam client. Such conflicts arise, for example, when the trades of an employee might have an impact on the price or availability of a particular security, or when the trades of the client might have an impact on price to the benefit of the employee. Thus, exceptions involve situations where the trade of a Putnam employee is unlikely to have an impact on the market.

• Regulatory Limits. Owing to a variety of federal statutes and regulations in the banking, savings and loan, insurance, communications, public utilities, and gaming industries, it is critical that accounts of Putnam clients do not hold more than 7% of the voting securities of any issuer in those industries. Subpart (b) of this rule limits employees’ personal trades to sales of shares in these areas because of the risk that the personal holdings of Putnam employees may be aggregated with Putnam holdings. Putnam’s so-called 7% rule will allow the regulatory limits to be observed.

• Options. For the purposes of this Code, options are treated like the underlying security. Thus, an employee may not purchase, sell, or “write” option contracts for a security that is on the

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Restricted List. The automatic exercise or assignment of an options contract (the purchase or writing of which was previously pre-cleared) does not have to be pre-cleared. Note, however, that the purchase or sale of securities obtained through the exercise of options must be pre-cleared.

• Involuntary Transactions. Involuntary personal securities transactions are exempted from the Code. Special attention should be paid to this exemption. (See Section I.D.)

• Tender Offers. This Rule does not prohibit an employee from tendering securities from his personal account in response to any and all tender offers, even if Putnam clients are also tendering securities. If tendering a security in response to a “partial tender offer,” an employee must pre-clear the trade on the day she submits instructions to her broker, and she will be prohibited from trading if Putnam clients are also tendering the same security.

• Gifts of Securities. Pre-clearance is required for securities donated as a gift to a charitable organization or to an individual. Employees are required to provide a gift transfer certificate of the transaction (if produced) to the Code of Ethics Administrator along with an account statement reflecting the gift transaction. Employees who receive a security gift must report the gift to the Code of Ethics Administrator who will make the necessary adjustments in PTA. Access Persons must enter the gift as a security holding in PTA and report in their Annual Holdings Report.

Rule 3: Marsh & McLennan (MMC) securities

All employees trading MMC securities must pre-clear the trades in the PTA system. MMC securities include stock, options, and any other securities such as debt. Sales out of the MMC Employee Stock Purchase Plan and transactions in all Putnam and MMC employee benefit and bonus plans, i.e., rebalancing or exchanging out of the 401(k)/Profit Sharing/Bonus Plan, are included in this requirement.

Pre-clearance of MMC is required when, for example, you:

• Sell MMC out of the Stock Purchase Plan

• Exchange MMC shares out of your 401(k)/Profit Sharing/Bonus Plan

• Rebalance your Putnam fund choices, which results in a sale of MMC from your 401(k)/Profit Sharing/Bonus Plan

• Trade in MMC securities in other accounts held outside Putnam Investments

Pre-clearance is not required when you apply for a loan and/or make withdrawals of the stock from your 401(k)/Profit Sharing Plan.

COMMENTS

All transactions of MMC require pre-clearance in PTA before you contact Citi Smith Barney to sell shares out of your Stock Purchase Plan. Also, if MMC is one of your choices in the 401(k)/Profit Sharing Plan, all exchanges must be cleared. Even though clearance is not required for Putnam mutual funds, if you do not wish to include MMC shares when rebalancing any of your fund choices, which will result in an automatic exchange of your MMC shares, you must remember to exclude MMC shares prior to submitting your changes. If you are investing online, check the box to exclude MMC; or if you are investing by telephone with a Putnam representative, ask to exclude MMC before rebalancing the funds.

Additional MMC-related policies:

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• Transactions in MMC securities that are held in Putnam’s internal plans are not subject to the 90-Day Short-Term Rule (applicable to Access Persons only) or to the holding periods that apply to Putnam mutual funds.

B. Prohibited Transactions

Rule 1: Short-Selling Prohibition

Putnam employees are prohibited from short selling any security in their own account, whether or not the security is held in a Putnam client portfolio. Employees are prohibited from hedging investments made in securities of Power Corporation of Canada, Power Financial Corporation, and Great-West Lifeco Inc.

EXCEPTION

Short selling against broad market indexes (such as the Dow Jones Industrial Average, the NASDAQ Index, and the S&P 100 and 500 indexes) and short selling against the box are permitted (except that short selling shares of Power Corporation of Canada, Power Financial Corporation, and Great-West Lifeco Inc. against the box is not permitted).

Rule 2: Initial Public Offerings Prohibition

No Putnam employee shall purchase any security for her personal account in an initial public offering. Employees are also restricted from participating in Initial Public Offerings via a Discretionary Account.

EXCEPTION

Pre-existing Status Exception. A Putnam employee shall not be barred by this Rule or by Rule 2(a) of Section I.A. from purchasing securities for her personal account in connection with an initial public offering of securities by a bank or insurance company when the employee’s status as a policyholder or depositor entitles her to purchase securities on terms more favorable than those available to the general public, in connection with the bank’s conversion from mutual or cooperative form to stock form, or the insurance company’s conversion from mutual to stock form, provided that the employee has had the status entitling her to purchase on favorable terms for at least two years. This exception is only available with respect to the value of bank deposits or insurance policies that an employee owns before the announcement of the initial public offering. This exception does not apply, however, if the security app ears on the Restricted List in the circumstances set forth in subparts (b), (c), or (d) of Section I.A., Rule 2.

COMMENTS

• The purpose of this Rule is twofold. First, it is designed to prevent a conflict of interest between Putnam employees and Putnam clients who might be in competition for the same securities in a limited public offering. Second, the Rule is designed to prevent Putnam employees from being subject to undue influence as a result of receiving favors in the form of special allocations of securities in a public offering from broker-dealers who seek to do business with Putnam.

• Purchases of securities in the immediate after-market of an initial public offering are not prohibited, provided they do not constitute violations of other provisions of the Code of Ethics. For example, participation in the immediate after-market as a result of a special allocation from an underwriting group would be prohibited by Section III, Rule 3, concerning gifts and other favors.

• Public offerings subsequent to initial public offerings are not deemed to create the same potential for competition between Putnam employees and Putnam clients because of the pre-existence of a market for the securities.

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Rule 3: Private Placement Pre-approval Requirements

No Putnam employee shall purchase any security for his personal account in a limited private offering or private placement without prior approval of the Code of Ethics Officer. Privately placed limited partnerships and funds such as private equity or hedge funds are specifically included in this Rule.

COMMENTS

• The purpose of this Rule is to prevent a Putnam employee from investing in securities for his own account pursuant to a limited private offering that could compete with or disadvantage Putnam clients, and to eliminate any incentives Putnam employees might have to favor those who can affect access to limited offerings.

• Exemptions to the prohibition will generally not be granted where the proposed investment relates directly or indirectly to investments by a Putnam client, or where individuals involved in the offering (including the issuers, broker, underwriter, placement agent, promoter, fellow investors, and affiliates of the foregoing) have any prior or existing business relationship with Putnam or a Putnam employee, or where the Putnam employee believes that such individuals may expect to have a future business relationship with Putnam or a Putnam employee.

• An exemption may be granted, subject to reviewing all the facts and circumstances, for investments in:

(a) Pooled investment funds, including hedge funds, subject to the condition that an employee investing in a pooled investment fund would have no involvement in the activities or decision-making process of the fund except for financial reports made in the ordinary course of the fund’s business, and subject to the condition that the hedge fund does not invest significantly in registered investment companies.

(b) Private placements where the investment cannot relate, or be expected to relate, directly or indirectly to Putnam or investments by a Putnam client.

• Employees who apply for an exemption will be expected to disclose to the Code of Ethics Officer in writing all facts and relationships relating to the proposed investment.

• Applications to invest in private placements will be reviewed by the Code of Ethics Oversight Committee. This review will take into account, among other factors, the considerations described in the preceding comments.

Rule 4: Trading with Material Non-public Information

No Putnam employee shall purchase or sell any security for her personal account or for any Putnam client account while in possession of material non-public information concerning the security or the issuer. Please read Appendix A, Policy Statement Concerning Insider Trading Prohibitions.

Rule 5: No Personal Trading with Client Portfolios

No Putnam employee shall purchase from or sell to a Putnam client any securities or other property for his personal account, nor engage in any personal transaction to which a Putnam client is known to be a party, or in which the transaction may have a significant relationship to any action taken by a Putnam client.

IMPLEMENTATION

It is the responsibility of every Putnam employee to make inquiry prior to any personal transaction in order to satisfy himself that the requirements of this Rule have been met.

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COMMENT

This Rule is required by federal law. It does not prohibit a Putnam employee from purchasing any shares of an open-end Putnam fund. The policy with respect to employee trading in Putnam closed-end funds is attached as Appendix B.

Rule 6: Holding Putnam Mutual Fund Shares

Putnam employees may not hold shares of Putnam open-end U.S. mutual funds other than through accounts maintained at Putnam. Employees placing purchase orders in shares of Putnam open-end funds must place such orders through Putnam and not through an outside broker or other intermediary. Employees redeeming or exchanging shares of Putnam open-end funds must place those orders through Putnam and not through an outside broker or other intermediary. For transfer instructions, contact a Putnam Preferred Client Services (PCS) representative at 1-800-634-1590.

REMINDER

For purposes of this Rule, “employee” includes:

• Members of the immediate family of a Putnam employee who share the same household as the employee or for whom the Putnam employee has investment discretion (family member);

• Any trust in which a Putnam employee or family member is a trustee with investment discretion and in which such Putnam employee or any family members are collectively beneficiaries;

• Any closely held entity (such as a partnership, limited liability company, or corporation) in which a Putnam employee and his or her family members hold a controlling interest and with respect to which they have investment discretion; and

• Any account (including any retirement, pension, deferred compensation, or similar account) in which a Putnam employee or family member has a substantial economic interest and over which the Putnam employee or family member exercises investment discretion.

COMMENTS

These requirements also apply to:

• Self-directed IRA accounts holding Putnam fund shares;

• Variable annuities and variable insurance contracts, such as Putnam/Hartford Manager, that invest in Putnam Variable Trusts. Employees must designate Putnam Retail Management as the broker of record for all such accounts.

NOTE:

Employees are required to seek permission from the Code of Ethics Officer to hold Putnam funds in variable trusts outside of Putnam.

EXCEPTION

Retirement, pension, deferred compensation, and similar accounts that cannot be legally transferred to Putnam are not subject to the requirement. For example, a spouse of a Putnam employee may have a 401(k)/Profit Sharing Plan with her employer that invests in Putnam funds. Employees may also hold Putnam money market funds at Mercer Securities. Any employee who continues to hold shares in open-end Putnam funds outside of Putnam must notify the Code of Ethics Officer in writing of the account information, provide the reason why the account cannot be transferred to Putnam, and arrange for a quarterly statement of transactions in such account to be sent to the Code of Ethics Administrator.

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Rule 7: Putnam Mutual Fund Employee Restrictions

(a) Employees (defined in Rule 6) may not, within a 90-calendar day period, make a purchase followed by a sale or a sale followed by a purchase of shares of the same open-end Putnam mutual fund, even if the transactions occur in different accounts.

(b) Employees who are Access Persons may not, within a one-year period, make a purchase followed by a sale or a sale followed by a purchase of shares of the same open-end Putnam mutual fund or of shares of any U.S. registered mutual fund to which Putnam acts as advisor or sub-advisor, even if the transactions occur in different accounts.

(c) All employees are required to link their immediate family members’ accounts holding Putnam mutual funds to comply with the disclosure requirements. These accounts are also subject to the 90-day and one-year rules. To link these accounts, log on to Putnam’s intranet home page at http://intranet , and select Employee Essentials/Linked Mutual Fund Accounts. You are required to confirm the information and will be prompted to add any accounts that you or your family members have that should be linked, or delink accounts that you or your family members have closed.

COMMENTS

This Rule applies to transactions by a Putnam employee and family members as defined in the Code in any type of account including retail, IRA, variable annuity, and 401(k)/Profit Sharing Plan, as well as any deferred compensation accounts, and the restrictions apply across all accounts maintained by an employee and family members:

• An employee who buys shares of an open-end Putnam mutual fund may not sell any shares of the same mutual fund until 90 calendar days have passed, or one year for Access Persons.

• Example: If an employee buys shares of a Putnam fund on Day 1 for a retail account and then sells (by exchange) shares of the same fund for his or her 401(k)/Profit Sharing Plan accounts on Day 85, the employee has violated the rule.

• Similarly, an employee who sells shares of an open-end Putnam mutual fund may not buy any shares of the same mutual fund until 90 calendar days have passed, or one year for Access Persons.

• The purpose of these blackout period restrictions is to prevent any market timing or the appearance of any market timing activity.

• This Rule applies to transactions by a Putnam employee and his or her family members as defined in the Code in any type of account including retail, IRA, variable annuity, variable insurance, and 401(k)/Profit Sharing Plan, as well as any deferred compensation accounts.

• The minimum sanction for an initial violation of the blackout period will be disgorgement of any profit made on the transaction. Additional sanctions may apply, including termination of employment.

EXCEPTIONS

A. The restrictions do not apply to Putnam’s money market funds and Putnam Stable Value Fund.

B. 401(k)/Profit Sharing Plan Contributions and Payroll Deductions: The 90-day or one year restriction is not triggered by the initial allocation of regular employee or employer contributions or forfeitures to an employee’s account under the terms of Putnam employee benefit plans or a Putnam payroll-deduction direct-investment program; later exchanges of these contributions will be subject to either the 90-day or one-year blackout period.

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C. Systematic Programs: The restrictions do not apply with respect to shares sold or acquired as a result of participation in a systematic program for contributions, withdrawals, or exchanges, provided that an election to participate in any such program and the participation dates of the program are not changed more often than quarterly after the program is elected by the employee. Access Persons may elect a quarterly or semiannual rebalancing program although it may only be changed on an annual basis.

D. Employee Benefit Plan Withdrawals and Distributions: No restriction applies with respect to shares sold for withdrawals, loans, or distributions under the terms of Putnam employee benefit plans.

E. Dividends, Distributions, Mergers, and Share Class Conversions: No restriction applies with respect to the acquisition of shares as a result of reinvestment of dividends, distributions, mergers, conversions of share classes, or other similar actions. Subsequent transactions with respect to the shares will be covered.

F. College Savings Program: Redemptions from an employee’s college savings 529 plan to pay for qualified educational expenses for the beneficiary of the account (and redemptions due to death or disability) are exempt from the 90-day and one-year restrictions applicable to Putnam mutual funds. Qualified redemptions include:

• Tuition

• School fees

• Books

• Supplies and equipment required for enrollment

• Room and board

• Death

• Disability

G. Special Situations: In special situations as determined from time to time by Putnam’s Code of Ethics Oversight Committee, exceptions may by granted to the blackout periods as a result of death, disability, or special circumstances (such as personal hardship). Employees may request an exception by submitting a written request to the Code of Ethics Officer.

Rule 8: Special Orders

Good Until Canceled (GTC) Limit Orders are prohibited.

Any order not executed on the day of pre-clearance must be resubmitted for pre-clearance before being executed on a subsequent day. “Good until canceled limit” orders are prohibited because of the potential failure to pre-clear.

EXCEPTION

Same-day limit orders are permitted.

Rule 9: Excessive Trading

Putnam employees are strongly discouraged from engaging in excessive trading for their personal accounts. Employees are prohibited from making more than 10 trades in individual securities in any given quarter. For the purpose of this rule, an employee is prohibited from engaging in more than a total of 10 trades in all accounts the employee may hold (including those accounts held by his immediate family members), not 10 trades per individual account.

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EXCEPTION

For the purpose of calculating the number of trades in any quarter, trading the same security in the same direction (buy or sell) over a period of five business days will be counted as one transaction.

Trades in ETFs containing 25 or more issuers and trades of MMC stock in Putnam internal plans are not counted towards the 10-trade limit.

COMMENT

Although a Putnam employee’s excessive trading may not itself constitute a conflict of interest with Putnam clients, Putnam believes that its clients’ confidence in Putnam will be enhanced and that the likelihood of Putnam achieving better investment skills results for its clients over the long term will be increased if Putnam employees rely on their investment skills, as opposed to their trading skills in transactions for their own account. Moreover, excessive trading by a Putnam employee for his or her own account diverts an employee’s attention from the responsibility of servicing Putnam clients, and increases the possibilities for transactions that are in actual or apparent conflict with Putnam client transactions. Short-term trading is strongly discouraged, and employees are encouraged to take a long-term view.

Rule 10: Spread Betting

PIL employees may not enter into any spread betting contracts on financial instruments.

COMMENT

Spread betting provides exposure to the movement of an index or security price without holding any form of certificate.

This Rule guards against the danger that a Putnam employee may be in violation of the Code of Ethics by virtue of his spread betting transactions. Please note that this restriction also applies to the spouse of a Putnam employee and any relatives of a Putnam employee living in the same household as the employee, as their transactions are covered by the Code of Ethics. (See page 6.)

C. Discouraged Transaction Rule 1: Naked Options

Putnam employees are strongly discouraged from engaging in writing (selling) naked options for their personal accounts.

Naked option transactions are particularly dangerous, because a Putnam employee may be prevented by the restrictions in this Code of Ethics from covering the naked option at the appropriate time. All employees should keep in mind the limitations on their personal securities trading imposed by this Code when contemplating such an investment strategy. Engaging in naked options transactions on the basis of material non-public information is prohibited. (See Appendix A, Policy Statement Concerning Insider Trading Prohibitions.)

D. Exempted Transactions Rule 1: Involuntary Transactions

Transactions that are involuntary on the part of a Putnam employee are exempt from the prohibitions set forth in Sections I.A., I.B., and I.C.

COMMENTS

This exemption is based on categories of conduct that the Securities and Exchange Commission does not consider “abusive.”

• Examples of involuntary personal securities transactions include:

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(a) Sales out of the brokerage account of a Putnam employee as a result of a bona fide margin call, provided that withdrawal of collateral by the Putnam employee within the ten days previous to the margin call was not a contributing factor to the margin call;

(b) Purchases arising out of an automatic dividend reinvestment program of an issuer of a publicly traded security.

• Transactions by a trust in which the Putnam employee (or a member of his immediate family) holds a beneficial interest, but for which the employee has no direct or indirect influence or control with respect to the selection of investments, are involuntary transactions. In addition, these transactions do not fall within the definition of “personal securities transactions.” (See Definitions.)

• A good-faith belief on the part of the employee that a transaction was involuntary will not be a defense to a violation of the Code of Ethics. In the event of confusion as to whether a particular transaction is involuntary, the burden is on the employee to seek a prior written determination of the applicability of this exemption. The procedures for obtaining such a determination appear in Section VI.

Rule 2: Special Exemptions

Transactions that have been determined, in writing by the Code of Ethics Officer before the transaction occurs, to be no more than remotely harmful to Putnam clients because the transaction would be very unlikely to affect a highly institutional market, or because the transaction is clearly not related economically to the securities to be purchased, sold, or held by a Putnam client, are exempt from the prohibitions set forth in Sections I.A., I.B., and I.C.

IMPLEMENTATION

An employee may seek an ad hoc exemption under this Rule by following the procedures in Section VI.

COMMENTS

• This exemption is also based upon categories of conduct that the Securities and Exchange Commission does not consider “abusive.”

• The burden is on the employee to seek a prior written determination that the proposed transaction meets the standards for an ad hoc exemption set forth in this Rule.

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Section II — Additional Special Rules for Personal Securities Transactions

A. Access Persons and Certain Investment Professionals

Access Persons include all investment professionals and other employees as defined on page 1.

Rule 1: 90-Day Short-Term Rule

Access Persons may not sell a security at a profit within 90 days of purchase or buy a security at a price below which he or she sold it within the past 90 days.

EXCEPTION

None, unless prior written approval from the Code of Ethics Officer is obtained. Exceptions may be granted on a case-by-case basis when no abuse is involved and the equities of the situation support an exemption. For example, although an Access Person may buy a stock as a long-term investment, that stock may have to be sold involuntarily due to unforeseen activity such as a merger.

IMPLEMENTATION

A. The 90-Day Short-Term Rule applies to all Access Persons, as defined in the Definitions section of the Code.

B. Calculation of whether there has been a profit is based upon the market prices of the securities. The calculation includes commissions and other sales charges.

C. As an example, an Access Person would not be permitted to sell a security at $12 that he purchased within the prior 90 days for $10. Similarly, an Access Person would not be permitted to purchase a security at $10 that she had sold within the prior 90 days for $12.

COMMENTS

• The prohibition against short-term trading profits by Access Persons is designed to minimize the possibility that they will capitalize inappropriately on the market impact of trades involving a client portfolio about which they might possibly have information.

• Although Chief Investment Officers, portfolio managers, and analysts may sell securities at a profit within 90 days of purchase in order to comply with the requirements of the 7-Day Rule applicable to them (described below), the profit will have to be disgorged to charity under the terms of the 7-Day Rule.

B. Certain Investment Professionals Rule 2: 7-Day Rule

(a) Portfolio Managers: Before a portfolio manager (including a Chief Investment Officer with respect to an account he manages) places an order to buy a security for any Putnam client portfolio that he manages, he must sell that security or related derivative security if he has purchased it in his personal account within the preceding seven calendar days.

(b) Analysts: Before an analyst makes a purchase or an outperform recommendation for a security (including designation of a security for inclusion in the portfolio of Putnam Research Fund), he must sell that security or related derivative security if he has purchased it in his personal account within the preceding seven calendar days.

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COMMENTS

• This Rule applies to portfolio managers (including Chief Investment Officers with respect to accounts they manage) in connection with any purchase, no matter how small, in any client account managed by that portfolio manager or CIO (even so-called “clone accounts”). In particular, it should be noted that the requirements of this Rule also apply with respect to purchases in client accounts, including “clone accounts,” resulting from “cash flows.” To comply with the requirements of this Rule, it is the responsibility of each portfolio manager or CIO to be aware of the placement of all orders for purchases of a security by client accounts that he or she manages for seven days following the purchase of that security for his or her personal account.

• An investment professional who must sell securities to be in compliance with the 7-Day Rule must absorb any loss and disgorge to charity any profit resulting from the sale. The recipient charity will be chosen by the Code of Ethics Officer.

• This Rule is designed to avoid even the appearance of a conflict of interest between an investment professional and a Putnam client. A greater burden is placed on these professionals given their positions in the organization. Transactions executed for the employee’s personal account must be conducted in a manner consistent with the Code of Ethics and in such a manner as to avoid any actual or perceived conflict of interest or any abuse of the employee’s position of trust and responsibility.

• “Portfolio manager” is used in this Section as a functional label, and is intended to cover any employee with authority to authorize a trade on behalf of a Putnam client, whether or not such employee bears the title “portfolio manager.” “Analyst” is also used in this Section as a functional label, and is intended to cover any employee who is not a portfolio manager but who may make recommendations regarding investments for Putnam clients.

Rule 3: Blackout Rule

(a) Portfolio Managers: No portfolio manager (including Chief Investment Officers with respect to accounts they manage) shall: (i) sell any security or related derivative security for her personal account until seven calendar days have elapsed since the most recent purchase of that security or related derivative security by any Putnam client portfolio she manages or co-manages; or (ii) purchase any security or related derivative security for her personal account until seven calendar days have elapsed since the most recent sale of that security or related derivative security from any Putnam client portfolio that she manages or co-manages.

(b) Analysts: No analyst shall: (i) sell any security or related derivative security for his personal account until seven calendar days have elapsed since his most recent buy or outperform recommendation for that security or related derivative security (including designation of a security for inclusion in the portfolio of Putnam Research Fund); or (ii) purchase any security or related derivative security for his personal account until seven calendar days have elapsed since his most recent sell or underperform recommendation for that security or related derivative security (including the removal of a security from the portfolio of Putnam Research Fund).

COMMENTS

• This Rule applies to portfolio managers (including Chief Investment Officers with respect to accounts they manage) in connection with any purchase, no matter how small, in any client account managed by that portfolio manager or CIO (even clone accounts). In particular, it should be noted that the requirements of this rule also apply with respect to transactions in client accounts, including clone accounts, resulting from cash flows. In order to comply with the requirements of this Rule, it is the responsibility of each portfolio manager and CIO to be aware of all transactions in a security by client accounts that he or she manages that took place within the seven days preceding a transaction in that security for his or her personal account.

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• This Rule is designed to prevent a Putnam portfolio manager or analyst from engaging in personal investment conduct that appears to be counter to the investment strategy she is pursuing or recommending on behalf of a Putnam client.

Rule 4: Contra-Trading Rule

(a)Portfolio Managers: No portfolio manager shall, without prior clearance and written approval, sell out of his personal account securities or related derivative securities held in any Putnam client portfolio that he manages or co-manages.

(b)Chief Investment Officers: No Chief Investment Officer shall, without prior clearance and written approval, sell out of his personal account securities or related derivative securities held in any Putnam client portfolio managed in his investment group.

IMPLEMENTATION

A. Individuals Authorized to Give Approval. Prior to engaging in any such sale, a portfolio manager shall seek written approval of the proposed sale. In the case of a portfolio manager, prior written approval of the proposed sale shall be obtained from a Chief Investment Officer to whom he reports or, in his absence, another Chief Investment Officer. In the case of a Chief Investment Officer, prior written approval of the proposed sale shall be obtained from another Chief Investment Officer. In addition to the foregoing, prior written approval must also be obtained from the Code of Ethics Officer.

B. Contents of Written Approval. In every instance, use either the attached form of written approval known as “Appendix C” in this Booklet or such other form as the Code of Ethics Officer shall designate. The written approval should be signed by the Chief Investment Officer giving approval and dated when such approval was given, and shall state, briefly, the reasons why the trade was allowed and why the investment conduct pursued by the portfolio manager or Chief Investment Officer was deemed inappropriate for the Putnam client account controlled by the individual seeking to engage in the transaction for his personal account. Such written approval shall be sent by the Chief Investment Officer approving the transaction to the Code of Ethics Officer, for her approval, within 24 hours or as promptly as circumstances permit. Approvals obtained after a transaction has been completed, or while it is in process, will not satisfy the requirements of this Rule.

COMMENT

This Rule, like Rule 3 of this section, is designed to prevent a Putnam portfolio manager from engaging in personal investment conduct that appears to be counter to the investment strategy that he is pursuing on behalf of a Putnam client.

Rule 5: No Personal Benefit

No portfolio manager shall cause, and no analyst shall recommend, a Putnam client to take action for the portfolio manager’s or analyst’s own personal benefit.

COMMENTS

• A portfolio manager who trades in, or an analyst who recommends, particular securities for a Putnam client account in order to support the price of securities in his personal account, or who “front runs” a Putnam client order is in violation of this Rule. Portfolio managers and analysts should be aware that this Rule is not limited to personal transactions in securities (as that word is defined in the Definitions section). Thus, a portfolio manager or analyst who front runs a Putnam client purchase or sale of obligations of the U.S. government is in violation of this Rule. U.S. government obligations are excluded from the definition of security.

• This Rule is not limited to instances when a portfolio manager or analyst has malicious intent. It also prohibits conduct that creates an appearance of impropriety. Portfolio managers and

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analysts who have questions about whether proposed conduct creates an appearance of impropriety should seek a prior written determination from the Code of Ethics Officer, using the procedures described in Section VI.

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Section III — General Rules for All Employees

Rule 1: Compliance with All Laws, Regulations, and Policies

All employees must comply with applicable laws and regulations as well as company policies. This includes tax, anti-trust, political contribution, and international boycott laws. In addition, no employee at Putnam may engage in fraudulent conduct of any kind.

COMMENTS

• Putnam may report to the appropriate legal authorities conduct by Putnam employees that violates this Rule.

• It should also be noted that the U.S. Foreign Corrupt Practices Act makes it a criminal offense to make a payment or offer of payment to any non-U.S. governmental official, political party, or candidate to induce that person to affect any governmental act or decision, or to assist Putnam’s obtaining or retaining business.

Rule 2: Conflicts of Interest

No Putnam employee shall conduct herself in a manner that is contrary to the interests of, or in competition with, Putnam or a Putnam client, or that creates an actual or apparent conflict of interest with a Putnam client.

COMMENTS

• This Rule is designed to recognize the fundamental principle that Putnam employees owe their chief duty and loyalty to Putnam and Putnam clients.

• It is expected that a Putnam employee who becomes aware of an investment opportunity that she believes is suitable for a Putnam client whom she services will present it to the appropriate portfolio manager prior to taking advantage of the opportunity herself.

Rule 3: Gifts and Entertainment Policy

No Putnam employee shall accept anything of material value from any broker-dealer, financial institution, corporation, or other entity; any existing or prospective supplier of goods or services with a business relationship to Putnam; or any company or other entity whose securities are held in or are being considered as investments for the Putnam funds, or any other client account. Included are gifts, favors, preferential treatment, special arrangements, or access to special events.

COMMENTS

This Rule is intended to permit the acceptance of only proper types of customary and limited business amenities.

A Putnam employee may not, under any circumstances, accept anything that could create the appearance of a conflict of interest. For example, acceptance of any consideration is prohibited if it would create the appearance of a reward or inducement for conducting Putnam business either with the person providing the gift or his employer.

IMPLEMENTATION

A. Gifts. An employee may not accept gifts with an aggregate value of more than $100 in any year from any one source, i.e., entity or firm. Any Putnam employee who is offered or receives an item exceeding $100 in value must report the details to the Code of Ethics Officer and surrender or return the gift. Any entertainment event provided to an employee where the host is not in attendance is treated as a gift and is subject to the $100 per year per source limit.

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B. Entertainment. Putnam’s rules are designed to permit reasonable, ordinary business entertainment, but prohibit any events that may be perceived as extravagant or that involve lavish expenditures.

1. Occasional lunches, dinners, cocktail parties, or comparable gatherings conducted for business purposes are permitted.

For example, occasional attendance at group functions sponsored by sell-side firms is permitted where the function relates to investments or other business activity. Occasional attendance at these functions is not required to be counted against the limits described in section (B)(2) below.

2. Other entertainment events, such as sporting events, theater, movies, concerts, or other forms of entertainment conducted for business purposes, are permitted only under the following conditions: (i) The host must be present for the event.

(ii) The location of the event must be in the metropolitan area in which the office of the employee is located. For wholesalers, the wholesaler’s entire territory is considered to be his or her metropolitan area.

(iii)Spouses or other family members of the employee may not attend the entertainment event or any meals before or after the entertainment event.

(iv)The value of the entertainment event provided to the employee may not exceed $200, not including the value of any meals that may be provided to the employee before or after the event.

Acceptance of entertainment events that have a market value materially exceeding the face value of the entertainment, which includes, for example, attendance at sporting event playoff games, is prohibited. This prohibition applies even if the face value of tickets to the events is $200 or less or if the Putnam employee offers to pay for the tickets. If there is any ambiguity about whether to accept an entertainment event in these circumstances, please consult the Code of Ethics Officer.

(v) The employee may not accept entertainment events under this provision in section (B)(2) more than six times a year and not more than two times in any year from any single source.

(vi)The Code of Ethics Officer may grant exceptions to these rules. For example, it may be appropriate for an employee attending a legitimate conference in a location away from the office to attend a business entertainment event in that location. All exceptions must be approved in advance by written request to the Code of Ethics Officer.

3. Any employee participating in meals or entertainment under the provisions in sections (B)(1) or (B)(2) above must report the meal or event in PTA within 20 business days (events are subject to the limits of section (B)(2) above). However, the reporting rules do not apply if meals or events are part of the regular program at an investment conference, i.e., open to all participants.

Planned absences, i.e., vacations, leaves (other than certain medical leaves) or business trips, are not valid excuses for providing late reports. Failure to meet the deadline violates the Code’s rule, and sanctions may be imposed.

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C. The following items are prohibited:

1. Any entertainment event attendance that would reflect badly on Putnam as a firm of the highest fiduciary and ethical standards. For example, events involving adult entertainment or gambling must be avoided.

2. Entertainment involving travel away from the metropolitan area in which the employee is located. Even if an exception is granted as discussed in section (B)(2)(vi) above, payment by a third party of the cost of transportation to a location outside the employee’s metropolitan area, lodging while in another location, and any meals not specifically approved by the Code of Ethics officer are prohibited.

3. Personal loans to a Putnam employee on terms more favorable than those generally available for comparable credit standing and collateral.

4. Preferential brokerage or underwriting commissions or spreads or allocations of shares or interests in an investment for the personal account of a Putnam employee.

D. As with any of the provisions of the Code of Ethics, a sincere belief by the employee that he was acting in accordance with the requirements of this Rule will not satisfy his obligations under the Rule. Therefore, an employee who is in doubt concerning the propriety of any gift or favor should seek a prior written determination from the Code of Ethics Officer, as provided in Section VI.C.

E. No Putnam employee may solicit any gift or entertainment from any person, even if the gift or entertainment, if unsolicited, would be permitted.

F. The Rule does not prohibit employees on business travel from using local transportation and arrangements customarily supplied by brokers or similar entities. For example, it is customary for brokers in developing markets to make local transportation arrangements. These arrangements are permitted so long as the expenses of lodging and air travel are paid by Putnam.

G. Putnam Retail Management (PRM) employees are subject to additional Financial Industry Regulatory Authority (FINRA) rules on gifts and entertainment, which can be found in the PRM Compliance Manual.

Rule 4: Anti-bribery/Kickback Policy

No Putnam employee shall pay, offer, or commit to pay any amount of consideration that might be, or appear to be, a bribe or kickback in connection with Putnam’s business.

COMMENT

Although the Rule does not specifically address political contributions (described in Rule 5), Putnam employees should be aware that it is against corporate policy to use company assets to fund political contributions of any sort, even where such contributions may be legal. No Putnam employee should offer or agree to make any political contributions (including political dinners and similar fundraisers) on behalf of Putnam, and no employee will be reimbursed by Putnam for such contributions made by the employee personally.

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Rule 5: Political Activities, Contributions, Solicitations, and Lobbying Policy

A. Corporate Contributions. Political activities of corporations such as Putnam are highly regulated, and corporate political contributions are prohibited. No corporate assets, funds, facilities, or personnel may be used to benefit any candidate, campaign, political party, or political committee, including contributions made in connection with fundraisers.

1. If employees anticipate that any corporate funds or assets (such as corporate facilities or personnel) may be used in connection with any political volunteer activity, they must obtain pre-approval from the Chief Compliance Officer.

2. Employees should not seek or approve reimbursement from Putnam for any political contribution expenses. Any contributions for which employees seek reimbursement from Putnam are considered contributions by Putnam and are subject to the corporate political contribution requirements.

B. Personal Contributions. Employees have the right to make personal contributions. However, if employees choose to participate in the political process, they must do so as individuals, not as representatives of Putnam.

In certain limited circumstances, individual contributions may raise issues under applicable laws regulating political contributions to public officials, or candidates for official positions, who could be in a position to hire Putnam. As a result, the following rules apply to individual contributions by employees.

1. Prior to making any political contribution to a person or entity with whom Putnam has a current or proposed business relationship, or who can make or influence decisions to engage Putnam to provide services, employees must pre-clear the proposed contribution with the Chief Compliance Officer.

2. Employees may not make contributions to candidates or elected officials for the following offices without prior written approval from the Chief Compliance Officer:

• State or local offices in California, New Jersey, Ohio, West Virginia, or Pennsylvania

• State Treasurer in Connecticut or Vermont

• Any public office in the City of Houston

• Contributions by certain PRM employees to Ohio officials and candidates are also subject to Putnam’s Municipal Securities Rulemaking Board (MSRB) Political Contribution Policy.

C. Government Official. Employees must obtain pre-approval from the Code of Ethics Officer or the Deputy Code of Ethics Officer prior to providing any gift (including meals, entertainment, transportation, or lodging) to any government official or employee.

D. Lobbying. Federal and state law imposes limits and registration requirements on efforts by individuals and companies to influence the passage of legislation or to obtain business from governments. Accordingly, Putnam employees should not engage in any lobbying activities without approval from the Legal and Compliance Department. Lobbying does not include solicitation of investment management business through the ordinary course of business, such as responding to a Request For Proposal (RFP).

For additional detail on entertainment and lobbying of elected officials, please refer to the State Regulation Governing Meals, Entertainment, Gifts — Lobbying Policy found on the Chief Compliance Officer’s Compliance site via Putnam’s intranet home page at http://intranet or contact the Legal and Compliance Department.

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COMMENTS

• Putnam has established a political action committee (PAC) that contributes to worthy candidates for political office. Any request received by a Putnam employee for a political contribution must be directed to Putnam’s Legal and Compliance Department.

• This Rule prohibits solicitation on personal letterhead by Putnam employees except as approved by the Code of Ethics Officer.

• Certain officers and employees of Putnam Retail Management (PRM) and other employees involved in Putnam’s College Advantage Section 529 Plan with Ohio Tuition Trust Authority are subject to special rules on political contributions. For questions on these requirements, please call the Director of Compliance for PRM.

Rule 6: Confidentiality of Putnam Business Information

No unauthorized disclosure may be made by any employee or former employee of any trade secrets or proprietary information of Putnam or of any confidential information. No information regarding any Putnam client portfolio, actual or proposed securities trading activities of any Putnam client, or Putnam research shall be disclosed outside the Putnam organization unless doing so has a valid business purpose and is in accord with relevant procedures established by Putnam relating to such disclosures.

COMMENT

All information about Putnam and Putnam clients is strictly confidential. Putnam research information should not be disclosed without proper approval and never for personal gain.

Rule 7: Positions Outside Putnam

No Putnam employee shall serve as employee, officer, director, trustee, or general partner of a corporation or entity other than Putnam, without prior written approval of the Code of Ethics Officer. Requests for a role at a publicly traded company are especially disfavored and are closely reviewed. Permission will be granted only in extenuating circumstances. (See also Section IV, Rule 5.)

IMPLEMENTATION

A. All employees must provide a written request seeking approval from the Code of Ethics Officer if they wish to serve as an employee, officer, director, trustee, or general partner of a corporation or entity other than Putnam. The details of the position outside Putnam must be disclosed in PTA. Click on Certifications/Disclosures/Positions Outside Putnam/start/complete each question/click Submit. A determination will be sent via e-mail.

B. FINRA-licensed employees under PRM also have an obligation to disclose outside positions, new or terminated, in PTA as well.

C. Upon hire, all employees who also hold an outside position must complete a disclosure request in PTA to continue to hold the position.

EXCEPTION

Charitable or Non-profit Exception. Putnam employees may serve as an officer, director, or trustee of a charitable or not-for-profit institution, provided that the employee abides by the Code of Ethics and the Policy Statements with respect to any investment activity for which she has any discretion or input as officer, director, or trustee. The pre-clearance and reporting requirements of the Code of Ethics do not apply to the trading activities of such charitable or not-for-profit institutions for which an employee serves as an officer, director, or trustee unless the employee is responsible for day-to-day portfolio management of the account.

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COMMENTS

• This Rule is designed to ensure that Putnam cannot be deemed an affiliate of any issuer of securities by virtue of service by one of its officers or employees as director or trustee.

• Positions with public companies are especially problematic and will normally not be approved.

• Certain charitable or not-for-profit institutions have assets (such as endowment funds or employee benefit plans) that require prudent investment. To the extent that a Putnam employee (because of her position as officer, director, or trustee of an outside entity) is charged with responsibility to invest such assets prudently, she may not be able to discharge that duty while simultaneously abiding by the spirit of the Code of Ethics and the Policy Statements. Employees are cautioned that they should not accept service as an officer, director, or trustee of an outside charitable or not-for-profit entity where such investment responsibility is involved, without seriously considering their ability to discharge their fiduciary duties with respect to such investments.

Rule 8: Role as Trustee or Fiduciary Outside of Putnam Investments

No Putnam employee shall serve as a trustee, an executor, a custodian, or any other fiduciary, or as an investment advisor or counselor for any account outside Putnam.

EXCEPTIONS

A. Charitable or Religious Exception. Putnam employees may serve as a fiduciary with respect to a religious or charitable trust or foundation, so long as the employee abides by the spirit of the Code of Ethics and the Policy Statements with respect to any investment activity over which he has any discretion or input. The pre-clearance and reporting requirements of the Code of Ethics do not apply to the trading activities of such a religious or charitable trust or foundation unless the employee is responsible for day-to-day portfolio management of the account.

B. Family Trust or Estate Exception. Putnam employees may serve as a fiduciary with respect to a family trust or estate, as long as the employee abides by all of the Rules of the Code of Ethics with respect to any investment activity over which he has any discretion.

COMMENT

The roles permissible under this Rule may carry with them the obligation to invest assets prudently. Once again, Putnam employees are cautioned that they may not be able to fulfill their duties in that respect while abiding by the Code of Ethics and the Policy Statements.

Rule 9: Investment Clubs

No Putnam employee may be a member of any investment club.

COMMENT

This Rule guards against the danger that a Putnam employee may be in violation of the Code of Ethics and the Policy Statements by virtue of his personal securities transactions in or through an entity that is not bound by the restrictions imposed by this Code of Ethics and the Policy Statements. Please note that this restriction also applies to the spouse of a Putnam employee and any relatives of a Putnam employee living in the same household as the employee, as their transactions are covered by the Code of Ethics. (See pages 1 and 6.)

Rule 10: Business Negotiations for Putnam Investments

No Putnam employee may become involved in a personal capacity in consultations or negotiations for corporate financing, acquisitions, or other transactions for outside companies (whether or not held by any Putnam client), nor negotiate nor accept a fee in connection with these activities

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without obtaining the prior written permission of the Chief Executive Officer of Putnam Investments.

Rule 11: Accurate Records

No employee may create, alter, or destroy (or participate in the creation, alteration, or destruction of) any record that is intended to mislead anyone or to conceal anything that is, or is reasonably believed to be, improper. In addition, all employees responsible for the preparation, filing, or distribution of any regulatory filings or public communications must ensure that such filings or communications are timely, complete, fair, accurate, and understandable.

COMMENTS

• In many cases, this is not only a matter of company policy and ethical behavior but also required by law. Our books and records must accurately reflect the transactions represented and their true nature. For example, records must be accurate as to the recipient of all payments; expense items, including personal expense reports, must accurately reflect the true nature of the expense. No unrecorded fund or asset shall be established or maintained for any reason.

• All financial books and records must be prepared and maintained in accordance with generally accepted accounting principles and Putnam’s existing accounting controls, to the extent applicable.

Rule 12: Family Members’ Conflict Policy

No employee or member of an employee’s immediate family shall have any direct or indirect personal financial interests in companies that do business with Putnam, unless such interest is disclosed and approved by the Code of Ethics Officer. Investment holdings in public companies that are not material to the employee are excluded from this prohibition. The Code also provides more detailed supplemental rules to address potential conflicts of interests that may arise if members of employees’ families are closely involved in doing business with Putnam.

Corporate Purchase of Goods and Services — Putnam will not acquire goods and services from any firm in which a member of an employee’s immediate family serves as the sales representative in a senior management capacity or has an ownership interest with the supplier firm (excluding normal investment holdings in public companies) without permission from the Director of Procurement and the Code of Ethics Officer. Any employee who is aware of a proposal to purchase goods and services from a firm at which a member of the employee’s immediate family meets one of the previously mentioned conditions must notify the Director of Procurement and the Code of Ethics Officer.

Portfolio Trading — Putnam will not allocate any trades for a portfolio to any firm that employs a member of an employee’s immediate family as a sales representative to Putnam (in a primary, secondary, or backup role). Any Putnam employee who is aware that an immediate family member serves as a broker-dealer’s sales representative to Putnam should inform the Code of Ethics Officer.

Definition of Immediate Family (specific to Rule 12) — “Immediate family” of an employee means (1) spouse or domestic partner of the employee, (2) any child, sibling, or parent of an employee and any person married to a child, sibling, or parent of an employee, and (3) any other person who lives in the same household as the employee.

Rule 13: Affiliated Entities

Non-Putnam affiliates (NPAs), listed below in the last comment, provide investment advisory services. No employee shall:

(a)Directly or indirectly seek to influence the purchase, retention or disposition of, or exercise of voting consent, approval, or similar rights with respect to any portfolio security in any account or fund advised by the NPA and not by Putnam;

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(b)Transmit any information regarding the purchase, retention or disposition of, or exercise of voting, consent, approval, or similar rights with respect to any portfolio security held in a Putnam or NPA client account to any personnel of the NPA;

(c)Transmit any trade secrets, proprietary information, or confidential information of Putnam to the NPA unless doing so has a valid business purpose and is in accord with any relevant procedures established by Putnam relating to such disclosures;

(d)Use confidential information or trade secrets of the NPA for the benefit of the employee, Putnam, or any other NPA; or

(e)Breach any duty of loyalty to the NPA derived from the employee’s service as a director or officer of the NPA.

COMMENTS

• Sections (a) and (b) of the Rule are designed to help ensure that the portfolio holdings of Putnam clients and clients of the NPA need not be aggregated for purposes of determining beneficial ownership under Section 13(d) of the Securities Exchange Act or applicable regulatory or contractual investment restrictions that incorporate such definition of beneficial ownership. Persons who serve as directors or officers of both Putnam and an NPA should take care to avoid even inadvertent violations of Section (b). Section (a) does not prohibit a Putnam employee who serves as a director or officer of the NPA from seeking to influence the modification or termination of a particular investment product or strategy in a manner that is not directed at any specific securities. Sections (a) and (b) do not apply when a Putnam affiliate serves as an advisor or sub-advisor to the NPA or one of its products, in which case normal Putnam aggregation rules apply.

• As a separate entity, any NPA may have trade secrets or confidential information that it would not choose to share with Putnam. This choice must be respected.

• When Putnam employees serve as directors or officers of an NPA, they are subject to common law duties of loyalty to the NPA, despite their Putnam employment. In general, this means that when performing their duties as NPA directors or officers, they must act in the best interest of the NPA and its shareholders. Putnam’s Legal and Compliance Department will assist any Putnam employee who is a director or officer of an NPA and has questions about the scope of his or her responsibilities to the NPA.

• Entities that are currently non-Putnam affiliates within the scope of this Rule are: Nissay Asset Management Co., Ltd., LP and PanAgora Asset Management, Inc. (“PanAgora”).

• Putnam and PanAgora also maintain an information barrier between the investment professionals of each organization regarding investment and trading information.

Rule 14: Computer Systems and Network Use Policy

No employee shall use computers, the Internet, e-mail, instant messaging, phones, fax machines and/or the mail service in a manner that is inconsistent with their use as set forth in Putnam’s Employee Handbook. No employee shall introduce a computer virus or computer code that may result in damage to Putnam’s information or computer systems.

All Putnam business must be conducted on Putnam e-mail and instant messaging accounts in order to comply with regulatory and record-retention requirements. Conducting Putnam-related business through personal accounts such as Yahoo, AOL, Hotmail, etc., is prohibited.

COMMENT

Putnam’s policy statements relating to these matters are contained in the Computer System and Network Responsibilities section within the Employee Handbook. The online Employee Handbook is also available directly on Putnam’s intranet site at: http://intranet/employee _ handbook .

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Rule 15: CFA Institute Code of Ethics and Standards of Professional Conduct

All employees must follow and abide by the spirit of the Code of Ethics and the Standards of Professional Conduct of the CFA Institute. The text of the CFA Institute Code of Ethics and Standards of Professional Conduct are set forth in Appendix D.

Rule 16: Privacy Policy

Except as provided below, no employee may disclose to any outside organization or person any non-public personal information about any individual who is a current or former shareholder of any Putnam retail or institutional fund, or current or former client of a Putnam company. All employees shall follow the security procedures as established from time to time by a Putnam company to protect the confidentiality of all shareholder and client account information.

Except as Putnam’s Legal and Compliance Department may expressly authorize, no employee shall collect any non-public personal information about a prospective or current shareholder of a Putnam fund or prospective or current client of a Putnam company, other than through an account application (or corresponding information provided by the shareholder’s financial representative) or in connection with executing shareholder or client transactions, nor shall any information be collected other than the following: name, address, telephone number, date of birth, Social Security number, and investment, broker, and transaction information.

EXCEPTIONS

A. Putnam Employees. Non-public personal information may be disclosed to a Putnam employee in connection with processing transactions or maintaining accounts for shareholders of a Putnam fund and clients of a Putnam company, to the extent that access to such information is necessary to the performance of that employee’s job functions.

B. Shareholder Consent Exception. Non-public personal information about a shareholder’s or client’s account may be provided to a non-Putnam organization at the specific request of the shareholder or client or with the shareholder’s or client’s prior written consent.

C. Broker or Advisor Exception. Non-public personal information about a shareholder’s or client’s account may be provided to the shareholder’s or client’s broker of record.

D. Third-Party Service Provider Exception. Non-public personal information may be disclosed to a service provider that is not affiliated with a Putnam fund or Putnam company only when such disclosure is necessary for the service provider to perform the specific services contracted for, and only (a) if the service provider executes Putnam’s standard confidentiality agreement, or (b) pursuant to an agreement containing a confidentiality provision that has been approved by the Legal and Compliance Department. Examples of such service providers include proxy solicitors and proxy vote tabulators, mail services, and providers of other administrative services, and Information Services Division consultants who have access to non-public personal information.

COMMENTS

• Non-public personal information is any information that personally identifies a shareholder of a Putnam fund or client of a Putnam company and is not derived from publicly available sources. This privacy policy applies to shareholders or clients who are individuals, not institutions. However, as a general matter, all information that we receive about a shareholder of a Putnam fund or client of a Putnam company shall be treated as confidential. No employee may sell or otherwise provide shareholder or client lists or any other information relating to a shareholder or client to any marketing organization.

• All Putnam employees with access to shareholder or client account information must be trained in and follow Putnam’s security procedures designed to safeguard that information from unauthorized use. For example, a telephone representative must be trained in and follow Putnam’s security procedures to verify the identity of a caller requesting account information.

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• Any questions regarding this privacy policy should be directed to Putnam’s Legal and Compliance Department. A violation of this policy will be subject to the sanctions imposed for violations of Putnam’s Code of Ethics.

• Employees must report any violation of this policy or any possible breach of the confidentiality of client information, whether intentional or accidental, to the managing director in charge of the employee’s business unit. Managing directors who are notified of such a violation or possible breach must immediately report it in writing to Putnam’s Chief Compliance Officer and, in the event of a breach of computerized data, Putnam’s Chief Technology Officer.

Rule 17: Anti-money Laundering Policy

No employee may engage in any money laundering activity or facilitate any money laundering activity through the use of any Putnam account or client account. Any situations giving rise to a suspicion that attempted money laundering may be occurring in any account must be reported immediately to the managing director in charge of the employee’s business unit. Managing directors who are notified of such a suspicion of money laundering activity must immediately report it in writing to Putnam’s Chief Compliance Officer and Chief Financial Officer.

Rule 18: Record Retention

All employees must comply with the record retention requirements applicable to the business unit. Employees should check with their managers or the Chief Administrative Officer of their division to determine what record retention requirements apply to their business unit.

For PIL employees, the Code of Ethics incorporates any relevant requirements of the U.K. regulator, the Financial Services Authority (FSA), and will be amended from time to time to reflect any U.K. regulatory changes as required.

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Section IV — Reporting Requirements

Reporting of Personal Securities Transactions

Rule 1: Broker Confirmations and Statements

Each Putnam employee shall ensure that copies of all confirmations for securities transactions for personal brokerage accounts, and brokerage account statements are sent to the Legal and Compliance Department Code of Ethics Administrator. (For the purpose of this Rule, securities shall also include ETFs, futures, and other derivatives on broad-based market indexes excluded from the pre-clearance requirement.) Statements and confirmations are required for Putnam funds not held at Putnam or in a Putnam retirement plan, as well as for U.S. mutual funds sub-advised by Putnam.

Putnam employees must disclose their brokerage accounts in the PTA system and complete all required information, which will facilitate the instructions to the broker.

IMPLEMENTATION

A. Putnam employees should contact the Code of Ethics Administrator for a 407 letter instructing the broker to mail copies of confirmations and statements directly to Putnam. It is the employees’ responsibility to follow up with the broker on a reasonable basis to ensure that instructions are being followed.

B. Upon hire and within a designated time frame, Putnam employees are required to establish their broker profiles in PTA.

C. Specific procedures apply to employees of PIL. Employees of PIL should contact the London Code of Ethics Administrator.

D. Failure of a broker-dealer to comply with the instructions of a Putnam employee to send confirmations and statements shall be a violation by the Putnam employee of this Rule. Similarly, failure by an employee to report the existence of a personal account and, if the account is opened after joining Putnam, failure to obtain proper authorization to establish the account shall be a violation of this Rule.

E. Statements and confirmations must also be sent for members of an employee’s immediate family, including statements from a family member’s 401(k)/Profit Sharing Plan at another employer.

F. Employees are not required to provide broker confirmations and statements for MMC transactions in Putnam’s 401(k)/Profit Sharing and Stock Purchase Plan accounts because we rely on internal reporting.

COMMENTS

• Transactions for personal accounts are defined broadly to include more than transactions in accounts under an employee’s own name. (See Definitions.)

• Statements and confirmations are required for all personal securities transactions, whether or not exempted or excepted by this Code.

• To the extent that a Putnam employee has investment authority over securities transactions of a family trust or estate, confirmations of those transactions must also be made, unless the employee has received a prior written exception from the Code of Ethics Officer.

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Rule 2: Access Person — Quarterly Transaction Report

Every Access Person shall file a quarterly report within fifteen calendar days of the end of each quarter, recording all purchases and sales of securities for personal accounts as defined in the Definitions section. (For the purpose of this Rule, reportable “securities” also include exchange-traded funds (ETFs), futures, and any option on a security or securities index, including broad-based market indexes excluded from the pre-clearance requirement, and transactions in Putnam open-end funds if the account for the Putnam funds is not held at Putnam or in a Putnam retirement plan and for transactions in U.S. mutual funds sub-advised by Putnam.)

IMPLEMENTATION

It is mandatory that all Access Persons file a quarterly transaction report in the PTA online system. The form shall contain a representation that employees have complied fully with all provisions of the Code of Ethics.

The date for each transaction required to be disclosed in the quarterly report is the trade date for the transaction, not the settlement date.

Planned absences, i.e., vacations, leaves (other than certain medical leaves), or business trips, are not valid excuses for providing late reports. Failure to meet the deadline violates the Code’s rules and sanctions may be imposed.

COMMENT

If the requirement to file a quarterly report applies to you and you fail to report within the required 15-day period, monetary fines or harsher sanctions will be imposed. It is the responsibility of the employee to request an early report if he has knowledge of a planned absence, i.e., vacation, business trip, or leave.

Rule 3: Access Person — Initial/Annual Holdings Report

Access Persons must disclose their personal securities holdings in the Code of Ethics monitoring system, PTA, upon commencement of employment (within ten days of hire) and thereafter on an annual basis. These SEC requirements are mandatory and designed to facilitate the monitoring of personal securities transactions. Putnam’s Code of Ethics Administrator provides Access Persons with instructions regarding their submissions and certifications of these reports in PTA.

Non - Access Persons must disclose their brokerage accounts within 30 days of hire.

Rule 4: Certifications

All employees are required to submit a certification in PTA annually attesting to compliance with all of the conditions of the Code of Ethics.

Rule 5: Positions Outside Putnam

The details of a position outside Putnam must be disclosed in PTA under Certifications/Disclosures/Positions Outside Putnam. (See Section III, Rule 7.)

Rule 6: Business Ethics

If a Putnam employee suspects that fraudulent, illegal, or other irregular activity (including violations of the Code of Ethics) might be occurring at Putnam, the activity should be reported immediately to the managing director in charge of that employee’s business unit. Managing directors who are notified of any such activity must immediately report it in writing to Putnam’s Chief Financial Officer and Putnam’s Chief Compliance Officer.

An employee who does not feel comfortable reporting this activity to the managing director may instead contact the Chief Compliance Officer, the Putnam Ethics hotline at 1-808-475-4210, or Putnam’s Ombudsman.

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Rule 7: Ombudsman

Putnam has established the office of the corporate ombudsman as a resource to help employees address legal or ethical issues in the workplace and to allow employees to voice concerns or seek clarity on issues. The Ombudsman provides a confidential, independent, and impartial source to employees to discuss potential violations of law or of company standards without fear of retribution, and serves as a neutral party with no vested interest in a particular outcome. The Ombudsman is available on an anonymous basis by calling 1-866-ombuds7 (866-662-8377) or by calling 1-617-760-8897.

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Section V — Education Requirements

Every Putnam employee has an obligation to fully understand the rules and requirements of the Code of Ethics.

Rule 1: Distribution of Code

A copy of the Code of Ethics will be distributed to every Putnam employee at least annually. All Access Persons will be required to certify annually that they have read, understood, and will comply with the provisions of the Code of Ethics, including the Code’s Policy Statement Concerning Insider Trading Prohibitions.

Rule 2: Annual Training Requirement

Every employee will be required to complete training on Putnam’s Code of Ethics on an annual basis.

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Section VI — Compliance and Appeal Procedures

A. Restricted List

No employee may engage in a personal securities transaction without prior clearance.

B. Consultation of Restricted List

It is the responsibility of each employee to pre-clear through PTA or consult with the Code of Ethics Administrator, prior to engaging in a personal securities transaction, to determine if the security he proposes to trade is on the Restricted List and, if so, whether it is subject to the Large-/Mid-Cap Exemption.

C. Request for Determination

An employee who has a question concerning the applicability of the Code of Ethics to a particular situation shall request a determination from the Code of Ethics Officer before engaging in the conduct or personal securities transaction about which he has a question.

If the question pertains to a personal securities transaction, the request shall state for whose account the transaction is proposed, the relationship of that account to the employee, the security proposed to be traded, the proposed price and quantity, the entity with whom the transaction will take place (if known), and any other information or circumstances of the trade that could have a bearing on the Code of Ethics Officer’s determination. If the question pertains to other conduct, the request for determination shall give sufficient information about the proposed conduct to assist the Code of Ethics Officer in ascertaining the applicability of the Code. In every instance, the Code of Ethics Officer may request additional information, and may decline to render a determination if the information provided is insufficient.

The Code of Ethics Officer shall make every effort to render a determination promptly.

No perceived ambiguity in the Code of Ethics shall excuse any violation. Any person who believes the Code to be ambiguous in a particular situation should request a determination from the Code of Ethics Officer.

D. Request for Ad Hoc Exemption

Any employee who wishes to obtain an ad hoc exemption under Section I.D., Rule 2, should request from the Code of Ethics Officer an exemption in writing in advance of the conduct or transaction sought to be exempted. In the case of a personal securities transaction, the request for an ad hoc exemption shall give the same information about the transaction required in a request for determination under Section VI.C., and should state why the proposed personal securities transaction would be unlikely to affect a highly institutional market, or is unrelated economically to securities to be purchased, sold, or held by any Putnam client. In the case of other conduct, the request shall give information sufficient for the Code of Ethics Officer to ascertain whether the conduct raises questions of propriety or conflict of interest, real or apparent.

The Code of Ethics Officer shall make reasonable efforts to promptly render a written determination concerning the request for an ad hoc exemption.

E. Appeal to Code of Ethics Officer with Respect to Restricted List

If an employee ascertains that a security that he wishes to trade for his personal account appears on the Restricted List, and thus the transaction is prohibited, he may appeal the prohibition to the Code of Ethics Officer by submitting a written memorandum containing the same information as

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would be required in a request for a determination. The Code of Ethics Officer shall make every effort to respond to the appeal promptly.

F. Information Concerning Identity of Compliance Personnel

The names of Code of Ethics personnel are available by contacting the Legal and Compliance Department and will be published on Putnam’s intranet site.

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Section VII — Sanctions

Sanction Guidelines

The Code of Ethics Oversight Committee is responsible for setting sanctions policies for violating the Code. The Committee has adopted the following minimum monetary sanctions for violations of the Code. These sanctions apply even if the exception results from inadvertence rather than intentional misbehavior. The Code of Ethics Officer is authorized to impose the minimum sanction on employees without further Committee action. However, the sanctions noted below are only minimums and the Committee reserves the right to impose additional sanctions such as higher monetary sanctions, trading bans, suspension, or termination of employment as it determines to be appropriate.

A. The minimum sanction per violation of the following Rules is disgorgement of any profits or payment of avoided losses and the following payments:

Section I.A., Rule 1 (Pre-clearance and Restricted List) Section I.B., Rule 1 (Short selling) Section I.B., Rule 2 (IPOs) Section I.B., Rule 3 (Private Placements) Section I.B., Rule 4 (Trading with Inside Information) Section I.B., Rules 6-8 (Holding and Trading of Putnam Funds) Section II, Rule 2 (7-Day Rule) Section II, Rule 3 (Blackout Rule) Section II, Rule 4 (Contra-Trading Rule) Section II, Rule 5 (Trading for Personal Benefit)

Officer Level	SMD/MD	SVP/VP	AVP/non-officer
1st violation	$500	$250	$50
2nd violation	$1,000	$500	$100
3rd violation	Minimum monetary sanction as above with ban on all new personal
	individual investments.

B. The minimum sanction for violations of all other Rules in the Code is as follows:

Officer Level	SMD/MD	SVP/VP	AVP/non-officer
1st violation	$100	$50	$ 25
Subsequent violation	$200	$100	$ 50

The reference period for determining whether a violation is initial or subsequent will be five years.

NOTE

The Committee’s belief that an employee has violated the Code of Ethics intentionally will result in more severe sanctions than outlined in the guidelines above. The Code of Ethics Oversight Committee retains the right to increase or decrease the sanctions for a particular violation in light of the circumstances.

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Appendix A — Insider Trading Prohibitions Policy Statement

Putnam has always forbidden trading by its employees on material non-public information (inside information). Tough federal laws make it important for Putnam to state that prohibition in the strongest possible terms, and to establish, maintain, and enforce written policies and procedures to prevent the use of material non-public information.

Unlawful trading while in possession of inside information can be a crime. Federal law provides that an individual convicted of trading on inside information may go to jail for a period of time. There is also significant monetary liability for an inside trader; the Securities and Exchange Commission can seek a court order requiring a violator to pay back profits, as well as penalties substantially greater than those profits. In addition private plaintiffs can seek recovery for harm suffered by them. The inside trader is not the only subject to liability. In certain cases, controlling persons of inside traders, including supervisors of inside traders or Putnam itself, can be liable for large penalties.

Section I. of this Policy Statement contains rules concerning inside information. Section II. contains a discussion of what constitutes unlawful insider trading.

Neither material non-public information nor unlawful insider trading is easy to define. Section II. of this Policy Statement gives a general overview of the law in this area. However, the legal issues are complex and must be resolved by the Code of Ethics Officer. If an employee has any doubt as to whether she has received material non-public information, she must consult with the Code of Ethics Officer prior to using that information in connection with the purchase or sale of a security for his own account or the account of any Putnam client, or communicating the information to others. A simple rule of thumb is if you think the information is not available to the public at large, do not disclose it to others and do not trade securities to which the inside information relates.

An employee aware of, or in possession of, inside information must report it immediately to the Code of Ethics Officer. If an employee has failed to consult the Code of Ethics Officer, Putnam will not excuse employee misuse of inside information on the grounds that the employee claims to have been confused about this Policy Statement or the nature of the information in his possession.

If Putnam determines, in its sole discretion, that an employee has failed to abide by this Policy Statement, or has engaged in conduct that raises a significant question concerning insider trading, he will be subject to disciplinary action, including termination of employment.

There are no exceptions to this policy statement, and no one is exempt.

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Appendix A — Definitions: Insider Trading

Code of Ethics Administrator The individual designated by the Code of Ethics Officer to assume responsibility for day-to-day, nondiscretionary administration of this Policy Statement. The Code of Ethics Administrator is Laura Rose.

Code of Ethics Officer The Putnam officer who has been assigned the responsibility of enforcing and interpreting this Code. The Code of Ethics Officer shall be the Chief Compliance Officer or such other person as is designated by the Chief Executive Officer of Putnam Investments. If the Code of Ethics Officer is unavailable, the Deputy Code of Ethics Officer shall act in his stead. The Code of Ethics Officer is Bob Leveille. The Deputy Code of Ethics Officer is Kathleen Griffin.

Immediate family Spouse, domestic partner, minor children, or other relatives living in the same household as the Putnam employee.

Purchase or sale of a security Any acquisition or transfer of any interest in the security for direct or indirect consideration, including the writing of an option.

Putnam Any or all of Putnam Investments Trust, and its subsidiaries, any one of which shall be a Putnam company.

Putnam client Any client of the Putnam mutual funds, or any advisory, trust, or other client for whom Putnam manages money.

Putnam employee (or employee) Any employee of Putnam.

Security Anything defined as a security under federal law. The term includes any type of equity or debt security, any interest in a business trust or partnership, and any rights relating to a security, such as put and call options, warrants, convertible securities, and securities indexes. (Note: The definition of security in this Insider Trading Prohibitions Policy Statement varies significantly from that in the Code of Ethics. For example, the definition in this Policy Statement specifically includes all securities of any type.)

Transaction for a personal account (or personal securities transaction) Securities transactions: (a) for the personal account of any employee; (b) for the account of a member of the immediate family of any employee; (c) for the account of a partnership in which a Putnam employee or immediate family member is a domestic partner with investment discretion; (d) for the account of a trust in which a Putnam employee or immediate family member is a trustee with investment discretion; (e) for the account of a closely held corporation in which a Putnam employee or immediate family member holds shares and for which he has investment discretion; and (f ) for any account other than a Putnam client account that receives investment advice of any sort from the employee or immediate family member, or as to which the employee or immediate family member has investment discretion. Officers and employees of PIL must also consult the relevant procedures on compliance with U.K. insider dealing legislation set forth in PIL’s Compliance Manual.

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Appendix A — Section I: Rules Concerning Inside Information

Rule 1: Inside Information

No Putnam employee shall purchase or sell any security listed on the Inside Information List (the Red List) either for his personal account or for a Putnam client.

IMPLEMENTATION

When an employee seeks clearance in the PTA system for a personal security transaction that is on the Red List, the request will be denied via a message in the PTA system.

COMMENT

This Rule is designed to prohibit any employee from trading a security while Putnam may have inside information concerning that security or the issuer. Every trade, whether for a personal account or for a Putnam client, is subject to this Rule.

Rule 2: Material Non-public Information

No Putnam employee shall purchase or sell any security, either for a personal account or for the account of a Putnam client, while in possession of material non-public information concerning that security or the issuer, without the prior written approval of the Code of Ethics Officer.

IMPLEMENTATION

In order to obtain prior written approval of the Code of Ethics Officer, a Putnam employee should follow the reporting steps prescribed in Rule 3.

COMMENTS

• Rule 1 concerns the conduct of an employee when Putnam possesses material non-public information. Rule 2 concerns the conduct of an employee who herself possesses material non-public information about a security that is not yet on the Red List.

• If an employee has any question as to whether information she possesses is material and/or non-public information, she must contact the Code of Ethics Officer immediately in accordance with Rule 3 prior to purchasing or selling any security related to the information or communicating the information to others. The Code of Ethics Officer shall have the sole authority to determine what constitutes material non-public information for the purposes of this Policy Statement.

Rule 3: Reporting of Material Non-public Information

Any Putnam employee who believes he is aware of or has received material non-public information concerning a security or an issuer shall immediately report the information to the Code of Ethics Officer, the Deputy Code of Ethics Officer or, in his or her absence, a lawyer in the Putnam Legal and Compliance Department and to no one else. After reporting the information, the Putnam employee shall comply strictly with Rule 2 by not trading in the security without the prior written approval of the Code of Ethics Officer and shall (a) take precautions to ensure the continued confidentiality of the information and (b) refrain from communicating the information in question to any person.

IMPLEMENTATION

A. An employee must communicate any potential material non-public information to the Code of Ethics Officer in a way designed to prevent the spread of such information and must do so prior to purchasing or selling a security or communicating the information to others. Once the employee has reported potential material non-public information to the Code of Ethics Officer, the Code of

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Ethics Officer will evaluate whether such information constitutes material non-public information, and whether a duty exists that makes use of such information improper. If the Code of Ethics Officer determines either (a) that the information is not material or is public or (b) that use of the information is proper, he will issue a written approval to the employee specifically authorizing trading while in possession of the information, if the employee so requests. If the Code of Ethics Officer determines (a) that the information may be non-public and material and (b) that use of such information may be improper, he will place the security that is the subject of such information on the Red List.

B. An employee who reports potential inside information to the Code of Ethics Officer should expect that the Code of Ethics Officer will need significant information, and time to gather such information, to make the evaluation, including information about (a) the manner in which the employee acquired the information and (b) the identity of individuals to whom the employee has revealed the information, or who have otherwise learned the information. In appropriate situations, the Code of Ethics Officer will normally place the affected security or securities on the Red List pending the completion of his evaluation.

C. If an employee possesses documents, disks, or other materials containing potential inside information, the employee must take precautions to ensure the confidentiality of the information in question. Those precautions include (a) putting documents containing such information out of the view of a casual observer, and (b) securing files containing such documents or ensuring that computer files reflecting such information are secure from viewing by others.

D. The PTA system will automatically reject requests to pre-clear a purchase or sale of securities of any of the following Putnam affiliates: Great-West Lifeco Inc., Power Financial Corporation, Power Corporation of Canada, and IGM Financial Inc. Any employee wishing to place a trade in one of these companies’ securities must contact the Code of Ethics Officer or the Deputy Code of Ethics Officer to request manual approval of the pre-clearance request. An employee requesting such approval must certify that he or she is not in possession of any material non-public information regarding the company in which he or she is seeking to place a trade. The decision whether or not to grant the pre-clearance request is in the sole discretion of the Code of Ethics Officer and the Deputy Code of Ethics Officer. The Code of Ethics Officer and Deputy Code of Ethics Officer will reject any such request for pre-clearance made by members of Putnam’s Executive Board and cert ain members of the Chief Financial Officer’s staff from the end of each calendar quarter to the date of announcement of Great-West Lifeco Inc.’s earnings for such quarter.

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Appendix A — Section II: Overview of Insider Trading

Introduction

This section of the Policy Statement provides guidelines for employees as to what may constitute inside information. It is possible that in the course of her employment, an employee may receive inside information. No employee should misuse that information, either by trading for her own account or by communicating the information to others.

What constitutes unlawful insider trading?

The basic definition of unlawful insider trading is trading on material non-public information (also called inside information) by an individual who has a duty not to take advantage of the information. The following sections help explain the definition.

What is material information?

Trading on inside information is not a basis for liability unless the information is material. Information is material if a reasonable person would attach importance to the information in determining his course of action with respect to a security. Information that is reasonably likely to affect the price of a company’s securities is material, but effect on price is not the sole criterion for determining materiality. Information that employees should consider material includes, but is not limited to, dividend changes, earnings estimates, changes in previously released earnings estimates, reorganization, recapitalization, asset sales, plans to commence a tender offer, merger or acquisition proposals or agreements, major litigation, liquidity problems, significant contracts, and extraordinary management developments.

Material information does not have to relate to a company’s business. For example, a court considered as material certain information about the contents of a forthcoming newspaper column that was expected to affect the market price of a security. In that case, a reporter for the Wall Street Journal was found criminally liable for disclosing to others the dates that reports on various companies would appear in the Journal’s “Heard on the Street” column and whether those reports would be favorable or not.

What is non-public information?

Information is non-public until it has been effectively communicated to, and sufficient opportunity has existed for it to be absorbed by, the marketplace. One must be able to point to some fact to show that the information is generally public. For example, information found in a report filed with the Securities and Exchange Commission, or appearing in Dow Jones, Reuters, the Wall Street Journal , or other publications of general circulation would be considered public.

Who has a duty not to “take advantage” of inside information?

Unlawful insider trading occurs only if there is a duty not to take advantage of material non-public information. When there is no such duty, it is permissible to trade while in possession of such information. Questions as to whether a duty exists are complex, are fact-specific, and must be answered by a lawyer. If you have any doubt, err on the side of caution.

Insiders and Temporary Insiders Corporate insiders have a duty not to take advantage of inside information. The concept of insider is broad. It includes officers, directors, and employees of a corporation. In addition, a person can be a temporary insider if she enters into a special confidential relationship with a corporation and, as a result, is given access to information concerning the corporation’s affairs. A temporary insider can include, among others, accounting firms, consulting

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firms, law firms, banks, and the employees of such organizations. Putnam would generally be a temporary insider of a corporation it advises or for which it performs other services, because typically Putnam clients expect Putnam to keep any information disclosed to it confidential.

EXAMPLE

An investment advisor to the pension fund of a large publicly traded corporation, Acme, Inc., learns from an Acme employee that Acme will not be making the minimum required annual contribution to the pension fund because of a serious downturn in Acme’s financial situation. The information conveyed is material and non-public.

COMMENT

Neither the investment advisor, its employees, nor its clients can trade on the basis of that information, because the investment advisor and its employees could be considered temporary insiders of Acme.

Misappropriators Certain people who are not insiders (or temporary insiders) also have a duty not to deceptively take advantage of inside information. Included in this category is an individual who misappropriates (or takes for his own use) material non-public information in violation of a duty owed either to the corporation that is the subject of inside information or some other entity. Such a misappropriator can be held liable if he trades while in possession of that material non-public information.

EXAMPLE

The Chief Investment Officer of Acme, Inc., is aware of Acme’s plans to engage in a hostile takeover of Profit, Inc. The proposed hostile takeover is material and non-public.

COMMENT

The Chief Investment Officer of Acme cannot trade in Profit, Inc.’s stock for his own account. Even though he owes no duty to Profit, Inc., or its shareholders, he owes a duty to Acme not to take advantage of the information about the proposed hostile takeover by using it for his personal benefit.

Tippers and Tippees A person (the tippee) who receives material non-public information from an insider or misappropriator (the tipper) has a duty not to trade while in possession of that information if he knew, or should have known, that the information was provided by the tipper for an improper purpose and in breach of a duty owed by the tipper. In this context, it is an improper purpose for a person to provide such information for personal benefit.

EXAMPLE

The Chief Executive Officer of Acme, Inc., tells his daughter that negotiations concerning a previously announced acquisition of Acme have been terminated. This news is material and, at the time the father tells his daughter, non-public. The daughter sells her shares of Acme.

COMMENT

The father is a tipper because he has a duty to Acme and its shareholders not to take advantage of the information concerning the breakdown of negotiations, and he has conveyed the information for an improper purpose. The daughter is a tippee and is liable for trading on inside information because she knew, or should have known, that her father was conveying the information to her for his personal benefit, and that her father had a duty not to take advantage of Acme information. A person can be a tippee even if he did not learn the information directly from the tipper, but learned it from a previous tippee.

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EXAMPLE

An employee of a law firm that works on mergers and acquisitions learns at work about impending acquisitions. She tells her friend and her friend’s stockbroker about the upcoming acquisitions on a regular basis. The stockbroker tells the brother of a client on a regular basis, who in turn tells two friends, A and B. A and B buy shares of the companies being acquired before the public announcement of the acquisition, and regularly profit from such purchases. A and B do not know the employee of the law firm. They do not, however, ask about the source of the information.

COMMENT

A and B, although they have never heard of the tipper, are tippees because they did not ask about the source of the information, even though they were experienced investors, and were aware that the “tips” they received from this particular source were accurate.

Who can be liable for insider trading?

The categories of individuals discussed above (insiders, temporary insiders, misappropriators, or tippees) can be liable if they trade while in possession of material non-public information.

In addition, individuals other than those who actually trade on inside information can be liable for trades of others. A tipper can be liable if (a) he provided the information in exchange for a personal benefit in breach of a duty, and (b) the recipient of the information (the tippee) traded while in possession of the information.

Most importantly, a controlling person can be liable if the controlling person knew or recklessly disregarded the fact that the controlled person was likely to engage in misuse of inside information and failed to take appropriate steps to prevent it. Putnam is a controlling person of its employees. In addition, certain supervisors may be controlling persons of those employees they supervise.

EXAMPLE

A supervisor of an analyst learns that the analyst has, over a long period of time, secretly received material inside information from Acme, Inc.’s Chief Investment Officer. The supervisor learns that the analyst has engaged in a number of trades for his personal account on the basis of the inside information. The supervisor takes no action.

COMMENT

Even if he is not liable to a private plaintiff, the supervisor can be liable to the Securities and Exchange Commission for a civil penalty of up to three times the amount of the analyst’s profit.

Penalties for insider trading

Penalties for misuse of inside information are severe, both for individuals involved in such unlawful conduct and their employers. A person who violates the insider trading laws can be subject to some or all of the types of penalties below, even if he does not personally benefit from the violation. Penalties include:

• Jail sentences, criminal monetary penalties

• Injunctions permanently preventing an individual from working in the securities industry

• Injunctions ordering an individual to disgorge profits obtained from unlawful insider trading

• Civil penalties substantially greater than the profit gained or loss avoided by the trader, even if the individual paying the penalty did not trade or did not benefit personally

• Civil penalties for the employer or other controlling person

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• Damages in the amount of actual losses suffered by other participants in the market for the security at issue Regardless of whether penalties or money damages are sought by others, Putnam will take whatever action it deems appropriate, including dismissal, if Putnam determines, in its sole discretion, that an employee appears to have committed any violation of this Policy Statement, or to have engaged in any conduct that raises significant questions about whether an insider trading violation has occurred.

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Appendix B — Policy Statement Regarding Employee Trades in Shares of Putnam Closed-End Funds

Pre-clearance

Any purchase or sale of Putnam closed-end fund shares by a Putnam employee must be pre-cleared. A list of the closed-end funds can be obtained from the Code of Ethics Administrator.

Reporting

Employees must direct their brokers to provide to the Code of Ethics Administrator duplicate confirmations and statements of all purchases and sales. If you are an access person required to file a quarterly report of all personal securities transactions, you must include all purchases and sales of closed-end fund shares.

Special Rules Applicable to Managing Directors of Putnam Investment Management, LLC, Executive Board, and officers of the Putnam Funds

Please be aware that managing directors of Putnam Investment Management, LLC, Executive Board, the investment manager of the Putnam mutual funds, Putnam Executive Board members, and officers of the Putnam Funds will not receive clearance to engage in any combination of purchase and sale, or sale and purchase, of the shares of a given closed-end fund within six months of each other. Therefore, purchases should be made only if you intend to hold the shares more than six months; no sales of fund shares should be made if you intend to purchase additional shares of that same fund within six months.

Certain forms are also required to be filed with the Securities and Exchange Commission in connection with purchases and sales of Putnam closed-end funds. You will be notified by the Code of Ethics Administrator if this applies to you. Please contact the Code of Ethics Officer Administrator for further information.

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Appendix C — Contra- Trading Rule Clearance Form
To: Code of Ethics Officer
From:
Date:
Re: Sale of Personal Security
This serves as prior written approval to sell the following personal security:
Name of portfolio manager contemplating personal sale:
Security to be sold:
Number of shares to be sold:
Fund(s) holding security:
Number of shares held by fund:
Reason for the personal sale:
Specify the reason why the sale is inappropriate for fund:
(Please attach additional sheets if necessary. )
CIO approval:	Date:
Code of Ethics Officer/
Deputy Code of Ethics Officer approval:	Date:

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Appendix D — CFA Institute Code of Ethics and Standards of Professional Conduct

The CFA Institute Code of Ethics and Standards of Professional Conduct (Code and Standards) are fundamental to CFA Institute’s values and essential to achieving its mission to lead the investment profession globally by setting high standards of education, integrity, and professional excellence. High ethical standards are critical to maintaining the public’s trust in financial markets and in the investment profession.

Since their creation in the 1960s, the Code and Standards have promoted the integrity of CFA Institute members and served as a model for measuring the ethics of investment professionals globally, regardless of job function, cultural differences, or local laws and regulations. All CFA Institute members (including holders of the Chartered Financial Analyst® (CFA®) designation) and CFA candidates must abide by the Code and Standards and are encouraged to notify their employer of this responsibility. Violations may result in disciplinary sanctions by CFA Institute. Sanctions can include revocation of membership, candidacy in the CFA Program, and the right to use the CFA designation.

The Code of Ethics

Members of CFA Institute (including Chartered Financial Analyst® (CFA®) charterholders) and candidates for the CFA designation (“Members and Candidates”) must:

• Act with integrity, competence, diligence, and respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets.

• Place the integrity of the investment profession and the interests of clients above their own personal interests.

• Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities.

• Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession.

• Promote the integrity of, and uphold the rules governing, capital markets.

• Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals.

Standards of Professional Conduct

I. PROFESSIONALISM

A. Knowledge of the Law. Members and Candidates must understand and comply with all applicable laws, rules, and regulations (including the CFA Institute Code of Ethics and Standards of Professional Conduct) of any government, regulatory organization, licensing agency, or professional association governing their professional activities. In the event of conflict, Members and Candidates must comply with the more strict law, rule, or regulation. Members and Candidates must not knowingly participate or assist in and must dissociate from any violation of such laws, rules, or regulations.

B. Independence and Objectivity. Members and Candidates must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities.

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Members and Candidates must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity.

C. Misrepresentation. Members and Candidates must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

D. Misconduct. Members and Candidates must not engage in any professional conduct involving dishonesty, fraud, or deceit, or commit any act that reflects adversely on their professional reputation, integrity, or competence.

II. INTEGRITY OF CAPITAL MARKETS

A. Material Non-public Information. Members and Candidates who possess material non-public information that could affect the value of an investment must not act or cause others to act on the information.

B. Market Manipulation. Members and Candidates must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

III. DUTIES TO CLIENTS

A. Loyalty, Prudence, and Care. Members and Candidates have a duty of loyalty to their clients and must act with reasonable care and exercise prudent judgment. Members and Candidates must act for the benefit of their clients and place their clients’ interests before their employer’s or their own interests. In relationships with clients, Members and Candidates must determine applicable fiduciary duty and must comply with such duty to persons and interests to whom it is owed.

B. Fair Dealing. Members and Candidates must deal fairly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

C. Suitability.

1. When Members and Candidates are in an advisory relationship with a client, they must:

a) Make a reasonable inquiry into a client’s or prospective clients’ investment experience, risk and return objectives, and financial constraints prior to making any investment recommendation or taking investment action, and must reassess and update this information regularly.

b) Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates, and constraints before making an investment recommendation or taking investment action.

c) Judge the suitability of investments in the context of the client’s total portfolio.

2. When Members and Candidates are responsible for managing a portfolio to a specific mandate, strategy, or style, they must only make investment recommendations or take investment actions that are consistent with the stated objectives and constraints of the portfolio.

D. Performance Presentation. When communicating investment performance information, Members or Candidates must make reasonable efforts to ensure that it is fair, accurate, and complete.

E. Preservation of Confidentiality. Members and Candidates must keep information about current, former, and prospective clients confidential unless:

1. The information concerns illegal activities on the part of the client or prospective client.

2. Disclosure is required by law.

3. The client or prospective client permits disclosure of the information.

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IV. DUTIES TO EMPLOYERS

A. Loyalty. In matters related to their employment, Members and Candidates must act for the benefit of their employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to their employer.

B. Additional Compensation Arrangements. Members and Candidates must not accept gifts, benefits, compensation, or consideration that competes with, or might reasonably be expected to create a conflict of interest with, their employer’s interest unless they obtain written consent from all parties involved.

C. Responsibilities of Supervisors. Members and Candidates must make reasonable efforts to detect and prevent violations of applicable laws, rules, regulations, and the Code and Standards by anyone subject to their supervision or authority.

V. INVESTMENT ANALYSIS, RECOMMENDATIONS, AND ACTION

A. Diligence and Reasonable Basis. Members and Candidates must:

1. Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations, and taking investment actions.

2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.

B. Communication with Clients and Prospective Clients. Members and Candidates must:

1. Disclose to clients and prospective clients the basic format and general principles of the investment processes used to analyze investments, select securities, and construct portfolios, and must promptly disclose any changes that might materially affect those processes.

2. Use reasonable judgment in identifying which factors are important to their investment analysis, recommendations, or actions and include those factors in communications with clients and prospective clients.

3. Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

C. Record Retention. Members and Candidates must develop and maintain appropriate records to support their investment analysis, recommendations, actions, and other investment-related communications with clients and prospective clients.

VI. CONFLICTS OF INTEREST

A. Disclosure of Conflicts. Members and Candidates must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Members and Candidates must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

B. Priority of Transactions. Investment transactions for clients and employers must have priority over investment transactions in which a Member or Candidate is the beneficial owner.

C. Referral Fees. Members and Candidates must disclose to their employer, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received by, or paid to, others for the recommendation of products or services.

VII. RESPONSIBILITIES AS A CFA INSTITUTE MEMBER OR CFA CANDIDATE

A. Conduct as Members and Candidates in the CFA Program. Members and Candidates must not engage in any conduct that compromises the reputation or integrity of the CFA Institute or the CFA designation or the integrity, validity, or security of the CFA examinations.

B. Reference to the CFA Institute, the CFA designation, and the CFA Program. When referring to the CFA Institute, CFA Institute membership, the CFA designation, or candidacy in the

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CFA Program, Members and Candidates must not misrepresent or exaggerate the meaning or implications of membership in the CFA Institute, holding the CFA designation, or candidacy in the CFA Program.

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Appendix E — Inducement Policy for Putnam Investments Limited (PIL) Employees

Inducements

Putnam Investments Limited has adopted the following procedures to enable it to comply with, and demonstrate compliance with, the requirements in this area:

Gifts, business meals, or entertainment events that are given or received (“inducements”) and that exceed a value of £25 (40 euros or equivalent) must be reported through the PTA system within 20 business days.

PIL’s policy limits gifts to a value of £100 (150 euros or equivalent) per item.

No limit is applied to meals provided such meals are for business purposes, reasonable, and not lavish.

Entertainment provided to, or received from, suppliers (including brokers) is limited to a value of £150 (225 euros or equivalent). When receiving or providing entertainment to clients or potential clients, the limit of £150 (225 euros or equivalent) may be exceeded provided that such event is for business purposes, reasonable, and not lavish. Pre-clearance must be obtained from the PIL Compliance Officer.

Inducements exceeding these limits should be politely declined, explaining that PIL’s internal policies will not permit their acceptance.

There may be rare occasions where you are unexpectedly offered a gift or are entertained where the value exceeds the limits and it would be very discourteous to decline, or difficult to pay part of the bill yourself (such as in a members’ dining club). In these circumstances the gift should be handed in to the PIL Compliance Officer, who will arrange to give it to charity, or the entertainment reported immediately to the PIL Compliance Officer with an explanation of the circumstances.

Where the gift is below £100 (150 euros or equivalent) or the entertainment is below £150 (225 euros or equivalent) for any individual, no pre-clearance is necessary. Above these levels, pre-clearance is required from the PIL Compliance Officer. If you are in doubt as to whether limits might be exceeded, please err on the side of caution and seek pre-clearance.

Employees must disclose inducements in PTA where the value is above £25 (40 euros or equivalent).

Inducements below £25 (40 euros or equivalent), e.g., an umbrella, a casual drink, or a snack, need not be reported.

No more than six entertainment events per year, and no more than two events may be accepted from a single source. Meals are not included in this limit.

Where breaches of the inducement policy occur, sanctions may apply.

Employees are required to make an annual declaration that they have reported all reportable inducements given and received, or that they have not given or received any inducements during the course of the year.

Further detailed guidance on PIL’s Inducement Policy is available in the PIL Compliance Manual.

54

407 Letter	2, 33	Employees
7-Day Rule	3, 19, 20	general rules for	23
90-Day Short-Term Rule	12, 19	personal political contributions	26
Access Person		Entertainment Policy	23
definition	5	Excessive trading (over 10 trades) prohibited	16
reporting requirements for	33	Exchange-traded index funds (ETFs)	6, 8, 17, 33, 34
reporting transactions/holdings	33	Exempted transactions	17
Ad Hoc Exemption	37	Family member accounts	15
Affiliated Entities	29	Family Members’ Conflict Policy	29
Analysts		Fiduciary	28
special rules	19, 20, 21	Gifts and Entertainment Policy	23
Annual Holdings Report	11, 34	Gifts donated as securities	11
Anti-bribery/Kickback Policy	25	Good Until Canceled (GTC) Limit orders	16
Anti-money Laundering Policy	32	Goods and services, purchasing	29
Anti-trust and other laws	23	Great-West Lifeco Inc.	2, 8, 12, 43
Appeal Procedures	38	Initial holdings report	34
Blackout Rule
trading by portfolio managers,		Initial Public Offerings (IPOs)	12
analysts, and CIOs	3, 20	Inside Information	1, 43, 44
Boycott laws	23	material, non-public information	13, 42
		policy statement	40
Bribes	25	sanctions for	39, 46
Broker accounts	2, 33	Inside Information List (Red List)	42
Business ethics	34	Insider Trading
CFA Institute Code of Ethics	31	definitions	41
CFA Institute Code of Ethics and Standards of		explanations of	44
Professional Conduct	50	liability for	46
		penalties for	46
Chief Investment Officer		policy statement	40
special rules on trading	19
Closed-end fund	2, 5, 6, 7, 8, 48	Investment clubs	28
Code of Ethics Administrator	6	Involuntary transactions	11, 17
Code of Ethics Officer	6	Kickback Policy	25
Deputy Code of Ethics Officer	6	Large-/Mid-Cap Exemption	9
Code of Ethics Oversight Committee	6, 13, 16, 39	Limit Orders	16
Compliance and Appeal Procedures	37	Linked accounts	15
Computer and Network Use Policy	30	Lobbying Policy	26
Confidentiality	1, 27	Market timing prohibition	15
Confirmations and broker statements	2, 33	Marsh & McLennan (MMC) securities	8, 11, 17, 33
Conflicts of interest	1, 4, 23	Material information	1, 13, 40, 42, 43, 44, 46
Contra-Trading Rule	3, 21	Naked Options	17
Clearance Form	49	Negotiations prohibition	28
Corporate purchase of goods and services	29	Non-public information	1, 13, 40, 42, 43, 44, 46
Corporate/political contributions.	26	Non-Putnam affiliates (NPAs)	29
Currencies	7	Officer, prohibited to serve for another entity	27
Director, prohibited to serve for another entity	27	Ombudsman	35
Discretionary account	6, 10, 12	Options
Dividend reinvestment program	18	defined as securities	10
Education Requirements	36	naked	17

55

Partner, prohibited to serve for another entity	27	90-Day Rule	15
Partnerships, covered in personal securities		One-Year Rule	15
transactions	7, 41	Putnam Variable Trusts	14
Personal securities transactions	3	Quarterly Report of Securities Transactions	2, 33
Personal Trading Assistant (PTA)		Records
2, 6, 8, 9, 11, 24, 27, 33, 34		accuracy records policy	29
Political activities, contributions, lobbying	26	retention policy	32
Portfolio managers, special rules on trading	19-22	Red List	42, 43
Portfolio Trading	21, 29	Reporting Requirements	33
Postiions outside Putnam	27, 34	Restricted List	7-9, 12, 37, 38
Power Corporation of Canada	2, 8, 12, 43	Sanctions	39
Power Financial Corporation	2, 8, 12, 43	Shares by subscription, pre-clearance	10
Pre-clearance	2, 6-12	Special rules for investment professionals	3, 19-22
sanctions for failure to pre-clear properly	39	Spread betting	17
Privacy Policy	31	Tender Offers	11
Private offerings and private placement		Trustee	7, 14, 27, 28, 41
pre-approval	13	Trusts	1, 7, 14, 41
Prohibited transactions	12-18	U. S. government obligations	7
Putnam mutual fund restrictions	2, 14, 15	Warrants	7, 8, 41

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Boston, Massachusetts 02109
1-617-292-1000
www.putnam.com

248344 5/08