What additional steps has Putnam taken to prevent market-timing and excessive trading in the future?
Since the inception of these events, Putnam has been subject to an intense review by regulatory authorities, the Audit Committee of the Funds’ Board of Trustees, and an independent compliance consultant appointed under the SEC settlement agreement. As a result of aggressive action taken by Putnam’s corporate parent in coordination with the Funds’ Trustees, disciplinary and corrective actions were taken and new management was installed at Putnam in late 2003. To guard against market timing and protect the interests of long-term investors, Putnam has enhanced short-term trading fee policies, “fair value” pricing of our international and global funds, and internal controls to detect and halt market timing activities, and has implemented stricter controls on employee trading.
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