2005-08-08
Added · Updated
The SEC staff will not recommend enforcement action if Putnam Tax-Free Health Care Fund omits a shareholder proposal from its 2005 proxy materials because the proposal was received on April 13, 2005, which is after the April 11, 2005 deadline established in the Fund's 2004 proxy statement. The staff determined that the proposal was untimely under Rule 14a-8(f)(1) because the proponent failed to provide proof of delivery prior to the deadline, despite the letter being postmarked on April 8, 2005. This decision applies to the Fund and its exclusion of the proposal submitted by Phillip Goldstein on behalf of Opportunity Partners L.P.
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Securities Exchange Act of 1934 - Rule 14a-8(f)(1) Putnam Tax-Free Health Care Fund August 8, 2005 John W. Gerstmayr, Esquire Ropes & Gray LLP One International Place Boston, MA 02110-2624
Re:
Putnam Tax-Free Health Care Fund File No. 811-6659
Dear Mr. Gerstmayr:
In a letter dated June 6, 2005, you requested our assurance that we would not recommend enforcement action to the Commission if the Putnam Tax-Free Health Care Fund ("Fund") omits from its proxy material a shareholder proposal from Phillip Goldstein (the "Proponent") postmarked April 8, 2005, and received by the Fund on April 13, 2005. The Proposal states:
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