In conjunction with its January 2006 announcement regarding the filing of a civil fraud action against six former officers of Putnam Fiduciary Trust Company ("PFTC"), the SEC also announced that it would not be initiating any action against PFTC, citing the "extraordinary" cooperation and remedial steps taken by the company. Through this announcement, the SEC provides its latest affirmation regarding the types of action and cooperation it expects from an organization to bolster its chances of avoiding enforcement action.

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